Rochford Core Strategy Development Plan Document - Schedule of Changes

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

A RESPONSE TO THE PROPOSED CHANGES
TO THE CORE STRATEGY FOR ROCHFORD DISTRICT

SUMMARY

The following comments to the proposed changes are made with particular relevance
to part of the Allocations Development Plan Document Preferred Option SWH4 at
South West Hullbridge; being land on the south east corner of the junction of Hullbridge
Road and Lower Road.

ROCHFORD CORE STRATEGY-PROPOSED AMENDMENTS

(Dated 14th October 2010. ITEM 3 ) .

RESPONSES

Page 3.1, Item 3.2.

The Hanover Land Trust considers the proposals to reduce the annual housing quota from 250 to 190 and to extend the Core Strategy from a 10 -15 year period to one of twenty years, will be less positive for the district in terms of economic vivacity and future sustainability, bearing in mind the proposals already activated for the expansion and redevelopment of Southend/London airport and other regional locations of investment.

Rochford Core Strategy Schedule of Changes
Page 3.7. Appendix 1. Item 4.6 and Page 3.8 Item 4.16.

The Hanover Land Trust (H LT) fully supports these proposals, but it is considered that more dwellings, (particularly the proportional quota of affordable housing) will be needed earlier than the 500 units scheduled here for 2026 to 2031 and that an earlier phasing would be beneficial for the locality and district in general.

Page 3.9 Item 4.24. The HLT site within Preferred Option SWH4 is immediately deliverable, unlike many of the sites elsewhere in the district scheduled for earlier phasing.

Item 4.25. Due to various factors windfall sites often cannot be relied upon to come forward
as required as opposed to the above proposed site within Preferred Option SWH4. We therefore consider that less emphasis should be given to such in town sites in the probability that they will not fulfil what may be expected of them.

Item 4.26. The above site does conform to the other policies within the CS.

Item 4.27. HLT fully supports this statement.

Page 3.12. Item (H3 the 4th column second paragraph onwards). HLT fully supports this statement.
Item (GB1 the 4th column) HLT fully supports this statement.

Page 3.13. Policy H1-The efficient use of land for housing.
Item Paragraph 2. HLT fully supports this statement as part of the above site is already
developed and contains a portion of previously developed white land.

Page 3.15. Policy H3 Extension to residential envelopes post-2026.
HLT generally supports Policy H3 except that the above site could be brought forward
within Preferred Option SWH4 or in isolation, in conjunction with the present and urgent
need for the redesign and improvement of the infra-structure at the busy three-way junction
of Hullbridge Road, Watery Lane and Lower Road.

Page 3.42. Appendix 2. Topic Paper 3 - Sustainable Housing Allocation for Rochford
District.
2. Revocation of the Regional Spatial Strategy and Option 1 ' Figures.
Item 2.5. The proposed figure of 190 dwellings per annum is considered insufficient and
incompatible with good sustainability for the district, particularly with regard to the proposed plan being extended to 2031.

Page 3.50. Demand for Affordable Housing. Items 3.25 to 3.28.

These proposals, based on out of date figures, support our proposal for more affordable
housing to be implemented earlier in the CS plan period, considering the backlog referred to by Councillor Lucas -Gill earlier this year in the attached press cutting. We place particular emphasis on the current and future government budget cuts, which will affect both private and public sector service worker jobs, mortgages and pensions in tandem with increasingly more expensive private rentals due to anticipated additional demand. We believe the proposed changes will establish a too limited supply of dwellings over an unnecessarily extended time period.

Page 3.51. 4. Environmental and Physical Constraints within Rochford District.
Item 4.1
The HLT fully supports this statement as the above site is a mixture of existing development
within the Hullbridge town planning envelope, previously used White land and a lapsed planning consent fronting Lower Road. The whole site is self contained and is part of the south west corner of the Council's Preferred Option area SWH4.
Item 4.5 and 4.6 Development of the above site would not impact on the European
sites in and around the Rochford District and would not coalesce with neighbouring
settlements.

Page 3.55. 6. Infrastructure. Item 6.1
The HLT fully supports this statement as it would be prepared to work in conjunction
with service and infra-structure providers. The above site is the most suitable site for
. earlier release within SWH4 and adjacent to existing services, unlike much of Preferred
Options SWH1, SWHZ, and SWH3. For the various foregoing reasons, we believe this
site should be implemented in the earlier phasing of the CS plan period. Not least due
to the present urgent need for an improved drainage scheme to the west of the busy 3-
way road junction entrance into Hullbridge town.

Page 3.56
7. Overview of Implications of the Revocation of the East of England Plan.

Page 3.57. Item 7.10 and 7.11. Windfall sites have been dealt with in our response to
Item 4.25 and HLT considers these two proposals will impact negatively for the
Rochford District.

Page 3.58.
8- Conclusions. Items 8.1 to 8.5.
Except for the proposed numbers of units, HLT generally supports these statements.

