Rochford Core Strategy Development Plan Document - Schedule of Changes

Core Strategy Consultation October/ November 2010

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

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

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

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

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

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

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

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

Core Strategy Consultation October/ November 2010

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

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

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

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

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

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

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

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

Core Strategy Consultation Oct/Nov 2010

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

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

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

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

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

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

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

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

Core Strategy Consultation October/ November 2010

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

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

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

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

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

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

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

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

Core Strategy Consultation Oct/Nov 2010

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

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

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

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

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

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

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

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

Core Strategy Consultation October/ November 2010

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

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

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

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

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

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

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

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

Core Strategy Consultation October/ November 2010

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

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

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

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

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

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

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

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

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.

Dear Mr Scrutton

Re: Future Development of Rochford District

I refer to your letter dated 18thOctober 2010 and would just like to re-iterate my view that I think that the land at 340-370 Eastwood Road, Rayleigh and the back land reaching to the A127 should be considered for development as this will not eat into the more legitimate countryside.

Dear Sir/ Madam,

Proposed changes to the Core Strategy

Thank you for your letter dated 18th October with reference to the proposed changes to the Core Strategy.

Members have noted changes you have made and have no further comment to make except that they fully agree with the reduced number of houses to be built and the length of time in which they must be built.

Please find enclosed our original comments which were submitted in June for your information.
(1) In the introduction at 1.4 there is a statement that the purpose of the Core Strategy is not to identify specific locations but goes on to state a preference later in the document for one particular area "North of London Road" (i.e. between London Road and Rawreth Lane) thus automatically ruling out consideration of a number of suitable alternatives identified in the "call for sites" exercise and is therefore unsound.
(2) p38 Objectives 4 "Prioritise the redevelopment of appropriate brownfield sites for housing to minimise the release of Green Belt land" However two brownfield sites in the centre of Rawreth village which would be suitable alternatives in part to north of London Road and which are favoured by Rawreth Parish Council have not been included. Which we consider to be unsound.
(3) P18 Priority 5 is unsound in that it ignores the fact that public transport is poor or non-existent with little prospect of improvement in the foreseeable future and that walking or cycling are not viable alternatives for the not so young or fit.
(4) P43 Para 4.19 States that development should have the potential to create a defensible Green Belt boundary.
The proposal for 550 houses on land "north of London Road" is unsound in that it creates a boundary that is difficult to defend until the A1245 road is reached.
A better alternative would be to locate some of these on proposed brownfield sites in Rawreth village. The remainder could be located on smaller sites in Rayleigh which have been ruled out by the preference for this larger area.
This would meet the guidance in PPG2 "to check the unrestricted sprawl of large built up areas" preventing the eventual coalescence of Rayleigh, Rawreth and Shotgate.
(5) P50 Policy H7 Gypsy and traveller accommodation
Where particular traveller sits have been identified as being undesirable on planning grounds (e.g. highway safety) the temptation to ignore the results of legal process and designate such sites as appropriate simply for administration convenience must be resisted. Therefore policy H7 is considered to be unsound and must be more prescriptive particularly on highway safety grounds.
(6) P65 Para 6.3 The majority of the District's 12763 hectares of Green Belt is located in the east of the District. The preference for "north of London Road" would see the release of a disproportionate amount of green belt land in the west of the District and therefore this statement is considered to be unsound.
(7) P80 Policy ENV4 For SUDS to be sustainable it is necessary for the Environment Agency and landowners to maintain ditches and watercourses in a satisfactory manner. This unfortunately is not the case at the moment. Without this there will undoubtedly be future flooding problems. This policy is considered to be unsound in its present form and should be made far more robust in conjunction with ENV3.
(8) P89 Policy CLT1 It has been estimated that approximately £1 billion will be needed to make up the shortfall in infrastructure provision.
It is unrealistic to expect this to be made up by "standard charges" (as much as £300,000 per dwelling across the total number of dwellings proposed)
On this basis this policy is unsound unless it includes a requirement that these plans are unsustainable without considerable Government funding.
(9) P93 Policy CLT5 The second paragraph needs to be more specific and robust in particular forming a barrier between any possible new development and the A1245 road preventing any further westward sprawl and coalescence of Rayleigh and Rawreth. (see (4) above)
(10) P96 Policy CLT9 The second paragraph should be made more specific, in particular seeking the provision of a swimming pool at the Rayleigh Leisure Centre by means of developer contributions.
(11) P106 Policy T3 Encouraging alternatives to the use of the private car must not be used as an excuse by developers to lower standards of parking and vehicle storage. This policy is considered to be unsound unless it includes a statement to this effect and is made more prescriptive.

In addition the Town Council is particularly supportive of the following:-
(a) P65 Para 6.1 Strongly support this
(b) P104 Policy T1 Whilst generally supporting this it is felt that safeguards need to be built in to this policy to ensure that S106 finance is actually used for the infrastructure improvements for which it is intended, particularly in the light of recent revelations of the loss of such monies.
(c) P110 Policy T8 Parking standards We strongly support what is a commonsense approach to the provision of minimum parking standards to residential developments.
(d) P94 Policy CLT6 Strongly support this.

ROCHFORD DISTRICT COUNCIL

CORE STRATEGY EXAMINATION

PLANNING POTENTIAL ON BEHALF OF FAIRVIEW NEW HOMES



Further Representations on:

Schedule of Changes - Housing Distribution by Settlement
Topic Paper 3 - Sustainable Housing Allocation for Rochford
Topic Paper 4 - Revision to the Greenbelt Boundary
Topic Paper 5 - The Implications of Changes to PPS3




NOVEMBER 2010



Introductory Comments:

Planning Potential Ltd are instructed by, and act on behalf of, Fairview New Homes Ltd. We have actively been involved in the preparation of the Core Strategy (CS), having submitted representations at key stages of consultation, and have attended earlier hearing sessions to discuss Issues and Matters raised by the Inspector.

