Introduction

The Council states that to be Sound the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

Essex County Council, Alastair Southgate, Transportation Strategy Manager, stated in an email to me on 21 December 2012 "On a local level every strategic development proposal is accompanied by a transport assessment, the scope of which must be agreed with the Highway Authority. This assessment considers the impact the proposed development will have on the highway network and includes industry standard forecasted growth (TEMPRO) to ensure a comprehensive approach that accounts for present traffic conditions (including any new and committed development) and future traffic growth."

It is concluded by me that the Allocations DPD is not legally compliant and not sound as the Highways Authority has evidently not looked strategically at the cumulative effect of traffic impacts on the Rochford Core Strategy through the Local Transport Plan because the information quoted by Mr. Southgate has not been published in the Evidence Base.

The Evidence Base for the Allocations of Sites DPD comes from the Core Strategy and that renders the Allocation of Sites DPD Unsound because it, and the strategic development proposed in the Allocations of Sites DPD, is not supported by sustainable evidence from a cumulative traffic assessment for the District.

The Planning Inspector is asked to reject the Allocations DPD and return this to Council with the requirement to await the formal and reported assessment of the strategic cumulative effects of all developments contemplated by the Core Strategy on Highways infrastructure in Rochford District by ECC in accordance with the LTP 2011.

By the same argument the HAAP is a proposal for strategic development which again according to ECC this must be accompanied by a transport assessment, the scope of which must be agreed with the Highway Authority. This assessment considers the impact the proposed development will have on the highway network and includes industry standard forecasted growth (TEMPRO) to ensure a comprehensive approach that accounts for present traffic conditions (including any new and committed development) and future traffic growth.

For the same reasons the Planning Inspector is asked to reject the HAAP and return this to Council with the requirement to await the formal and reported assessment of the strategic effect of such proposed strategic development on Highways infrastructure in Rochford District by ECC.

Furrther Evidence

According to ECC, Mr. Southgate, "the current Essex Local Transport Plan (LTP) was developed in line with Department for Transport Guidance on LTPs. This LTP represents a significant change from previous LTPs. It is not a 5 year plan that sets out a specific programme, instead it is a long term document that provides the framework within which transport programmes can be developed."

Further according to ECC, Mr. Southgate, The Rochford District Council response to the LTP Consultation was as follows;

"Rochford District Council are generally supportive of the approach taken in the Local Transport Plan, particularly of the five outcomes that the plan must deliver. RDC are also supportive of the approach taken in outlining both Rayleigh and Rochford as areas that currently suffer from peak period congestion and pockets of poor air quality. It should be noted that the location of London Southend Airport is in Rochford District, and the expansion of this airport is likely to have impacts on the highway network."

It is evident, therefore, that RDC is concerned about highways congestion and must evidence by future traffic assessment that the strategic development proposals in the Rochford Core Strategy can be delivered with or without fully funded strategic highway infrastructure improvements. ECC has a similar obligation according to Mr. Southgate.

According to RDC (Minutes of Council 27/11/12);

"Responding to a supplementary Member question relating to the cumulative effect of all the proposed development on the local highways, officers advised that the Highways Authority was looking strategically at the cumulative effect of traffic impacts through the Local Transport Plan; in addition, the emerging community infrastructure levy should facilitate strategic highways improvements."

ECC as Highways Authority has been asked by me to "advise in detail what ECC is currently looking at strategically with regard to the cumulative effect of traffic impacts of the Rochford District Core Strategy through the Local Transport Plan. When and how will ECC consult with the community and when and how will ECC report on findings with a funded strategic action plan for highway improvement. Please confirm that ECC is looking at the effects of all developments contemplated by the Core Strategy."

ECC has declined to directly answer these questions.

But

Essex County Council, Alastair Southgate, Transportation Strategy Manager, agrees in an email to me on 21 December 2012 "On a local level every strategic development proposal is accompanied by a transport assessment, the scope of which must be agreed with the Highway Authority. This assessment considers the impact the proposed development will have on the highway network and includes industry standard forecasted growth (TEMPRO) to ensure a comprehensive approach that accounts for present traffic conditions (including any new and committed development) and future traffic growth."

It is concluded by me that the Allocations Submission Document is not sound as the Highways Authority is evidently not currently looking strategically at the cumulative effect of traffic impacts on the Rochford Core Strategy through the Local Transport Plan as stated by Officers at Council on 27 November 2012.

This is of particular concern because in excess of 1000 (926 in one central part of the District) new dwellings have been approved in planning applications since 13 December 2011 (date of adoption of the Core Strategy by RDC) and still no strategic cumulative assessment has been undertaken.

The Planning Inspector is asked to examine this failure.

The Planning Inspector is asked to reject the Allocations DPD and return this to Council with the requirement to await the formal and reported assessment of the strategic cumulative effects of all developments contemplated by the Core Strategy on Highways infrastructure in Rochford District by ECC in accordance with the LTP 2011.

