Policy SER1 - North of London Road, Rayleigh

The development will disfigure the approach and exit from Rayleigh.
The development will reduce the green belt in a sensitive area between Wickford and Rayleigh, and undermine the setting of Rawreth as a seperate settlement.
It is not clear why a green buffer is required, and the remaining farmland cannot continue in arable use.
The development could still take place in this area without a long swathe of farmland being taken, if it were concentrated in the area cut in towards Rayleigh and spread westwards less.
Rawreth Hall will lose its rural setting, and become a remnant of what the area once looked like.

A concern of the committee of LDERA is the increased traffic onto the London Road which is already a very busy road which is difficult to cross for the elderly. With the development at the old Eon site this is going to generate a flow of traffic almost "motorway proportions"
We are pleased to see that the problem of flooding has been addressed and that public open space is thought of (this must be retained)
The retention of the green belt is important to stop Rayleigh joining up with Wickford!!
A bus route along London Road is needed

Officers are pleased to see that previous suggestions for new community services and facilities as part of the development have been taken on board.

The first objection relates to the need for more detail being required in the concept statement (paragraph 3.37) about the proposals for replacement playing field provision within the site. The proposal would result in the existing Rayleigh Town Sports & Social Club site which has a range of pitches and clubhouse facilities used by local football, cricket and other sports club needing to be replaced within the development. While it is acknowledged that it is the Council's intention that the playing field and ancillary facilities would be replaced before the removal of the existing facilities, the policy has the following shortcomings:
1. It has not been made explicit in the concept statement that the replacement playing field and ancillary facilities will need to be equivalent or better in both quantity and quality to the facilities that would be lost. Without this, there is a concern that the replacement pitches, clubhouse, parking etc could be inferior in size, design, quality etc to the facilities that they would replace. Policy CLT10 of the Council's adopted core strategy resists the loss of playing pitches unless their replacement is equal or better and paragraph 74 of the NPPF as well as Sport England's playing fields policy also takes this policy approach. Clarity on this point is therefore required for consistency with national policy and the Council's core strategy. It is also advocated that the replacement playing pitches and ancillary facilities will be required to meet the design guidance of Sport England and the relevant sports governing bodies in order to ensure that the facilities are of a suitable quality and fit for purpose from a sports perspective as well as an environmental perspective (BREEAM).
2. It has not been made explicit in the concept statement that the replacement playing field and ancillary facilities will need to be subject to at least equivalent management arrangements to the existing facilities. The current Rayleigh Sports & Social Club site will presumably be either owned on a freehold basis by the club or the subject of a long term lease. This is necessary to provide security of tenure and to help facilitate investment in maintaining and improving the facilities for the community. No mention is made of this in the policy and consequrently there is a concern that the replacement facilities could be subject to inferior tenure/management arrangements e.g. short leases, hire arrangements etc which would be unacceptable and could prejudice the long term viability of the club facilities. Sport England's playing fields policy requires replacement playing fields to be at least equivalent in terms of management arrangements to avoid such scenarios. Clarity on this point is therefore required for consistency with national policy.
3. The proposal to relocate the club within the development site would be acceptable in terms of the broad location as this should not affect existing users of the facilities. However, to avoid a scenario where a planning application is submitted which proposes an unsuitable location and access for the sports club it is advocated that that the policy makes provision for a master plan/framework plan for the whole site to be submitted and approved in advance of any planning application in order to ensure that the location is acceptable in practice. This would also be helpful for addressing the other planning requirements set out in the concept statement in view of the size and complexity of the proposed allocation. Without this there is a risk that a planning application will be progressed which does not make provision for for a suitable replacement facility in terms of location/access.
4. The proposal for the clubhouse and associated development to be positioned adjacent to the new residential settlement is of potential concern because the use of the current Rayleigh Sports & Social Club's clubhouse for social functions during the evenings/weekends would riase potential residential amenity concerns such as noise. At present, this would not appear to be an issue as the clubhouse is not located in close proximity to residential development. However, if a new clubhouse had to be integrated with adjoining residential development this would threaten the continuity of using the clubhouse for such events (e.g. the licence could be removed). As sports clubs rely heavily on the revenue raised from social functions and bar use for maintaining and improving the sports facility it is considered essential that the relocated facilities do not prejudice the replacement clubhouse from being used for such purposes as this could affect the long term viability of the facilities. Consequently, the reference in the concept statement should be amended to make provision for the clubhouse and associated facilities being relocated where the continued use of the clubhouse for social functions will not be prejudiced by residential amenity concerns.
5. As Sport England will be a statutory consultee on any future planning application due to the loss of playing fields, it is requested that the concept statement makes reference to the need for engagement with Sport England before a planning application is submitted in order to ensure that the issues raised above can be satisfactorily addressed in practice in order to avoid the potential delays and uncertainty associated with delivering the residential development if a statutory objection is made due to replacement playing field provision not being considered acceptable.

