Rochford Core Strategy Development Plan Document - Schedule of Changes

ROCHFORD CORE STRATEGY SUBMISSION: SCHEDULE OF CHANGES

We act on behalf of Mr Maughan and Mr Lambourn who own land south of Eastwood Road, Rayleigh, and Mrs M. Bingley and Mr H. Johnson who own land south of Wyburns Primary School, Rayleigh. Both sites are identified on the enclosed site plan.

My clients consider that the following amendments are neither consistent with national policy, justified nor effective.

* Paragraph 2.29 (P39);
* Paragraph 2.31 (P39);
* Paragraph 4.4 (P39);
* Paragraph 4.6 (P39);
* Table (P30/40);
* Appendix CSSC1;
* Appendix CSSC2; and
* Appendix CSSC3.

(i) Consistent with National Policy

The 'Schedule of Changes' are not compliant with national planning policy and in particular fails to take account of the adopted East of England Plan and fails to take account of emerging planning policy set out in the Government White Paper titled 'Local Growth: Realising Every Place's Potential - Presented to Parliament by the Secretary of State for Business, Innovation & Skills by Command of Her Majesty (28 October 2010)'.

East of England Plan

The proposed amendments to the housing numbers and the phasing set out in the Schedule of Changes conflicts with the requirements of Policy H1 of East of England Plan. This policy sets the housing provision requirement of Rochford District at 4,600 dwellings to be built between 2001 and 2021. The proposed changes are therefore unsound.

It is recognised that the Regional Spatial Strategy was revoked in June 2010, however the High Court ruled that the Communities Secretary Eric Pickles acted unlawfully by revoking the regional planning strategies. Therefore the East of England Plan stills forms part of the development plan and is still a material consideration in planning decisions. The Council was premature in making the amendments to the housing numbers prior to the High Court ruling.

The East of England Plan (regional spatial strategy) is part of the 'development plan' for Rochford by virtue of Section 38(3) of the Planning and Compulsory Purchase Act 2004. The importance of the East of England Plan is emphasised in regulation 29 of the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 states which that a local planning authority must make a request to assess the general conformity of the DPD with the regional spatial strategy.

Furthermore paragraph 1.6 of Planning Policy Statement 12 (PPS12) states that spatial planning objectives for local areas, as set out in the LDF, should be aligned not only with national and regional plans, but also with the shared local priorities set out in Sustainable Community Strategies. Paragraph 2.1 states that the spatial planning process of place shaping and delivery aims to produce a vision for the future of places that responds to the local challenges and opportunities, and is based on evidence, a sense of local distinctiveness and community derived objectives, within the overall framework of national policy and regional strategies. The text box in Section 3 states that regional spatial strategies provide the overall spatial vision for the entire region, identifying the broad locations for growth, together with the housing numbers to be provided for in LDDs. The East of England Plan is a product of effective engagement with the local authorities and therefore it provides the regional framework against which local participation in creating Sustainable Community Strategies and Core Strategies takes place.

Therefore the housing provision for Rochford District as set out in Policy H1 of the East of England Plan is still relevant.

Government White Paper titled 'Local Growth: Realising Every Place's Potential

The Council has failed to take account of proposed reforms to the planning system set out in the Government White Paper titled 'Local Growth: Realising Every Place's Potential. On 28th October 2010 the Government published the Local Growth White Paper, which sets out a new approach to sub-national growth, including more information about Local Enterprise Partnerships and the Regional Growth Fund. It focuses on three key themes:

* Shifting power to local communities and businesses.
* Increasing confidence to invest, that is to create the right conditions for growth through Government allowing market forces to determine where growth takes place and provide incentives which ensure that local communities benefit from development.
* Focused intervention by tackling barriers to growth that the market will not address itself, supporting investment that will have a long term impact on growth and supporting areas with long term growth challenges manage their transition to what is appropriate for the local area.

Section 3 of the White Paper confirms that the Government is committed to reforming the planning system, so that it actively encourages growth. Reforms will ensure that people have greater ownership of the planning system. Actions proposed include:

* Introducing a national presumption in favour of sustainable development, which will apply to decisions on all planning applications;
* Giving local communities new Right-to-Build powers;
* fundamentally reforming and streamlining national planning policy and guidance, presenting to Parliament a simple national planning framework; and
* Placing a new statutory duty to cooperate with local authorities, public bodies and private bodies that are critical to plan-making, such as infrastructure providers.

Paragraph 3.7 states a key part of planning reforms will therefore be to introduce a national presumption in favour of sustainable development, which will apply to decisions on all planning applications and will support the strategic provision of new homes, offices, schools and other developments that help drive the growth of the economy.

Paragraph 3.1 of the White Paper states that the main function of the planning system is to give people the opportunity to shape the look and feel of their communities, including to protect and promote important environmental and social interests and to provide sufficient housing to meet demand.

In respect to development plan, Paragraph 3.8 states that communities will be centre-stage in the reformed planning system whilst paragraph 3.9 states every neighbourhood will be given the chance to shape its own development through the creation of neighbourhood plans, which will give local communities greater flexibility and the freedom to bring forward more development than set out in the local authority plan. Neighbourhood plans will need to respect the overall national presumption in favour of sustainable development, as well as other local strategic priorities such as the positioning of transport links and meeting housing need.

The text box in Section 3 of the White Paper explains that the Government will create a framework of incentives for local authorities to deliver sustainable economic development, including the New Homes Bonus scheme, starting in 2011-12, which will support new housing development. Paragraph 3.29 provides further details of the New Homes Bonus. The scheme will ensure that communities and local authority decision-makers enjoy the benefits of growth and not just the costs. Starting in 2011-12 the scheme will match fund the additional council tax for each new home and property brought back into use, for each of the six years after that home is built. Central government will help establish the scheme with support of £196 million in the first year and £250 million for each of the following three years.

The promotion of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to enhance the quality of life of its residents, enhance the individuality and character of Rochford. The Core Strategy should therefore be a product of genuine community involvement that provides local people the opportunity to shape their communities.

It is clear from the scale of representations and comments received during the production of the Core Strategy that the local residents are strongly opposed to the spatial distribution of housing proposed across the district. In the interests of promoting localism and embracing the emerging planning policy, the Council should amend its spatial strategy to build in mechanism to introduce 'Neighbourhood Plans' that will set the quantum and location of housing and economic development for each neighbourhood. The Core Strategy should therefore set the district-wide housing requirements but not the broad locations.

Summary

The 'Schedule of Changes' are not complaint with existing national and regional planning policy and they do not take account of emerging planning policy reforms. There is no policy basis in which to make the changes and they are therefore unsound.

(ii) Justified

The changes made as noted above are unsound on the basis that they are not justified.

PPS12 states that to be 'justified' a DPD needs to be founded on a robust and credible evidence base involving evidence of participation of the local community and others having a stake in the area, and robust research. It is further stated that the most appropriate strategy when considered against reasonable alternatives.

The significant reduction of the housing numbers does not reflect the East of England Plan or the evidence base that informed this document.

General Approach

The East of England Plan requires a minimum of 4,600 dwellings to be provided in the District between 2001 and 2021. In addition, the Local Planning Authority is required to plan for delivery of housing for at least 15 years from the date of adoption of the Core Strategy. Therefore housing needs to be identified for the period to 2024.

The 2009 Strategic Housing Land Availability Assessment (SHLAA) examined the supply of housing land and, although identified some capacity from extant permissions and other appropriate sites, also ascertained that Green Belt would have to be reallocated in order to meet the requirements of the East of England Plan. It is stated that 2,745 dwellings are required on Green Belt land between 2006 and 2024. This is in addition to the 2,005 dwellings to be delivered on previously developed land.

The Core Strategy sets out the general locations for housing development. The Council state that the primary factors in determining the location of future housing include current infrastructure; access to services; facilities; housing demand/need; deliverability; public transport/possibility of reducing car dependency; opportunities to utilise brownfield land; community needs and physical constraints; need to protect areas of landscape value, ecological importance and high quality agricultural land. The Council states that it seeks balance the distribution of housing by focusing growth upon the higher tier settlements.

The population of Rochford District is unevenly distributed with the largest settlement being Rayleigh which, in 2001, was home to 30,196 people, 38% of the District's residents. As such the Council identified Rayleigh as a primary tier settlement as it contains a range services and facilities including good public transport accessibility. The Core Strategy however notes that their housing needs evidence indicates that 44% of the housing need in the borough originates from Rayleigh. This provides a strong basis in which to focus housing development upon Rayleigh.

Despite what is said in the Core Strategy, it is clear that Council has failed to consider a more balanced approach to housing delivery. The unbalanced approach is set out in the Schedule of Changes. However the Council's proposed housing locations do not reflect this statement as the scattered approach around the district will deliver housing away from public transport and key services and will lead to unsustainable patterns of growth. The Council's own evidence states that 44% of the need for housing is focused on Rayleigh, yet Rayleigh will only deliver 19% of housing on Green Belt sites. This will result in increased car movements between the settlements and will have an unsustainable impact upon the existing infrastructure.

The Schedule of Changes has failed to take account of the housing need for Rayleigh. There is a need for the Council to identify and significant increase in the housing provision for Rayleigh to meet the socio-economic objectives set out in the Rochford Core Strategy Submission draft.

(iii) Effective

The schedule of changes are unsound on the basis that they are not effective. The reduction of housing will have housing deliverability implications that will render these changes unsound. There is no demonstration of sound infrastructure planning. The Council should therefore consider smaller and easily developable sites that are well connected to the primary tier and most sustainable settlement of Rayleigh.

The housing reduction target is a material change that needs to careful consideration. If the Council is minded to pursue the housing reduction, then they will need to reassess the spatial strategy to take account of existing infrastructure; access to services; facilities; housing demand/need; deliverability; public transport/possibility of reducing car dependency. The housing reduction would provide the opportunity for the Council to reassess its approach and consider a more appropriate spatial strategy that meets the housing needs of Rayleigh.

On this basis, my clients consider that land south of Rayleigh would provide a more suitable and sustainable broad housing location. The sites that make up land south of Rayleigh are included on the enclosed site plan. Land south of Rayleigh is located to the south of the urban area of Rayleigh and has the potential to deliver up to approximately 290 market and affordable dwellings.

This broad location is just 1 mile from Rayleigh town centre and 1.4 miles from Rayleigh Train Station which provides convenient public transport connections to Southend-on-Sea, Stratford and London Liverpool Street. A number of bus routes operate along Eastwood Road, with a bus stop adjacent to the proposed access. This provides good and convenient public transport accessibility to Rayleigh Town Centre and Rayleigh Train Station and access to existing services.

This broad location is well located to the main centres of employment in Rayleigh being located in close proximity to the town centre but is also just 800 metres by foot from Brook Street Industrial Estate or approximately 1.5 miles by bike or car.

The site adjoins the urban edge of Rayleigh to the south. The broad location abuts the rear boundary line of the dwellings located along South View Road and Eastwood Road and land to the south of Wyburns Primary School.

The broad location is visually contained by a mature wooded area that would also create a natural and defensible boundary for a future development.

This broad location has no existing function other than being used for extended residential garden use. The broad location has no beneficial agricultural function, no viable equestrian function and no commercial function. This land represents under-used land that in its current state detracts from the character and function of the area.

Land south of Rayleigh also has the following benefits:

* There are no public footpaths or rights of way that cross this site and the site has no recreational value.
* The proposed site is connected to existing utilities infrastructure.
* The proposed site could be accessed from Eastwood Road and Daws Heath Road.
* There are no contamination issues at this location.

(iv) Legal Compliance

My clients consider that the Core Strategy is not legally compliant on the basis that my client's were not invited to make representations to the Core Strategy Submission Draft. The Council were therefore in breach of Regulation 25(3) and PPS12 paragraphs 4.24 to 4.29. My client's were therefore not given the opportunity to comment on the spatial strategy and attend the Examination in Public.

This issue was raised at the recent Site Allocations consultation. The Council subsequently forwarded the Core Strategy Proposed Submission letters that were addressed to my clients. Despite forwarding these letters, it does not prove that the Council sent the letters as neither of my client's who all reside at four separate addresses received the said letters which suggests that a process error occurred at the time the Council published its Proposed Submission Core Strategy.

(v) Conclusion

I trust that the comments, made on behalf of my clients will be considered. However should you require clarification on any matters raised above, please do not hesitate to contact me.

ROCHFORD CORE STRATEGY SUBMISSION: SCHEDULE OF CHANGES

We act on behalf of Mr Maughan and Mr Lambourn who own land south of Eastwood Road, Rayleigh, and Mrs M. Bingley and Mr H. Johnson who own land south of Wyburns Primary School, Rayleigh. Both sites are identified on the enclosed site plan.

My clients consider that the following amendments are neither consistent with national policy, justified nor effective.

* Paragraph 2.29 (P39);
* Paragraph 2.31 (P39);
* Paragraph 4.4 (P39);
* Paragraph 4.6 (P39);
* Table (P30/40);
* Appendix CSSC1;
* Appendix CSSC2; and
* Appendix CSSC3.

(i) Consistent with National Policy

The 'Schedule of Changes' are not compliant with national planning policy and in particular fails to take account of the adopted East of England Plan and fails to take account of emerging planning policy set out in the Government White Paper titled 'Local Growth: Realising Every Place's Potential - Presented to Parliament by the Secretary of State for Business, Innovation & Skills by Command of Her Majesty (28 October 2010)'.

East of England Plan

The proposed amendments to the housing numbers and the phasing set out in the Schedule of Changes conflicts with the requirements of Policy H1 of East of England Plan. This policy sets the housing provision requirement of Rochford District at 4,600 dwellings to be built between 2001 and 2021. The proposed changes are therefore unsound.

It is recognised that the Regional Spatial Strategy was revoked in June 2010, however the High Court ruled that the Communities Secretary Eric Pickles acted unlawfully by revoking the regional planning strategies. Therefore the East of England Plan stills forms part of the development plan and is still a material consideration in planning decisions. The Council was premature in making the amendments to the housing numbers prior to the High Court ruling.

The East of England Plan (regional spatial strategy) is part of the 'development plan' for Rochford by virtue of Section 38(3) of the Planning and Compulsory Purchase Act 2004. The importance of the East of England Plan is emphasised in regulation 29 of the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 states which that a local planning authority must make a request to assess the general conformity of the DPD with the regional spatial strategy.

Furthermore paragraph 1.6 of Planning Policy Statement 12 (PPS12) states that spatial planning objectives for local areas, as set out in the LDF, should be aligned not only with national and regional plans, but also with the shared local priorities set out in Sustainable Community Strategies. Paragraph 2.1 states that the spatial planning process of place shaping and delivery aims to produce a vision for the future of places that responds to the local challenges and opportunities, and is based on evidence, a sense of local distinctiveness and community derived objectives, within the overall framework of national policy and regional strategies. The text box in Section 3 states that regional spatial strategies provide the overall spatial vision for the entire region, identifying the broad locations for growth, together with the housing numbers to be provided for in LDDs. The East of England Plan is a product of effective engagement with the local authorities and therefore it provides the regional framework against which local participation in creating Sustainable Community Strategies and Core Strategies takes place.

Therefore the housing provision for Rochford District as set out in Policy H1 of the East of England Plan is still relevant.

Government White Paper titled 'Local Growth: Realising Every Place's Potential

The Council has failed to take account of proposed reforms to the planning system set out in the Government White Paper titled 'Local Growth: Realising Every Place's Potential. On 28th October 2010 the Government published the Local Growth White Paper, which sets out a new approach to sub-national growth, including more information about Local Enterprise Partnerships and the Regional Growth Fund. It focuses on three key themes:

* Shifting power to local communities and businesses.
* Increasing confidence to invest, that is to create the right conditions for growth through Government allowing market forces to determine where growth takes place and provide incentives which ensure that local communities benefit from development.
* Focused intervention by tackling barriers to growth that the market will not address itself, supporting investment that will have a long term impact on growth and supporting areas with long term growth challenges manage their transition to what is appropriate for the local area.

Section 3 of the White Paper confirms that the Government is committed to reforming the planning system, so that it actively encourages growth. Reforms will ensure that people have greater ownership of the planning system. Actions proposed include:

* Introducing a national presumption in favour of sustainable development, which will apply to decisions on all planning applications;
* Giving local communities new Right-to-Build powers;
* fundamentally reforming and streamlining national planning policy and guidance, presenting to Parliament a simple national planning framework; and
* Placing a new statutory duty to cooperate with local authorities, public bodies and private bodies that are critical to plan-making, such as infrastructure providers.

Paragraph 3.7 states a key part of planning reforms will therefore be to introduce a national presumption in favour of sustainable development, which will apply to decisions on all planning applications and will support the strategic provision of new homes, offices, schools and other developments that help drive the growth of the economy.

Paragraph 3.1 of the White Paper states that the main function of the planning system is to give people the opportunity to shape the look and feel of their communities, including to protect and promote important environmental and social interests and to provide sufficient housing to meet demand.

In respect to development plan, Paragraph 3.8 states that communities will be centre-stage in the reformed planning system whilst paragraph 3.9 states every neighbourhood will be given the chance to shape its own development through the creation of neighbourhood plans, which will give local communities greater flexibility and the freedom to bring forward more development than set out in the local authority plan. Neighbourhood plans will need to respect the overall national presumption in favour of sustainable development, as well as other local strategic priorities such as the positioning of transport links and meeting housing need.