Since the outset when the council start produced its first documents of the LDF and even as recent as the acceptance of the Core Strategy and the original Site Allocations Document there has been significant changes to things that have an impact on matters concerning the LDF and especially the Site Allocations Document etc:- The Global economic recession has had a negative impact on the U.K.'s economy where availability of funds for mortgages and business loans are extremely hard to come by. Not only this but as the government works to reduce it's deficit it does so by cutting funding and expenditure to projects like highways, emergency services staffing etc.,
The global recession especially in Europe has a negative impact on new business's starting up or existing business's expanding, therefore the chances of take up of business land that is actually developed is lesser and so impacts the council's ability to provide employment opportunities in the district.
The weather has become more dramatic with more situations of flooding, droughts etc., this has made Insurance companies make recommendations to both government and house builders on what they consider to be necessary steps to mitigate risks to allow them to keep house premiums to an acceptable level. Some Insurance companies will no longer quote for house insurance where properties are near rivers or have records of subsidence near by. on Global Economy, U.K. Economy, Local Economy, Weather conditions, Government policies, Insurance risk evaluation of properties built near rivers.

These are but a few of things that would impact the sustainability of the development in the area, yet none of the documentation supporting the Core Strategy/ Site Allocations document (Evidence Base) show any signs of being reviewed, altered etc., There is not one document dated 2012 or 2013. Therefore I feel the document is unsound as decisions on the sites have not taken into account any of the recent changes, especially as the call for sites is over 5 years old and new and more suitable sites may now be available as farmers and land owners look for ways to raise to capital.

The document focuses on individual sites but does not have a section that details impact on district as a of all developments. It also does not show or take into consideration impact of neighboring district's plans especially Southend. Therefore as there is no proof of the sustainability of the total developments meeting the council's and government's objectives this document can only be considered unsound.

Basildon Borough Council welcomes Rochford District Council's proactive steps in making land available for future Gypsy and Traveller needs and employment development in line with its adopted Core Strategy.

The Core Strategy describes how '' Rochford District Council will work in partnership with Essex County Council to design and implement a Transportation Strategy Supplementary Planning Document for Rochford District. The Strategy will assess the transport issues in the District and set out how they will be improved and dealt with''.
This SPD has not been prepared and consulted upon. Its production and successful implementation is vital in ensuring that the developments in the Allocations Submission Document can be achieved in a sustainable manner and not add to the stress in a District that continues to suffer from inadequate highways infrastructure.

Whilst our particular interest is in the residential allocation for South Canewdon, there are a number of areas where we consider that RDC's own policies have been unlawfully disegarded resulting in the ASD failing the appropriate tests of soundness. We urge the Council to delay the submission of this document and reconsider the contents of the ASD in light of our comments.

Despite the ASD making it clear that the Core Strategy must be adhered to and that the ASD is part of a suite of policy documents (the Development Plan) that are used in part to implement the objectives of the Core Strategy this is simply not the case as currently proposed. As stated in paragraphs 1.22 and 1.26 which state respectively that:
"...the Allocations Document will have to conform to the Core Strategy."

and

"The Core Strategy, as the main planning policy document of the District's Local Development Framework, has a key role to play in delivering all of the above. The Allocations Document will address the Sustainable Community Strategy priorities primarily through aiding the delivery of the Core Strategy."

Para 1.28 continues by stating that:

"National planning policy in the form of the National Planning Policy Framework or NPPF, has also shaped the production of the Allocations Document."

This cannot however be the case when the ASD is set to fail the moment it is implemented.

The ASD fails this crucial conformity test by the proposals within the document being contrary to key objectives of the Core strategy to ensure the appropriate delivery of housing within the district. The sites chosen, the high infrastructure costs and the unrealistic programme described is not achievable, thus the ASD fails on this point alone. RDC has requested that where amendments are sought, the proposed changes are provided. In this instance, this is not possible as we are seeking that the Council revert back to the NPPF and amend multiple sections of the ASD in order to ensure that it adheres to the NPPF and the Core Strategy by being realistic about the delivery of the residential allocations it is proposing.

The proposed allocations and in particular South Canewdon does NOT adhere to the Core Strategy Key Diagram. The location of the proposed allocation sits directly to the WEST of Canewdon. It therefore does not comply with the Core Strategy as it must, in order to be found as being sound by the Inspector. We therefore urge the Council to reconsider this particular allocation. Sites to the east of Canewdon, that are no more south than the proposed allocation were dismissed in part for not being "south of Canewdon". There is clear inconsistencies in the decision making by RDC.

We provide further details under the specific policy of our concerns regarding the Canewdon allocation and how this in many ways is contrary to the Core Strategy and NPPF, resulting in the ASD being viewed as unsound.


Consultation

Mr Stacey is an active member of the Canewdon community and it is evident that very few people knew of the current consultation. There has been very little advertising by Rochford District Council and although extended to 8 weeks, there has been much less active consultation, if any, unlike the "Discussion and Consultation Document Feb 2010" which included a presentation/meeting with each of the villages.