The second objection relates to the lack of provision within the policy for providing additional outdoor sports facilities to meet the additional needs generated by the development. The Council's Playing Pitch Strategy has assessed playing pitch needs and has identified deficiencies across the district especially for mini and junior football pitches. Such deficiencies would be aggrevated by the additional population associated with the new development unless provision was made for meeting these additional needs. It should be noted that paragraph 6.12 of the Playing Pitch Strategy specfically refers to when opportunities arising for providing new pitches they should be on the western side of the district in Rayleigh. Policy CLT5 of the adopted core strategy refers to the need for residential development to provide new open space and specifically refers to residential development in the west of Rayleigh incorporating a significant amount of open space. While the concept statement makes provision for youth facilities and play space to be provided within the development it is therefore surprising in the context of the core strategy policies and the evidence base provided by the playing pitch strategy that no specific provision is made for the development providing additional playing pitch provision. The proposed allocation provides a rare opportunity for new playing pitch provision to be provided in an area where an identified need exists. As it is proposes that a replacement playing field is to bprovided for Rayleigh Town Sports & Social Club, an obvious and appropriate way to address this would be for the policy to make provision for the replacement playing field and ancillary facilities to be extended to incorporate additional facility provision to meet the needs of the development. This would allow the football, cricket etc clubs that use the facilities to expand to incorporate the additional needs genertaed by the development. In its current form the policy is not considered to meet the soundness tests relating to being justified and consistent with national policy as the proposals do not respond to needs justified by the Council's evidence base and core strategy policies or accord with NPPF policy e.g. paragraph 73 which advises assessments of need for sports facilities to be used for determining what sports provision is required.

The proposals for the building of 772 dwellings mainly on Green belt agricultural land North of the London Road an South of Rawreth Lane will have the effect of removing the last open vista on the historic route into Rayleigh Town Centre. The London to Southend coaching route travelled this way for centuries. The views towards Rayleigh are an important aspect of many works of local art. The rural nature of the distance views of the Holy Trinity Church and Historic Mill, situated on the Rayleigh Mount, will be forever lost by this act of vandalism. The road access currently shows a town surrounded by a rural environment, this development will make it appear like any other characterless dormatory town. Future generations will consider this disgraceful despoiling of the district in the same way the residents view the ruination of the top end of the High Street, in the 1960/70's, when the ugly carbuncle Police Station and adjacent development were permitted by Planners and Councillors. All the flower baskets and green ironwork on earth cannot obscure that appalling debacle.

The proposed development will result in the area being virtually linked to Wickford/Shotgate to the west losing a valuable rural buffer between our towns. The long held view that the Essex series of towns along the old London to Southend road should remain seperate and distinct from each other, by the ribbons of rural land being maintained between them, is in danger of being ignored with these proposals. This policy has been long held to be almost sacristant. What has prompted a reversal of this stated aim? The beautiful open views of farmland stretching towards the sunset on summer evenings, as you approach our town from Chelmsford or London, will be lost to future generations. Instead residents will leave the expanding road network to be greeted by soulless rooftops. That is, of course, if they are not distracted by the proposed new commercial carbuncle, to be allowed on their right, on the London Road.

Do the current cabal of Councillors have no vision? Are they blind to the destruction this current set of plans will make to the general ambience of this area? Given that they have allowed such intrusive and unwelcome developments previously perhaps that answer is a given.

Who cannot be dismayed at the bright green, 24 hour neon lit, supermarket development they agreed on Rawreth lane without suitable restrictions on the shielding of light from residential homes during the night? The permitting of the huge ugly distribution outlet sign that dominates part of the skyline as you drive up Rawreth Lane, not to mention the failure to protect the residents in Vernon Avenue from the Tesco parking menace that has been foisted upon them? The Geoff Bray site is another disgrace, there are numerous other smaller failures that have blighted the lives of residents. Those trusted with the protection of our town have, and are continuing, to fail in their duty to the people who have trusted them with their vote and paid them with their taxes.