Further to the written and oral representations that we have already made on behalf of our client in respect of the Examination into the 'Soundness' of the Rochford District Council Core Strategy, to the side letter submitted to the Inspector (copy attached) with regards to procedures in light of recent guidance issued by the Planning Inspectorate and the Judgement(s) on the Cala Homes Challenge - quashing the SoS's revocation of Regional Strategies - the following further written representations are made.

You will no doubt also be aware of the 'second' challenge by Cala Homes, as to the legality of the continued insistence by the SoS of its 'intention' to revoke RSS's should remain a material consideration. An interim review has been expedited, with the effect that it is stayed until further notice. We note that the Court has agreed to this, pending a full legal hearing into the lawfulness of this approach. As such, until the outcome of that hearing is announced, it is clear that decision makers should have full regard to Regional Spatial Strategies as part of the statutory development plan.

In short, the SoS's revocation of RSS's was unlawful, and the continued 'insistence' that the intention to revoke is a material consideration, has too been stayed. In light of this, the adopted RSS, being the East of England Plan remains [currently] in full force, and in light of this, the following comments are made. Until RSS's are formally withdrawn all LPA's needs to adhere to them fully.


Comments on Proposed Changes:

In summary, we understand that the primary changes now being proposed are;

Topic Paper 3 - Sustainable Housing Allocation for Rochford District

The Council are placing significant reliance on the EoEP reviews' evidence base to support the proposed changes. The Council are following the "Option 1" housing numbers - which come from the EoEP draft review. This was approved by the Regional Assembly, and submitted to the SoS in March 2010 - the proposed changes have not been the subject of Examination, and having discussed this with the Planning Inspector, there is no timetable for this Examination. According to the most recent update posted by the East of England Regional Assembly, for the purpose of Regional Planning Policy, the Adopted RSS forms this document - and not the review.

The adopted East of England Plan (EoEP) remains part of the Development Plan. It requires 250 units to be delivered per year over the period 2001 - 2021. The revisions to Rochford's CS are now proposing 190 per year over the period 2011 to 2031 (see para 2.4 of Topic Paper 3).

Taking all factors into account, although the Council are 'dressing up' the revisions as the same total quantum, yet over a longer period of time, it is actually incorrect, and will in fact result in a reduced delivery of circa 1,500 - depending how one calculates this (over the remaining plan period, or, the extended plan period).

According to the Councils "housing need register", the up-to-date need, identified in the SHMA 2010, has recently risen from 702 to 920 (para 3.2 of Topic Paper 3). Accordingly, the Council accept they have an annual affordable housing requirement of 196 units / year, but that the revised [reduced] housing figures will only deliver in the order of 60 odd units per year. Clearly, this figure will not in any way cater for the local need.

A key change is that the housing numbers are now expressed as a maximum - rather than a minimum (para 7.2 of Topic Paper 3). The Council believes this will greatly assist the Plan, Monitor and Manage approach, as it will capture windfalls WITHIN the AMR monitoring and SHLAA processes, rather than adding windfalls onto the total number. This is not in accordance with the EoEP which clearly states in Policy H1, that the District targets should be minimums. The proposed changes to the Core Strategy will thus be in direct conflict with the Regional Strategy. Additionally, PPS3 makes it clear that wind fall sites should not be included and thus this approach is contrary to national guidance.

On a general point, the Council do not clearly state whether the housing target is a net or gross figure, which is required by PPS3. This should [by default] be expressed as a net figure, which means the Council should also be identifying those units to be lost, which of course must be made up in the 5 year land supply.

Topic Paper 4 - Revision to the Green Belt Boundary

The Council acknowledge (both in the Draft Submission Core Strategy and the proposed further changes) they will still need to release [at least] 1% of their existing Green Belt to facilitate the required housing land. Understandably, regardless of the actual housing target, greenbelt land will need to be released.

Whilst my client has, and continues to support this approach, any release should be in accordance with the tests clearly identified in PPG2, and the assessment of those sites that will, and should contribute the housing need in terms of green belt release, should be undertaken strictly in accordance with this approach.

It is apparent in reflection that there are sites, such as my client's which are located on the edge of settlements, yet in the green belt which are sustainable, while located in terms of accessibility and sustainability, and in fact, probably preferable than some urban sites. These should be considered as suitable alternatives in the first instance.

Topic Paper 5 - The Implication of Changes to PPS3

Although the Council state that there is no material change being proposed in light of this, my client has already submitted representations on the impact of this, and would kindly request, rather than repeating, that those earlier representations are considered.

Summary

For the avoidance of doubt, whilst the Council propose changes to the submitted Core Strategy, as discussed above, my clients' representations made to date remain valid, and my client wishes these to continue to be considered by the Inspector. My client maintains that the Core Strategy submitted (or, amended as proposed) remains unsound.

With specific reference to the distribution of housing per settlement (Analysis of Housing Paper) my client would support the identification of the majority of housing being directed to settlements that have best access to services and facilities - Rochford & Rayleigh. The settlement hierarchy proposed, as shown in Table 1, Figure 1, Table 2 and Figure 2 is supported by my client.

Whilst my client has shown, through earlier representations, that we questioned the ability for the Council to meet the housing requirements as set out in the Regional Spatial Strategy, and that is due to the questions arising with the evidence base, and the lack of flexibility in the plan, we still consider the Core Strategy to be unsound.