These meetings previously undertaken by Officers of RDC during early 2010 allowed the local community to voice their opinion, however it is not evident from researching the evidence used by RDC that these meetings and their outcomes have indeed been taken into account. No record appears to exist of the items discussed, the principal point being the desire of the local community to protect the setting of the village church. It is our understanding that at this meeting the local community voted in favour of the then option SC1 to the south of Anchor Lane and specifically voted AGAINST development in the location that is now being proposed.

A direct response from RDC on this particular point is essential to ensure that they have taken on board the views of the local community. Until RDC can demonstrate that the appropriate level of consultation has taken place and that the views of the local community has been taken into account, the submission of the ASD must be delayed.

We do not agree that it was appropriate for the Council to consult on the "options" available for the allocations and then not consult the community further until the current "submissions" stage. It is requested that information is provided as to the consultation that took place in respect of the Council's "preferred options" and the response from the community, as we do not believe that the appropriate level of consultation has taken place.

Allocations Submission Document

On behalf of Rawreth Parish Council I confirm that this letter is a formal response and representation of the Councils views with regards to the Allocations submission Document.
This Council believes the LDF Core Strategy, Allocations Submission Document is unsound on two counts. The two counts are detailed below, together with supporting facts and examples. In addition there appears to be no acknowledgement of previous consultations and publication of responses was delayed 12 months after publication of preferred Site Allocations, Policy GB1.

Count 1. Preference and proposed use of Green Belt land over land previously used or brown field sites: Policy ED4 Core Strategy Preferred Options Future Employment Options. GB1 Core Strategy Preferred Options. ENV3 Core Strategy Preferred Options Flood Risk. PPS25 Development & Flood Risk)
Within the Development Management DPD - Preferred Options Document 3.1 clearly states under PPG2, the most important aspect of the Green Belt is its openness. In addition, PPG2 also states within the five purposes of not including land within the Green Belt :

To check the unrestricted sprawl of large built-up areas
To prevent neighbouring towns from merging into one another
To assist in safeguarding the countryside from encroachment
Our first example of unsoundness is the proposed Housing at " Land North of London Road, West of Rayleigh (Rawreth)" vs land previously put forward in the "Call for Sites" at: Hambro Nurseries Rawreth, Former nursery land at Weir Farm, Rayleigh and the Site of Garden Centre and former nurseries in Eastwood Road.

Our second example is the proposed housing in " Hullbridge, Malyons Farm (Rawreth)" vs the at land at NSEC Lower Road Hockley" which was also put forward in the "Call for Sites". All the Sites given in our examples were put forward in the "Call for Sites" and all this land is previously used or brown field land which would provide hundreds of sustainable houses with good access to present infrastructure all falling within PPG2. However they have all been rejected by Rochford District Council as not acceptable.

Our third example is the relocation of Rawreth Industrial Site to a Greenbelt site on the A129 next to Swallows Aquatic Centre vs brown field land at Michelins Farm, adjacent to the A127, put forward in the "Call forSites".

Our fourth example is the erosion of Green Belt and the coalescence of two conurbations, Wickford/Shotgate and Rayleigh, entirely contrary to Green Belt Policy GB1 and H1. If smaller, more appropriate brownfield sites were used, as put forward in the "Call for Sites", this erosion and coalescence would not take place.

This Council believes this document to be UNSOUND as due consideration has not been given to more appropriate sites that clearly fall within PPG2.

Count 2. This Council believes there is an absence of an overall effective Transport Risk Assessment and Traffic Impact Statement which would clearly show the effects of present and future housing on traffic flow on the existing inadequate road network. (Policy T1 & T2)

At the Public Examination in 2010,conducted by the Government Planning Inspector, both this Council and the public were assured that adequate infrastructure would be looked at when the Essex County Council Local Transport Plan was reviewed in 2011. In 2012 ECC explained that " the current Essex Local Transport Plan was developed in line with Department for Transport Guidance and which provides the framework within which transport programmes can be developed."

In the Development Management DPD, Preferred Policy Options Document Rochford District Council's Vision states " The Highway Authority will look at solutions to congestion issues across the District to ensure the highway infrastructure becomes "fit for purpose". Without the risk assessments, congestion issues have not been addressed and the necessary documentation therefore, is not in the Evidence Base which makes the document unsound.


In Minutes of Rochford District Council 27/11/2012 officers advised that "the Highways Authority was looking strategically at the cumulative effect of traffic impact through the Local Transport Plan" and, in addition, " the emerging community infrastructure levy should facilitate strategic highways improvements" yet, there is still no Traffic Impact Assessment of the District within the Evidence Base. DM28
As a Council we know from day to day that the overall highways infrastructure within the District cannot cope with present traffic flow and, therefore, believe that without major infrastructure improvements the situation will become intolerable.
RDC stated in its Public Consultation that to be "SOUND" the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements consistent with sustainable development.