The tragedy is that the deplorable decision to spoil this attractive entrance to our town is not necessary. The requirement of the Local Authority to find extra housing development sites could easily be met if the Council Planning group and Councillors charged with this task hadn't been so LAZY. They are throughout Rochford and district. It is a quick simple action to draw a line round virgin Greenbelt farmland and redesignate it as residential building land. A small child with a crayon could have done this with ease. The many areas of scrubland and unused small parcels of land, in Daws Heath and at the back of Great Wheatleys (surely not!), could fill part of the need. To the South of London Road there are acres of land that is unused and scruffy, much of it rat infested. I understand an approach, by a landowner, to use part of this wasted site was refused. There is a wealth similar under utilized plotlands and ragged unused commercial sites North of Rawreth Lane that could provide as much, if not more, land for building than the present suggested open green belt farmland. Yes, it would take more time and negotiation. Yes, it will prove more difficult to develop. Yes, a relief road would be needed to access the area and Hullbridge beyond, but that would truly be a future benefit to the whole area. We currently experience road delays and sometimes gridlock on the two roads that will straddle this proposed develoment.

To suggest another 772 dwellings can be accommodated without any new major road infrastructure is lunacy at it extreme. This development will effectively be a sizeable village added to the west side of Rayleigh with no upgrade of any services. 772 households will mean thousands of more cars and many thousands of extra daily car movements in this already congested area. The ridiculous suggestion that a bus route through this 'estate' will allieviate many of the problems this development will generate would be laughable if it wasn't so dishonest. Can the Council staff and Councillors responsible for this proposal advise how many 'bus' miles they travel in the course of their duties? I suggest a small postcard will suffice for the answer. I have never met a Councillor who didn't arrive in a car, nor a Council official, so please do not treat the public you serve with such contempt.

The redesignation of agricultural 'Green belt' land to 'Building land' will result in a tremendous 'windfall' in financial terms for the landowners concerned. I would request that a full disclosure of the names of the landowners involved be made public prior to the decision to proceed. A forensic test should be made to examine just who will 'benefit' from this unwelcome plan. I'm sure no one has anything to hide but the details should be fully disclosed.

As I have such serious reservations about the need for the greenbelt land to be despoiled, believing there are alternatives, I would want to be sure that those charged with making this decision have made it in the full interest of the local people and not for any other reason. Can we be sure that no Councillor (past or present), no Council employee (past or present) their family, friends, or business interests etc. will be enriched by this unwelcome proposal.? Can we be clearly sure that large building concerns have not paid 'retainers' to any of the stated persons or businesses on an understanding that they get first preference of purchase should the status of the Greenbelt farmland be changed?

I have a recollection of the issues that pertained at Doncaster Council and would want to be assured that the present decisions were not purposefully, or obliquely, made due to any unacceptable influence by those charged with overseeing this new allocation . Simply removing oneself from meetings when ones friends/colleagues are deciding whether such enrichment should befall one is not enough to quell any unease the residents might have that the decisions were in the public interest. The Doncaster Council corruption scandal saw many such conflict of interest deals to the detriment of the people of Doncaster. A full disclosure of those gaining from this new proposal will dispell any fears that residents might have.

The pressure on services such as doctors and police even if school places are met has not been addressed. It is vital that our health services and security requirements can be met when such a large number of extra residents are being encouraged into such a already over-subscribed area.

My concerns are such that I believe a full unfettered Judicial Review should be called for due to the far reaching change this proposal will have on this area. In particular the change, in status of the Green belt area North of London Road, will make to this district.

We support the concept statement acknowledging:
- That approximately 3.1ha of the site is within Flood Zone 2 and 3 and that this land should be set aside for public open space. We strongly support this which would address the NPPF requirement for a sequential approach to be applied. 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;
- SuDS need to be provided and a drainage strategy submitted

3.14 There is a foul sewer crossing the site that requires a 4 metre easement either side of the pipe and could effect the developmment of the site . This existing public sewer should be located in highway or public open space and should not be located in privare gardens. If this is not possible, AW will consider an application under Section 185 Water Industry Act 1991 to divert the sewer ( this would be at the developers expense).