With regards to the overall provision of housing, we have previously challenged and questioned the Councils ability to meet their housing requirements, and notwithstanding the fact that the Council are now proposing to deliver less housing, over a longer period, we are of the view that this approach is contrary to PPS3, paragraph 53, which states:

"At the local level, Local Planning Authorities should set out in Local Development Documents their policies and strategies for delivering the level of housing provision, including identifying broad locations and specific sites that will enable continuous delivery of housing for at least 15 years from the date of adoption, taking account of the level of housing provision set out in the Regional Spatial Strategy..."

Our client is also mindful of the second part of paragraph 53 (of PPS3), which states that "... In circumstances where Regional Spatial Strategies are in development, or subject to review, Local Planning Authorities should also have regard to the level of housing provision as proposed in the relevant emerging Regional Spatial Strategy." As mentioned in paragraph 5.1 above, the review of the East of England Plan cannot have any status, given there is no timetable for its examination, or indeed, ultimate adoption.

In summary, we have, on behalf of our Client, already made our case in terms of the draft submission Core Strategy. In terms of 'Matter 1' Spatial Vision and 'Matter 2' Location and Supply of New Homes, our submissions, both written and orally, still stand. We have demonstrated above that the proposed [recent] changes are in conflict with the Regional Spatial Strategy which is part of the Development Plan. PPS 12 makes it clear that Core Strategies should be in general conformity with the RSS - para 4.2. Paragraph 4.33 goes on to state that "growth" as an example (and by inference, housing numbers) should follow National and Regional Policy.

Additionally, we have shown that the mechanism of housing supply and demonstrating delivery, as outline in PPS3, have not been complied with.

For the purposes of above, we have shown that the proposed changes are not consistent with National and Regional Policy, are not based on a sound evidence base, and should not be considered.

Finally, as you are aware my clients specific interest is in the Land off Poyntens Road, my client would continue to argue that in light of the above comments, given the need to identify additional land that is suitable and meets the criteria of PPG2, their land would provide a suitable and justifiable release. My clients land is located adjacent to the edge of settlement, in an area close to Rayleigh Town Centre, with good accessibility and well located to facilities, and should be considered as a priority site, over those that are less well located. The delivery of my clients land for housing, would not conflict with the tests of PPG2.

ROCHFORD SUBMISSION CORE STRATEGY - EXAMINATION IN PUBLIC
RESPONSE TO CONSULTATION ON PROPOSED CHANGES TO THE CORE STRATEGY

Further to your letter of 18 October, we write to confirm the response of Colonnade Land LLP (Colonnade) to the proposed changes to the Core Strategy.

The response to the proposed changes to the Core Strategy seeks to take the effects of recent announcements from the coalition Government and the implications of the recent High Court judgement (referred to hereafter as the Cala judgement) into account, alongside an assessment of the implications of the proposed changes. However, before considering these issues, Colonnade remains concerned that the extent and magnitude of the changes to the submitted Core Strategy, alongside the nature of the supplementary evidence, the effect of the change in Government on the structure of the planning system (including fundamental changes proposed to the Development Plan) and the recent High Court judgement by the Honourable Mr Justice Sales (hereafter referred to as the Cala judgement) is the Core Strategy as submitted does not provide a credible basis for the future spatial planning of the District. Fundamentally, Colonnade is concerned that it will be unable to be made sound in the face of ongoing uncertainty and changes within and to the planning system.

In summary, Colonnade considers the Examination of the Core Strategy, the recent changes to which are neither supported by a robust evidence base nor a satisfactory Strategic Environmental Assessment, should be held in abeyance until the evidence base is made sound and greater certainty is established in the weight afforded to recently published guidance and the status of the documents that form part of the development plan.

a) Background

Iceni has acted for Colonnade throughout the preparation of the Rochford Local Development Framework and most recently throughout the ongoing Core Strategy Examination in Public. In this context, we have been involved in the planning process in Rochford for a considerable length of time.

Your recent letter of 18 October confirmed that the proposed changes to the Core Strategy that are subject to the current consultation are predicated on the revocation of Regional Strategies. However, the Cala judgement confirmed the decision to revoke Regional Strategies was unlawful. Furthermore, the decision was also taken without consideration of the potential significant environmental effects as required under the SEA Directive.

The Cala judgement is conclusive in finding that the Secretary of State acted unlawfully in revoking Regional Strategies and the proper route for doing so requires both primary legislation and Strategic Environmental Assessment. As such, Regional Strategies remain part of the Development Plan. Having found the decision to revoke Regional Strategies unlawful in itself, and having separately identified the need to subject the decision to screening in accordance with the requirements of European Directive 2001/42/EC, it is clear that and very little, if any, weight can be afforded to the 27 May 2010 letter announcing the intention to revoke Regional Strategies. It is significant that the recent letter from the Chief Planner, which referred to the weight to be afforded to the 27 May 2010 letter is subject to a fresh challenge.

The findings of the Honourable Mr Justice Sales in paragraph 54 of the Cala judgement specifically clarify that:

"there has been no effective change in any planning guidance brought about by the Secretary of State's decision"

It follows, therefore that Core Strategies are required to conform with the policies of the East of England Plan and any Core Strategy that does not conform with the policies of the East of England Plan is unsound. As currently drafted, the Core Strategy fails to accord with the East of England Plan, in respect of both the minimum housing provision targets and affordable housing targets, and cannot be found sound.

It is also relevant to note that the intention of the Secretary of State in proposing the revocation of Regional Strategies is to "promote more extensive house-building overall". The proposed changes to the Core Strategy that seek to reduce house-building do not accord with the fundamental aims of the Secretary of State for Communities and Local Government, or indeed the policies of PPS3, as revised, which seek to provide for a step change in housing delivery. Indeed, neither does the intention to include windfalls in the total allocation as confirmed in correspondence from the Chief Executive of the Council.

b) Assessment of Proposed Changes to the Core Strategy

In the context of the reinstatement of Regional Strategies, the changes proposed to the Core Strategy should all be reversed, save the changes to the dates, which are required to provide the 15 year horizon.