ECC stated in December 2012 "every strategic development proposal is accompanied by a transport assessment agreed with the Highway Authority which will consider the impact of proposed development on the highway network to ensure a comprehensive approach accounting for present traffic conditions and future traffic growth".

Right from the beginning of the Local Development Framework, all the documents within and including the Rochford Core Strategy state clearly "in order for development to be sustainable it must meet the needs of the present and future in terms of highways and traffic impact" and quotes "Improvements must be made to East/West routes"."RDC must ensure there are adequate highway infrastructure improvements to serve new developments and to mitigate their impact".

We believe that this Allocations Submission Document is not "SOUND" on the two Counts as detailed.

One, that the Highway Authority has not objectively assessed the developments and infrastructure requirements taking account of present traffic and future traffic growth. Evidence Base is essential for the "SOUNDNESS" of this document and a Traffic Impact Statement has not been provided within this Base.

Two, the preference and proposed use of Green Belt land over land previously used or brown field sites is contrary to GB1 and, therefore, renders the document UNSOUND.

Support the fact that the Green Belt boundary should be revised as part of the allocations contained within this document.

Support the Allocation [SER8] proposed for South East Ashingdon.

Our client, Fairview New Homes has an interest in the land at Poyntens Road, Rayleigh (a site plan is attached to this submission for reference), and has been actively involved, via the submission of relevant representations to numerous Development Plan Documents and associated consultations associated with the Local Development Framework (Core Strategy, Aloocations DPD Discussion and Consultation Document, Strategic Housing Land Availability Assessment (SHLAA)). The comments made with regard to this consultation are in line with representations submitted previoulsy during these other public consultation opportunities.

The site represents a suitable site for new residential development to be delivered in the forthcoming plan period, therefore contributing towards the Council's housing supply. On this basis, we have continually promoted this site for residential development on behalf of our client, and consider that the failure to include this site with this document makes the document unsound, due to the fact that it is unjustified by not being based on a robust and credible evidence base.

As outlined in our representations submitted to date, it is considered that the Council has failed to consider a suitable site for residential development, and importantly, has not provided a robust response as to why the site has been discounted from the Allocations DPD and also the SHLAA 2012 Review. The Council's Evidence Base, which has fed into the production of the Allocations DPD should be a factual document, and should not therefore discount appropriate sites for development. That said, the SHLAA should also include sites which are not suitable for development, to illustrate that all sites have been assessed approriately, therefore providing for a robust and credible evidence base. The LPA should demonstrate evidence of participation of the local community and others having an interest in the community, and show that the choices made within the document are backed up by facts. The ommitance of the Poyntens site by the Council is therefore contrary to guidance.

Since the adoption of the Core Strategy in December 2011, the National Planning Policy Framework (NPPF) has been published (March 2012), which must be taken into consideration with regard to ensuring the Allocations DPD is consistent with national policy. Paragraph 47 of the NPPF states that that LPAs should use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the market area. It also states that LPA's should identify and update annually a supply of specific deliverable sites sufficient to provide 5 years worth of housing against their housing requirements with an additional buffer of 5%, or where there has been a record of persistent under delivery of housing, a buffer of 20%.

Having reviewed the AMR 2011 and the Core Strategy, it is clear that the Council has continually failed to meet the housing target set by the RSS, and carried forward in the Core Strategy, of 250 dwellings per year. As stated in the Core Strategy, the Council fell short of the target between 2007 and 2011 by a substantial amount, therefore it is considered that the Council must allocate sufficient and suitable sites in order to overcome this clear deficit. Due to the current economic climate, and the proposed allocated sites for residential development within this DPD, it is considered that the Council should allow for changing circumstances and allow for flexibility with regard to the delivery of housing, on the basis that some housing sites may not come forward as expected. It is considered that in order to allow for flexibility, and for the DPD to be considered sound, additional and suitable sites, such as the Poyntens site, should be included.

Due to the revocation of the East of England Plan in January 2013, this also enhances the need for the LDF to be consistent with the NPPF.

Our client is fully aware that the site falls within the Green Belt, and this fact is not contested, albeit it is clear from the Allocations DPD that the release of Green Belt land is required in order to meet housing delivery targets. On this basis, there is no sound reason why our client's site has been discounted above other Green Belt sites. In actual fact, a number of sites, retained by the Allocations DPD are less suitable Green Belt sites, for example, Policy SER1 - North of London Road, Rayleigh is a site which is in agricultural use and located within Flood Zones 2 and 3, Policy SER4 - South Hawkwell comprises open land used for grazing, paddocks and a tree nursery and is located in Flood Zones 2 and 3 and Policy SER9 - West Great Wakering are also agricultural sites and located adjacent to a local wildlife site. The Poyntens site is a wooded area bound by agricultural fields to the south and residential dwellings to the north. The site also has access roads in place, is located in Flood Risk Zone 1 (low probability of flooding) and has good access to services and leisure facilities in Rayleigh. On this basis, it is considered, and has actively been promoted by our client as a site suitable for residential use.