3.17 Support the requirement for sustainable urban drainage systems

Introduction
Our clients, Countryside Properties, control land between London Road and Rawreth Lane to the west of Rayleigh, and are committed to the delivery of a high quality sustainable urban extension in this location, in accordance with the Adopted Core Strategy. They are in the process of drawing up their Masterplan proposals for the site.
We support much of the Site Allocations DPD as it relates to site SER1, and the Council's broad vision for the area is essentially the same at the vision that Countryside Properties has for the area. However, there are specific elements of the site allocation and the Concept statement with which we disagree. In particular, and as discussed further below, we do not agree that the western extents of the proposed allocated area for a logical boundary to the development, provides the necessary flexibility that the Masterplan requires (as per our representations elsewhere), or provides an appropriate long term Green Belt boundary, having regard to paragraph 85 of the NPPF.
Representations
Paragraphs 3.17, 3.19, 3.20 and Figure 6 - Site Capacity, Reserve Land/Flexibility and Green Belt Boundary
We agree that the quantum of development and list of land uses identified in the Concept Statement is capable of delivery within the area of land shown in Figure 6. We do not seek to suggest that the quantum of land proposed for allocation is, per se, insufficient for the stated purposes.
However, we do not consider that the boundary shown for the proposed allocation (which in effect defines the new boundary to the Green Belt) is the most appropriate (and therefore Justified), will enable the full requirements of the Core Strategy to be delivered (Effective/Positively Prepared), or that it is consistent with the objectives for the long-term protection of the Green Belt (compliant with National Policy). We consider these matters further below.
Paragraph 85 of the NPPF sets out 6 requirements for LPAs when defining boundaries, and we consider these each in turn, and in the context of the above:
(i) Ensure consistency with the Local Plan Strategy for meeting identified requirements.
Figure 6 is labelled "residential area pre 2021" and in so far as the Core Strategy requires development of 550 homes in this area by 2021, it is consistent with the Core Strategy.
However, as previously discussed, the Core Strategy requires flexibility from the growth locations so that they can potentially accommodate additional development, to make up for shortfall elsewhere. Unnecessarily constraining the development area removes the flexibility that the Core Strategy requires, and therefore the allocation is not consistent with the LP strategy, as adopted in the CS.
Furthermore, the Core Strategy itself only covered a 13 year period to 2025, and, in advance of the promised Core Strategy review, there can be no certainty at this stage as to where further development may be accommodated in the medium term (i.e. beyond the remaining 12 years covered by the Core Strategy).
(ii) Not include land which is it unnecessary to keep permanently open.
It will be evident that the boundary shown on Figure 6 on the western side of the proposed allocation is arbitrary in nature. Since the pylons are likely to remain, the Council has broadly used this as a boundary to the western extent of the development, and in the Concept statement, the Council refers to a need for a 'green buffer' on the western side of the development. It will be seen that towards the southern half of the site, the pylon line is used as the extent of the development, whereas to the north of the area, the development edge is set back some 60m from the Pylon line. Following the terminology used in the NPPF it is difficult to see why this thin strip of land between the pylons and the edge of the development is "necessary to be kept permanently open" on the north side of the site, whereas on the south side of the site there appears to be no such need. Taking in to account also that there will remain a substantial area open, undeveloped land to the west of the Pylon line, the 'necessity' for retaining this strip of land is further diminished.
A common application of logic to the definition of the Green Belt boundary would be that, if the pylon line is to be used as the physical marker for the Green Belt boundary, that marker is used consistently for the western edge.
There is no definitive guidance on appropriate off-set distances from power lines. From a Masterplan and from a marketing perspective, Countryside Properties are proposing to leave a separation of around 30 metres. There is no justification that we are aware of for a 60m off-set.
(iii) Where necessary, identify in their plans areas of 'safeguarded land' between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period.
For the reasons given elsewhere in our submissions i.e. this is an instance where the Site Allocations only has a relatively short time horizon (up to 2025), and where it is acknowledged that an early review of the Core Strategy is required in order to extend the life of the plan and render it NPPF-compliant in terms of housing requirement, this is a situation whereby the LPA should be looking to identify safeguarded land to ensure that Green Belt boundaries set now will endure beyond the length of the Plan period.
Indeed, in this instance, the setting of a Green Belt boundary to 2021 (which is what Figure 6 is stated to be) ignores the fact that additional land may well be required to be brought forward within the lifetime of this Plan, in order to meet a likely lack of delivery elsewhere in the area.
(iv) Make clear that safeguarded land is not allocated for development at the present time.
A simple alteration to the Concept Statement could make clear that any safeguarded land is not allocated for development.
(v) Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
For the reasons given above, there can be no certainty that the Green Belt boundary as proposed might not need to be altered within the current Plan period to cater for lack of delivery elsewhere, since the 5% flexibility allowance is insufficient, let alone certainty that it would not need to be altered at the end of the Plan period.
(vi) Define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
We accept that the lack of substantial boundaries on the ground does represent a challenge to defining the Green Belt boundary in this location, but the NPPF nevertheless states that this should be achieved.
As stated above, if the pylons are to be used as the new Green Belt boundary, then this should be applied consistently, and the off-set on the northern side, which follows no feature whatsoever, removed and the line redrawn westwards to the pylons.
However, there are physical features on the ground that could be used in this instance, and taking in to account also the need for some flexibility in the site area, and the need to define a Green Belt boundary that may endure, a more appropriate (and therefore Justified) Green Belt boundary can be set, which would also then be consistent with National Policy.
In accordance with our comments above, at the very least, if the pylon line is to be used as a physical marker for the Green Belt boundary, then it should be applied consistently, and the arbitrary 60m off-set for part of its length removed, such that the Green Belt boundary/allocated site would be as shown on the plan at Figure 1 overleaf:

Figure 1 - Green Belt boundary using pylon line.
However, to properly comply with the NPPF and the adopted Core Strategy, then as per our submissions above the Green Belt boundary should be defined for the long-term, taking account of physical features, and provide the flexibility necessary to ensure that the requirements of the Core Strategy can be met. The proposed alternative boundary is shown on Figure 2 overleaf.

Figure 2 - NPPF and Core Strategy compliant boundary.
Of course, it does not follow that the proposed housing itself would extend to the west of the Pylon line, even with the proposed revised boundary. The Concept Statement requires a green buffer to the west of the development, and even though excluded from the Green Belt, there is no reason why the land between the pylons and the revised boundary cannot stay open and used for such purposes.
However, the revision of the Green Belt boundary in the manor suggested will:
(a) accord with the criteria in the NPPF for definition of boundaries having regard to physical features and permanence;

(b) provide flexibility, should there be a need for additional development (whether as a result of a shortfall in housing, or, as per our separate objections to Policy NEL1, a shortfall in commercial land to meet the Core Strategy requirement);


(c) will ensure that all infrastructure associated with the development can be provided within the area excluded from the Green Belt (including the means of access from London Road, which is proposed west of the pylon line, and the link road between London Road and Rawreth Lane, which is also likely to run west of the pylons at least in part);

(d) would enable open spaces uses such as any relocated playing fields (and associated parking areas/buildings) to be provided within the excluded area; and

(e) will allow a comprehensive approach to Masterplanning which recognises at least the potential need to allow for flexibility, rather than relying on ad hoc additional releases in the event of a shortfall in delivery.