The text box in Section 3 of the White Paper explains that the Government will create a framework of incentives for local authorities to deliver sustainable economic development, including the New Homes Bonus scheme, starting in 2011-12, which will support new housing development. Paragraph 3.29 provides further details of the New Homes Bonus. The scheme will ensure that communities and local authority decision-makers enjoy the benefits of growth and not just the costs. Starting in 2011-12 the scheme will match fund the additional council tax for each new home and property brought back into use, for each of the six years after that home is built. Central government will help establish the scheme with support of £196 million in the first year and £250 million for each of the following three years.

The promotion of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to enhance the quality of life of its residents, enhance the individuality and character of Rochford. The Core Strategy should therefore be a product of genuine community involvement that provides local people the opportunity to shape their communities.

It is clear from the scale of representations and comments received during the production of the Core Strategy that the local residents are strongly opposed to the spatial distribution of housing proposed across the district. In the interests of promoting localism and embracing the emerging planning policy, the Council should amend its spatial strategy to build in mechanism to introduce 'Neighbourhood Plans' that will set the quantum and location of housing and economic development for each neighbourhood. The Core Strategy should therefore set the district-wide housing requirements but not the broad locations.

Summary

The 'Schedule of Changes' are not complaint with existing national and regional planning policy and they do not take account of emerging planning policy reforms. There is no policy basis in which to make the changes and they are therefore unsound.

(ii) Justified

The changes made as noted above are unsound on the basis that they are not justified.

PPS12 states that to be 'justified' a DPD needs to be founded on a robust and credible evidence base involving evidence of participation of the local community and others having a stake in the area, and robust research. It is further stated that the most appropriate strategy when considered against reasonable alternatives.

The significant reduction of the housing numbers does not reflect the East of England Plan or the evidence base that informed this document.

General Approach

The East of England Plan requires a minimum of 4,600 dwellings to be provided in the District between 2001 and 2021. In addition, the Local Planning Authority is required to plan for delivery of housing for at least 15 years from the date of adoption of the Core Strategy. Therefore housing needs to be identified for the period to 2024.

The 2009 Strategic Housing Land Availability Assessment (SHLAA) examined the supply of housing land and, although identified some capacity from extant permissions and other appropriate sites, also ascertained that Green Belt would have to be reallocated in order to meet the requirements of the East of England Plan. It is stated that 2,745 dwellings are required on Green Belt land between 2006 and 2024. This is in addition to the 2,005 dwellings to be delivered on previously developed land.

The Core Strategy sets out the general locations for housing development. The Council state that the primary factors in determining the location of future housing include current infrastructure; access to services; facilities; housing demand/need; deliverability; public transport/possibility of reducing car dependency; opportunities to utilise brownfield land; community needs and physical constraints; need to protect areas of landscape value, ecological importance and high quality agricultural land. The Council states that it seeks balance the distribution of housing by focusing growth upon the higher tier settlements.

The population of Rochford District is unevenly distributed with the largest settlement being Rayleigh which, in 2001, was home to 30,196 people, 38% of the District's residents. As such the Council identified Rayleigh as a primary tier settlement as it contains a range services and facilities including good public transport accessibility. The Core Strategy however notes that their housing needs evidence indicates that 44% of the housing need in the borough originates from Rayleigh. This provides a strong basis in which to focus housing development upon Rayleigh.

Despite what is said in the Core Strategy, it is clear that Council has failed to consider a more balanced approach to housing delivery. The unbalanced approach is set out in the Schedule of Changes. However the Council's proposed housing locations do not reflect this statement as the scattered approach around the district will deliver housing away from public transport and key services and will lead to unsustainable patterns of growth. The Council's own evidence states that 44% of the need for housing is focused on Rayleigh, yet Rayleigh will only deliver 19% of housing on Green Belt sites. This will result in increased car movements between the settlements and will have an unsustainable impact upon the existing infrastructure.

The Schedule of Changes has failed to take account of the housing need for Rayleigh. There is a need for the Council to identify and significant increase in the housing provision for Rayleigh to meet the socio-economic objectives set out in the Rochford Core Strategy Submission draft.

(iii) Effective

The schedule of changes are unsound on the basis that they are not effective. The reduction of housing will have housing deliverability implications that will render these changes unsound. There is no demonstration of sound infrastructure planning. The Council should therefore consider smaller and easily developable sites that are well connected to the primary tier and most sustainable settlement of Rayleigh.

The housing reduction target is a material change that needs to careful consideration. If the Council is minded to pursue the housing reduction, then they will need to reassess the spatial strategy to take account of existing infrastructure; access to services; facilities; housing demand/need; deliverability; public transport/possibility of reducing car dependency. The housing reduction would provide the opportunity for the Council to reassess its approach and consider a more appropriate spatial strategy that meets the housing needs of Rayleigh.

On this basis, my clients consider that land south of Rayleigh would provide a more suitable and sustainable broad housing location. The sites that make up land south of Rayleigh are included on the enclosed site plan. Land south of Rayleigh is located to the south of the urban area of Rayleigh and has the potential to deliver up to approximately 290 market and affordable dwellings.

This broad location is just 1 mile from Rayleigh town centre and 1.4 miles from Rayleigh Train Station which provides convenient public transport connections to Southend-on-Sea, Stratford and London Liverpool Street. A number of bus routes operate along Eastwood Road, with a bus stop adjacent to the proposed access. This provides good and convenient public transport accessibility to Rayleigh Town Centre and Rayleigh Train Station and access to existing services.

This broad location is well located to the main centres of employment in Rayleigh being located in close proximity to the town centre but is also just 800 metres by foot from Brook Street Industrial Estate or approximately 1.5 miles by bike or car.

The site adjoins the urban edge of Rayleigh to the south. The broad location abuts the rear boundary line of the dwellings located along South View Road and Eastwood Road and land to the south of Wyburns Primary School.

The broad location is visually contained by a mature wooded area that would also create a natural and defensible boundary for a future development.

This broad location has no existing function other than being used for extended residential garden use. The broad location has no beneficial agricultural function, no viable equestrian function and no commercial function. This land represents under-used land that in its current state detracts from the character and function of the area.

Land south of Rayleigh also has the following benefits:

* There are no public footpaths or rights of way that cross this site and the site has no recreational value.
* The proposed site is connected to existing utilities infrastructure.
* The proposed site could be accessed from Eastwood Road and Daws Heath Road.
* There are no contamination issues at this location.

(iv) Legal Compliance

My clients consider that the Core Strategy is not legally compliant on the basis that my client's were not invited to make representations to the Core Strategy Submission Draft. The Council were therefore in breach of Regulation 25(3) and PPS12 paragraphs 4.24 to 4.29. My client's were therefore not given the opportunity to comment on the spatial strategy and attend the Examination in Public.

This issue was raised at the recent Site Allocations consultation. The Council subsequently forwarded the Core Strategy Proposed Submission letters that were addressed to my clients. Despite forwarding these letters, it does not prove that the Council sent the letters as neither of my client's who all reside at four separate addresses received the said letters which suggests that a process error occurred at the time the Council published its Proposed Submission Core Strategy.

(v) Conclusion

I trust that the comments, made on behalf of my clients will be considered. However should you require clarification on any matters raised above, please do not hesitate to contact me.

ROCHFORD CORE STRATEGY SUBMISSION: SCHEDULE OF CHANGES

We act on behalf of Mr Maughan and Mr Lambourn who own land south of Eastwood Road, Rayleigh, and Mrs M. Bingley and Mr H. Johnson who own land south of Wyburns Primary School, Rayleigh. Both sites are identified on the enclosed site plan.

My clients consider that the following amendments are neither consistent with national policy, justified nor effective.

* Paragraph 2.29 (P39);
* Paragraph 2.31 (P39);
* Paragraph 4.4 (P39);
* Paragraph 4.6 (P39);
* Table (P30/40);
* Appendix CSSC1;
* Appendix CSSC2; and
* Appendix CSSC3.

(i) Consistent with National Policy

The 'Schedule of Changes' are not compliant with national planning policy and in particular fails to take account of the adopted East of England Plan and fails to take account of emerging planning policy set out in the Government White Paper titled 'Local Growth: Realising Every Place's Potential - Presented to Parliament by the Secretary of State for Business, Innovation & Skills by Command of Her Majesty (28 October 2010)'.

East of England Plan

The proposed amendments to the housing numbers and the phasing set out in the Schedule of Changes conflicts with the requirements of Policy H1 of East of England Plan. This policy sets the housing provision requirement of Rochford District at 4,600 dwellings to be built between 2001 and 2021. The proposed changes are therefore unsound.

It is recognised that the Regional Spatial Strategy was revoked in June 2010, however the High Court ruled that the Communities Secretary Eric Pickles acted unlawfully by revoking the regional planning strategies. Therefore the East of England Plan stills forms part of the development plan and is still a material consideration in planning decisions. The Council was premature in making the amendments to the housing numbers prior to the High Court ruling.

The East of England Plan (regional spatial strategy) is part of the 'development plan' for Rochford by virtue of Section 38(3) of the Planning and Compulsory Purchase Act 2004. The importance of the East of England Plan is emphasised in regulation 29 of the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 states which that a local planning authority must make a request to assess the general conformity of the DPD with the regional spatial strategy.

Furthermore paragraph 1.6 of Planning Policy Statement 12 (PPS12) states that spatial planning objectives for local areas, as set out in the LDF, should be aligned not only with national and regional plans, but also with the shared local priorities set out in Sustainable Community Strategies. Paragraph 2.1 states that the spatial planning process of place shaping and delivery aims to produce a vision for the future of places that responds to the local challenges and opportunities, and is based on evidence, a sense of local distinctiveness and community derived objectives, within the overall framework of national policy and regional strategies. The text box in Section 3 states that regional spatial strategies provide the overall spatial vision for the entire region, identifying the broad locations for growth, together with the housing numbers to be provided for in LDDs. The East of England Plan is a product of effective engagement with the local authorities and therefore it provides the regional framework against which local participation in creating Sustainable Community Strategies and Core Strategies takes place.

Therefore the housing provision for Rochford District as set out in Policy H1 of the East of England Plan is still relevant.

Government White Paper titled 'Local Growth: Realising Every Place's Potential

The Council has failed to take account of proposed reforms to the planning system set out in the Government White Paper titled 'Local Growth: Realising Every Place's Potential. On 28th October 2010 the Government published the Local Growth White Paper, which sets out a new approach to sub-national growth, including more information about Local Enterprise Partnerships and the Regional Growth Fund. It focuses on three key themes:

* Shifting power to local communities and businesses.
* Increasing confidence to invest, that is to create the right conditions for growth through Government allowing market forces to determine where growth takes place and provide incentives which ensure that local communities benefit from development.
* Focused intervention by tackling barriers to growth that the market will not address itself, supporting investment that will have a long term impact on growth and supporting areas with long term growth challenges manage their transition to what is appropriate for the local area.

Section 3 of the White Paper confirms that the Government is committed to reforming the planning system, so that it actively encourages growth. Reforms will ensure that people have greater ownership of the planning system. Actions proposed include:

* Introducing a national presumption in favour of sustainable development, which will apply to decisions on all planning applications;
* Giving local communities new Right-to-Build powers;
* fundamentally reforming and streamlining national planning policy and guidance, presenting to Parliament a simple national planning framework; and
* Placing a new statutory duty to cooperate with local authorities, public bodies and private bodies that are critical to plan-making, such as infrastructure providers.

Paragraph 3.7 states a key part of planning reforms will therefore be to introduce a national presumption in favour of sustainable development, which will apply to decisions on all planning applications and will support the strategic provision of new homes, offices, schools and other developments that help drive the growth of the economy.

Paragraph 3.1 of the White Paper states that the main function of the planning system is to give people the opportunity to shape the look and feel of their communities, including to protect and promote important environmental and social interests and to provide sufficient housing to meet demand.

In respect to development plan, Paragraph 3.8 states that communities will be centre-stage in the reformed planning system whilst paragraph 3.9 states every neighbourhood will be given the chance to shape its own development through the creation of neighbourhood plans, which will give local communities greater flexibility and the freedom to bring forward more development than set out in the local authority plan. Neighbourhood plans will need to respect the overall national presumption in favour of sustainable development, as well as other local strategic priorities such as the positioning of transport links and meeting housing need.

The text box in Section 3 of the White Paper explains that the Government will create a framework of incentives for local authorities to deliver sustainable economic development, including the New Homes Bonus scheme, starting in 2011-12, which will support new housing development. Paragraph 3.29 provides further details of the New Homes Bonus. The scheme will ensure that communities and local authority decision-makers enjoy the benefits of growth and not just the costs. Starting in 2011-12 the scheme will match fund the additional council tax for each new home and property brought back into use, for each of the six years after that home is built. Central government will help establish the scheme with support of £196 million in the first year and £250 million for each of the following three years.

The promotion of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to enhance the quality of life of its residents, enhance the individuality and character of Rochford. The Core Strategy should therefore be a product of genuine community involvement that provides local people the opportunity to shape their communities.

It is clear from the scale of representations and comments received during the production of the Core Strategy that the local residents are strongly opposed to the spatial distribution of housing proposed across the district. In the interests of promoting localism and embracing the emerging planning policy, the Council should amend its spatial strategy to build in mechanism to introduce 'Neighbourhood Plans' that will set the quantum and location of housing and economic development for each neighbourhood. The Core Strategy should therefore set the district-wide housing requirements but not the broad locations.

Summary

The 'Schedule of Changes' are not complaint with existing national and regional planning policy and they do not take account of emerging planning policy reforms. There is no policy basis in which to make the changes and they are therefore unsound.

(ii) Justified

The changes made as noted above are unsound on the basis that they are not justified.

PPS12 states that to be 'justified' a DPD needs to be founded on a robust and credible evidence base involving evidence of participation of the local community and others having a stake in the area, and robust research. It is further stated that the most appropriate strategy when considered against reasonable alternatives.

The significant reduction of the housing numbers does not reflect the East of England Plan or the evidence base that informed this document.

General Approach

The East of England Plan requires a minimum of 4,600 dwellings to be provided in the District between 2001 and 2021. In addition, the Local Planning Authority is required to plan for delivery of housing for at least 15 years from the date of adoption of the Core Strategy. Therefore housing needs to be identified for the period to 2024.

The 2009 Strategic Housing Land Availability Assessment (SHLAA) examined the supply of housing land and, although identified some capacity from extant permissions and other appropriate sites, also ascertained that Green Belt would have to be reallocated in order to meet the requirements of the East of England Plan. It is stated that 2,745 dwellings are required on Green Belt land between 2006 and 2024. This is in addition to the 2,005 dwellings to be delivered on previously developed land.

The Core Strategy sets out the general locations for housing development. The Council state that the primary factors in determining the location of future housing include current infrastructure; access to services; facilities; housing demand/need; deliverability; public transport/possibility of reducing car dependency; opportunities to utilise brownfield land; community needs and physical constraints; need to protect areas of landscape value, ecological importance and high quality agricultural land. The Council states that it seeks balance the distribution of housing by focusing growth upon the higher tier settlements.

The population of Rochford District is unevenly distributed with the largest settlement being Rayleigh which, in 2001, was home to 30,196 people, 38% of the District's residents. As such the Council identified Rayleigh as a primary tier settlement as it contains a range services and facilities including good public transport accessibility. The Core Strategy however notes that their housing needs evidence indicates that 44% of the housing need in the borough originates from Rayleigh. This provides a strong basis in which to focus housing development upon Rayleigh.

Despite what is said in the Core Strategy, it is clear that Council has failed to consider a more balanced approach to housing delivery. The unbalanced approach is set out in the Schedule of Changes. However the Council's proposed housing locations do not reflect this statement as the scattered approach around the district will deliver housing away from public transport and key services and will lead to unsustainable patterns of growth. The Council's own evidence states that 44% of the need for housing is focused on Rayleigh, yet Rayleigh will only deliver 19% of housing on Green Belt sites. This will result in increased car movements between the settlements and will have an unsustainable impact upon the existing infrastructure.

The Schedule of Changes has failed to take account of the housing need for Rayleigh. There is a need for the Council to identify and significant increase in the housing provision for Rayleigh to meet the socio-economic objectives set out in the Rochford Core Strategy Submission draft.

(iii) Effective

The schedule of changes are unsound on the basis that they are not effective. The reduction of housing will have housing deliverability implications that will render these changes unsound. There is no demonstration of sound infrastructure planning. The Council should therefore consider smaller and easily developable sites that are well connected to the primary tier and most sustainable settlement of Rayleigh.

The housing reduction target is a material change that needs to careful consideration. If the Council is minded to pursue the housing reduction, then they will need to reassess the spatial strategy to take account of existing infrastructure; access to services; facilities; housing demand/need; deliverability; public transport/possibility of reducing car dependency. The housing reduction would provide the opportunity for the Council to reassess its approach and consider a more appropriate spatial strategy that meets the housing needs of Rayleigh.

On this basis, my clients consider that land south of Rayleigh would provide a more suitable and sustainable broad housing location. The sites that make up land south of Rayleigh are included on the enclosed site plan. Land south of Rayleigh is located to the south of the urban area of Rayleigh and has the potential to deliver up to approximately 290 market and affordable dwellings.

This broad location is just 1 mile from Rayleigh town centre and 1.4 miles from Rayleigh Train Station which provides convenient public transport connections to Southend-on-Sea, Stratford and London Liverpool Street. A number of bus routes operate along Eastwood Road, with a bus stop adjacent to the proposed access. This provides good and convenient public transport accessibility to Rayleigh Town Centre and Rayleigh Train Station and access to existing services.

This broad location is well located to the main centres of employment in Rayleigh being located in close proximity to the town centre but is also just 800 metres by foot from Brook Street Industrial Estate or approximately 1.5 miles by bike or car.