With regard to Green Belt, the NPPF notes its 5 purposes:
- to check the unrestricted sprawl of large built-up areas;
- to prevent neighbouring towns merging into one another;
- to assist in safeguarding the countryside from encroachment;
- to preserve the setting and special character of historic towns; and
- to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

It is considered that the release of the Poyntens site from the Green Belt is therefore no more inappropriate than the other sites, outlined above. We therefore question why the Council have considered appropriate Green Belt sites at the early stages of the Call for Sites, but have since discounted them (Poyntens).

In addition to our comments made above, we request that our representations made previously, to all aspects of the LDF, be placed in front of the Inspector for information, and to support our comments made. Should additional copies of the representations be required, we would be happy to provide them.

ESSEX COUNTY COUNCIL
RESPONSE TO ROCHFORD DISTRICT COUNCIL ALLOCATIONS SUBMISSION DOCUMENT (NOVEMBER 2012)

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific allocations for development at the general locations identified within the Core Strategy will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of allocations not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District.

The County Council generally supports the proposed content of the document whilst suggesting some amendments to the text to assist clarity on future requirements and to provide contextual information that should assist delivery and implementation.

This response is structured as,
* Specific Highway and Transport comment on Policy NEL2 and Policy GT1
* Comments on topics and themes
* Site specific comments
* Annex on Historic environment considerations on individual sites

1. Specific Highway and Transport comment on Policy NEL2 and Policy GT1

a) Policy NEL2: West of the A1245, Rayleigh
The content of paragraph 5.35 and subsequent paragraphs 5.36 to 5.39 relating to highways and transport requirements and considerations for development of this site is noted. Access to the proposed allocation at this location would be contrary to a number of current Highways Development Management Policies. Given the location of the site at a key strategic junction lack of design compliant access points would contribute to an increase in congestion and safety concerns. The County Council is unaware of any studies or evidence to indicate that access/egress on and off the site can be secured in a design compliant manner. In these circumstances the highway authority is unable to support allocation of the site for the proposed employment uses.

b) Policy GT1: Gypsy and Traveller Accommodation
The site access/egress to the proposed allocation would contribute to congestion and safety concerns at this strategic junction and be contrary to a number of current Highways Development Management Policies. Nevertheless, it may be possible to cater for the traffic movements arising from not more than 15 gypsy and traveller pitches in a manner that has minimum impact on existing levels of traffic movement and safety. Accordingly, the local highway authority would wish to further discuss with the district council the potential traffic implications of this proposed allocation.

2. Comments on topics and themes

a) Flood Risk and Water Management
* Essex County Council, as a Lead Local Flood Authority, now has a strategic role to oversee the management of local flood risk. This covers the risk of flooding from surface water runoff, groundwater and ordinary watercourses that occurs as a result of heavy rainfall. The County Council has produced a number of inter-related Flood and Water Management documents which seek to improve understanding of surface water flood risk with the ultimate aim of reducing that risk wherever possible. The following documents should be added to the Evidence Base listed in paragraph 1.29,
o Preliminary Flood Risk Assessment (PFRA) - is a requirement under the Flood Risk Regulations (2009). The PFRA is a high level, county-wide analysis which considers past flooding and possible future flooding from,
 Essex Flood Risk Management Strategy - to be published Feb/March 2013 meets responsibilities under the Flood and Water Management Act (2010). This strategy looks at ways to tackle local flood risk in a co-ordinated way. It will identify some strategic actions needing to occur over the next two years and the underlying principles upon which to base future decisions.
 Surface Water Management Plans (SWMP) - these are plans which outline the preferred surface water management strategy for a given location. A SWMP will establish a long-term action plan to manage surface water in an area and should influence future capital investment, drainage maintenance, public engagement and understanding, land-use planning, emergency planning and future developments.

* On Page 11, fifth bullet, 'Surface Water Management Plan 2011' should read 'South Essex Surface Water Management Plan 2012'.

* The County Council welcomes the promotion of Sustainable Drainage Systems (SuDS) within the Concept Statements for each site allocation. However, the existing text should be amended to include reference to,
o the involvement of the Environment Agency - Essex County Council is not expected to become the SuDS Approving Body until at least April 2014 and therefore cannot officially comment/determine SuDS proposals until then.
o The need for a site specific flood risk assessment - any site drainage strategy for a site will be informed by and need to address issues arising from a specific flood risk assessment.
o The inclusion of source control as part of the SuDS proposals - source control, i.e. the control of runoff or pollution at or near its source, will be needed as well as attenuation measures to ensure an acceptable sustainable drainage system.

The relevant text should be amended to read as follows and included as a paragraph in the Concept Statement of each proposed site allocation,
"Attenuation and source control Sustainable Drainage Systems (SUDS) of a size proportionate to the development should be used such as balancing ponds, swales, detention basins and green roofs. This could be incorporated into the greenspace provided on-site. Appropriate SUDS should be determined in consultation with Essex County Council and the Environment Agency. A site specific flood risk assessment incorporating a surface water drainage strategy should be prepared for the site."

b) Minerals and Waste
* The Minerals and Waste Local Plans produced by Essex County Council are part of the Development Plan for Rochford District and regard must be had to relevant policies in those documents in determination of the future development of the District. The section of the document entitled 'Relationship with other LDF Documents' should be amended to include appropriate and relevant reference to the status of the Minerals and Waste Local Plans.