However, it is important to note the Core Strategy is unlikely to be adopted until after the end of the housing monitoring period 1 April 2010 - 31 March 2011. As housing land supply figures are calculated from the following monitoring year, with supply for the existing monitoring year (1 April 2011 - 31 March 2012) counting towards the current provision, the housing trajectory should run from the monitoring period 1 April 2012 - 31 March 2013.

The schedule of changes should include changes to the text to reflect the findings of the Thames Gateway South Essex Strategic Housing Market Assessment Update 2010 (SHMA 2010). Specifically, SHMA 2010 confirms the projected formation of 350 new households per annum, leading to an annual affordable housing need of 196 net additional dwellings. These updated projections should be reflected in the text at paragraph 2.35 and throughout Chapter 4 of the Core Strategy.

i. Derivation of the proposed annual housing target

Setting aside the fundamental issues relating to the soundness of the proposed changes to consider the evidence for the revised figure it is first necessary to consider the derivation of the proposed figure of 190 units per annum.


In response to the East of England Regional Assembly consultation on the draft Review of the Regional Strategy to 2031 (EoEP2031), the Council provided a series of responses to the 'Scenarios for housing and economic growth'. A copy of the full response of the Council to the consultation is provided for reference. [Attached].

In response to the question regarding which was the preferred growth strategy (Comment ID 1327 on page 2 of the attached) the Council confirmed that:

"For Rochford, a delivery rate set at a level below the current East of England Plan level would be appropriate. It may be that the simplest arrangement would be to assume the housing provision specified in the Council's Core Strategy as the total provision to 2031 rather than, as at present 2025. This would reduce the overall annual rate of housing to about 190 dwellings per annum over the extended plan period or 75% of the current rate."

It is significant, therefore, that Coalition Ministers clarified (in oral evidence to the Communities and Local Government Select Committee of 13 September 2010) that:

"...it is open to local authorities to review their local development frameworks and to reintroduce their own assessment of the housing needs in their area. But it needs to be rigorous. They can't just pick a number and put it in and regard that as being the end of it. They need to make an assessment, and they need to put that, and justify that, in their plans."

Our assessment of the derivation of the proposed figure of 190 units per annum is based on our understanding of the documents submitted with the Core Strategy submission and those requested subsequently by the Inspector. It is also supplemented by evidence presented to the Coombes Farm inquiry and our involvement in the production of the East of England Plan, including the consultation on the draft EoEP2031.

We do not consider, therefore, that the proposed figure of 190 units per annum is sufficiently rigorous in the context of the evidence of Coalition Ministers. Rather, it would appear that the assessment is simply the 'simplest arrangement' and the Council has sought to construct the evidence to support the reduction in housing numbers rather than undertake a full and rigorous assessment of the housing requirements arising from locally derived needs.

Should the derivation of the proposed figure of 190 units per annum be any different to the above, then we would invite the Inspector to request a separate audit trail of the evidence base leading to the derivation of the figure upon the reopening of the Examination.

ii. Assessment of Housing Land Supply

When assessing the housing land supply in Rochford, the historic supply has fallen short of targets and Colonnade remains concerned that the proposed future provision fails to provide sufficient sites, or the flexibility required, to ensure sufficient land is available to meet the locally generated needs. Against both the proposed reduced provision target and the East of England Plan target, historic provision has fallen short.

In the ten year period 1 April 2001 - 31 March 2011 a total of 1,673 units were provided (sum of 810 within 01-06, 618 in 06-08, 102 in 08-09, 86 in 09-10 and 57 in 10-11), an annual average provision of 167.3 units. This represents a shortfall against the Regional Strategy minimum target for the period of 627 (2,300 - 1,673). It also represents a shortfall against the proposed reduced annual average housing provision target of 227 (1,900 - 1,673). We can conclude, in accordance with the interpretation of delivery by the Coombes Farm appeal Inspector, that against either target, the Council has failed to meet the basic requirements for the ten year period 1 April 2001 - 31 March 2011.


Turning to future provision, the trajectory included in the 'Breakdown of 2011 - 2031 housing trajectory by source' table relies on a 100% implementation rate on all the extant planning permission sites, a presumption that was found to be unsound in the Bromley appeal (APP/G5180/A/07/2043219/NWF).

Furthermore, the figures included in the row 'Appropriate Brownfield sites identified in SHLAA' include provision of a number of constrained sites, which are neither commercially viable, nor attractive to the market. An example being the Stambridge Mills site. Whilst it is now accepted that the site can deliver significantly less than the 250 units originally proposed, it remains unlikely to be delivered in the timescales anticipated by the Council. It is significant that the application was screened in 2007 and whilst an application was submitted in September 2011 it remains invalid.

Colonnade has highlighted its concerns with the future provision relied upon by the Council throughout the production of the Core Strategy and the pursuance of the Coombes Farm planning application. As such, its concerns regarding the future provision within Rochford are well documented and the number of changes made to the assessment of sites in the SHLAA tables confirms the fragility of continuing to rely on the assessment contained within the SHLAA. The Inspector will not need reminding of the objections of Colonnade to the SHLAA, or those relating to the timing of its publication, nor the concerns Colonnade had that its representations on the methodology were not registered despite being validly submitted. However, the changes necessary to the deliverability findings on a number of sites could have been avoided had the SHLAA been published for comment prior to the submission of the Core Strategy. The fact that it wasn't meant it was simply not possible for Colonnade to subject the assessment of sites to sufficient scrutiny.