Item 8.6. HLT contests this viewpoint which states the "section of population most
likely to form new households, (20-34 year olds) will shrink. " In the general sense
Rochford District is one of the most desireable places to live in this part of Essex and
this age group is only the core of the overall age group who aspire to live in the
Rochford District via new affordable housing schemes. There is also the 34-55 year
age group who througn a variety of circumstances need this form of accommodation.
In addition there is the 55-70 years age group similarly affected as the former category,
who wish to retire here having relatives in the district, but cannot afford to do so without
the assistance of a housing association. We therefore believe demand will actually increase
above the norm when the economy improves. Notwithstanding this prospect,
there is an increasing social tendency for existing younger family sub-division, which
will inevitably, use up the number of dwelling units proposed at an increased rate. On
this basis we question whether the Council's new proposals will be sufficient for the
ongoing sustainability required for the future population of the Rochford district.

Item 8.7. With reference to the foregoing points we disagree with this statement and
propose that additional/earlier new housing supplemented by more light industrial/office provision would stimulate an increase of sustainability in Rochford District. An
example being that the former Eastern Electricity offices in London Road, Rayleigh
should be retained for it's existing use for commerce and employment as there appears
to be sufficient housing land allocated in west Rayleigh.

Item 8.8 The above responses, along with the District's geographical location and
burgeoning new business ventures (p Ius anticipated demand) would indicate that the Rochford District is a growth area up to a point, and as stated in Item 8.8, "new market
housing is definitely required in the District" which HLT supports to enable the District
to capitalise on and maintain it's sustainability, when or as the economy improves.

Appendix 3

Page 3.59. Topic Paper 4-Revision to the Green Belt Boundary.
2. Exceptional Circumstances.

Item 2.1 to 2.6. In the hope of avoiding undue repetition of detail, HLT believes that exceptional
circumstances apply to the above site for the following reasons:
HLT believes the above site is the best individual site within Preferred Option SWH4 as
the site is already partly developed. The site also contains a section of unused White
Land lying within the existing development envelope of South West Hullbridge. A significant
section of the site also obtained a planning consent since lapsed. It was also
recently proposed by Essex County Council to construct an important cycleway on the
northern and western perimeter of the site. HLT supported this project, but County
funding was not forthcoming and might possibly be best left installed in conjunction
with the new development and infra-structure improvements so badly needed at the
present time in this location. Should this small portion of the above land needed, to accommodate this project be released from the Green Belt as outlined above, the proposed
cycleway could easily be accommodated for the benefit of users travelling between Hullbridge to Rayleigh at no land cost. To include this remaining green belt area of approximately 3 acres (51/2 acre site in total ) for release would be an appropriate use of the above site and dispose of the current aesthetically displeasing appearance of the area and would at the same time contribute to easing pressure on better quality green belt land in the locality.

Page 3.60. The Allocation of Land for Employment Uses.
Item 2.9. The former Eastern Electricity site is not deemed to be a "bad neighbour"
and part of this site includes the conveniently located Bright Sparks children's day nursery a valuable facility for employees and families in the locality.

Page 3.61. Conclusion., Item 3.1
HLT generally supports the Conclusion statement except to question that the limited
and sometimes mythical development opportunities predicted to come from inside the
existing town envelope, will ever happen. Also bearing in mind that it is against Council
policy to create undesireable "town cramming". Over the recent past the District
Council has conducted an exemplary exercise in limiting and negating Council Tax increases
without significant cuts in services. However, the Council must maintain sufficient
Council Tax income to help keep the District viable and sustainable for the period
of Core Strategy future planning (2011-2031 ) and create a sound foundation for further
sustainability for the period beyond. HLT considers that development of the above
site would assist in this precept. With all the multitudinous and variable factors involved
in the distillation of the best future plan for the Rochford District, we do question
whether there will be sufficient new land released for; 1. The required amount of future
housing and, 2. New business opportunity and employment?

Having submitted our comments above, regarding the Rochford Core Strategy-
Proposed Amendments, we trust the content may be of some assistance to the Council
and the Planning Policy Team for the Inspector's forthcoming Examination. (Please
see attached aerographic view of the above site) .

Finally, with the number of submissions made over the Core Strategy programme period,
we apologise for any necessary repetition of detail.

The following comments are made concerning the proposed development of West Rochford and particularly the proposed construction of 600 new houses : Green belt land still proposed in first stage without full evaluation of alternatives
Prime agricultural land still proposed to be released in the first phase
Lack of appropriate infrastructure. Existing infrastructure is unable to cope with present demands.
No account taken of the need identified originally in the Core Strategy i.e 44% of waiting list applicants want to live in Rayleigh. There is no development proposed to take place in Rayleigh during the first 15years of the Development plan.
The proposed use of windfall sites to reduce the release of green belt land is of no value with regards to West Rochford. It will be too late as 500 new homes are proposed in the next 10 years and a further 100 in the next 5 years

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.

It is unrealistic to extend the plan period to 2031; this is too far ahead to be sure about housing/employment requirements.

The plan period should not go beyond 2026. The amount of housing/employment site allocations should be reduced accordingly. This would mean some of the proposed sites being deleted from the plan (ie the Rayleigh sites).