* The National Planning Policy Framework requires Minerals Planning Authorities to define Mineral Safeguarding Areas within their Local Plans so that known locations of specific minerals are not needlessly sterilised by other forms of development, whilst not creating a presumption that the defined resources will ever be worked. The County Council has done this through Policy S8 (Safeguarding mineral resources and mineral reserves) in the Replacement Minerals Plan Pre-Submission Draft January 2013. It is necessary to safeguard existing mineral workings and Preferred Sites to prevent the possibility of new incompatible neighbours being established and ultimately restricting extraction activities. Mineral Consultation Areas (MCAs) apply to the safeguarded site itself and extend for a distance of 250 metres outwards from the site boundary of each of these safeguarded sites. The following proposed allocation sites fall within a Mineral Safeguarding Area:
o Policy SER2 West Rochford
o Policy SER5 East Ashingdon
o Policy SER8 South East Ashingdon
o Policy SER9 West Great Wakering
o Policy NEL3 South of Great Wakering
o Policy NEL4 North of London Southend Airport
o Policy EDU3 King Edmund School

To ensure compatibility and consistency between the Allocations Document and the Minerals Local Plan the following text should be added to the Concept Statement for each of the seven (7) sites listed above,
'The site is within a Minerals Safeguarding Area and therefore consultation on the proposed development of the site with Essex County Council is required'

* It should be noted that the Replacement Minerals Plan Pre-Submission Draft safeguards the following two sites in Rochford District,
o the Strategic Aggregate Recycling Site (SARS) at Purdey's Industrial Estate is safeguarded under Policy S5 'Creating a network of aggregate recycling facilities';
o the coated stone plant at Suttons Wharf is considered to be of 'strategic importance' in policy terms and is safeguarded under Policy S9 'Safeguarding mineral transhipment sites and secondary processing facilities'.

c) Historic Environment
Essex County Council is pleased at the identification of the Historic Environment within the Document and the specific mention of the Historic Environment Characterisation Report for the District. An annex to this response sets out additional detailed information on a site-specific basis that could usefully be added to the Document to ensure awareness of the key historic environment features and requirements associated with development of proposed allocations.

d) Biodiversity
* The Concept Statements for most proposed development sites include reference to green buffers, site boundary treatment, tree/hedge planting or habitat mitigation. For clarity and to make a positive contribution to local ecology the concept statement for each site should use, or adapt, as appropriate the statement in paragraph 5.58 which states: "landscaped green buffers should be provided in the form of publicly accessible green space, with conditions attached to ensure that it has ecological value".

* Potential development proposals should be prepared in accordance with the Institute of Ecological and Environmental Management (IEEM) guidelines for Ecological Impact Assessment (EcIA) which require,
o applications for development over 0.1ha to be accompanied by an ecological statement, which should include a Phase 1 habitat survey, a data search for records of designated sites and protected species within 2km of the site, and an assessment of habitat suitability for European Protected Species.
o for major developments (10 or more dwellings, or creation of more than 1000 square meters), a full Ecological Impact Assessment, prepared in accordance with the IEEM guidelines for EcIA, will be required (http://www.ieem.net/ecia-guidelines-terrestrial-freshwater-and-coastal-).

* Policy ELA1 should require completion of the Management Plans that will be drawn up for Local Wildlife Sites and that they be taken into account, as appropriate, during design and construction phases and that their disturbance is avoided. Development sites subject to Policy SER8 (South East Ashingdon), Policy SER9 (West Great Wakering), and Policy NEL3 (South of Great Wakering) should contain a similar specific requirement.

* Several sites show potential to support European Protected Species, namely,
o Policy SER4 - South Hawkwell
o Policy SER6 - South West Hullbridge
o Policy SER9 - West Great Wakering
o Policy NEL1 - South of London Road, Rayleigh

e) Urban Design
* Generally, the vision for each of the allocation should be developed further as .the concept statements provide limited evaluation of the sites and their infrastructure requirements. A solution could be for a master plan or design brief to be required, prior to the submission of a planning application, for all sites of a certain size or sensitivity setting out the vision for future development with design codes for larger sites where development will be phased (as supported by Paragraph 59 of the National Planning Policy Framework). A landscape strategy promoting green links and biodiversity corridors for each site should also be required.

* The document could also be improved with more visual content. Simple diagrams illustrating the principles/objectives referred to in the text would add clarity, particularly where connections are required between different sites or parts of a site that may be developed at different stages or post 2021, for example, between the land allocations for employment South of Great Wakering (NEL3), Star Lane Industrial Estate Great Wakering (BFR1) and land south of the High St (SER9b).