In summary, therefore, Colonnade considers the assessment of housing land supply fails to take account of historic underprovision, is overly optimistic in terms of future supply and the baseline for the assessment of future supply was not subjected to sufficient scrutiny through consultation.

iii. Evidence of Housing Need

As confirmed above, Colonnade is concerned that the assessment of housing need contained within Topic Paper 3 has been constructed to support the reduction in housing numbers rather than in response to a full and rigorous assessment of the housing requirements arising from locally derived needs. In simple terms, the Topic Paper (and the attached response to the document confirms:

* 400 units per annum would be required to meet the national growth targets identified in the EoEP2031 consultation (Comment ID 1325 on page 3 of the attached);
* 2010 SHMA identified 350 new household formulations (not taking account of past underprovision);
* The 350 new household formulations result in a net annual affordable housing need of 196 dwellings;
* The real increases in the Social Housing waiting list (which has subsequently grown further from 702 to 920 since the report was prepared);
* The projected population increase of 17,511 people in the period 2001 - 2026; and
* The projected increases in the older age population cohorts in the District and the increased pressure this will have on the availability of housing for newly forming households.

In addition to the above, the Sustainability Appraisal of the Core Strategy Preferred Options assessed the effects of the emerging policies based on the minimum net annual housing provision target of 250 units (adjusted to take account of historic underprovision). It stated that the plan would have 'significant positive effects through meeting the housing needs of the District'. It is inherent that the Sustainability Appraisal could not have come to this same conclusion had the minimum net annual housing provision target of 250 units been an overprovision in the context of local need.

Similarly, the Sustainability Appraisal of the East of England Plan established that the housing provision figures were confirmed to be sustainable in the regional context. A number of the arguments put forward by the Council within the Topic Paper need to be critically assessed in the regional context, as Colonnade is concerned that they fail to take a sufficiently strategic view of their logical conclusions. In particular, the arguments that culminates in paragraphs 3.20 and 3.21 require measured consideration.

Paragraph 3.20 relates to the potential changes in population profile and fails to take account of the proposed growth in employment within Rochford. The increase in employment opportunities will attract new residents from the 'working age' cohorts, thereby increasing the rate of newly forming households within all of the 'working age' cohorts. In combination with the accepted increase in the 'older age' cohorts, increases to the 'working age' cohorts associated with employment growth will be significant.

It is unclear what paragraph 3.21 is seeking to achieve, as the forecasts within the 2008 SHMA were based on a clear understanding of the housing distribution contained within the East of England Plan and policy intervention of the sort referred to can only be achieved at a strategic level.

Colonnade is also concerned that the Council has failed to take account of the essential characteristics of Green Belts, which is clarified at paragraph 2.1 of PPG2 that states:

"The essential characteristic of Green Belts is their permanence. Their protection must be maintained as far as can be seen ahead."

Having established that changes to the Green Belt are required to accommodate housing growth, the failure of the Council to plan for the housing growth arising from an assessment of national growth targets, have a potentially deleterious effect on the essential characteristics of Green Belts, as it comes under increasing pressure to meet burgeoning needs.

It is also concerning to note that the Council appears to place the protection of the Green Belt above the social and economic benefits of meeting housing needs. This is confirmed in Section 4 of the Topic Paper, which seeks to protect the Green Belt at the expense of social and economic effects, and in the case of Stambridge Mills, above the concerns of the Environment Agency regarding the potential loss of life.

There are a number of other specific points to note in relation to the other findings of the Topic Paper, including:

* Paragraph 3.24 - the Thames Gateway remains a focus for economic growth;
* Paragraph 3.24 - there is no evidence of a change in commuting levels presented; and
* Paragraph 3.28 - reducing the housing target to 190 will make it impossible to meet affordable housing needs.

In summary, the assessment of housing need is neither robust nor logical. The evidence base presented by the Council to justify a reduction in the housing provision figure is confused and could have a deleterious effect on the essential characteristic of the Green Belt in Rochford.

c) Assessment of the Strategic Environmental Assessment of the Proposed Changes

The Sustainability Appraisal of the proposed changes to the Core Strategy confirms that the effect of the proposed changes on the housing objective will be negative. It confirms that the range and affordability of dwellings will be reduced, but fails to offer any realistic mitigation measures.

It also fails to effectively balance the eventual loss of land to development that would occur over the extended plan period with the significant and real negative social and economic implications of reducing housing provision figures.

d) Conclusion

The proposed changes to the Core Strategy are unsound. They do not accord with the development plan and the evidence base that the Council has prepared to support them, including the findings of the Sustainability Appraisal, appear to have been constructed to support the reduction in housing numbers rather than in response to a full and rigorous assessment of the housing requirements arising from locally derived needs and a balanced assessment of the social and economic effects.

The number and degree of changes required to make the document sound are so extensive that it would be difficult to prepare a clear and logical report of the necessary changes. It would not be in the interests of coherent and sustainable spatial planning to press ahead with the proposed changes to the Core Strategy, nor is it an appropriate response in the context of the Cala judgement and other challenges that are being pursued.

Until the Core Strategy evidence base is sound and greater certainty is established in the planning system, there is a risk that proceeding with the Examination of the Core Strategy will result in a rushed and fragmented document conceived and prepared under an outdated planning system. This is particularly so where the evidence base so clearly points towards a high demand for housing to meet locally generated needs.

Should you have any queries relating to the above, then we would be pleased to provide further clarification. We would be grateful if you were to provide confirmation of the Council's position on the above issues and the views of the Inspector on the further progression of the examination. Finally, we would also be grateful for confirmation that this letter has been received and passed to the Inspector for consideration.