The site adjoins the urban edge of Rayleigh to the south. The broad location abuts the rear boundary line of the dwellings located along South View Road and Eastwood Road and land to the south of Wyburns Primary School.

The broad location is visually contained by a mature wooded area that would also create a natural and defensible boundary for a future development.

This broad location has no existing function other than being used for extended residential garden use. The broad location has no beneficial agricultural function, no viable equestrian function and no commercial function. This land represents under-used land that in its current state detracts from the character and function of the area.

Land south of Rayleigh also has the following benefits:

* There are no public footpaths or rights of way that cross this site and the site has no recreational value.
* The proposed site is connected to existing utilities infrastructure.
* The proposed site could be accessed from Eastwood Road and Daws Heath Road.
* There are no contamination issues at this location.

(iv) Legal Compliance

My clients consider that the Core Strategy is not legally compliant on the basis that my client's were not invited to make representations to the Core Strategy Submission Draft. The Council were therefore in breach of Regulation 25(3) and PPS12 paragraphs 4.24 to 4.29. My client's were therefore not given the opportunity to comment on the spatial strategy and attend the Examination in Public.

This issue was raised at the recent Site Allocations consultation. The Council subsequently forwarded the Core Strategy Proposed Submission letters that were addressed to my clients. Despite forwarding these letters, it does not prove that the Council sent the letters as neither of my client's who all reside at four separate addresses received the said letters which suggests that a process error occurred at the time the Council published its Proposed Submission Core Strategy.

(v) Conclusion

I trust that the comments, made on behalf of my clients will be considered. However should you require clarification on any matters raised above, please do not hesitate to contact me.

ROCHFORD CORE STRATEGY SUBMISSION: SCHEDULE OF CHANGES

We act on behalf of Mr Maughan and Mr Lambourn who own land south of Eastwood Road, Rayleigh, and Mrs M. Bingley and Mr H. Johnson who own land south of Wyburns Primary School, Rayleigh. Both sites are identified on the enclosed site plan.

My clients consider that the following amendments are neither consistent with national policy, justified nor effective.

* Paragraph 2.29 (P39);
* Paragraph 2.31 (P39);
* Paragraph 4.4 (P39);
* Paragraph 4.6 (P39);
* Table (P30/40);
* Appendix CSSC1;
* Appendix CSSC2; and
* Appendix CSSC3.

(i) Consistent with National Policy

The 'Schedule of Changes' are not compliant with national planning policy and in particular fails to take account of the adopted East of England Plan and fails to take account of emerging planning policy set out in the Government White Paper titled 'Local Growth: Realising Every Place's Potential - Presented to Parliament by the Secretary of State for Business, Innovation & Skills by Command of Her Majesty (28 October 2010)'.

East of England Plan

The proposed amendments to the housing numbers and the phasing set out in the Schedule of Changes conflicts with the requirements of Policy H1 of East of England Plan. This policy sets the housing provision requirement of Rochford District at 4,600 dwellings to be built between 2001 and 2021. The proposed changes are therefore unsound.

It is recognised that the Regional Spatial Strategy was revoked in June 2010, however the High Court ruled that the Communities Secretary Eric Pickles acted unlawfully by revoking the regional planning strategies. Therefore the East of England Plan stills forms part of the development plan and is still a material consideration in planning decisions. The Council was premature in making the amendments to the housing numbers prior to the High Court ruling.

The East of England Plan (regional spatial strategy) is part of the 'development plan' for Rochford by virtue of Section 38(3) of the Planning and Compulsory Purchase Act 2004. The importance of the East of England Plan is emphasised in regulation 29 of the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008 states which that a local planning authority must make a request to assess the general conformity of the DPD with the regional spatial strategy.

Furthermore paragraph 1.6 of Planning Policy Statement 12 (PPS12) states that spatial planning objectives for local areas, as set out in the LDF, should be aligned not only with national and regional plans, but also with the shared local priorities set out in Sustainable Community Strategies. Paragraph 2.1 states that the spatial planning process of place shaping and delivery aims to produce a vision for the future of places that responds to the local challenges and opportunities, and is based on evidence, a sense of local distinctiveness and community derived objectives, within the overall framework of national policy and regional strategies. The text box in Section 3 states that regional spatial strategies provide the overall spatial vision for the entire region, identifying the broad locations for growth, together with the housing numbers to be provided for in LDDs. The East of England Plan is a product of effective engagement with the local authorities and therefore it provides the regional framework against which local participation in creating Sustainable Community Strategies and Core Strategies takes place.

Therefore the housing provision for Rochford District as set out in Policy H1 of the East of England Plan is still relevant.

Government White Paper titled 'Local Growth: Realising Every Place's Potential

The Council has failed to take account of proposed reforms to the planning system set out in the Government White Paper titled 'Local Growth: Realising Every Place's Potential. On 28th October 2010 the Government published the Local Growth White Paper, which sets out a new approach to sub-national growth, including more information about Local Enterprise Partnerships and the Regional Growth Fund. It focuses on three key themes:

* Shifting power to local communities and businesses.
* Increasing confidence to invest, that is to create the right conditions for growth through Government allowing market forces to determine where growth takes place and provide incentives which ensure that local communities benefit from development.
* Focused intervention by tackling barriers to growth that the market will not address itself, supporting investment that will have a long term impact on growth and supporting areas with long term growth challenges manage their transition to what is appropriate for the local area.

Section 3 of the White Paper confirms that the Government is committed to reforming the planning system, so that it actively encourages growth. Reforms will ensure that people have greater ownership of the planning system. Actions proposed include:

* Introducing a national presumption in favour of sustainable development, which will apply to decisions on all planning applications;
* Giving local communities new Right-to-Build powers;
* fundamentally reforming and streamlining national planning policy and guidance, presenting to Parliament a simple national planning framework; and
* Placing a new statutory duty to cooperate with local authorities, public bodies and private bodies that are critical to plan-making, such as infrastructure providers.

Paragraph 3.7 states a key part of planning reforms will therefore be to introduce a national presumption in favour of sustainable development, which will apply to decisions on all planning applications and will support the strategic provision of new homes, offices, schools and other developments that help drive the growth of the economy.

Paragraph 3.1 of the White Paper states that the main function of the planning system is to give people the opportunity to shape the look and feel of their communities, including to protect and promote important environmental and social interests and to provide sufficient housing to meet demand.

In respect to development plan, Paragraph 3.8 states that communities will be centre-stage in the reformed planning system whilst paragraph 3.9 states every neighbourhood will be given the chance to shape its own development through the creation of neighbourhood plans, which will give local communities greater flexibility and the freedom to bring forward more development than set out in the local authority plan. Neighbourhood plans will need to respect the overall national presumption in favour of sustainable development, as well as other local strategic priorities such as the positioning of transport links and meeting housing need.

The text box in Section 3 of the White Paper explains that the Government will create a framework of incentives for local authorities to deliver sustainable economic development, including the New Homes Bonus scheme, starting in 2011-12, which will support new housing development. Paragraph 3.29 provides further details of the New Homes Bonus. The scheme will ensure that communities and local authority decision-makers enjoy the benefits of growth and not just the costs. Starting in 2011-12 the scheme will match fund the additional council tax for each new home and property brought back into use, for each of the six years after that home is built. Central government will help establish the scheme with support of £196 million in the first year and £250 million for each of the following three years.

The promotion of localism and the changes to the planning system being brought into place by the Government provide an opportunity for the Council to enhance the quality of life of its residents, enhance the individuality and character of Rochford. The Core Strategy should therefore be a product of genuine community involvement that provides local people the opportunity to shape their communities.

It is clear from the scale of representations and comments received during the production of the Core Strategy that the local residents are strongly opposed to the spatial distribution of housing proposed across the district. In the interests of promoting localism and embracing the emerging planning policy, the Council should amend its spatial strategy to build in mechanism to introduce 'Neighbourhood Plans' that will set the quantum and location of housing and economic development for each neighbourhood. The Core Strategy should therefore set the district-wide housing requirements but not the broad locations.

Summary

The 'Schedule of Changes' are not complaint with existing national and regional planning policy and they do not take account of emerging planning policy reforms. There is no policy basis in which to make the changes and they are therefore unsound.

(ii) Justified

The changes made as noted above are unsound on the basis that they are not justified.

PPS12 states that to be 'justified' a DPD needs to be founded on a robust and credible evidence base involving evidence of participation of the local community and others having a stake in the area, and robust research. It is further stated that the most appropriate strategy when considered against reasonable alternatives.

The significant reduction of the housing numbers does not reflect the East of England Plan or the evidence base that informed this document.

General Approach

The East of England Plan requires a minimum of 4,600 dwellings to be provided in the District between 2001 and 2021. In addition, the Local Planning Authority is required to plan for delivery of housing for at least 15 years from the date of adoption of the Core Strategy. Therefore housing needs to be identified for the period to 2024.

The 2009 Strategic Housing Land Availability Assessment (SHLAA) examined the supply of housing land and, although identified some capacity from extant permissions and other appropriate sites, also ascertained that Green Belt would have to be reallocated in order to meet the requirements of the East of England Plan. It is stated that 2,745 dwellings are required on Green Belt land between 2006 and 2024. This is in addition to the 2,005 dwellings to be delivered on previously developed land.

The Core Strategy sets out the general locations for housing development. The Council state that the primary factors in determining the location of future housing include current infrastructure; access to services; facilities; housing demand/need; deliverability; public transport/possibility of reducing car dependency; opportunities to utilise brownfield land; community needs and physical constraints; need to protect areas of landscape value, ecological importance and high quality agricultural land. The Council states that it seeks balance the distribution of housing by focusing growth upon the higher tier settlements.

The population of Rochford District is unevenly distributed with the largest settlement being Rayleigh which, in 2001, was home to 30,196 people, 38% of the District's residents. As such the Council identified Rayleigh as a primary tier settlement as it contains a range services and facilities including good public transport accessibility. The Core Strategy however notes that their housing needs evidence indicates that 44% of the housing need in the borough originates from Rayleigh. This provides a strong basis in which to focus housing development upon Rayleigh.

Despite what is said in the Core Strategy, it is clear that Council has failed to consider a more balanced approach to housing delivery. The unbalanced approach is set out in the Schedule of Changes. However the Council's proposed housing locations do not reflect this statement as the scattered approach around the district will deliver housing away from public transport and key services and will lead to unsustainable patterns of growth. The Council's own evidence states that 44% of the need for housing is focused on Rayleigh, yet Rayleigh will only deliver 19% of housing on Green Belt sites. This will result in increased car movements between the settlements and will have an unsustainable impact upon the existing infrastructure.

The Schedule of Changes has failed to take account of the housing need for Rayleigh. There is a need for the Council to identify and significant increase in the housing provision for Rayleigh to meet the socio-economic objectives set out in the Rochford Core Strategy Submission draft.

(iii) Effective

The schedule of changes are unsound on the basis that they are not effective. The reduction of housing will have housing deliverability implications that will render these changes unsound. There is no demonstration of sound infrastructure planning. The Council should therefore consider smaller and easily developable sites that are well connected to the primary tier and most sustainable settlement of Rayleigh.

The housing reduction target is a material change that needs to careful consideration. If the Council is minded to pursue the housing reduction, then they will need to reassess the spatial strategy to take account of existing infrastructure; access to services; facilities; housing demand/need; deliverability; public transport/possibility of reducing car dependency. The housing reduction would provide the opportunity for the Council to reassess its approach and consider a more appropriate spatial strategy that meets the housing needs of Rayleigh.

On this basis, my clients consider that land south of Rayleigh would provide a more suitable and sustainable broad housing location. The sites that make up land south of Rayleigh are included on the enclosed site plan. Land south of Rayleigh is located to the south of the urban area of Rayleigh and has the potential to deliver up to approximately 290 market and affordable dwellings.

This broad location is just 1 mile from Rayleigh town centre and 1.4 miles from Rayleigh Train Station which provides convenient public transport connections to Southend-on-Sea, Stratford and London Liverpool Street. A number of bus routes operate along Eastwood Road, with a bus stop adjacent to the proposed access. This provides good and convenient public transport accessibility to Rayleigh Town Centre and Rayleigh Train Station and access to existing services.

This broad location is well located to the main centres of employment in Rayleigh being located in close proximity to the town centre but is also just 800 metres by foot from Brook Street Industrial Estate or approximately 1.5 miles by bike or car.

The site adjoins the urban edge of Rayleigh to the south. The broad location abuts the rear boundary line of the dwellings located along South View Road and Eastwood Road and land to the south of Wyburns Primary School.

The broad location is visually contained by a mature wooded area that would also create a natural and defensible boundary for a future development.

This broad location has no existing function other than being used for extended residential garden use. The broad location has no beneficial agricultural function, no viable equestrian function and no commercial function. This land represents under-used land that in its current state detracts from the character and function of the area.

Land south of Rayleigh also has the following benefits:

* There are no public footpaths or rights of way that cross this site and the site has no recreational value.
* The proposed site is connected to existing utilities infrastructure.
* The proposed site could be accessed from Eastwood Road and Daws Heath Road.
* There are no contamination issues at this location.

(iv) Legal Compliance

My clients consider that the Core Strategy is not legally compliant on the basis that my client's were not invited to make representations to the Core Strategy Submission Draft. The Council were therefore in breach of Regulation 25(3) and PPS12 paragraphs 4.24 to 4.29. My client's were therefore not given the opportunity to comment on the spatial strategy and attend the Examination in Public.

This issue was raised at the recent Site Allocations consultation. The Council subsequently forwarded the Core Strategy Proposed Submission letters that were addressed to my clients. Despite forwarding these letters, it does not prove that the Council sent the letters as neither of my client's who all reside at four separate addresses received the said letters which suggests that a process error occurred at the time the Council published its Proposed Submission Core Strategy.

(v) Conclusion

I trust that the comments, made on behalf of my clients will be considered. However should you require clarification on any matters raised above, please do not hesitate to contact me.

To Whom it May Concern,

I wish to register my objections to the Core Strategy. I particularly object to the building of new houses. I believe our district s not a suitable place for additional housebuilding for a number of reasons, the biggest being a severe lack of infrastructure to support additional residents and vehicles.

The South East, as every knows, is very densely populated, and our district is no exception. Roads in the area are badly congested, and many road surfaces are of poor quality. There are no local jobs and healthcare is already severely stretched.

I would appeal to you not to abuse our district, especially the precious Green Belt, by allowing the building of more new homes. I believe local people are overwhelmingly against this plan and as our representatives you should honour that and not press ahead with the current plans.

I write in connection with the proposed development in Hullbridge and wish to lodge my objections to the core strategy of developing any houses in our region. I wrote to you on this subject in detail on the 13th April '10, outlining all my legitimate concerns and reasons for the objection and still stand by my decision.



With regard to developing the south east, because we are the most densely populated country in the EU bar Malta and the South-East has no further room, what is it that the government know that we do not!

Proposed Changes to Core Strategy
Submission Document, October 2010
Public Consultation Period 18.10.10 to 30.11.10



The Efficient Use of Land for Housing
There is still no evidence that the authority has researched sites for development that are not on prime agricultural land. (BMV Land). There is no evidence that a proper search has been carried out for Brownfield sites. Also, referring to the Call for Sites carried out in 2007, no evidence that these have been fully explored.

BMV land is proposed in the first phase. This may not prove to be necessary in a few years. By that time it will be too late!

At the hearing earlier this year, a number of landowners put forward land for development which were turned down with no evidence that these sites had been explored and/or whether there are proper reasons for refusal to develop these sites.


Need For Housing - Affordable Housing
The proposed development in the Core Strategy does not reflect the numbers of people on the Housing Register. The figures produced by the Authority show the largest number of people on the Housing Register are for Rayleigh where no housing is planned for 15 years. Development is centred in the middle of the district where the need is shown to be significantly less. No need demonstrated to warrant building in the Green Belt.


Lack of Appropriate Infrastructure
The Core Strategy proposes development in the centre of the district which will not cope with the increase in traffic. At peek times, the surrounding roads are at saturation point.

Reliance was placed on the proposed South Essex Rapid Transport scheme. This appears to have been scrapped. There should now be a sustainability appraisal in connection with proposed sites in the centre of the district in the absence of the SERT scheme.

More dwellings around the roads that are already congested will make travel for all road users hazardous.


Windfall Sites
There has been no published estimation on the number of windfall sites that may come forward during the first building phase. Looking at the number of dwellings built since 2001, it would be possible to have a meaningful prediction of the number dwellings that may be built during the first phase. The council is committed to 190 dwellings per year. There is no evidence that a consideration of windfall sites has been made. This could negate the need for building in the Green Belt.


Best Most Versatile Land (BMV)
At a time when we constantly read about the need to feed the population and the rise in cost of wheat based products, there is no evidence that the Authority has considered the loss of BMV land and/or provided exceptional circumstance why BMV land should be developed. This should be the last category of land to be developed, not land earmarked in phase one!






The Core Strategy remains unsound: No further evidence has emerged since the first consultation to show that this is compliant with PPG2 and PPG13. The proposed loss of prime agricultural land is not economically sound or sustainable.

Change needed: The council need to look more closely at the damage the proposed development in the green belt will cause to those living in the district by way of loss of amenity.

AMENDED CORE STRATEGY - OCTOBER 2010


The Parish Council recognises that some provision of housing may be necessary in future years but welcomes the government's revocation of the East of England Plan. This should have given the District Council the opportunity to reassess comprehensively the Core Strategy and the proposed distribution of development across the district but that opportunity has not been taken.