3. Site specific comments

a) Policy BFR1: Star Lane Industrial Estate, Great Wakering
* This is one of the few industrial estates in the District where there are relatively few environmental impediments to the establishment of a future waste treatment facility. Provision of housing on the site will introduce a sensitive use and make the estate potentially incompatible for waste uses. 'Guidance for local planning authorities on implementing planning requirements of the EU Waste Framework Directive (2008/98/EC)' (December 2012) is relevant to this issue. The Guidance expects those local planning authorities which do not deal directly with waste planning applications to contribute to delivery of the waste hierarchy. This includes working constructively with waste planning authorities to identify and protect those sites needed for waste management facilities and considering, where relevant, the likely impact of proposed, non-waste related development on existing waste management sites and on sites and areas allocated for waste management. Planning authorities should ensure that any such proposal does not prejudice the implementation of the waste strategy set out in the local Waste Plan. The County Council, as waste planning authority, would welcome discussion with the District Council to identify an alternative suitable industrial site within the District to accommodate waste treatment facilities that could have been established on this estate.
* In paragraph 2.34 the words 'Transport Impact Assessment' should be amended to read 'Transport Assessment'. Equivalent amendments should be made where a similar reference is made throughout the document.

b) Policy SER1: North of London Road, Rayleigh
* In paragraph 3.17, first bullet, the text should be extended to include the words 'with commensurate early years and childcare provision' to reflect the full requirement for provision of education facilities on the site.
* Figure 7 should be deleted as being a matter more appropriate for inclusion in a masterplan or design brief where possible highway and transport links can be directly related and integrated with green links, biodiversity corridors and relationship to adjacent development. Consequent to the above comment, paragraph 3.27 should be amended to simply note that the means access and scope of transport assessment should be explored with Essex County Council Highways, to include the site being served by public transport and designed to ensure that it is not used as a through route for private traffic.

c) Policy SER2: West Rochford
The precise site boundary of the proposed education facilities on the site has been agreed through a s106 agreement and could be indicated on Figure 8.

d) Policy SER5: East Ashingdon
Paragraph 3.141 should specifically identify the proposed improved access/egress to King Edmund School, which is the subject of a s106 agreement, and show the precise site boundary of the proposed new bus/car park for King Edmund School on Figure 11 (p53).

e) Policy SER6: South West Hullbridge
Paragraph 3.178 should be amended to note that highway improvements would focus on the strategic network, which includes the junction of Hullbridge Road/ Watery Lane. Watery Lane is not part of the strategic network and the reference to improvements should be deleted.

f) Policy SER8: South East Ashingdon
* In paragraph 3.218 the word 'access' should be amended to read 'accesses' because the proposed development is a minimum of 500 dwellings for which a single access is insufficient.
* Paragraph 3.240 should be extended to state that 'All internal layout options should be considered in line with the Essex Design Guide'.
* Paragraph 3.242, second sentence, should be amended to read 'Pedestrian and cycle routes to south of site.....'.

g) Policy SER9: West Great Wakering
Paragraph 3.277 should be amended to read 'Pedestrian and cycle routes to the north...'.

h) Policy EDU1: North of London Road, Rayleigh
The criteria listed in paragraph 7.5 are not exhaustive and omit some of the most key characteristics. Accordingly, the text of the paragraph should be deleted and replaced by cross reference to the full list provided in the Developers' Guide Education Supplement (Appendix D).

i) Policy EDU2: West Rochford
The criteria listed in paragraph 7.9 are not exhaustive and omit some of the most key characteristics. Accordingly, the text of each paragraph should be deleted and replaced by cross reference to the full list provided in the Developers' Guide Education Supplement (Appendix D).

j) Policy EDU3: King Edmund School
For ease of reference Figure 27 (p104) should also show the land south of Bray's Lane that has been secured by King Edmund for a new bus/car park.

k) Policy EDU4: Existing Primary and Secondary Schools
As Local Education Authority, the County Council welcomes acknowledgement in paragraph 7.15 that schools change and expand over time in order to meet local need. However, the proposals in paragraph 7.15 are potentially confusing and unduly restrictive because in most cases school expansion and/or re-modelling will extend beyond the existing built footprint on school sites. Retaining Green Belt status for school playing fields in their entirety would not offer sufficient flexibility to attain the policy intent due to some school expansion proposals necessarily straddling the Green Belt boundary.


ANNEX TO
ESEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS SUBMISSION DOCUMENT (NOVEMBER 2012)

Key Historic Environment Features and Requirements

This annex to the County Council response sets out additional detailed information on a site-specific basis that could usefully be added to the Document to ensure awareness of the key historic environment features and requirements associated with development of proposed sites. Reference to Historic Environment Zones (HECZ) within this Annex is taken from the Historic Characterisation Study for Rochford District.