I wrote to you 27/4/10 on behalf of both my wife and I regarding the disproportionate level of house building in Hullbridge proposed in the Rochford District Council Core Strategy paper. I strongly objected then, and having read the 'revised' core strategy, I strongly object now.

I have lived in Hullbridge for 43 years and had visited here for a number of years prior to that. I am deeply unhappy at the number of buildings and the green belt location proposed, both aspects would simply ruin the appeal of the village and change the very nature of the country village living I moved here to enjoy.

My records show that I am still awaiting a reply to my concerns that I already outlined to you previously, such as why are you building on green belt and when there are numerous brown site areas across the district? How are 500 additional properties going to be serviced by amenities that struggle at times to service the needs of the existing infrastructure? How will the development deal with the flooding the proposed location already suffers from? What about the impact on local traffic, since the roads are barely able to cope at pear times as it is - are there plans to build more roads?

I think the whole proposal to indiscriminately build so many new houses in Hullbridge is poorly thought through. The fact that the 'new' Core strategy proposal is almost identical to the old one smacks of laziness rather than a concerted and genuine effort to balance the future district housing obligations with the needs of local residents.

I thoroughly reject the new Core Strategy document and urge you to please expend some effort in meeting your planning obligations through identifying areas with less social and environmental impact.

In reply to your letter of 18th October, our objections remain the same as laid down in previous correspondence to you, mainly that the proposal to build 500 houses in S.W. Hullbridge on Green Belt is far and above the number that can be sustained by our present infrastructure, even when building 190 per year until 2031.

Once again we reiterate that Hullbridge has only a one road access to the village and that traffic in, out and through is even now at peak levels in the morning and evening. Construction traffic would only add to this congestion.

Has anyone looked at the local flood problems in Watery Lane, adjacent fields and Church Road that Aviva Insurance had expressed concerns about as the Environmental Agencies only looked at the local tidal river and not surface water?

We also have a problem with a local sewage odour which no one seems to resolve.

We would also be interested to know where the 14 gypsy sites are to be located and how many are designated for Hullbridge.

Although we haven't referred in detail to the Core Strategy, we object most strongly to planning which affects us all in Hullbridge and feel that we are continually being ignored whilst wondering if any objections or proposed alterations to the above would be meaningfully considered.

Thank you for the opportunity to peruse and comment on the revised Core Strategy document. You may recall I wrote to you back in April this year objecting to the disproportionate allocation of new developments proposed for the green belt area adjacent to the west of Hullbridge. Since in essence the Council's proposal with respect to Hullbridge remains the same with but a slight alteration to the timeline, I remain vehemently opposed to the building of 500 new properties.

With respect, I feel the original plan was ill conceived and only remains as the default position of the council because the pre-planning work was already carried out under the obligation to the previous Labour government. It appears that rather than actually listen to the people most affected by this proposal and try and come up with viable alternatives, the soft option has been taken to re-present the original proposal.

I have still had no response from the Council in how they intend to address my concerns as originally expressed (I quote):

1. Environmental - Hullbridge is a village surrounded by farmland and green belt creating a pleasant environment to live, which was why my family moved here in the 60's. The amount of local wild land available to animals and plants has been dwindling with every new development (consider how much habitat was lost when South Woodham Ferrers was expanded for example). The Hullbridge site zoned for proposed development hosts slow growing indigenous trees such as oaks and has hedgerow (rare enough these days sadly) which provides a much needed refuge for our wildlife. The open areas bounded by hedgerow provides habitat for flowers and insects and hunting habitat fir birds such as Kestrels. It also provides a much needed break preventing the urban sprawl engulfing our country i.e. green belt should be considered unavailable. This notwithstanding, historically, this area has always been prone to flooding as the aptly named Watery lane testifies. Covering this area in asphalt and concrete will prevent the land from soaking up such water as it currently does and will inevitable exacerbate the extent of flooding (and even possibly create an area prone to disastrous flash flooding). So you can see I am concerned that building on this land would be detrimental to both Wildlife and the well-being of residents (both existing and proposed).

2. Transport - there is already a problem with peak time travel congestion not just for and by residents of Hullbridge, but for those using Watery Lane/Lower Road as a back route to Hockley/Hawkwell/Rochford/Southend. Expanding the size of the village by a third would add considerably to the congestion and misery for all trying to use the barely adequate existing transport infrastructure. Naturally congestion equates to more pollution, something I'm sure we're all keen to avoid not just for the sake of local air quality but for preventing unwanted greenhouse gas emissions.

3. Services - Inadequate drainage I mentioned above is a severe problem already. I've also mentioned that existing transport infrastructure is unable to accommodate peak travel demands, it's clear increasing the size of Hullbridge by a third is ill conceived. Electricity supply is already prone to brown outs. Sewerage is already close to capacity if the smell is anything to go by, schooling, medical and basic shopping facilities are not up to meeting the demand of 1500+ extra residents. Can you please explain how these issues are to be addressed?

4. Travellers Site - I have heard a rumour that the council intend to create a Traveller's site nearby off Hullbridge road. Is there any truth to this rumour? My concern is it's impossible to determine if these Travellers are truly people of no fixed abode (many have land/property in Ireland and abroad) and not just exploiting legal loopholes created by Labour to make money tax-free, create pollution and place a burden on law enforcement and local resources before moving on leaving the residents in the area to foot the bill for cleaning up. Certainly I'm unaware of a single Traveller's site in the country where the residents have attempted to successfully integrate into the local community. So until such time comes as these people are proven beyond doubt to be otherwise homeless, are prepared to pay their taxes and show social responsibility, then I am opposed to them being allowed to reside in the area.