To simply extend the period for provision for 3,800 new homes from 2026 to 2031 does not address the problem of the siting the majority of the housing in H2 in the centre of the district. The concentration of development in south Hawkwell, west Rochford and east Ashingdon will add significantly to the congestion already experienced in Ashingdon Road, Rectory Road and Hall Road. There is no evidence that the consolidated impact of these various developments on the highway network has been assessed and no consideration has been given to mapping highway improvements to the proposed house phasing. As with other environmental issues the capacity of the highway network should be assessed formally with consideration of the cumulative effects on other developments.

The appraisal of sustainability of Rochford District states that Rayleigh has the best access to services, the highway network provides good links to London, Chelmsford, Basildon and Thurrock. Yet no housing is proposed for Rayleigh till post 2026.

H3. The use of windfall sites to reduce the numbers of houses in the green belt is to be welcomed, however it will not help Hawkwell as all the proposed housing is in the first phase and it will be too late to prevent the loss of green belt once the land is developed.

The Core Strategy states that most of Rochford District lies within the green belt and very little will be lost. We regard this as, at best misleading and at worst disingenuous. The majority of open space in the district is on Foulness Island, Wallasea Island, Pagglesham, Canewdon and Wakering. To imply that use of such a small percentage of greenbelt is acceptable fails to recognise the concentration of development that is being proposed. There is very little open space in the centre of the district yet some 67% of the housing plus employment sites in London Southend Airport and Rayleigh are in the green belt and concentrated in the centre.

We are unconvinced of the fairness of the arguments put forward and retain the view that the location of proposed housing is as a result of political pressure from Members who represent the west of the district. Therefore for all these reasons the Parish Council considers the Core Strategy as amended in October 2010 to be unsound.

The Parish wishes to be represented at the examination in public in the New Year.

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.

We act on behalf of Bellway Homes Ltd who control some 33.45 ha of land to the west of Rochford. 'Land to the West of Rochford' has been identified by Rochford District Council (RDC) as a location for housing development in the Submission draft of the Core Strategy (CS) Document Plan Document (DPD) (see policy H2 and Appendix H1). Bellway support this proposal and we have appeared at previous hearing sessions of the Examination of the CS.

We write in response to the current consultation on the changes (Schedule of Proposed Changes 19th October - 30th November 2010) to the CS. The Inspector has requested the views of participants and this representation outlines Bellway's position in respect of these changes.

Revisions to the Core Strategy

The schedule of proposed changes sets out the Council's response to the Secretary of State's decision to revoke RSS dated 6 July 2001 and the guidance provided at that time by the DCLG. In short, the Council has sought to amend the CS to provide for housing in accordance with Option 1 RSS figures. The key changes to the CS include: a reduction in the number of dwellings to be provided in the District per annum from 250 to 190; the housing allocation to be a maximum rather than a minimum figure; the plan to run for a longer period of time (to 2031, rather than 2026); and to adopt a flexible 'plan, monitor, manage approach to housing provision. In addition, references to the East of England Plan were deleted. In terms of spatial strategy, this remains broadly the same as submitted; the principle effect being to extend the plan period and reduce the annual rate of delivery. Over the extended plan period, the total dwelling requirement remains broadly similar to that submitted.

In light of the CALA Homes High Court Judgement issued on 10 November 2010, the RSS has been reinstated and now once again forms part of the development plan. Accordingly, the emerging CS ought to be in conformity with the East of England Plan (see para 5.2 of PSS12). Following the Cala Homes Judgement, the Secretary of State wrote setting out his intention to revoke RSS through the prospective legislation and that this intention constituted a material consideration (see letter dated 10th November). We understand that this letter is likely to be subject of a High Court challenge. Furthermore, it is highly likely that further guidance will be issued before the Examination hearings reconvene in the New Year. Indeed, we understand that we are to expect revised guidance on 5 year housing land supply, together with the Localism and Democracy Bill. Further changes to the Government's planning policy are also expected.




The CS was submitted in the context of the East of England Plan (EEP) (RSS) and set out the Council's proposed response to the policies set out therein. It is open to the Council to revert to the CS as submitted and not to proceed with the recent changes. However, this raises the issue of whether the CS should ignore changes that are likely to be promoted by the Government through legislation and the likely response of the Council.

In our view, it is important that preparation of the CS does not come to an abrupt halt as a result of proposed changes to planning policy as this would have a very negative and unnecessary impact upon housing delivery in Rochford in the short-term. Para 4.4 of PPS12 requires Core Strategies to be flexible. Flexibility ought to include capacity to respond to changes in Government policy and practice. The CS seeks to set the spatial vision and strategy for the District for at least 15 years (see Para 4.13 of PPS12). The recent 'Schedule of Proposed Changes' (October 2010) confirmed the Council's position that notwithstanding the proposed revocation of RSS (the EEP) and the ability for the Council to set housing requirements locally, the broad spatial strategy and vision as set out in the Submission draft of the CS remained valid, with the principle change being the rate of delivery.

The Examination will test the soundness of the CS including its general conformity with the EEP and its flexibility. However, in terms of the capacity of the CS to respond to a future revocation of the EEP, given the Council's stance, we would argue that the spatial strategy is flexible and the variation in delivery rates (and the housing trajectory) can be achieved through an effective policy mechanism to monitoring and management.

It may well be that an extension to the plan period and/or a reduction in the annual rate, whilst maintaining the spatial strategy, may require a formal revision to the CS but in such circumstances, on the basis that the CS is adopted at that time and that the spatial strategy and vision is being pursued, any such review could be limited.

The Council may decide to proceed with the submitted changes but this will raise the issue of conformity with the CS. Alternatively, the Council may wish to proceed with the changes as an alternative strategy in the event that the RSS is revoked in advance of adoption or early in the life span of any adopted CS (a 'plan B'). On this basis, we would comment as follows:

Extended Plan Period

In the event that RSS is revoked and the Council adopt the housing requirements set out in the submitted changes, Bellway support the extension of the plan period, but that the effective delivery of the CS is dependent upon effective monitoring and management.

Quantum of Development

Notwithstanding the physical and environmental characteristics of the District, there is still a local housing need and the new household projections contained in Topic Paper 3 indicate that substantial green belt releases are still required to meet the 'Option 1' requirements. Furthermore, it is acknowledged that 'new market housing is definitely required' (Topic Paper 3 para 8.8) even if the focus of development is directed to other parts of the Thames Gateway South Essex market area.

Strategic Growth Locations

In terms of changes to policy H2 (Extension to residential envelopes), Bellway note the modification of housing delivery in strategic growth locations. With respect to West Rochford, it is proposed that 500 units are built between 2011 - 2021 and a further 100 between 2021 - 2026. Bellway confirm that the development of the site can satisfy this requirement.




Five Year Supply

In terms of five year supply, revised policies H2 and H3 set out appropriate quantum for the preferred development locations in the event of a reduced annual requirement across the District. As a result, the five year supply of housing would be reduced from 950 from 1250. Again, Bellway confirm that the implementation of the site can make a positive contribution to 5 year land supply.

Next Steps

We understand that the Council will forward this and other responses to the Inspector with the hearing sessions reconvening week commencing 17 January 2011. We note the guidance issued by PINS following the Cala Homes Judgement and appendix B, para 4 in particular. We await with interest the response of the Council.

We trust these representations will be considered appropriately.

We act on behalf of Bellway Homes Ltd who control some 33.45 ha of land to the west of Rochford. 'Land to the West of Rochford' has been identified by Rochford District Council (RDC) as a location for housing development in the Submission draft of the Core Strategy (CS) Document Plan Document (DPD) (see policy H2 and Appendix H1). Bellway support this proposal and we have appeared at previous hearing sessions of the Examination of the CS.

We write in response to the current consultation on the changes (Schedule of Proposed Changes 19th October - 30th November 2010) to the CS. The Inspector has requested the views of participants and this representation outlines Bellway's position in respect of these changes.

Revisions to the Core Strategy

The schedule of proposed changes sets out the Council's response to the Secretary of State's decision to revoke RSS dated 6 July 2001 and the guidance provided at that time by the DCLG. In short, the Council has sought to amend the CS to provide for housing in accordance with Option 1 RSS figures. The key changes to the CS include: a reduction in the number of dwellings to be provided in the District per annum from 250 to 190; the housing allocation to be a maximum rather than a minimum figure; the plan to run for a longer period of time (to 2031, rather than 2026); and to adopt a flexible 'plan, monitor, manage approach to housing provision. In addition, references to the East of England Plan were deleted. In terms of spatial strategy, this remains broadly the same as submitted; the principle effect being to extend the plan period and reduce the annual rate of delivery. Over the extended plan period, the total dwelling requirement remains broadly similar to that submitted.

In light of the CALA Homes High Court Judgement issued on 10 November 2010, the RSS has been reinstated and now once again forms part of the development plan. Accordingly, the emerging CS ought to be in conformity with the East of England Plan (see para 5.2 of PSS12). Following the Cala Homes Judgement, the Secretary of State wrote setting out his intention to revoke RSS through the prospective legislation and that this intention constituted a material consideration (see letter dated 10th November). We understand that this letter is likely to be subject of a High Court challenge. Furthermore, it is highly likely that further guidance will be issued before the Examination hearings reconvene in the New Year. Indeed, we understand that we are to expect revised guidance on 5 year housing land supply, together with the Localism and Democracy Bill. Further changes to the Government's planning policy are also expected.




The CS was submitted in the context of the East of England Plan (EEP) (RSS) and set out the Council's proposed response to the policies set out therein. It is open to the Council to revert to the CS as submitted and not to proceed with the recent changes. However, this raises the issue of whether the CS should ignore changes that are likely to be promoted by the Government through legislation and the likely response of the Council.

In our view, it is important that preparation of the CS does not come to an abrupt halt as a result of proposed changes to planning policy as this would have a very negative and unnecessary impact upon housing delivery in Rochford in the short-term. Para 4.4 of PPS12 requires Core Strategies to be flexible. Flexibility ought to include capacity to respond to changes in Government policy and practice. The CS seeks to set the spatial vision and strategy for the District for at least 15 years (see Para 4.13 of PPS12). The recent 'Schedule of Proposed Changes' (October 2010) confirmed the Council's position that notwithstanding the proposed revocation of RSS (the EEP) and the ability for the Council to set housing requirements locally, the broad spatial strategy and vision as set out in the Submission draft of the CS remained valid, with the principle change being the rate of delivery.

The Examination will test the soundness of the CS including its general conformity with the EEP and its flexibility. However, in terms of the capacity of the CS to respond to a future revocation of the EEP, given the Council's stance, we would argue that the spatial strategy is flexible and the variation in delivery rates (and the housing trajectory) can be achieved through an effective policy mechanism to monitoring and management.

It may well be that an extension to the plan period and/or a reduction in the annual rate, whilst maintaining the spatial strategy, may require a formal revision to the CS but in such circumstances, on the basis that the CS is adopted at that time and that the spatial strategy and vision is being pursued, any such review could be limited.

The Council may decide to proceed with the submitted changes but this will raise the issue of conformity with the CS. Alternatively, the Council may wish to proceed with the changes as an alternative strategy in the event that the RSS is revoked in advance of adoption or early in the life span of any adopted CS (a 'plan B'). On this basis, we would comment as follows:

Extended Plan Period

In the event that RSS is revoked and the Council adopt the housing requirements set out in the submitted changes, Bellway support the extension of the plan period, but that the effective delivery of the CS is dependent upon effective monitoring and management.

Quantum of Development

Notwithstanding the physical and environmental characteristics of the District, there is still a local housing need and the new household projections contained in Topic Paper 3 indicate that substantial green belt releases are still required to meet the 'Option 1' requirements. Furthermore, it is acknowledged that 'new market housing is definitely required' (Topic Paper 3 para 8.8) even if the focus of development is directed to other parts of the Thames Gateway South Essex market area.

Strategic Growth Locations

In terms of changes to policy H2 (Extension to residential envelopes), Bellway note the modification of housing delivery in strategic growth locations. With respect to West Rochford, it is proposed that 500 units are built between 2011 - 2021 and a further 100 between 2021 - 2026. Bellway confirm that the development of the site can satisfy this requirement.




Five Year Supply

In terms of five year supply, revised policies H2 and H3 set out appropriate quantum for the preferred development locations in the event of a reduced annual requirement across the District. As a result, the five year supply of housing would be reduced from 950 from 1250. Again, Bellway confirm that the implementation of the site can make a positive contribution to 5 year land supply.

Next Steps

We understand that the Council will forward this and other responses to the Inspector with the hearing sessions reconvening week commencing 17 January 2011. We note the guidance issued by PINS following the Cala Homes Judgement and appendix B, para 4 in particular. We await with interest the response of the Council.

We trust these representations will be considered appropriately.

AMENDED CORE STRATEGY - OCTOBER 2010


The Parish Council recognises that some provision of housing may be necessary in future years but welcomes the government's revocation of the East of England Plan. This should have given the District Council the opportunity to reassess comprehensively the Core Strategy and the proposed distribution of development across the district but that opportunity has not been taken.

To simply extend the period for provision for 3,800 new homes from 2026 to 2031 does not address the problem of the siting the majority of the housing in H2 in the centre of the district. The concentration of development in south Hawkwell, west Rochford and east Ashingdon will add significantly to the congestion already experienced in Ashingdon Road, Rectory Road and Hall Road. There is no evidence that the consolidated impact of these various developments on the highway network has been assessed and no consideration has been given to mapping highway improvements to the proposed house phasing. As with other environmental issues the capacity of the highway network should be assessed formally with consideration of the cumulative effects on other developments.

The appraisal of sustainability of Rochford District states that Rayleigh has the best access to services, the highway network provides good links to London, Chelmsford, Basildon and Thurrock. Yet no housing is proposed for Rayleigh till post 2026.

H3. The use of windfall sites to reduce the numbers of houses in the green belt is to be welcomed, however it will not help Hawkwell as all the proposed housing is in the first phase and it will be too late to prevent the loss of green belt once the land is developed.

The Core Strategy states that most of Rochford District lies within the green belt and very little will be lost. We regard this as, at best misleading and at worst disingenuous. The majority of open space in the district is on Foulness Island, Wallasea Island, Pagglesham, Canewdon and Wakering. To imply that use of such a small percentage of greenbelt is acceptable fails to recognise the concentration of development that is being proposed. There is very little open space in the centre of the district yet some 67% of the housing plus employment sites in London Southend Airport and Rayleigh are in the green belt and concentrated in the centre.

We are unconvinced of the fairness of the arguments put forward and retain the view that the location of proposed housing is as a result of political pressure from Members who represent the west of the district. Therefore for all these reasons the Parish Council considers the Core Strategy as amended in October 2010 to be unsound.

The Parish wishes to be represented at the examination in public in the New Year.

AMENDED CORE STRATEGY - OCTOBER 2010


The Parish Council recognises that some provision of housing may be necessary in future years but welcomes the government's revocation of the East of England Plan. This should have given the District Council the opportunity to reassess comprehensively the Core Strategy and the proposed distribution of development across the district but that opportunity has not been taken.

To simply extend the period for provision for 3,800 new homes from 2026 to 2031 does not address the problem of the siting the majority of the housing in H2 in the centre of the district. The concentration of development in south Hawkwell, west Rochford and east Ashingdon will add significantly to the congestion already experienced in Ashingdon Road, Rectory Road and Hall Road. There is no evidence that the consolidated impact of these various developments on the highway network has been assessed and no consideration has been given to mapping highway improvements to the proposed house phasing. As with other environmental issues the capacity of the highway network should be assessed formally with consideration of the cumulative effects on other developments.

The appraisal of sustainability of Rochford District states that Rayleigh has the best access to services, the highway network provides good links to London, Chelmsford, Basildon and Thurrock. Yet no housing is proposed for Rayleigh till post 2026.

H3. The use of windfall sites to reduce the numbers of houses in the green belt is to be welcomed, however it will not help Hawkwell as all the proposed housing is in the first phase and it will be too late to prevent the loss of green belt once the land is developed.

The Core Strategy states that most of Rochford District lies within the green belt and very little will be lost. We regard this as, at best misleading and at worst disingenuous. The majority of open space in the district is on Foulness Island, Wallasea Island, Pagglesham, Canewdon and Wakering. To imply that use of such a small percentage of greenbelt is acceptable fails to recognise the concentration of development that is being proposed. There is very little open space in the centre of the district yet some 67% of the housing plus employment sites in London Southend Airport and Rayleigh are in the green belt and concentrated in the centre.

We are unconvinced of the fairness of the arguments put forward and retain the view that the location of proposed housing is as a result of political pressure from Members who represent the west of the district. Therefore for all these reasons the Parish Council considers the Core Strategy as amended in October 2010 to be unsound.

The Parish wishes to be represented at the examination in public in the New Year.

AMENDED CORE STRATEGY - OCTOBER 2010


The Parish Council recognises that some provision of housing may be necessary in future years but welcomes the government's revocation of the East of England Plan. This should have given the District Council the opportunity to reassess comprehensively the Core Strategy and the proposed distribution of development across the district but that opportunity has not been taken.

To simply extend the period for provision for 3,800 new homes from 2026 to 2031 does not address the problem of the siting the majority of the housing in H2 in the centre of the district. The concentration of development in south Hawkwell, west Rochford and east Ashingdon will add significantly to the congestion already experienced in Ashingdon Road, Rectory Road and Hall Road. There is no evidence that the consolidated impact of these various developments on the highway network has been assessed and no consideration has been given to mapping highway improvements to the proposed house phasing. As with other environmental issues the capacity of the highway network should be assessed formally with consideration of the cumulative effects on other developments.