A. Brownfield Residential land allocations

Policy BFR1 - Star Lane, Industrial Estate, Great Wakering.
The southern section is currently a disused brickworks. Although the site has now been cleared of all upstanding structures, without a historic building record being undertaken, the site still retains considerable archaeological potential for the study of the countys' industrial archaeology and in particular the development of brick making within the region (EHER 15369). Records depict this development from the use of brick clamps in the early post war period to oil fired down draught kilns by the 1970s and gas fired kilns by the 1990s. Whilst brickworks are not necessarily considered significant in purely architectural or aesthetic terms they represent an increasingly rare site and structure type which have been identified in the regional research agendas as being of particular interest. Any redevelopment should be preceded by archaeological desk-based research and investigation of surviving underground deposits.

Policy BFR3 - Stambridge Mills, Rochford
Stambridge Mill survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. A building record of all surviving structures has been completed with no further archaeological conditions required.

Policy BFR4 - Rawreth Industrial Estate
A number of brick-built World War II accommodation huts survive at the southern end of the industrial estate. These were associated with the heavy anti-aircraft gunsite TN4 'Rayleigh' (EHER 20133) sited here during World War II and are a rare survival. Where possible these buildings should be retained within any development. However if this proves impossible to achieve they will require a historic building survey to record the complex prior to any demolition.

B. Settlement Extension Residential Allocations

Policy SER1 - North of London Road Rayleigh
A pre-determination assessment (by fieldwalking and geophysical survey) of the archaeology on-site is currently ongoing. Any future large scale housing development would require an agreed programme of work, depending on the present evaluation and any future trial trenching to ensure that the historic environment assets are either protected in situ or preserved by excavation.

Policy SER2 - West Rochford
A pre-determination assessment (by trenching) of the archaeology on-site has been completed. The results are expected shortly and will be used to ensure that there is appropriate management and/or a mitigation strategy agreed to protect the historic environment assets that will be impacted.

Policy SER3 - West Hockley
For those parts of the site not previously developed, a programme of archaeological evaluation should be undertaken to ensure that the Historic Environment is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

Policy SER4 - South Hawkwell
The proposed development south of Hawkwell lies within Historic Environment Characterisation Zone 26 (HECZ 26: Land between Hockley and Ashingdon). This area of predominantly rural landscape, sloping down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material, and its potential for archaeological sites despite little formal investigation having been carried out. Any future housing development would require a programme of archaeological evaluation to ensure that the historic environment is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

Policy SER6 - South West Hullbridge
The Historic Environment Character Zone (HECZ 36) for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed development area while a medieval moated site is located close by. A programme of archaeological evaluation would be required to ensure that the historic environment is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

Policy SER7 - South Canewdon
The Historic Environment Character Zone (HECZ 12) shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. By comparison with similar settlements it is reasonable to assume that archaeological remains survive within, and in the proximity of, the historic settlement, particularly those historic assets associated with the coast and historic core. A programme of archaeological evaluation would be required to ensure that the historic environment is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

Policy SER8 - South East Ashingdon
The site lies within Historic Environment Character Zone (HECZ 13) characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. A programme of archaeological evaluation would be required to ensure that the historic environment is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

Policy SER9 - West Great Wakering
Options for West Great Wakering lie within Historic Environment Character Zone (HECZ 7) an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. For those areas not quarried there would be a requirement for a programme of archaeological evaluation to ensure that the historic environment is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

Policy NEL1 - South of London Road
The Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HECZ 34). Any future development would require a programme of archaeological evaluation to ensure that the historic environment potential of the area is taken into account at an early stage.

Policy NEL2 - West of the A1245
The Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HECZ 34). Any future development would require a programme of archaeological evaluation to ensure that the historic environment potential of the area is taken into account at an early stage.

Policy NEL3 - South of Great Wakering
Although the proposed development area has been subject to some quarrying, there is still potential that some archaeological features remain in situ. The Essex Historic Environment Record (EHER) lists a number of archaeological sites in the vicinity: cropmarks of a linear feature and a rectangular enclosure (EHER 11157) and find spots including a Bronze Age vessel (EHER 11085). A programme of archaeological evaluation would be required to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

POLICY NEL4 - North of London Southend Airport
This area has a large amount of historic environment assets recorded on the EHER. Excavations to the east of Cherry Orchard Farmhouse identified the remains of a medieval or post medieval kiln (EHER 9744) during salvage excavations on the birckearth quarry. This kiln is clearly a precursor of the later Cherry Orchard Brickworks which continued production in to the early 21st century. The brickworks has now been demolished although there is potential for surviving deposits relating to the industry surviving beneath the ground. Cherry Orchard Farmhouse is a listed 17th century timber framed farmhouse which is nationally designated as a grade II listed building. Archaeological evaluation at Westbarrow Hall Farm (EHER17441) has recorded extensive multi-period archaeological deposits over a wide area. A number of military monuments relating to the defence of Southend Airport during World War II survive (including two examples of rare cantilever pillboxes). Detailed discussion will be required to produce a development proposal which protects the most significant deposits and provides for a mitigation strategy including excavation for any remains that cannot be preserved.