Policy BFR4 - Rawreth Industrial Estate, Rayleigh

We support the concept statement acknowledging:
- A contaminated land study will be required due to the previous uses of the site;
- SuDS need to be provided and a drainage strategy submitted;
- That upgrades to the foul water infrastructure network may be required. This issue is acknowledged in your Water Cycle Study so the reference in your allocations DPD is welcomed.

We are also pleased that you have suggested the greenspace could be located in the area of the site at risk of flooding. We strongly support this which would address the sequential approach advocated by the NPPF. A Flood Risk Assessment should support any future planning application to ensure all areas of Flood Zone are correctly identified. You may consider it useful to add this requirement to the policy as a minor amendment.

It would be beneficial if the policy could recognise the relationship of the site to the employment area nearby. There are several permitted waste sites on Rawreth Industrial Estate which could have issues associated with them which would cause nuisance to residents, for example noise, dust, odour and pests.

2.109 I support the view on the use of Sustainable Urban Drainage and requirement for consultation with the County Council. I also endorse the requirement for a foul and surface water drainage strategy for the site that should be agreed with Rochford before commencement of develpment.
2.110 Anglian Water offer a pre planning services and developers are encouraged to contact us at the earliest opportunity to ensure infrastructure requirements can be considered and implemented. Details can be found:

http://www.anglianwater.co.uk/developers/planning/

Policy BFR4 (and supporting text) - Rawreth Industrial Estate
Introduction
In these representations, we raise a number of concerns regarding the delivery of the proposed allocation at Rawreth Industrial Estate, and the manner in which the proposed allocation is presented in the document.
By way of background, Countryside Properties objected to the proposed site allocation at the Core Strategy stage, on the basis that this existing industrial estate, which is in multiple ownership and with an even greater multitude of tenants, is highly unlikely to be delivered in the plan period, and there is no party other than the Council promoting the land for redevelopment.
The Site Allocations document provides no more information or detail on the matter of the practical delivery of the land, or the timetable within which that could be achieved, and therefore provides no new information that would suggest that the land is in fact either capable or feasible of comprehensive redevelopment.
The fact that this allocation is consistent with the Core Strategy does not of itself make the allocation deliverable, and we would suggest that its inclusion within the Site Allocations still needs to be justified on the basis of positive evidence that the site can in fact be developed as suggested.
Representations
Deliverability
Following on from the above, our first representation in respect of this matter is that Policy BFR4 is unsound since there is no evidence to suggest that the policy proposals are deliverable, and hence the policy is neither Justified nor Effective.
Paragraphs 2.82, 2.88, 2.94, 2.106, and 2.113 of the DPD all provide evidence as to why this site is unlikely to be delivered i.e. because it has a range of existing commercial uses; is likely to require remediation as a result of previous contamination; cannot be delivered until existing uses have been relocated, and development will require significant contributions to community, social, and highway infrastructure. Conversely, the supporting text to the Policy provides no evidence on the viability or feasibility of the site coming forward in the light of these constraints.
Missing from the draft text, but of equal if not greater significance, is the fact that the site is in multiple ownership, is not being promoted for development by the landowners, and in practice the site could only come forward on a comprehensive basis with all landowners involved. All of these factors support our contention that the Policy is Unsound.
Para 2.82 (Site Characteristics)
Following the above, we object specifically to the wording at paragraph 2.82, on the basis that to be Effective, the supporting text to the policy should explain that any redevelopment of the site will need to be on a comprehensive basis, in order to protect the amenity of new residents, and to ensure effective remediation and an appropriate form of development. Paragraph 2.82 should be amended as follows:

"There are a range of industrial buildings, structures and hardstanding on site. Decontamination of the site may be required prior to development. The site is in multiple ownership, and any redevelopment will need to be undertaken on a comprehensive basis in order to protect the amenity of new residential occupiers, to achieve an appropriate form of development having regard to the nature of the existing industrial users and their potential for disturbance, and to ensure effective remediation."