The appraisal of sustainability of Rochford District states that Rayleigh has the best access to services, the highway network provides good links to London, Chelmsford, Basildon and Thurrock. Yet no housing is proposed for Rayleigh till post 2026.

H3. The use of windfall sites to reduce the numbers of houses in the green belt is to be welcomed, however it will not help Hawkwell as all the proposed housing is in the first phase and it will be too late to prevent the loss of green belt once the land is developed.

The Core Strategy states that most of Rochford District lies within the green belt and very little will be lost. We regard this as, at best misleading and at worst disingenuous. The majority of open space in the district is on Foulness Island, Wallasea Island, Pagglesham, Canewdon and Wakering. To imply that use of such a small percentage of greenbelt is acceptable fails to recognise the concentration of development that is being proposed. There is very little open space in the centre of the district yet some 67% of the housing plus employment sites in London Southend Airport and Rayleigh are in the green belt and concentrated in the centre.

We are unconvinced of the fairness of the arguments put forward and retain the view that the location of proposed housing is as a result of political pressure from Members who represent the west of the district. Therefore for all these reasons the Parish Council considers the Core Strategy as amended in October 2010 to be unsound.

The Parish wishes to be represented at the examination in public in the New Year.

Consultation on Core Strategy Schedule of Changes

Thank you for the opportunity to comment on the Core Strategy Schedule of Changes.
EEDA's principal role is to improve the East of England region's economic performance. Our main concern with strategy documents is therefore that they will help deliver, and provide the spatial framework for:
* sustainable economic development and regeneration in the East of England, and in particular,
* the Regional Economic Strategy (Inventing the Future - Collective Action for a sustainable economy, 2008).

The decision to revoke Regional Strategies has now been quashed although the Secretary of State has reiterated his intention to abolish the regional tier. Cala Homes has also brought a second round of proceedings against the government over its approach to the abolition of regional spatial strategies and are currently seeking a declaration from the Court that the government's stated intention to enact primary legislation in the future to abolish Regional Strategies is not a material consideration for determining planning applications. In the light of these ongoing decisions and the recent White Paper on Local Growth we would stress that the Council should ensure it has relevant, appropriate and sound evidence to support its policies and the approach to its delivery and implementation.

It is therefore relevant to suggest that the RSS and RES remain part of the material consideration until such time as it is legally revoked or the Cala injunction is resolved.

If you would like to discuss any of these matters in further detail, please do not hesitate to contact me at the above address.

Introduction

(i) This response is submitted on behalf of our clients, Countryside Properties (respondent ID 8650), and sets out our comments on the proposed changes to the Core Strategy published by the Council in October, and which arose from the revocation of RSS.

(ii) Since then, of course, the RSS has been reinstated. In addition, the passage of time also raises new concerns regarding the end date of the Plan, which we consider are relevant. Furthermore, and irrespective of our comments on the overall level of housing provision, we consider that there are specific anomalies to the phasing of the principal growth locations in the latest amendments that are not "Justified", and that both the proposed Phasing and lack of flexibility in Policy H2 will mean that the Policy will not be "Effective".

(iii) Our submissions are therefore made under four main headings:

(1) Housing Provisions in the "With the RSS Scenario", being the current position (and which also deals with the relevance or otherwise of the Secretary of State's insistence that the future revocation of RSS is a 'material consideration');

(2) Housing Provisions in the "Without the RSS Scenario", being the position that existed at the time the Council decided to amend the housing provisions of the Core Strategy, and the position that may exist again at some as yet unspecified date in the future;

(3) End Date of the Core Strategy, in relation to PPS12 requirements for duration and monitoring;

(4) Amendments to the Phasing Provisions for the growth areas in the proposed Core Strategy Changes (Policy H2).

(iv) Finally, under Section 5, we set out our summary/conclusions, including the changes we believe are required to render the Core Strategy sound.

1. Housing Provisions in the "With the RSS Scenario"

1.1 Section 24 (1) of the Planning and Compulsory Purchase Act states that all Local Development Documents must be in general conformity with the Regional Strategy i.e. in this case, the East of England Plan 2008. Paragraph 4.50 of PPS12 provides relevant guidance on this issue, noting that conformity with the Regional Strategy is one of the 'Legal' tests of soundness.

1.2 Whilst the RSS exists, being in "general conformity" with it is not an optional extra - it is a basic legal requirement of Soundness.

1.3 In his letter of 27th May 2010 the Secretary of State invited Local Planning Authorities and the Inspectorate to have regard to the Government's intention in the future to abolish Regional Spatial Strategies as a 'material consideration', and this is repeated in the recent letter from Mr Quartermain of 10th November 2010. However, this is an Examination in respect of a Development Plan Document, where the only consideration is that of Soundness - the concept of a "material consideration" simply has no applicability in the DPD process.

1.4 Perhaps the most significant aspect of the Cala Homes decision is that it is a firm reminder that the Secretary of State cannot change statute without going through due process, no matter how many letters he may choose to write, and whatever exhortations he might seek to place on decision makers to have regard to a new piece of legislation that has yet to be placed before Parliament, let alone debated or brought in to being.

1.5 We note that the Courts have, as of 29th November, made an announcement which confirms this view, but in any event case, the 'general conformity' test is prescribed by statute, and whilst the RSS exists, the need for general conformity remains.

1.6 The level of new housing to be provided at district level is one of the more significant functions that the RSS performs. PPS11, the operational guidance in force at the time of the preparation and adoption of the East of England Plan, sets out at paragraphs 1.2-1.8 the purpose and scope of RSS, with the one of the key matters being the "identification of the scale and distribution of provision for new housing" (para 1.3). Paragraph 34 of PPS3 provides specifically that the RSS should set out both the overall level of housing provision for the region, and that it should set out how this is to be distributed amongst housing market and local planning authority areas.

1.7 There is no equivocation in the manner in which the East of England Plan sets out the housing requirement. Policy H1 sets a minimum dwelling provision for Rochford District of 3,790 units between 2006 and 2021, and a requirement to provide for a further 1,250 dwellings between 2021 and 2026.

(Please note that we use an end of 2026, rather than 2025, due to the PPS12 requirement for a minimum of 15 years provision from the date of adoption - see Section 3 of these submissions).

1.8 The effect of the proposed amendments to the Core Strategy by the Council is twofold:

(i) To reduce provision between 2011 and 2026 to 2,850 units, and
(ii) To make no provision at all for the period between 2006-2011 (other than the default position of the number of units actually built during that period - Topic Paper 3 paragraph 7.7, we understand the projected completions 06-11 are 863).

1.9 The proposed amendments therefore make provision for only 3713 (partly as a result of the default position to 2011, and partly through future planned provision), against the RSS requirement for the same period of 5,040 units i.e. a shortfall of over 1327 units.

1.10 Although the Council's original Position Statement seeks to argue that the level of housing provision is largely the same as the RSS, just delivered over a longer period, this was essentially a 'glossing' of the position, and we note that Topic Paper 3 does not seek to maintain this position (see para 7.11 of TP3 "in short, the amended Core Strategy will deliver fewer dwellings in total over a longer period").

1.11 When tested against the RSS, the actual level of housing provision for the period 2006-2026 is over 1300 units below the minimum requirement, well over 25% less than the absolute minimum.

1.12 In that context, there can be no credibility in an argument that to substantially fail to meet the RSS housing requirement could still leave a Core Strategy in "general conformity".

1.13 With the revised and lower housing provision, this Core Strategy is not in general conformity, and it therefore fails one of the key legal tests of soundness.

1.14 The Core Strategy can however be made sound by restoring the Pre-Submission housing figures (alongside our previous representations), which have been subject to both SA and consultation.

2. Housing Provisions in the "Without the RSS scenario"

2.1 Given recent events, its seems only prudent in these submissions to consider the position that would exist were the RSS to be revoked again, although since no challenge has been lodged and the enactment of the Localism Bill is still a long way off, at the present time this seems an unlikely proposition before the close of this Examination.

2.2 We turn now to consider the position in the 'without RSS' scenario, under the following main headings:

* The so called 'Option 1' position;
* The status/implications of the Draft East of England Plan of March 2010, upon which the Council's case substantially relies;
* The Evidence Base - an assessment of what the Council's own evidence base tells the Examination about the Justification for the revised housing provision put forward by the Council.
* An assessment and response to the Council's Topic Paper 3 (and previously issued Position Statement) in the light of the above matters.

Option 1

2.3 The explanatory note on transitional arrangements issued by the Secretary of State on 6th July alongside the initial revocation of Regional Spatial Strategies noted that in the absence of RSS, it might be appropriate for Local Planning Authorities in the alternative to rely on their 'Option 1' figure, being the level of housing set out in the "original" draft RSS.

2.4 In an attempt to clarify the meaning of 'Option 1', Mr Robert Neill MP gave an answer to a parliamentary question on 1st July, which stated that for the East of England Region, the Option 1 figure should be taken as being the level of housing set out in the 2010 Draft RSS, and we note that this explanation is relied upon by Rochford District Council at paragraph 2.3 of Topic Paper 3. Mr Neill actually referred to a January 2010 version, but the published version was March 2010.

2.5 However, on 22nd July, Ipswich Borough Council wrote to DCLG to ask the same question, and on 9th August, DCLG responded by making clear that for the East of England Region, the Option 1 figure should be taken as being the "original Regional Regional Spatial Strategy" of 8th December 2004 (thereby flatly contradicting Mr Neill).

2.6 As the Inspector will be aware, the housing provisions in the original RSS as per the above are the same as the figures upon which the original Pre-Submission Draft was based i.e. 4,600 2001-2021, plus 250 units per annum from 2021.

2.7 So reliance upon the so called 'Option 1' number in the alternative to the adopted RSS would not support the reduction in housing that the Council now proposes.

Draft East of England Plan, March 2010

2.8 Notwithstanding the above, it may be relevant to consider whether the March 2010 Draft East of England Plan provides any support for the Council's revised proposals in any event, since this is the document upon which the Council revised level of housing is based.

2.9 The first point to note is that the Draft RSS was seeking to provide a 'roll-forward' of the RSS, covering the period 2011-2031. The provisions of the adopted RSS up to 2011 would have remained in force, up to the adoption of the new guidance for the period going forward beyond 2011. If the Council is to rely on the RSS as evidence, it cannot pick and choose its application. The housing figures in the roll forward of the RSS for 2011-2031 would have been in addition to the housing required under the adopted RSS for the period 2001-2011.

2.10 In that context, it is relevant to note that Rochford provided 810 units from 2001-2006, and note previously, the completions for 2006 to 2011 are stated by the Council to be 863, equating to a total provision 2001-2011 of just 1673 (pro-rata, the RSS requirement 2001-2011 would have been 2,300).

2.11 So even if the Draft RSS can be relied upon as a source of evidence, the shortfall arising from the adopted RSS to 2011 would also logically need to be provided for, but is not.

2.12 The second point regarding the Draft RSS is the weight to attach to it as 'evidence' in relation to this Examination, particularly bearing in mind its provisions have never been tested. There is no way of knowing whether or not the level of housing provision set out in the Draft would have been retained, and no way of knowing whether that level was any more justified than any of the other ranges of provision that were the subject of previous consultation.

2.13 However, in terms of what is known about the Draft RSS, and to assist the Inspector in considering the weight that might be attached to it, we would make the following two observations:

(1) The November 2009 RSS Consultation set out four different housing growth scenarios, based on varying sources of evidence on housing need across the region as a whole, including roll forward of the existing RSS (scenario 1), housing need forecasts (scenarios 2 and 3), and household projections (scenario 4). The total quantum of growth tested under the scenarios was: 521,120; 602,020; 599,480; and 673,000. The March 2010 Draft Plan H1 provisions were for 500,700. The trail of paperwork from the Regional Planning Panel provides no substantive evidence to support the lower figure eventually selected, and therefore the draft Plan as a piece of 'evidence' in its own right can have very limited weight attached to it.

In all scenarios, the requirement for Rochford ranged between 5,000 and 8,000 dwellings over the period 2011-2031, substantially more than the eventual draft RSS.

In terms of 'evidence' therefore, the technical assessments that underpinned the emerging RSS all supported a higher level of growth, both for the region as a whole, and for Rochford in particular, than the Council is now proposing;

(2) In respect of this particular Core Strategy, there is more detailed and substantive evidence available within Rochford Council's own evidence base that also supports a substantially higher level of housing growth than those set out in the (untested) Draft RSS.

2.14 For the above reasons, the Draft RSS does not provide a substantive body of evidence that supports the reduction in housing provision now being proposed by the Council. We turn now instead to consider the implications of Rochford's own evidence base.

The Rochford Core Strategy Evidence Base

2.15 In our original letter to the Examination in July following the initial revocation of RSS, we pointed out that the existence or otherwise of an RSS in no way altered the procedural requirements for the preparation of DPDs, and specifically that the content of any DPD needs to be based on evidence. Removing the RSS housing numbers does not remove the requirement for a DPD to be "sound", and this Core Strategy must still meets the tests of soundness, including that it be "Justified" i.e. founded on a robust and credible evidence base, and the most appropriate strategy when considered against the reasonable alternatives (PPS12 para 4.52).

2.16 The principle document in the Council's published evidence base that relates to the issue of housing need is the SHMA. The key conclusions of the 2008 Thames Gateway South Essex SHMA are as follows:

* The RSS housing provision for TGSE at 44,300 2001-2021 is already below the CLG's trend-based projections for household growth of 46,500 (para 10.27 of the SHMA);

* If the economic growth projections of the RSS of 55,000 additional jobs are achieved without any substantial shift in commuting patterns, then the pressure for housing growth would be even higher. The SHMA's authors predict a requirement in that eventuality for 62,100 new homes over the same period, 40% above the current RSS requirement (para 10.28). Although the policy intention is to reduce commuting to London, the authors go on to conclude that notwithstanding that policy aspiration, a projected surplus of jobs to houses in the capital may increase commuting (paras 10.38-10.52), and hence the potential for job growth in TGSE to fuel the need for more housing than the RSS currently provides is not idle speculation, but a relevant consideration;

* In terms of Affordable Housing need, Figure 11.13 on page 209 of the SHMA calculates a net annual affordable housing need in Rochford of 131 dwellings, equating to just over 50% of the RSS annual requirement of 250 dwellings per year. 50% affordable housing delivery is neither proposed nor viable. Delivering 131 affordable housing units per annum at 30% or 35% would require between 374 and 437 dwellings per annum, significantly higher than the residual RSS requirement upon which the Core Strategy is currently based. Any reduction in the overall level of housing delivery will have a direct knock on effect on the delivery of affordable housing, and even the current RSS housing number will result in a substantial shortfall in affordable housing delivery compared to need.

* The conclusions of the SHMA at paragraph 13.3 notes that a SHMA forms one of the inputs in to determining housing requirements and residential land-supply in LDFs. In the absence of the RSS, the SHMA would become the most important consideration in respect of the "need" side of the equation, representing the most comprehensive assessment of affordable and housing market requirements.

* The conclusions of this SHMA show that the current RSS provision should indeed be considered as a "minimum", since both market and affordable housing need are likely to exceed the level of provision established by the RSS.

2.17 The 2008 SHMA was updated in May 2010. The 2010 SHMA Update continues to support the findings set out above, but also notes the following:

* In-migration from East London boroughs remains a significant driver for the TGSE Housing Market, as a result of the differential value of housing stock between East London and TGSE and continuing ease of access to Central London and the City from South Essex (paras 2.8-2.9 of SHMA 2010);

* For Rochford District, in-migration from other parts of the UK is by far the most significant factor driving the need for new housing (cf Table 2.11 with tables 2.7-2.10);

* Rochford District has now overtaken Castle Point to the dubious distinction of being "the least affordable place for local residents" in TGSE (para 3.20 of SHMA 2010);

* Whereas in the SHMA 2008, affordable housing requirements equated to 50% of the RSS total, as set out above, the SHMA 2010 now estimates the affordable housing requirement as being 85% of the RSS annual total, with the net annual housing need having risen from 131 dwellings per annum to 196 dwellings per annum, compared to the 250 per annum required by the (former) East of England Plan.

2.18 The other principle source of evidence on housing provision levels of course is the adopted RSS (since this is the version that has been tested and found to properly establish an appropriate balance between meeting housing need and environmental/infrastructure constraints). A specific part of the evidence base that underpinned the consideration of the housing numbers in the original RSS was the ONS household and population forecasts. The EERA Technical Paper of September 2005 set out at Table A.1 the results of the 2002 ONS Household projections, by District. The projection for Rochford District was 7,000 additional households between 2001 and 2021, compared to the eventual proposal for 4,600 dwellings.

2.19 We recognise of course that the ONS projections take account of trends in migration, but nil-net migration is not a credible basis on which to base local housing requirements. Migration is a fact of life, and it is neither credible not reasonable to pretend that migration does not have an impact on housing demand and need in the Eastern Region, and particularly in the South Essex area, where the SHMA itself migration as being a key driving factor of housing need.

2.20 Taking in to account the available evidence on housing need, we would suggest that this not only supports the retention of a level of housing commensurate with the existing RSS, but that it also supports the continued application of that level of housing as a minimum. All of the evidence suggests that housing need, and particularly affordable housing need, is well in excess of the 4,600 units set out in the RSS.