So again in conclusion, I strongly object to your current proposals in the Core Strategy for building 500 houses on local greenbelt and for creating a Travellers site. I still urge you to re-examine other options, hopefully meeting your obligations by preferably redeveloping existing urban, brown and abandoned sites.

We are writing once again to PROTEST MOST STRONGLY regarding the Planning Application for 600 homes to be put on the large field in Hall Road.

We have lived and enjoyed being here for 37 years because of the farmland opposite, which is also very arable GREEN BELT, a bird and small animal sanctuary. We have over the years seen more and more traffic build up and now to the point where we cannot get out of our driveway for the enormous stationery traffic jam. Everywhere you go to get out of Rochford in the mornings and late afternoon are impossible because of the traffic.

1200-1400 extra cars will bring everything to a grinding halt. There is no infrastructure to support a scheme of this size and it will ruin what little countryside we have left. Should windfall sites occur it will be TOO LATE to save our very precious GREEN BELT. We object most strongly to this scheme and feel that not nearly enough consideration has been given to where people wish to live and also the total lack of infrastructure to support it.

Rochford has been an ancient village for a very long time and all this new building will destroy it. There are many other brownfield sites that could be used for the purpose required and NOT touch our GREEN BELT, for example, the Old Brick fields in Cherry Orchard Way, with direct Access onto the A127.

This potential planning will, and has already DEVALUED OUR PROPERTIES in Hall Road. Just WHO is going to compensate us for this depreciation?

With absolutely EVERYONE protesting against this proposed development, further serious discussion is paramount as to where an alternative development site could be situated.

Thank you for your letter of 18th October 2010. Having now had the opportunity of reviewing the proposed changes to the Core Strategy, I would like the make the following comments and objections with reference to CSSC1 CSSC2 and CSSC3 insofar as they relate to Hullbridge:-

1. I am pleased to see that it is proposed that any release of green belt will now be deferred until post 2026. I am disappointed to note, however, that the Council still proposes that 500 houses should be built in Hullbridge and to release green belt for this purpose. This figure neither represents local needs as stipulated by the Government nor reflects the wishes of the vast majority of local residents who are totally against development on this scale in the village. Building this many houses would transform Hullbridge from a village into a small town but without the necessary supporting infrastructure, services and amenities, making life miserable for everyone living here.

2. a) I have seen a number of maps proposing various areas of green belt to be released for development ranging from the south side of the Hullbridge Road right the way through to the River Crouch. The core strategy is not specific in this regard merely referring to the green belt to be released as "South West Hullbridge". Failure clearly to identify the affected green belt 'blights all the houses in the whole of this area which currently overlook open countryside as regards both value and saleability. It is unfair and wrong to taint all of these houses in this manner.

b) My understanding is that this particular land has been selected for development purposes because it is currently the best on offer. With its propensity to flood the land is not ideal for building houses and would be costly to develop. The period 2027 to 2031 is a long way off and I do wonder why the Council are trying to second guess what will be needed at that time. Much could have changed by then both in terms of housing requirements and land then available for development (viz more brownfield sites becoming available and/or other landowners wishing to offer up their land for development) preferable both in terms of suitability, development costs and adverse impact on existing residents. Accordingly, I think it is both wrong and premature for the Council even to be considering housing requirements for so far into the future let alone at this stage identifying green belt land to be released for this purpose. All these decisions should be left until nearer the time.

c) The plans I have seen all incorporate Malyons farm buildings and surrounding paddocks which provide the only local horse riding facilities. To allow buildings on this land is contrary to the Council's stated policy (Policy CLT9 - Leisure Facilities) to maintain and enhance leisure facilities in the area.

d) The proposal to release green belt land at Hullbridge in no way satisfies the Government's Planning Guidance 2 which states that green belt should only be built on in exceptional circumstances. The Hullbridge green belt only seems to have been proposed as a convenience to enable the Council to meet an arbitrary number of houses which it thinks need to be built way off into the future and which cannot be known or justified at this point in time.

I would like to put my objections to the proposed building of the housing in Hullbridge and Rochford area.

We can take no more cars and our roads are so congested so are our trains standing room only at the busy times morning and evening. Also our hospitals an not cope now with the waiting times are getting longer.

Also our junior schools are all out of the Hullbridge area. So please think of our green belt land as our most precious thing we now have.

I strongly object to the Core Strategy being upheld.

Please leave our green belt alone. Essex is one of our most beautiful county's that's why we live here. Don't turn it into a town, our services can't manage now, more crime, cars, rubbish etc.

The green belt loses will cause more flooding to the areas we pay to live here because we love it the way it is, if it's true the Government is willing double council tax to councils for every home built, that shows everyone it's wrong.

Look to your voting residents trust in you for looking after their interests don't ruin Essex.

I am writing to you in protest of the proposed 3800 house to be built in the Rochford District Council Area.

I was given to understand that the present government had revoked region housing targets and started towards abolishing regional strategies and return decision making to the local Councils, if this is the case why are Rochford Council still proceeding with the building even ore houses which is against all the residents wishes.

I thought that Rochford Councillors were in office to ensure that the interests of the Community are best served, allowing this project to go ahead is certainly not that.

As already stated in my previous letter the problems that will arise if the project goes ahead are listed as follows.

The infrastructure is not built to accommodate even more cars (possible extra 1000 cars all trying to get in and out of Hullbridge)
Flood (Watery Lane and surrounding area are always prone to flooding) Properties will be uninsurable.
Schools (are already at capacity)
Doctors (are already at capacity)
Council Services, including Fire and Police.

You do not mention any improvements to the infrastructure, flood defences schools, doctors, fire and police within your revised Core Strategy, is this another Council mess up, build the houses and hope nobody will notice more delays on our roads, property being flooded class sizes increasing, have to wait weeks to see a Doctor, crime will be on the increase as the police are overstretched, (Government Cutbacks) fire service at breaking point.