Core Strategy Consultation Oct/Nov 2010

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

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

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

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

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

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

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

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

Core Strategy Consultation Oct/Nov 2010

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

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

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

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

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

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

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

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

Core Strategy Consultation Oct/Nov 2010

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

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

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

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

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

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

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

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

Core Strategy Consultation 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.

The Department of Transport has announced that the proposed rapid Transport System has been postponed pending a further review. This places further doubt on the future of this proposals and further undermines the already shaky credibility of RDC's transport proposals. The Highways proposals in the Core Strategy are unsustainable and unsound.

The Department of Transport has announced that the proposed rapid Transport System has been postponed pending a further review. This places further doubt on the future of this proposals and further undermines the already shaky credibility of RDC's transport proposals. If the proposed RTS does not proceed there will not be any buses or other public transport to the main employment area. The Highways proposals in the Core Strategy are unsustainable and unsound.

At 8am traffic is already backed up from the Arterial right down Nestuda and Cherry Orchard Way as far as Toomey's. In the other direction the jam starts at the White Hart and goes all the way through Hockley. Going through the Hall Road bridge you're stymied again and competing with traffic from Ashingdon, Stambridge and Canewdon. Is it seriously planned to add another 600-900 vehicles to this? Of the three railway crossings at Rectory Road, Hall Road and Warners' Bridge, one is about to be virtually severed by the runway extension forcing yet more traffic onwards to the Arterial.

Introduction


We represent Barratt Eastern Counties who have an interest in land at South Hawkwell, off Rectory Road. Set out below are representations to the most recent set of Core Strategy changes. Barratt Eastern Counties previously made representations under representation numbers 16915 to 16928.

Representations

2.29 and 4.2- Barratt Eastern Counties recognise that the revocation of the RSS and emphasis on local housing targets will require changes to emerging Core Strategies. Barratt Eastern Counties support the revised housing requirement of 190 dwellings per annum between 2011 and 2031 subject to clarification on the following.

It is not clear from the data and tables how recent shortfalls in the immediate past have been subsumed into the proposed changes to the Core Strategy. If the following issues are considered valid then the Inspector may need to consider additional housing at some of the green field general locations. This being the case, the evidence we have previously submitted in support of the south Hawkwell general location would indicate that additional housing should be targeted at this area.

1. It is the case that RSS was adopted in 2008 and applicable as a development plan between 2006 and its revocation in 2010. As such the shortfalls in housing delivery during this period should be factored into the proposed changes to the dwelling requirement set out in Table 39,40. Even if a date from adoption of the RSS were taken, the shortfall would be calculated from the 86 dwellings delivered in 2009-10 (see Appendix CSSC4 of the proposed changes) and 102 dwellings for 2008-09 as noted at Figure 4.4 of the AMR 2009). This shortfall would amount to 312 dwellings based on the RSS requirement of 250 dwellings per annum from 2008 to 2010 or an uplift of 192 dwellings if the 190 dwellings per annum is applied as the Council currently propose. Either way there is a shortfall that should be added to the table. The net effect would be to revise the 190 dwellings per annum upwards to take into account the shortfall.

2. The new Government has not advised that a clean slate (in terms of housing numbers) begins from July 2010 or that any previous shortfalls should be ignored.

3. The Council is clearly only applying the 190 dwelling per annum requirement to the period 2011 onwards which leaves a shortfall for 2008 to 2010. It suggests that local authorities identify their own targets but it does not say that shortfalls should not be catered for or that targets should begin from 2010.

4. In any event, it should be part of the strategy of the Plan that any shortfalls that exist should be made up early in the development plan period rather than left to accumulate until latter years. In this way the needs of the District can be met in a timely manner which does not harm affordable housing provision. This approach accords with PPS3.

39,40 Table - Whilst there are no objections in principle to replacing the table with one which reflects the revised strategy, it is important to note in the supporting text that the table reflects a particular point in time and that the requirement will vary according to the results of the annual monitoring report, for example, some extant planning permissions may never be developed for various reasons and fall away or the sites identified in the SHLAA may not come forward for deliverability reasons. Indeed any revisions coming out of the previous objections made to the inclusion of shortfalls for the period 2006 to 2010 will also affect this table. These circumstance could change the amount required on green field sites.

Policy H1 and Appendix CSSC1 - Barratt Eastern Counties support the efficient use of land for housing. Although guidance is given that previously developed land will be prioritised, the guidance should also explain that where insufficient previously developed sites exist the Council will actively seek to bring forward green field sites to maintain the housing land supply. It should be noted that green field releases may be required even if previously developed sites exists and have planning permission but have not been delivered. The tests in PPS3 relating to deliverability remain relevant.

Policy H2 and Appendix CSSC2 - Barratt Eastern Counties support the revisions to Policy H2 and the table at CSSC2 in so far as it sets out a revised phasing strategy for new housing at South Hawkwell. Barratt's previous comments on the west of Rochford general location are not repeated here but will no doubt be considered by the Examination Inspector in due course and if accepted the proportions set out in the table may vary. It may also be the case that if Barratt's comments in relation to the inclusion of previous shortfalls are taken on board then these proportions will vary in any event.