Assessment and Response to Rochford District Council's Topic Paper 3 (and Position Statement)

2.21 Finally, we turn to the contents of Topic Paper 3, which sets out the Council's justification for the revised approach to housing provision. We set out below our response to the matters raised, in the order they arise:

2.22 Pages 1-2 - RSS Revocation - we have covered the technical matters in relation to this above. The Council notes that the DCLG advice allows for the evidence base for the RSS to be considered to be relevant (and we do not disagree with that) and the Council in turn then seeks to rely on the provisions of the March 2010 Draft RSS roll-forward. However, the Council gives no consideration as to what the actual 'evidence' was that led to that document, and as explained above, the technical evidence actually supported a level of growth in excess even of the original RSS;

2.23 Pages 3-9 - Housing Need - Although this is the longest section in Topic Paper 3, much of the material is drawn from the SHMAs (2008 and 2010) and is not therefore new material, and we have addressed much of this in our discussion of the Evidence Base above. Our comments below relate primarily to the interpretation of this evidence in Topic Paper 3.

Affordable Housing Need

2.24 At Paragraphs 3.2 and 3.25-3.28, we note that since the SHMA of 2010, the number of applicants on the Council's waiting list as increased. In the same way that the 2010 SHMA showed a worsening position in respect of affordability, so this further indicator shows that in relation to access to housing, the picture is not static in Rochford, but is continuing to get worse.

2.25 There is nothing in Topic Paper 3 that contradicts the conclusion from the SHMA 2010 that Rochford is "the least affordable place for local residents" in Thames Gateway, and the need for affordable housing delivery should be a significant factor in the determination of the level of overall housing provision in the Core Strategy.

Population Growth and Migration

2.26 Paragraphs 3.5-3.13 contain a commentary on published population projections for Rochford.

2.27 We note at paragraph 3.10 the suggestion that whilst internal migration from London is the dominant driver of population change in Thames Gateway, Rochford District has absorbed a relatively small proportion of this growth. This may be true, but as Table 2.11 of the SHMA 2010 shows (see extract below), internal migration is still the dominant driver of population change within Rochford (as the Council goes on to note at paragraph 3.7)

2.28 At paragraphs 3.12-3.13, the Council seeks to cast doubt on the accuracy of population forecasting, bearing in mind that different assumptions about migration can make significant differences to forecasts. It identifies three population projections based on the Population and Household Growth in the East of England 2001-2021, being:

* +5,500 persons 2001-2021 (275 pa) based on the "long-run" migration projection (i.e. migration levels between 1991 and 2001);
* +10,500 persons 2001-2021 (525 pa) based on the "short-run" migration projection (i.e. migration levels between 1996 and 2001); and
* +8,100 persons 2001-2021 (405 pa) based upon EERA's updated model run in 2006.

2.29 Whilst it is clearly true that different assumptions on migration will result in different projections, Figure 2.11 of the 2010 SMHA shows that actual internal migration 2002-2008 has tended to be in excess of 600 persons per annum, above even the highest projection. The total in-migration to Rochford in the period to date has therefore already in all likelihood exceeded the lower "long-run" migration figure, with over 10 years to go to 2021.

2.30 The evidence therefore of actual migration strongly supports the forecasting assumptions that Rochford does and will continue to experience high levels of in-migration.

Household Growth

2.31 At paragraph 3.16, Topic Paper 3 notes that based on 2007 population projections, the 2008 SHMA estimated 300 new households forming per annum, and the 2010 SHMA estimated 350 new households i.e. between 6,000 and 7,000 new households between 2006 and 2026 (the period the Core Strategy should cover).

2.32 As per our assessment in the 'With RSS Scenario' above, by contrast, the Core Strategy now seeks to provide 2,850 units 2011-2026 (the 190 per annum) and the 863 units 2006-2011 (173 units per annum).

2.33 It is clear therefore that the scale of provision in the Core Strategy is well below the locally arising need, which will in turn further exacerbate the cost and accessibility of housing, including affordable housing.

An Aging Population

2.34 At paragraphs 3.14 and 3.17-3.20, the Council seek to cast doubt on the findings of the SHMA in terms of its projections of housing need, in particular arguing in paragraphs 3.19-3.20 that the evidence that the Council presents on ageing might alter future projections of household formation/housing need. But there are two main problems with such arguments:

* An ageing population does not necessarily mean less housing need, and indeed in many respects the reverse is true. There is a greater tendency and indeed an encouragement for more elderly people to live independently, and therefore houses that might otherwise become available on the market stay occupied, whilst long-living elderly households are part and parcel of the increased trend towards smaller household sizes;

* The SHMA estimates for future household growth of between 300-350 dwellings per annum did take account of the ageing profile of the population (see paragraphs 2.3-2.4 of the SHMA 2010 in particular).

Household Size

2.25 At paragraph 3.22, the Council notes that reducing household size is a factor that creates pressure for new housing. This is undoubtedly true, but the fact that single person households might be the main component of household growth does not alter the number of dwellings required to meet that need (nor out of interest does it necessarily impact on property sizes, due to 'under-occupancy').

Policy Interventions, Economic Growth, and Commuting

2.26 At paragraph 3.21, Topic Paper 3 notes that the SHMA forecasts take no account of 'policy interventions' such as redirecting growth to neighbouring districts. Since this is not a policy intervention that is going to happen (for the reasons previously explained), it is not a consideration that should be given much weight.

2.27 Conversely, at paragraph 3.24, Topic Paper 3 suggests that the SHMA forecasts do take account of projected enhanced levels of economic growth in Thames Gateway. Since this is a 'policy intervention' that is being pursued by Thames Gateway Districts in their Core Strategies (following the projected employment targets in the RSS), this is a legitimate policy intervention to consider. Indeed, Rochford are helping to contribute towards it through this Core Strategy and in particular the Airport Joint Area Action Plan.

2.28 Paragraph 3.24 also notes that the forecasts assume commuting levels remain consistent with 2001 levels. As noted in our analysis of the SHMA above, the concern here is that a surplus of jobs in the capital may increase commuting, and that, coupled with successful employment growth in Thames Gateway, that might result in an even greater demand for new housing that the RSS provided for.

Conclusion on housing need

2.29 In our view, the analysis in Topic Paper 3 simply reinforces the evidence from the SHMA that the actual level of housing need substantially exceeds not only the revised level of housing suggested in the Core Strategy changes, but actually exceeds the level of housing required by the RSS in the first place.

2.30 Pages 10-11 - Environmental and Physical Constraints - The Council seeks to argue that the results of the Sustainability Appraisal raise concerns regarding the quantum of development allocated to the District. It also argues that the provisions of PPG2 point to reducing the amount of development that will take place.

2.31 The first simple point to make is that nowhere in this section does the Council seek to argue that any key environmental or physical constraint is in fact breached by the level of housing provision set out in the original Submission Draft, despite the title. This is perhaps not surprising, since the original Submission Draft was considered by the Council to be a 'Sound' plan.

2.32 The actual substance of this section is simply to say that if Rochford were to provide less housing, the consequences on the environment and on the Green Belt would be less, and by implication that this would therefore be more sustainable.

2.33 Whilst an apparently simple proposition, we would argue that this is not the case. Reducing the level of provision does not reduce the level of need, and therefore the net effect would be one of two potentially less sustainable outcomes:

(1) There is a general under-provision of housing, such that any environmental benefits are outweighed by adverse economic and social consequences (the other two 'pillars' of sustainable development); or

(2) The under-provision of new homes in Rochford leads to more development in other areas, with potentially equal implications for sustainability.

2.34 It should be noted that all of the neighbouring Districts are also in the Green Belt, all have areas of sensitive landscape and areas of international importance for bio-diversity, and have their own objectives for balancing employment and housing growth, alongside investment in infrastructure. All are or have worked hard on their own plans to try and successfully meet the demands for growth that they face already with the pressures for maintaining their Green Belts and ensuring that development respects local environmental constraints. There is no 'spare capacity' over the border.

2.35 In either context, the Sustainability Appraisal for Rochford cannot be assessed in isolation, or only in relation solely to environmental/Green Belt implications in Rochford. The logical conclusion would be that as Rochford provides fewer homes than needed, so some other area has to provide more homes, with potentially similar or greater impacts.

2.36 Pages 12-13 - Economic Development and Relationship with neighbouring areas - The argument presented here is to the effect that because there are other Districts nearby with the potential for greater economic growth than Rochford, it is acceptable for Rochford District Council to under-provide against housing need within its area (so that it can be the 'green part' of Thames Gateway, as the original Position Statement sought to argue), with an expectation that "policy makers" will intervene to enable housing growth to be re-directed to other areas.

2.37 This approach cannot be sound, both on procedural grounds and in terms of the basic justification for the argument.

2.38 On the first matter, there are no "policy makers" who can intervene to redistribute growth, nor is there any mechanism (in the absence of strategic planning) by which such a redistribution could occur. Each Local Authority now has to look after its own requirements. We can say quite categorically that there are no other Districts in the South-Essex area who are bringing forward Core Strategies that seek to over-provide against their own needs so that Rochford can under-provide on its needs.

2.39 On the second matter, the District Council's argument ignores the fact that the RSS already takes account of the fact that Basildon, Southend and Thurrock will provide more jobs to the Sub-Region than Rochford, which is why the housing provisions for these areas are already much higher (10,700 at Basildon, 6,500 at Southend, and 18,500 at Thurrock for the period 2001-2021, compared to 4,600 at Rochford and 4,000 at Castle Point) - the adjustment to balance homes and jobs is already made by the RSS.

2.40 Page 14 - Infrastructure - Other than confirming that sufficient infrastructure can be provided to meet the housing needs of the Core Strategy, this paragraph provides no argument to support a lower provision. The suggestion that other parts of the Thames Gateway might benefit from greater investment in infrastructure in the future is both unfounded and irrelevant.

2.41 Pages 15-16 - Implications of Revocation of the RSS - Clearly the position has now changed again in respect of the RSS. As outlined in our "with RSS Scenario", it is now once more a legal requirement of Soundness that the Plan be in general conformity with the RSS. The Council's proposed amendments render the Core Strategy not in general conformity, and therefore legally unsound.

2.42 We note at paragraph 7.5 the suggestion that the current RSS sets a requirement of 4,750 dwellings between 2006-2021. In the interests of clarity, we should say that we do not consider this to be right. Policy H1 requires 3,790 dwellings 2006-2021, and would have required another 1,000 dwellings by 2025, or 1250 by 2026 (which is when the end date of the Plan now should be, if it is to have a full 15 year life-span).

2.43 There is already an inherent under-provision in the Submission Draft Core Strategy against the RSS, caused firstly by the Council's 'rounding down' on the Policy H1 requirement to 250 dwellings per annum from 253 dwellings per annum (see para 4.4 of the original Submission Draft), which results in a shortfall of 40 dwellings, and this has subsequently been compounded by the need to extend the Plan period to 2026 due to the delay in adoption, rendering the shortfall in the original Submission draft to 290 units. As set out in the original submissions by Countryside Properties, there is a need for the growth locations to be expressed as minima, both to accord with the RSS and to address the shortfall.

2.44 At paragraph 7.12, the Council confirms that the position in respect of the supply of affordable housing will be significantly worse as a result of the proposed amendments. Although over the longer period to 2031, the Council might argue that largely the same number will be provided, the point is that the need exists now, and in respect of the delivery of affordable housing, the "temporal aspects" to which the Council refers are significant, because of the scale and the urgent need to address the growing problem of affordable housing delivery.

2.45 Page 17 - Implications for green belt release - Both the original Submission Draft and the proposed changes make provision for 2,785 units as 'extensions to residential envelopes', with the difference being that the former made that provision by 2026 and the latter by 2031. In terms of the actual commitment to Green Belt development, however, both versions are the same, and therefore protection of the Green Belt per se cannot be a justification for the amended provisions.

2.46 Pages 17 - Conclusions - We deal briefly with the key parts of the conclusions as follows:

* Para 8.1: "There is a very considerable requirement for the delivery of affordable homes". We agree with this.

* Para 8.4: "The district is limited in its capacity to accommodate new development by environmental and physical constraints". That may well be true, but there is no evidence to show that the level of housing provision put forward in the original Submission draft breached key constraints - indeed, it is evident that the Council does not consider this to be the case either, because it put the Submission draft forward on the basis that it was a 'sound' plan. The Council's statement provides no additional evidence to the effect that a reduction in housing provision is needed because of a breach in environmental or physical constraints, and the suggestion that need can be met elsewhere ignores the fact that the same or similar constraints exist in neighbouring areas.

* Para 8.5: "There is a local housing need" - We agree with this. Local housing need is a function of a variety of factors, not least of which is the impact that internal migration has on the availability and affordability of local housing.

* Paras 8.7 and 8.8 : "Rochford District is clearly not the most sustainable location in the housing market area to accommodate additional housing development" and "Higher levels of new housing are more appropriately directed to other parts of the Thames Gateway."

We do not agree with these assertions. No proper comparative sustainability analysis of different locations is put forward by the Council. The larger settlements in the District, most notably Rayleigh, are highly sustainable locations to accommodate growth, in terms of the range of jobs and serviced provided, public transport linkages, and relative lack of environmental constraints to growth.

In any event, the Districts that the Council puts forward as being more appropriate in its view for growth are already taking a much larger share of the sub-region's housing delivery, and it is neither desirable nor appropriate for Rochford Council to under-provide in relation to its needs in the hope that another District might provide more (particularly when these Districts have legitimate concerns of their own).

3. End Date of the Core Strategy

3.1 We appreciate that this issue has already been considered by the Inspector in respect of the discussion under Matter 2, but in our view the delay to the Core Strategy as a result of the proposed changes highlights this matter again, since it will no longer be possible to adopt the Core Strategy in 2010.

3.2 As well as the requirement under PPS12 for Core Strategies to have a minimum 15 year housing provision (para 4.13), there is also a requirement for all Core Strategies to be capable of effective monitoring (para 4.47 of PPS12), and there are clearly set out national requirements for effective monitoring, which include undertaking assessments against an April base date. The first full year of monitoring after adoption of this Core Strategy will be from April 2011, and a full 15 year period will be April 2011 to March 2026.

3.3 Following on from the above, it is becoming increasingly uncertain as to whether the Core Strategy will now be adopted before April 2011. If it is adopted after 1st April 2011, the full 15 year monitoring period would be April 2012 to March 2027.

4. Phasing (Policy H2)

4.1 A key concern raised by Countryside Properties in their submissions on Matter 2 in respect of the former Policy H2 was that the Greenfield phasing provisions were not deliverable, and therefore Policy H2 was not "Effective".

4.2 Policy H2 as per the original Submission Draft allocated 775 units to be delivered by 2015 at West Rochford, West Hockley, South Hawkwell and East Ashingdon i.e. all within a few miles of each other, and importantly, all within the same Rochford/Hockley Housing Sub-Market as defined by the SHMA. In addition, it was noted that the results from the Water Cycle Study showed constraints at Rochford WwTW which would preclude major development in that area prior to 2015, and the majority of strategic transportation improvements identified in Policy T2 would also affect the timing and rate of delivery of new homes in the eastern half of the district.

4.3 Against those constraints to delivery, it was noted that no Greenfield development was proposed for Rayleigh until post 2015, notwithstanding the fact that Rayleigh is demonstrably the most sustainable settlement, is the most buoyant Housing Sub-Market in the District, and has no short-term infrastructure constraints. It was also noted that there was an absence of evidence to support the reliance of the Core Strategy on the delivery of certain brownfield sites (notably Rawreth Industrial Estate), and that therefore a more flexible approach to the main growth locations was required. In that context, the proposed Phasing in H2 also failed the "Justified" test of soundness.

4.4 Rather than addressing the situation identified above, the proposed revisions to Policy H2 (as set out at Appendix CSS2 of the Schedule of Changes) actually makes the situation worse. In the revised H2, the number of homes proposed in the Rochford/Hockley Sub-Market increases to 845 homes (2011-2021), with no major Greenfield release at Rayleigh before 2021, and with the overall quantum of new homes at Rayleigh reduced from 550 in the Plan period to 400.

4.5 We accept of course that housing land supply does not only stem from the H2 Greenfield sites, and other land will come forward from the urban areas. There is no doubt however that the main source of new housing will be the Greenfield sites, as the updated housing trajectory at Appendix 1 of the Schedule of Changes shows - 1,386 units are identified to be delivered from non-Green Belt sites by 2026, compared 1,835 dwellings from the Green Belt sites.

4.6 Rayleigh is the largest (and most sustainable) town in the district, and it is not surprising therefore that it has the largest share of the urban capacity. We estimate from Appendix 1 of the Schedule of Changes that Rayleigh/Eastwood accounts for around 42%, Hockley/Hawkwell around 20%, Rochford/Ashingdon around 20%, and the remainder at Hullbridge and other rural settlements.

4.7 However, the effect of the Policy H2 phasing is to deny any Greenfield growth in the Rayleigh Sub-Market up to 2021, such that it is dependent solely upon its 585 units of urban capacity, whilst over the same period to 2021, the Rochford/Hockley Sub-Market is expected to deliver some 1,390 units (the combined total of the urban capacity and Greenfield sites). Bearing in mind also that 220 of the Rayleigh units fall within Rawreth Industrial Estate, which we have previously identified as being unlikely to be developed at all, the skew in the proposed phasing towards the eastern and more constrained half of the District is even more pronounced.

4.8 We are not raising new objections to the overall broad distribution of housing across the District. However, the Phasing provisions of the Plan as set out in Policy H2 still need to be "Justified" in terms of their rationale and "Effective" in terms of actually securing the delivery of the new homes required - in our submissions Policy H2 is neither Justified nor Effective.