I would have thought all the above should be addressed first then look at housing.

Travellers Sites

I understand from the revised Core Strategy that 14 no. sites are now required to be made available for travellers by 2021, are the Council in a position to give the residents of Rochford some indication of where these sites will be.

I do not have any objections to travellers but unfortunately present day travellers would not bring anything to our village except vandalism and harassment of the local residents, all property prices would fall and any residents hoping to move would not be able to sell their properties.

If you need more insight into travellers sites in this village ask the residents of Gardiner's Lane Cray Hill what they have to endure over many years.

Burglary, threats with guns, vehicles being driven around the camp late at night, dog excrement being put through their letterbox. Travellers children hurling verbal abuse at the residents if they are ask not to kick footballs or play on the residents properties.

It appears Local Authorities or police do not have any powers to remove these travellers even though they do not pay taxes, council tax, rates, their children disrupt the school when they attend. (I understand Crays Hill School now only have travellers children attending the school as the parents of local children have removed them because the standard of the education in the school was now at extremely low level.

Classification of Land

It appears that Developers have already brought and put in Planning applications for land which is designated green belt land, I was given to understand any green belt land would have to go through certain procedure to be de-classified, which a public enquiry is part of the procedure.

I would appreciate clarification on this matter.

It appears to the residents of Hullbridge, that Rochford District Councillors who live in Rayleigh, Rochford, and Hockley instead of throwing out this proposed development of 3800 houses and 14 traveller sites they have adopted the attitude (as long it is not in my back yard), which I find appalling as they were elected to serve all the residents of the Rochford District not just Rayleigh Rochford or Hockley.

If I have been given incorrect information I apologise for the some of the statements I have made, but if the Council had consulted the Local Residents in the correct manner we would not be in the situation we now find ourselves.

Please all Rochford Councillors stop this madness and leave this village as it should be, a village.

I am responding to your letter of 18.10.2010 delivered to my old address of regarding future development in Rochford in general and Hullbridge in particular. As you are aware I am opposed to any development on green belt land in Rochford District and especially the proposed building on green belt land to the west of Hullbridge ie Watery Lane.

Since the change of government you can no longer hide behind the excuse that 'Central Government made me do it."

As anybody who lives anywhere in the district is aware the strain on public services in general and the roads in particular is at breaking point. We simply cannot afford to keep building new houses!

I would draw your attention to the article written by Joyn Hayter in the local press which makes many relevant points about Rochfords building strategy, amongst which the double council tax 'bribe' and the Councils refusal to listen to local peoples concerns stand out.

For my own part I feel that the proposed Hullbridge development on green belt land for which there are no exceptional circumstances and which the local residents are over whelmingly against many over its council backing to rather more conventional 'bribes', possibly from the landowners and or developers. Please deny this and prove your point by scrapping this insane plan which can only result in even more traffic jams, roadworks, waiting lists etc than we have at present.

As stated in our previous correspondence, we are still opposed to building houses on green belt land in Hullbridge. The green belt land must be kept for future generations to enjoy, a long with all the wildlife that this land supports. We do not believe the infrastructure of Hullbridge can support an area of housing development and cater for all the extra vehicles this would bring.

We are only a small village and we demand that it is kept that way.

Thank you.

Dear Sirs Re: Rochford Councils Core Strategy

Having looked at the councils proposed changes to the core strategy I am very disappointed with your revisions.

Following the change of governement and the scrapping of the East of England Plan, I fail to see why the council are still intent on forcing through additional housing where it is not wanted.

As I live in Hullbridge I am against the idea of building 500 homes for all the reasons in my previous letter on this matter.

Please register this letter as protest against the unwanted building proposals.

Dear Sirs Re: Rochford Councils Core Strategy

Having looked at the councils proposed changes to the core strategy I am very disappointed with your revisions.

Following the change of governement and the scrapping of the East of England Plan, I fail to see why the council are still intent on forcing through additional housing where it is not wanted.

As I live in Hullbridge I am against the idea of building 500 homes for all the reasons in my previous letter on this matter.

Please register this letter as protest against the unwanted building proposals.

Core Strategy Consultation Oct/Nov 2010

I/we wish to register the following objections regarding the above consultation:

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

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

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

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

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

6. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited. This issue has caused a lot of concern to many residents who favour a single, manageable site in a location with good road access and all appropriate services and the proposals are unsound and, probably, unsustainable.
* 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. Revised proposals have now been made on aspects covered by the DPD. Similarly, proposals for Hockley Village Centre have been repeatedly rejected but are still included. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.

Core Strategy Consultation October/November 2010

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

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

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

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

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

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

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

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

One last comment on your latest Core Strategy paper. One of the most important proposals is to build 500 houses in West Rochford. This is a large development which will have major impact on the area especially in traffic using our already congested main road routes. The B1013 is already one of the busiest B roads in the country. Adding to this we have the development of Southend Airport which will generate large increases in traffic.

Of course the development of major roads is the responsibility of Essex County Council but I have not seen any papers which mention any discussions with ECC on major routes in the area. As it is Rochford will be building large numbers of houses with over a thousand extra cars likely to be using the main road network suck as it is. Surely there should be at least the outline of a major east west road route (eg development of Lower Road in Hockley to take greater traffic volumes). If there is no prospect of this kind of development we will end with the whole area being in a constant gridlock situation.

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.

I am pleading with you not to build any more houses in this area.

I moved away from built up areas and over crowded areas. I moved here to get away from it, and I found a lovely village with just the right amount of housing. If they want to build 3800 homes, why don't they look at the land that Ford's of Dagenham had. There is plenty of land there, then we can all live happy ever after.

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.