Para 2.85 - Density

The suggested density of up to 60 dph is excessive for this location. Whilst recognising that the site falls within the existing urban area, it is not within a town centre location, and the suggested density is excessive given the character of the area. The adjoining development at Stirling Close/Victoria Avenue immediately to the east is of a similar size (5.6 ha) and has 122 homes at a density of just under 22 dph. Even the more densely developed estate of Grosvenor Road/Brunswick Place has just 109 properties on around 2.9 hectares, giving a density of 37.5 dph.
In the context of the surrounding area, it is difficult to see that the suggested density of up to 60 dwellings per hectare is either feasible (since it would have to rely on a high degree of flatted properties, which the market would not want to deliver in a location such as this), or indeed appropriate. The suggested density is neither Justified nor, given the lack of market interest in developing at this density, Effective.
We would suggest that a density range of 30-35 dph (net) is the most that could be achieve on this site, particularly given the constraints identified elsewhere in the Concept Statement in terms of retaining TPO's and providing on-site open space.
Paras 2.86, 2.87, 2.91 and 2.105 - Scale of development
The text in these paragraphs is confusing as to the scale of development that could be provided on the site. On the one hand it refers to an expectation of 222 dwellings as per the SHLAA (paras 2.87 and 2.91), and on the other hand the calculation of the quantum of open space is based on 89 dwellings (para 2.105), and the assessment at 2.86 would suggest that a yield of up to 140 is more likely based on a realistic density.
The lack of certainty over what the site can deliver stems in part from the fact that there is no party actively promoting or able to deliver the redevelopment of the site. Even so, it would be evident that at the higher development yield suggested, the open space contribution of the site would need to increase above and beyond that set at in the Concept Statement, which raises questions as to whether or not the higher yield suggested in the SHLAA is actually achievable. Even at the lower range of up to 140, the open space quoted for at para 2.105 would be insufficient.
Realistically, having netted off the open space and applied an appropriate density of around 30 dph, the yield from this site would be more likely to be in the region of the 140 units suggested at paragraph 2.86, leaving a 60-70 unit shortfall in the delivery of homes from Rayleigh (even if the site is developed at all).

Policy BFR4 (and supporting text) - Rawreth Industrial Estate
Introduction
In these representations, we raise a number of concerns regarding the delivery of the proposed allocation at Rawreth Industrial Estate, and the manner in which the proposed allocation is presented in the document.
By way of background, Countryside Properties objected to the proposed site allocation at the Core Strategy stage, on the basis that this existing industrial estate, which is in multiple ownership and with an even greater multitude of tenants, is highly unlikely to be delivered in the plan period, and there is no party other than the Council promoting the land for redevelopment.
The Site Allocations document provides no more information or detail on the matter of the practical delivery of the land, or the timetable within which that could be achieved, and therefore provides no new information that would suggest that the land is in fact either capable or feasible of comprehensive redevelopment.
The fact that this allocation is consistent with the Core Strategy does not of itself make the allocation deliverable, and we would suggest that its inclusion within the Site Allocations still needs to be justified on the basis of positive evidence that the site can in fact be developed as suggested.
Representations
Deliverability
Following on from the above, our first representation in respect of this matter is that Policy BFR4 is unsound since there is no evidence to suggest that the policy proposals are deliverable, and hence the policy is neither Justified nor Effective.
Paragraphs 2.82, 2.88, 2.94, 2.106, and 2.113 of the DPD all provide evidence as to why this site is unlikely to be delivered i.e. because it has a range of existing commercial uses; is likely to require remediation as a result of previous contamination; cannot be delivered until existing uses have been relocated, and development will require significant contributions to community, social, and highway infrastructure. Conversely, the supporting text to the Policy provides no evidence on the viability or feasibility of the site coming forward in the light of these constraints.
Missing from the draft text, but of equal if not greater significance, is the fact that the site is in multiple ownership, is not being promoted for development by the landowners, and in practice the site could only come forward on a comprehensive basis with all landowners involved. All of these factors support our contention that the Policy is Unsound.
Para 2.82 (Site Characteristics)
Following the above, we object specifically to the wording at paragraph 2.82, on the basis that to be Effective, the supporting text to the policy should explain that any redevelopment of the site will need to be on a comprehensive basis, in order to protect the amenity of new residents, and to ensure effective remediation and an appropriate form of development. Paragraph 2.82 should be amended as follows:

"There are a range of industrial buildings, structures and hardstanding on site. Decontamination of the site may be required prior to development. The site is in multiple ownership, and any redevelopment will need to be undertaken on a comprehensive basis in order to protect the amenity of new residential occupiers, to achieve an appropriate form of development having regard to the nature of the existing industrial users and their potential for disturbance, and to ensure effective remediation."

Para 2.85 - Density

The suggested density of up to 60 dph is excessive for this location. Whilst recognising that the site falls within the existing urban area, it is not within a town centre location, and the suggested density is excessive given the character of the area. The adjoining development at Stirling Close/Victoria Avenue immediately to the east is of a similar size (5.6 ha) and has 122 homes at a density of just under 22 dph. Even the more densely developed estate of Grosvenor Road/Brunswick Place has just 109 properties on around 2.9 hectares, giving a density of 37.5 dph.
In the context of the surrounding area, it is difficult to see that the suggested density of up to 60 dwellings per hectare is either feasible (since it would have to rely on a high degree of flatted properties, which the market would not want to deliver in a location such as this), or indeed appropriate. The suggested density is neither Justified nor, given the lack of market interest in developing at this density, Effective.
We would suggest that a density range of 30-35 dph (net) is the most that could be achieve on this site, particularly given the constraints identified elsewhere in the Concept Statement in terms of retaining TPO's and providing on-site open space.
Paras 2.86, 2.87, 2.91 and 2.105 - Scale of development
The text in these paragraphs is confusing as to the scale of development that could be provided on the site. On the one hand it refers to an expectation of 222 dwellings as per the SHLAA (paras 2.87 and 2.91), and on the other hand the calculation of the quantum of open space is based on 89 dwellings (para 2.105), and the assessment at 2.86 would suggest that a yield of up to 140 is more likely based on a realistic density.
The lack of certainty over what the site can deliver stems in part from the fact that there is no party actively promoting or able to deliver the redevelopment of the site. Even so, it would be evident that at the higher development yield suggested, the open space contribution of the site would need to increase above and beyond that set at in the Concept Statement, which raises questions as to whether or not the higher yield suggested in the SHLAA is actually achievable. Even at the lower range of up to 140, the open space quoted for at para 2.105 would be insufficient.
Realistically, having netted off the open space and applied an appropriate density of around 30 dph, the yield from this site would be more likely to be in the region of the 140 units suggested at paragraph 2.86, leaving a 60-70 unit shortfall in the delivery of homes from Rayleigh (even if the site is developed at all).

Policy BFR4 (and supporting text) - Rawreth Industrial Estate
Introduction
In these representations, we raise a number of concerns regarding the delivery of the proposed allocation at Rawreth Industrial Estate, and the manner in which the proposed allocation is presented in the document.
By way of background, Countryside Properties objected to the proposed site allocation at the Core Strategy stage, on the basis that this existing industrial estate, which is in multiple ownership and with an even greater multitude of tenants, is highly unlikely to be delivered in the plan period, and there is no party other than the Council promoting the land for redevelopment.
The Site Allocations document provides no more information or detail on the matter of the practical delivery of the land, or the timetable within which that could be achieved, and therefore provides no new information that would suggest that the land is in fact either capable or feasible of comprehensive redevelopment.
The fact that this allocation is consistent with the Core Strategy does not of itself make the allocation deliverable, and we would suggest that its inclusion within the Site Allocations still needs to be justified on the basis of positive evidence that the site can in fact be developed as suggested.
Representations
Deliverability
Following on from the above, our first representation in respect of this matter is that Policy BFR4 is unsound since there is no evidence to suggest that the policy proposals are deliverable, and hence the policy is neither Justified nor Effective.
Paragraphs 2.82, 2.88, 2.94, 2.106, and 2.113 of the DPD all provide evidence as to why this site is unlikely to be delivered i.e. because it has a range of existing commercial uses; is likely to require remediation as a result of previous contamination; cannot be delivered until existing uses have been relocated, and development will require significant contributions to community, social, and highway infrastructure. Conversely, the supporting text to the Policy provides no evidence on the viability or feasibility of the site coming forward in the light of these constraints.
Missing from the draft text, but of equal if not greater significance, is the fact that the site is in multiple ownership, is not being promoted for development by the landowners, and in practice the site could only come forward on a comprehensive basis with all landowners involved. All of these factors support our contention that the Policy is Unsound.
Para 2.82 (Site Characteristics)
Following the above, we object specifically to the wording at paragraph 2.82, on the basis that to be Effective, the supporting text to the policy should explain that any redevelopment of the site will need to be on a comprehensive basis, in order to protect the amenity of new residents, and to ensure effective remediation and an appropriate form of development. Paragraph 2.82 should be amended as follows:

"There are a range of industrial buildings, structures and hardstanding on site. Decontamination of the site may be required prior to development. The site is in multiple ownership, and any redevelopment will need to be undertaken on a comprehensive basis in order to protect the amenity of new residential occupiers, to achieve an appropriate form of development having regard to the nature of the existing industrial users and their potential for disturbance, and to ensure effective remediation."

Para 2.85 - Density

The suggested density of up to 60 dph is excessive for this location. Whilst recognising that the site falls within the existing urban area, it is not within a town centre location, and the suggested density is excessive given the character of the area. The adjoining development at Stirling Close/Victoria Avenue immediately to the east is of a similar size (5.6 ha) and has 122 homes at a density of just under 22 dph. Even the more densely developed estate of Grosvenor Road/Brunswick Place has just 109 properties on around 2.9 hectares, giving a density of 37.5 dph.
In the context of the surrounding area, it is difficult to see that the suggested density of up to 60 dwellings per hectare is either feasible (since it would have to rely on a high degree of flatted properties, which the market would not want to deliver in a location such as this), or indeed appropriate. The suggested density is neither Justified nor, given the lack of market interest in developing at this density, Effective.
We would suggest that a density range of 30-35 dph (net) is the most that could be achieve on this site, particularly given the constraints identified elsewhere in the Concept Statement in terms of retaining TPO's and providing on-site open space.
Paras 2.86, 2.87, 2.91 and 2.105 - Scale of development
The text in these paragraphs is confusing as to the scale of development that could be provided on the site. On the one hand it refers to an expectation of 222 dwellings as per the SHLAA (paras 2.87 and 2.91), and on the other hand the calculation of the quantum of open space is based on 89 dwellings (para 2.105), and the assessment at 2.86 would suggest that a yield of up to 140 is more likely based on a realistic density.
The lack of certainty over what the site can deliver stems in part from the fact that there is no party actively promoting or able to deliver the redevelopment of the site. Even so, it would be evident that at the higher development yield suggested, the open space contribution of the site would need to increase above and beyond that set at in the Concept Statement, which raises questions as to whether or not the higher yield suggested in the SHLAA is actually achievable. Even at the lower range of up to 140, the open space quoted for at para 2.105 would be insufficient.
Realistically, having netted off the open space and applied an appropriate density of around 30 dph, the yield from this site would be more likely to be in the region of the 140 units suggested at paragraph 2.86, leaving a 60-70 unit shortfall in the delivery of homes from Rayleigh (even if the site is developed at all).

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.

To meet the number of new jobs required in the District, if existing employment sites are de-allocated, then additional employment sites will be required. As the supply of employment land within the District is limited, any new sites will require the release of Green Belt land. As these sites will be outside of the existing urban areas, it is unlikely that these sites will be in as sustainable locations as the existing employment sites.

This site has very good accessibility, with links to the road network and close to the train station.

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.