4.9 There is no technical reason why the West of Rayleigh site should be deferred to post 2021 (as evidenced by Countryside Properties' own work and the fact that the Council were content to see development by 2015 in the Submission Draft), and the Council has advanced no justification that we are aware of for reducing the scale of development within the Plan period.

4.10 We also have to question, in the context of the above but also having regard to PPS12 para 4.46 regarding flexibility, whether or not the Phasing provisions of Policy H2 are in any event unduly prescriptive.

4.11 The Core Strategy is required to be capable of dealing with changing circumstances (and should not be dependent upon a review of the Core Strategy to deal with such circumstances). The delivery of sufficient housing remains a central objective, and clearly one of the major uncertainties that may arise is one or more of the Greenfield sites coming forward at the time anticipated, or indeed one or more of the major urban capacity sites not coming forward as expected (e.g. Rawreth Industrial Estate).

4.12 At the moment, Policy H2 not only lacks any justification in terms of why certain sites have been phased in the manner proposed, but its prescriptive nature also makes the Core Strategy incapable of responding to changing circumstances that might require either a particular site to be phased later (e.g. due to lack of infrastructure such as appropriate waste water disposal), or which might require one of more sites to be phased earlier to counteract non-delivery elsewhere.

4.13 We note that a very similar situation arose during the Examination of the St Edmundsbury Core Strategy, which also proposed a number of different growth locations, with proposed phasing for each location. The Inspector's Report at paragraphs 13.8-13.9 notes as follows:

"By spreading growth between a number of strategy locations Policy CS11 provides the opportunity to change course, subject to infrastructure considerations, should unforeseen events occur. However, each of the strategic locations is phased, with growth to the north-west and the completion of the Moreton Hall urban extension proposed from 2011 onwards. Growth to the west would be after 2016 while both north-east and south-east Bury St Edmunds would be developed after 2021 ....However, in my view the evidence base, including the IECA and the IDP, has not demonstrated a clear link between these dates and the timelines for resolving these matters. As result, the CS may be unnecessarily inflexible should there be a need to bring forward one of these locations earlier than anticipated ...I am recommending changes to Policy CS11 that will give an indication of the likely timescale without being prescriptive."

4.14 We would suggest that similar considerations are relevant here, and in particular we would ask the Inspector to consider the following questions:

(a) What is the evidence that supports the proposed Phasing in Policy H2, and are the proposed dates for development consistent with that evidence? And
(b) Does the lack of flexibility in Policy H2 render the Core Strategy unsound?


5. Summary/Conclusions and Changes Required to Achieve Soundness

5.1 Dealing firstly with the "Without RSS Scenario", the key issue that we would highlight from Topic Paper 3 is the lack of actual evidence being advanced to support the lower level of housing now being suggested.

5.2 Topic Paper 3 does identify the chronic need for affordable housing. Generally, its content supports the evidence on housing need already established by the SHMA. The actual level of housing need substantially exceeds not only the revised level of housing suggested in the Core Strategy changes, but indeed exceeds the level of housing required by the RSS in the first place.

5.3 Although Topic Paper 3 discusses environmental and physical constraints, there is no suggestion that the Core Strategy as originally submitted breached some measurement of finite capacity, nor is there any consideration as to the constraints that similarly exist in neighbouring areas.

5.4 The Council's main focus appears to be an argument that other Districts may be better placed to take Rochford's growth, but there is no analysis of either the ability or the likelihood of any District being able to do so, and of course no recognition of the fact that Rochford's neighbours are already having to deliver higher levels of new housing anyway.

5.5 The Council seeks to rely on the March 2010 Draft RSS as 'evidence', without considering either the actual evidence that underpins that document, or seeking to explain why it should be held to be more relevant in terms of the determination of an appropriate level of housing than the Council's own local evidence base.

5.6 The Council also seek to rely on the Draft RSS of 2010 as providing its 'Option 1' figure, but our evidence suggests that it is the Draft RSS of 2004 that would be relevant (although we have to say in either event reliance on an 'Option 1' figure without analysis of the evidence to support it would fly in the face of the 'Justified' test of soundness in PPS12).

5.7 For all of the above reasons, we do not consider that the revised housing provisions are "Justified", having regard to the evidence.

5.8 Turning to the current "with RSS Scenario", much of the above debate becomes largely academic whilst the RSS exists, because of the legal requirement for a Core Strategy to be in general conformity with the RSS. The continued invitations by the Secretary of State to disregard the RSS cannot over-ride that basic legal requirement, and therefore such statements can carry no weight in the assessment of 'Soundness'.

5.9 In respect of the end date of the Plan, compliance with PPS12 suggests the end date must now be at least March 2026, since the Core Strategy can no longer be adopted in 2010.

5.10 In terms of the proposed revisions to Phasing set out in Policy H2, in the period up to 2021, the proposed Phasing provisions effectively serve to stifle development in the western half of the District in the Rayleigh Sub-Market area, despite the fact that the evidence base shows this to be the most buoyant housing sub-market and the one subject to the least technical/infrastructure constraints, whilst focussing the vast majority of new development up to 2021 in the more constrained (and less sustainable) Rochford/Hockley Sub-Market. Accordingly, it is submitted that the Phasing provisions of the amended Policy H2 are neither "Justified" nor will they be "Effective" in delivering the reduced number of homes proposed.

5.11 Further to the above, if the Phasing provisions are retained in Policy H2 as per the Proposed Changes, then there is still in any event in our view a need for the policy to recognise that the proposed phasing is indicative only, and that flexibility exists for the phasing to be amended should circumstances change.

Changes required to achieve 'Soundness'

5.12 In terms of the changes required to make the Core Strategy Sound, we would suggest that the first requirement is for the Core Strategy Schedule of Changes to be discarded in their entirety, since at the likely date of adoption, the RSS will still be in existence.

5.13 Additionally, we would commend the changes suggested in the original Matter 2 representations by Countryside Properties in respect of the use of 'minima' terminology for the growth locations, and the revised phasing put forward, to accord with the RSS, to provide the requisite flexibility in terms of delivery, and to deal with the shortfall in housing provision inherent in the original Submission Draft.

5.14 If, notwithstanding these submissions, the amended level of housing provision set out in the proposed changes is accepted, then our submissions regarding the unjustified phasing and lack of flexibility in the Core Strategy regarding phasing remain, as per our comments under our fourth main topic above.

Please see document

Please see document

Please see document

Please see document

Please see document

Having observed the Rochford Core Strategy Development Plan document - 'Schedule of Changes' I would like to have the opportunity to discuss my own observations.

To make a proper analysis of the changes is it possible to have a copy of the original document for comparison purposes.

Reference
Page 7 para 1.2 Do we have the opportunity to visit or have a copy of the 'Sustainable Community Strategy and Council's Corporate Plan', in accordance with the new 'openness' government policy.

Page 29, para 2.29 Please explain the meaning of this paragraph under the heading of 'The east of England Plan has been Revoked', but goes on to explain this represents 'Option 1' and does not indicate the actual 'revocation'.
In briefly scanning this document, I am unable to see what other 'options' were taken into consideration and does not provide any information regards the methods or reasons for the adoption of 'Option 1'.
Please explain your meaning of the word 'Sustainability' as mentioned in this paragraph.
What reasons were given for the change of 'development years' from 2001 - 2021 to 2011 - 2031, and I presume that the 'additional' 810 and 618 units (para 2.31) are included in the 2001 to 2011 appraisal.

Page 29, para 2.31 The revoked E of E Plan states 810 and 618 dwellings were completed between 2001 and 2008, are these figures included in the overall 3800 dwellings mentioned above.

Page 30, para 2.35 The phrase indicates additional 131 dwelling per annum to be developed, I can only presume the total number over and above the 190 dwelling planned will be 321, please explain. This figure equates to 6420 dwellings over 20 years (2011 - 2031). The Thames Gateway South Essex Strategic Housing market Assessment notes a need for at least 35% of these developments need to be 'affordable' which equates to 2247, is this correct?

Page 38 - Objectives. This clause ensures that the developments meet the 'District's Population', I hope this is meaningful and 'Highlighted' to mean the 'existing population'. What is the meaning of 'balanced with sustainability considerations' and 'environmental constraints in the district'.

Page 39, para 4.2 The E of E Plan (2008) having been revoked, why does RDC insist that 'Option 1' is deemed to be the most appropriate, without providing any information on alternatives that may have been considered.

Page 39, para 4.3 RDC allocation is based on meeting 'current and future' needs, but the repetition of the words 'balanced with sustainability considerations' needs explanation, in my view the words are vague, and according to your population figures you indicate an increase of 5,700 (87,000-81,300) by 2021. However if we consider the figure of 3800 units x average of 2 persons = 7,600, so how have you calculated your increased population figures?

Page 39, 40, para 4.4 and 4.6 and Table Can you explain why there is a change in years from 2001 - 2021 to 2011 - 2031 and whether the units stated on page 29, para 2.31 are included in the overall 3,800 units.
Allocation of land - please explain the distribution of units between 'brown field land', 'white land' and 'Greenbelt land' and the density of development per acre/hectare in accordance with the types of development, I am unable to find reference to this distribution.
Has the utilisation of derelict and abandoned land been taken into consideration in the above Plan.
The encroachment on green belt land will be approximately 105% on 1243 units, how is this justified.

Page 42 para 4.17 How are we to know that any green belt land allocation is being used as a 'last resort' and in accordance with all the applicable Local Government by-laws in relation to the Green belt land.

Pages 44 to 46 Clause 4.25 makes reference to 'contribution through windfall', please explain where I can observe the meaning of this in the Consultation document.

Page 46 para 4.30 The indicative aim for the district as a whole is set at 35% in the Viability Study Report and is not considered impractical, can you explain or justify the reasoning for this?

Pages 49 to 50 para 4.46 & 4.47 & Policy H7 Can you explain the justification for any requirement for gypsy and traveller accommodation, especially in respect to the financial constraints we are required to maintain in the forth coming years, and to whom will the financial burdens fall.
Where can I find the written matter explaining Policy H7.

Other business
In my observing the document I am unable to find any references to 'Risk assessment' made for the following:

The Environment
Infrastructure
Flood (Watery Lane in regular flood- featured on the National News).
Density
Drainage.
Main services
Roads
Access- (e.g. to and from Hullbridge).
Schools.
Doctors/ Medical services.
Council services, including Fire and police.
Health and Safety.
Employment
Local Financial Economy and Investment
Commercial and Industrial development.

Investment
Please explain how you are trying to attract 'investment' in this area, and how a Domestic Development will have the capacity to attract 'investment'.

I wonder how 'Social Affordable Housing' will be purchased, or indeed, will not be only made available for 'economic migrants'. Particularly in light of difficulty in obtaining mortgages.

Thank you for this opportunity to raise my concerns, and if I can be of assistance in this matter I will be pleased to help.

Re: The proposed future housing development of Hullbridge.

My family and I vehemently object to any large scale development in Hullbridge. We moved from the East End of London in 1978 to start a family and improve our quality of life in a quiet and safe Village community. We personally chose to live in an unadopted road as it was safer for our children due to a lower volume of traffic and overlooks some beautiful countryside/ farmland. We also accepted that we were isolated from London and high employment areas etc and have always been prepared to spend many hours travelling to and from work. For this we receive the privilege of a peaceful Village life that others were not prepared to sacrifice their time for.

With this in mind we recognized that we have always had, and still do put up with a poor roads and utility services infrastructure which barely copes with the level housing it currently supports. Our rear garden floods at least 3 times a year with raw sewage as the main culvert blocks on a regular basis. We get the full brunt of others feces and urine pouring down the length our garden. The council has never wanted to know about this over the years; despite it being a Health hazard and Anglian Water have done nothing to sort out the problem on a permanent basis. This has been going on since we moved in! Our road has no surface drainage, is of concrete single track construction and is of very poor surface. Despite this, we still want to live here. However, should a large development of 500 homes be built, the roads, drains and general area will not cope with such an increase in population, traffic, sewerage or surface water management.

We lodged a letter with the Parish council objecting to the Council trying to get us to adopt our road last year as we objected to paying thousands of pounds for the privilege of improving the access to any new proposed housing developments. At that time a developer was trying to get planning permission near Windermere Avenue for a large development. Our concerns and suspicions now appear to be 100 per cent correct now that it has been declared that a really major development is proposed, which is to add another 500 homes and will abut along the end of our road.
Can you imagine the sheer hell of 3 to 5 years of Construction traffic travelling up and down our single track roads, causing utter chaos, mess, noise pollution and personal despair over what may be possible a 10 year period? Our Village is not built to cope with this. Our children will be put at risk every day. Even if you provide site access and egress elsewhere, you will cause unprecedented chaos due to the existing surrounding poor roads infrastructure. The Strategic Housing Land Availability Assessment 2009 documents that the existing infrastructure is not a problem? What clever person was employed and paid to decided this? Lower road is now a busy route from Rochford and Southend and is not built for such traffic as it is. Watery lane already floods on a regular basis, even when it rains lightly and is now restricted to 3.5 ton vehicles as it is far too narrow for vehicles such as Construction traffic and delivery lorries. We still suffer with oversized vehicles travelling this route, despite the warning signs now in place. Who will police this when the work starts? Hullbridge road is our main outlet for Hullbridge Village traffic and will be severely disrupted when huge volumes of Construction and material Lorries frequent it. In the mornings, everyone using Lower road as a through route, now significantly contribute to the traffic congestion at the junction of Hambro Hill and Rawreth Lane. Rawreth Lane is now a known and still growing traffic black spot in the evening rush hour due to the already massive increase in the districts housing that has swollen the volume of through traffic over the last several years. Compounding this, many motorists are also leaving the A127 and travel down Rawreth Lane and then on to Lower road to avoid the sheer weight of traffic on the Southend bound carriageway. What will it be like if Hullbridge is swollen beyond comprehension too? There is only limited access and egress to the Village as it is significantly land locked already. However hard you try, the infrastructure will be further crippled and simply chocked to death. The developer will not pay for such a major traffic infrastructure improvement that could guarantee Hullbridge would not be severely damaged in this respect. Their profit margins will not allow as they would already contribute I suspect to affordable housing. We are looking at "very "significant and radical improvement that would be required.
Also, with new developments of this scale comes large scale affordable housing as part of the Sect 106 planning law agreements with developers and then follow all of the social problems that are already felt in virtually all large towns and cities across the country. Hullbridge has an extremely low crime rate and is safe for children. This will change without question and myself and my family will be sad to have to put our home on the market and leave. This has been our home all of our married life and all of our children's lives. We cannot afford to move, but will if pushed. We feel this strongly.

Insurance premiums will rise for homes and cars due to increased risk of crime and theft. I suspect Council taxes will rise significantly to cover the increase in infrastructure support costs across the board. Traffic could increase by up to 1,000 vehicles (possibly more) if 500 homes are built as targeted, and air quality will suffer. The water table will be drained further, thus increasing further risk of subsidence. This is already a known issue when trying to get home Insurance as this is already a high premium area. More wildlife will disappear, including the local bat population which we believe is a protected species. Need we go on?

Rochford District Council has conveniently neglected all these years and still neglects the fact that everyone living on unadopted roads is forced to contribute the same level of Council tax as those that live on adopted roads. For this, we have been paying disproportionate contributions for 32 years! We do not receive the same level of service, I.e. road repairs, verges cut etc that many others do, and we do not have the same amenities, I.e. road drainage etc.

PS: I have heard that the meadow along Poole's lane is also up for sale? Is this lined up for a mass housing scheme as well? Why don't the Council drive brown field developments and leave green belt uncontaminated. There are already huge areas of brown field that could be developed throughout Essex. Some of these sites have been empty for years and are far more appropriate for housing. Urban sprawl is moving at a frightening pace. All the more reason to preserve what villages are left in Essex. Furthermore, if all of the other identified sites contained in the Strategic Housing Land Availability Assessment 2009 are developed as well, then this entire area will become destroyed forever. The report is truly frightening when looking at all of the earmarked land. It has also been stated that this development will not be available to local residents, but is earmarked for workers related to port expansion (what ports?, they are extremely long distances away), airport expansion workers (Southend has high unemployment. Why not employ people living in the local area who already have a home?) and key workers such as hospital staff (not aware that Southend Hospital is expanding on any scale, but currently closing wards due to Government cuts, thus degrading the support infrastructure when considering 500extra family homes in Hullbridge alone?). These are all intangible claims made to try and legitimize the Governments directive to force indiscriminate house building.

This is shameful and the local Council who the population elected should be ashamed too. Once built on, Hullbridge, its village uniqueness, extremely low crime rate and surrounding countryside will be lost forever. This will be a very sad outcome and a very unnecessary one. Give more thought and effort to the problem of where housing can be built. Don't just pick on easy targets and accommodate eager landowners who want to sell and couldn't care less about their actions. Try targeting the Brownfield site landowners who just sit on land banks awaiting the ideal time to make a financial killing before putting us all through this unnecessary nightmare. It makes 100% common sense not to take countryside and improve ugly waste land instead. This is no legacy for our future generations.

Our reasons for objecting to the current proposed Changes to the Core Strategy, and in reference to CSSC1 CSSC2 & CSSC3, are:

* Green Belt proposals have not been correctly or appropriately evaluated, against government policy, and alternatives have not been considered. Constantly they say "brownfield" and previously developed sites will be developed first, but this is not being done and is, therefore, UNSOUND. Rochford District Council (RDC) have failed to consider currently developed sights which are classified as Greenbelt but which have industrial units on them currently or in the recent past.

* RDC suggests that the use of Green Belt land totals around 60%, if you take into account the relocation of industrial sites the figure will be in excess of 80%. That is 80% of the building will take place on Greenbelt land. You will never get this land back!


* There is no justification for the proposed 3,800 homes across the District or clear explanation as to how this figure was calculated. The Government recently told all local Councils to abandon previous figures and calculate their own local needs - RDC have stuck to the original figures without proper evaluation and explanation despite all of our previous protests this is UNSOUND.

* Within the Core Strategy Document, Policies H2 and H3 set out the extensions to residential envelopes and phasing of those extensions. The first phase is between the years 2015 and 2021, the second 2021 to 2026 and in addition they are also imposing housing targets for post 2026. This last phase, post 2026 will not, and cannot due to the timescales involved, take into account the needs for future generations, therefore it is unfair to agree this proposals and we believe this should be looked at and agreed by future Council leaders.


* Lack of appropriate infrastructure - as they will NOW not build in Hullbridge before 2021 anything built anywhere else throughout the District will cause ALL traffic to proceed through Rawreth Lane and Watery Lane with the majority of that then moving through Hullbridge and Lower Road. Highways impact has not been assessed or mapped to housing phasing and no consideration given to the fact that the majority of roads in Hullbridge are unadopted and unmade. "No discussions in any detail have taken place with Essex County Council concerning Highways or Schooling." It was not so long ago that Park School was closed due to "not enough" pupils in the area. Now you want to flood the area with no consideration to schools expansion or consideration of funding and teacher levels, given the cuts being made by the Government.

* Traveller & Gypsy site - although RDC's preferred option was to use the existing Traveller site at Bedloes Corner, and double it in size. A recent application by the Travellers themselves for the same site was REFUSED by the full Development Committee. Cllr Hudson indicated that they wanted to provide a transient site as opposed to a private, permanent residential one as at Bedloes Corner.
* Flood Risk - the only consideration they have given to this is Fluvial (tidal) with no consideration to surface water risk, as happens regularly in Church Road and Watery Lane and surrounding fields, including fields identified for building on in this Core Strategy - this is UNSOUND. Also, this is considered a high risk Insurance area by several Insurance companies due to the heavy clay soil and ever shrinking water table. Adding 500 homes will decimate the water table and cause unprecedented risk to existing homes in the area, as well as all of the new homes. Therefore, I suspect that to build these homes, far more expensive footings (or deep piling) will be required, making the aim of creation of affordable housing far more expensive.

* Rawreth Industrial Site is to be built on earlier than was first proposed, so the industrial site must be cleared and relocated onto Green Belt land sooner than previously thought. Where is this going to go? It is strange that Industrial site relocations always seem to end up being built on Green Belt land. I suspect that this is because the Developer does not have to pick up the demolition and any land remediation issues from Brownfield sites that are siting idle. I.e. it is "cheaper" to build on Green field land and leave Brownfield land empty. Housing Developers do not like using Brown field land either, as they also have to pick up these issues? Therefore, why does RDC not have a policy which makes it a priority to ensure that "ALL Developments" are built on available Brownfield sites first?


* The last Consultation on the DPD Allocations document which took place six months ago has not even been considered by RDC Members and yet they are now pressing ahead with these changes - surely this is undemocratic at the least.

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.

following a review of the proposed changes to the Rochford District Council's Core Strategy and with particular reference to SWH4, this document outlines Swan Housing Associations's response.

Response

Summary

The land at SWH4 is an ideal location for new housing and should be prioritised for development for the following reasons;

- It is close to existing housing, the site lends itself to integration with the neighbouring areas without changing their current feel. Appropriate integration will mitigate the impacts upon both the new community and the existing.
- The linkages that the development can build on and improve will also increase social inclusion within the new development and established communities.
- Swan has a proven track record for developing economically, environmentally and socially sustainable communities.
- The existing community will benefit from the addition of new homes, increased economic activity locally and the multiplier effect associated with construction.
- The Hullbridge site has strong boundaries which will ensure that any development is kept within a specific area without any precedent being established to challenge the greenbelt boundaries. Through the unique attributes of the site; the propensity for suburban sprawl is removed.


The case for additional Housing in Rochford

With population growth in the local area above the national average the proposed reduction of housing quota is a concern. Swan Housing Association is involved in several large regeneration projects across Essex where large scale estates were built quickly to meet explosive demand. The problems now experienced here could be avoided with realistic provision of Private Sale, Shared Ownership and Affordable housing, for years under provision has squeezed the vulnerable out of the housing market.

Population
All Persons, All Ages (Persons, June 09): 83,100
All Persons, All Ages (Persons, est 2021): 87,000
Source: Office for National Statistics, Rochford Local Authority

As illustrated below the average house price in Rochford is significantly higher than in the rest of Eastern England. This highlights the affordability gap that first time buyers and those without much equity face when trying to get onto the property ladder.

Average House Price (Median Average for Dwellings, Jan 07 - Dec 07) - Rochford £219,000 - East of England £190,000
Source: Office for National Statistics, Rochford Local Authority

With Average Gross Earnings in Rochford similar to those across the East of England region and with property prices being much higher there is a need for affordable housing or a risk of loosing people of working age as they migrate to more affordable areas.

Area - Rochford, Average Gross Earnings £24,009
Area - East of England, Average Gross Earnings £24,000
Source: ASHE 2007

Provision of affordable housing within the Rochford is already low compared to the East of England Region, which highlights potential issues in the present and likely issues in the future is the gap is not filled to meet demand. Levels of private housing are significantly higher than the East of England indicating the polarisation between

RP Housing Stock as Percentage of All Dwellings (Dwellings, April 09)

Rochford 8.1%
East of England 9.2%
Source: Office for National Statistics, Rochford Local Authority

Private Housing Stock as Percentage of All Dwellings (Dwellings, April 09)

Rochford 91.4%
East of England 83.7%
Source: Office for National Statistics, Rochford Local Authority

Levels of Homelessness highlights the need at on one extreme of the spectrum, during the period April '08 - March '09 there were 44 Statutory Homeless Households in Rochford. Within the area there are a total of 405 Households on the Local Authority register, this equates to a 1.23% of Households within the Rochford area being on the LA register.

Within Rochford limited development has taken place within the last 5 years so there is a need for sites such as SWH4 to be brought forward for development.

Swan trusts that the above information and analysis is useful to Rochford. If it raises any queries please do not hesitate to contact us as an organisation. In addition we feel that our expertise as a Regeneration Agency will be useful when considering the future of sustainable development.

Objection to the proposed Changes to the Core Strategy, and in reference to CSSC1 CSSC2 & CSSC3, are:



* Green Belt proposals have not been correctly or appropriately evaluated, against government policy, and alternatives have not been considered. Constantly RDC say "brownfield" and previously developed sites will be developed first, but this is not being done and is, therefore, UNSOUND. Rochford District Council (RDC) have failed to consider currently developed sites which are classified as Greenbelt but which have industrial units on them currently or in the recent past..

* RDC suggests that the use of Green Belt land totals around 60%, if RDC take into account the relocation of industrial sites the figure will be in excess of 80%. That is 80% of the building will take place on Greenbelt land.

* There is no justification for the proposed 3,800 homes across the District or clear explanation as to how this figure was calculated. The Government recently told all local Councils to abandon previous figures and calculate their own local needs - RDC have stuck to the original figures without proper evaluation and explanation despite all your previous protests this is UNSOUND.

* Within the Core Strategy Document, Policies H2 and H3 set out the extensions to residential envelopes and phasing of those extensions. The first phase is between the years 2015 and 2021, the second 2021 to 2026 and in addition RDC are also imposing housing targets for post 2026. This last phase, post 2026 will not, and cannot due to the timescales involved, take into account the needs for future generations, therefore it is unfair to agree this proposal and I believe this should be looked at and agreed by future Council leaders.

* Lack of appropriate infrastructure - as RDC will NOW not build in Hullbridge before 2021 anything built anywhere else throughout the District will cause ALL traffic to proceed through Rawreth Lane and Watery Lane with the majority of that then moving through Hullbridge and Lower Road. Highways impact has not been assessed or mapped to housing phasing and no consideration given to the fact that the majority of roads in Hullbridge are unadopted and unmade. No discussions in any detail have taken place with Essex County Council concerning Highways or schooling.

* Traveller & Gypsy site - although RDC's preferred option was to use the existing Traveller site at Bedloes Corner, and double it in size. A recent application by the Travellers themselves for the same site was REFUSED by the full Development Committee. Cllr Hudson indicated that they wanted to provide a transient site as opposed to a private, permanent residential one as at Bedloes Corner.

* Flood Risk - the only consideration they have given to this is Fluvial (tidal) with no consideration to surface water risk, as happens regularly in Church Road and Watery Lane and surrounding fields, including fields identified for building on in this Core Strategy - this is UNSOUND.

* Rawreth Industrial Site is to be built on earlier than was first proposed, so the industrial site must be cleared and relocated onto Green Belt land sooner than previously thought. Where is this going to go?

* The last Consultation on the DPD Allocations document which took place six months ago has not even been considered by RDC Members and yet RDC are now pressing ahead with these changes - surely this is undemocratic at the least.

I am writing to object to the changes in the Core Strategy and expect these views to be conveyed to the Inspector. The basis for these objections are as follows.

1. Green Belt proposal have not been evaluated properly, contrary to government policy, and alternatives have not been evaluated. Constatly they say 'brownfield' and previously developed sites will be developed first, but this is not being done and is, therefore, UNSOUND. The size of the proposed development for Hullbridge, at 500 dwellings and 25% of the current numbers. Such a massive development is out of place with the village and has ignored and is, therefore, UNSOUND. (CSSC1) (CSSC2)

2. Rochford District Council suggests that the use of Green Belt land totals around 60%, if you take into account the relocation of industrial sites the figure will be in excess of 80%. (CSSC1)

3. There is no justification for the proposed 3,800 homes across the District or clear explanation as to how this figure was calculated. The Government recently told all local Councils to abandon previous figures and calculate their own local needs - RDC have stuck to the original figures without proper evaluation and explanation despite all your previous protests this is UNSOUND. (CSSC1)

4. Within the Core Strategy Document, Policies H2 and H3 set out the extensions to residential envelopes and phasing of those extensions. The first phase is between the years 2015 and 2021, the second 2021 to 2026 and in addition they are also imposing housing targets for post 2026. This last phase, post 2026, is further ahead than the Core Strategy is required to plan for and I believe this should be looked at and agreed by future Council leaders, when housing needs for that future date can be properly assessed. (CSSC2) (CSSC3)

5. Lack of appropriate infrastructure - as they will NOW not build here before 2021 anything built anywhere else thoughout the District will cause ALL traffic to proceed through Rawreth Lane or Watery Lane with most traffic then passing through Hullbridge via Lower Road. Highways impact has not been assessed or mapped to housing phasing. (CSSC1) (CSSC2)

6. Flood Risk - the only consideration they have given to this is Fluvial (tidal) with no consideration to surface water risk, as happens regularly in Church Road and Watery Lane and surrounding fields, including for which housing is proposed - this is UNSOUND. (CSSC1)

7. The last Consultation on the DPD Allocations document which took place six months ago has not even been considered by Members and yet they are now pressing ahead with these changes surely this is undemocratic at the least.

I would like to make it clear that I wish to make verbal representations at the hearing.

Summary of Representation

Our clients, A W Squier Ltd, have land holdings on the eastern side of Ashingdon/Rochford (see attached plan ref: 010036/18). Their land to the south of Brays Lane is being brought forward with other parties for development of 100 units and is the subject of a separate representation. This representation relates to A W Squier Ltd's other land interests, namely land to the north of Brays Lane, which falls within the East Ashingdon broad location and land to the east and south of Oxford Road which forms part of an area known locally as The Racecourse and falls within the South East Ashingdon broad location. Land north of Brays Lane can act as reserve land, coming forward in the event of a shortfall and it benefits from flexibility in terms of the quantum of development that it can deliver. The Racecourse land can deliver dwellings in accordance with Policies H2 and H3 but also has the flexibility to come forward earlier in the Plan period if necessary.

Representation

Overall Housing Supply

As we set out in our response regarding the implications for the Core Strategy of the changes to government policy (letter dated 13/07/2010 attached), we are concerned that the changes to the annual housing supply are not supported by evidence. As detailed in our letter, it is clear from the various stages of the Core Strategy and the Council's supporting evidence base that there is a need for additional housing to meet the needs of the district. The Strategic Environmental Assessment and Sustainability Appraisal of the CS Issues and Options document found that not attempting to meet the RSS requirements would have negative effects in the medium to longer term.

It is our view that the Core Strategy should continue with the RSS housing figures as they are supported by strong evidence.

As detailed below, our clients land can contribute towards the housing requirements as identified in the amended Core Strategy but equally, there is flexibility to deliver earlier in the Plan period and in greater quantums than currently shown in the CS.

East Ashingdon

In accordance with our previous representations, we submit that our client's wider land is capable of delivering a quantum of development in excess of the 100 units stated in the Core Strategy. The attached master plan demonstrates that 100 dwellings can be accommodated to the south of Brays Lane (assuming that around 2ha of the reserve land for the school is located at the end of Oxford Road). Separate representations have been submitted on behalf of the consortium of landowners for this site which confirms that a planning application for 100 units to the south of Brays Lane will be submitted shortly.

Land North of Bray's Lane
The land to the north of Brays Lane (as identified in part under options EA2 and EA3 of the Site Allocations DPD and shown on the attached land ownership plan ref: 010036/18 as area B) can come forward for development in any of the phases within the Plan period. The SHLAA recognises that this land has a net developable area of 4.64 to 6.96 hectares and at a density of 45dph it identifies that this site could accommodate 209 to 313 dwellings. Even if the density is lowered to 30dph (which is arguably more appropriate having regard to the surrounding development) then it can still accommodate 209 dwellings. Development of this land to the north of Brays Lane would also enable public open space provision, which is a long term aspiration of the Council and is shown on their Local Plan Proposals Map. Other than the Compulsory Purchase route, development of this site is the only way that this public open space can come forward.

Land to the north of Brays Lane falls within the broad location of East Ashingdon and can contribute towards any shortfall in housing supply. This site should be identified as reserve land as it can be brought forward in the event that other sites, such as the former industrial sites identified for residential use in the CS or the Stambridge Mills site if they do not come forward at the appropriate time. Whilst the land to the north of Brays Lane can accommodate around up to 309 dwellings, it also has the capacity to deliver varying amounts dependant on need. The land is also available and deliverable with no environmental or landscape issues that would prevent its development. A Landscape and Visual Appraisal of this land found that the existing urban edge is quite harsh and has little containment along much of its edge with the intrinsic value and sensitivity of this landscape found to be low. The report found that the southern third of the northern parcel has no publicly appreciable relationship or visual link to the outlying countryside and therefore development here would not affect the character and openness of the Green Belt. Whilst the land further north has some visual link with the open countryside, these influences are highly limited and "development would not bring significant changes to that scene that may not be outweighed by the opportunity to provide an improved urban edge". In conclusion, development of this parcel could be mitigated by a landscape buffer as proposed at other broad locations identified within the Core Strategy such as West Rochford and Canewdon. In comparison with other sites, this site performs favourably, with the SHLAA identifying that it has a rating of good to medium accessibility for a range of services. In comparison with another broad location, the sites for expansion of Canewdon, for example, are in the SHLAA as having poor access to public transport and shops and, as recognised above, do not benefit from a defensible Green Belt boundary.

South East Ashingdon (The Racecourse)

The land falling within our client's ownership is shown as parcel C on the attached land ownership plan (ref: 010036/18). As set out in our earlier representations, this land is capable of coming forward with land immediately to the south for residential development within the South East Ashingdon broad location in accordance with the Core Strategy.

As we have identified above and in previous representations, we have concerns with regard to the delivery of some of the other sites that have been identified for residential development within the Core Strategy, such the employment sites and the Stambridge Mills site which are proposed for residential development. The South East Ashingdon site can be brought forward earlier than 2021 in the event that other sites do not deliver. The Plan should be amended to include wording to enable this flexibility. We suggest that the sentence "Development will be managed to ensure a housing delivery trajectory as set out in Appendix H2" is deleted. It should be replaced with "A flexible approach will be taken towards timing of completions to ensure that supply is not compromised".

In our submissions to the Site Allocations DPD we identified the land that should be identified for this broad location (ref: 010.036/08). Whilst it should be noted that 2ha of this land is likely to be reserved for the future use of the King Edmund School as playing pitches, this land is still of sufficient size to ensure that the housing requirement of 500 units is met whilst providing sufficient open space, community facilities (if necessary) and a landscape buffer to the east.

Development of this site could also be accompanied by further residential development off Doggetts Close/Doggetts Chase, which can also be considered as part of the 'South East Ashingdon' broad location. This site lies broadly adjacent to the Waterman Primary School and in close proximity to the town centre and walking distance of a secondary school, it also falls within our client's ownership. Again, development could be sensitively designed and landscaped to minimise visual impact.

Proposed Changes

The CS should have flexibility to deliver more than the 100 units at East Ashingdon in the event that identified sites fail to deliver. Land north of Brays Lane should be identified as reserve land.
"New Policy
In the event that housing supply is not being delivered in accordance with the Policies contained within this Plan, then reserve land to the north of Brays Lane should be brought forward to meet the shortfall."

The South East Ashingdon site can be brought forward earlier than 2021 in the event that other sites do not deliver. The Plan should be amended to include wording to enable this flexibility. We suggest that the sentence "Development will be managed to ensure a housing delivery trajectory as set out in Appendix H2" is deleted. It should be replaced with "A flexible approach will be taken towards timing of completions to ensure that supply is not compromised".