Policy SER1 North of London Road, Rayleigh (and supporting text)
Introduction
Our clients, Countryside Properties, control land between London Road and Rawreth Lane to the west of Rayleigh, and are committed to the delivery of a high quality sustainable urban extension in this location, in accordance with the Adopted Core Strategy. They are in the process of drawing up their Masterplan proposals for the site.
We support much of the Site Allocations DPD as it relates to site SER1, and the Council's broad vision for the area is essentially the same at the vision that Countryside Properties has for the area. However, there are specific elements of the site allocation and the Concept statement with which we disagree. In particular, and as discussed further below, we do not agree that the western extents of the proposed allocated area for a logical boundary to the development, provides the necessary flexibility that the Masterplan requires (as per our representations elsewhere), or provides an appropriate long term Green Belt boundary, having regard to paragraph 85 of the NPPF.
Representations
Paragraphs 3.17, 3.19, 3.20 and Figure 6 - Site Capacity, Reserve Land/Flexibility and Green Belt Boundary
We agree that the quantum of development and list of land uses identified in the Concept Statement is capable of delivery within the area of land shown in Figure 6. We do not seek to suggest that the quantum of land proposed for allocation is, per se, insufficient for the stated purposes.
However, we do not consider that the boundary shown for the proposed allocation (which in effect defines the new boundary to the Green Belt) is the most appropriate (and therefore Justified), will enable the full requirements of the Core Strategy to be delivered (Effective/Positively Prepared), or that it is consistent with the objectives for the long-term protection of the Green Belt (compliant with National Policy). We consider these matters further below.
Paragraph 85 of the NPPF sets out 6 requirements for LPAs when defining boundaries, and we consider these each in turn, and in the context of the above:
(i) Ensure consistency with the Local Plan Strategy for meeting identified requirements.
Figure 6 is labelled "residential area pre 2021" and in so far as the Core Strategy requires development of 550 homes in this area by 2021, it is consistent with the Core Strategy.
However, as previously discussed, the Core Strategy requires flexibility from the growth locations so that they can potentially accommodate additional development, to make up for shortfall elsewhere. Unnecessarily constraining the development area removes the flexibility that the Core Strategy requires, and therefore the allocation is not consistent with the LP strategy, as adopted in the CS.
Furthermore, the Core Strategy itself only covered a 13 year period to 2025, and, in advance of the promised Core Strategy review, there can be no certainty at this stage as to where further development may be accommodated in the medium term (i.e. beyond the remaining 12 years covered by the Core Strategy).
(ii) Not include land which is it unnecessary to keep permanently open.
It will be evident that the boundary shown on Figure 6 on the western side of the proposed allocation is arbitrary in nature. Since the pylons are likely to remain, the Council has broadly used this as a boundary to the western extent of the development, and in the Concept statement, the Council refers to a need for a 'green buffer' on the western side of the development. It will be seen that towards the southern half of the site, the pylon line is used as the extent of the development, whereas to the north of the area, the development edge is set back some 60m from the Pylon line. Following the terminology used in the NPPF it is difficult to see why this thin strip of land between the pylons and the edge of the development is "necessary to be kept permanently open" on the north side of the site, whereas on the south side of the site there appears to be no such need. Taking in to account also that there will remain a substantial area open, undeveloped land to the west of the Pylon line, the 'necessity' for retaining this strip of land is further diminished.
A common application of logic to the definition of the Green Belt boundary would be that, if the pylon line is to be used as the physical marker for the Green Belt boundary, that marker is used consistently for the western edge.
There is no definitive guidance on appropriate off-set distances from power lines. From a Masterplan and from a marketing perspective, Countryside Properties are proposing to leave a separation of around 30 metres. There is no justification that we are aware of for a 60m off-set.
(iii) Where necessary, identify in their plans areas of 'safeguarded land' between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period.
For the reasons given elsewhere in our submissions i.e. this is an instance where the Site Allocations only has a relatively short time horizon (up to 2025), and where it is acknowledged that an early review of the Core Strategy is required in order to extend the life of the plan and render it NPPF-compliant in terms of housing requirement, this is a situation whereby the LPA should be looking to identify safeguarded land to ensure that Green Belt boundaries set now will endure beyond the length of the Plan period.
Indeed, in this instance, the setting of a Green Belt boundary to 2021 (which is what Figure 6 is stated to be) ignores the fact that additional land may well be required to be brought forward within the lifetime of this Plan, in order to meet a likely lack of delivery elsewhere in the area.
(iv) Make clear that safeguarded land is not allocated for development at the present time.
A simple alteration to the Concept Statement could make clear that any safeguarded land is not allocated for development.
(v) Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
For the reasons given above, there can be no certainty that the Green Belt boundary as proposed might not need to be altered within the current Plan period to cater for lack of delivery elsewhere, since the 5% flexibility allowance is insufficient, let alone certainty that it would not need to be altered at the end of the Plan period.
(vi) Define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
We accept that the lack of substantial boundaries on the ground does represent a challenge to defining the Green Belt boundary in this location, but the NPPF nevertheless states that this should be achieved.
As stated above, if the pylons are to be used as the new Green Belt boundary, then this should be applied consistently, and the off-set on the northern side, which follows no feature whatsoever, removed and the line redrawn westwards to the pylons.
However, there are physical features on the ground that could be used in this instance, and taking in to account also the need for some flexibility in the site area, and the need to define a Green Belt boundary that may endure, a more appropriate (and therefore Justified) Green Belt boundary can be set, which would also then be consistent with National Policy.
In accordance with our comments above, at the very least, if the pylon line is to be used as a physical marker for the Green Belt boundary, then it should be applied consistently, and the arbitrary 60m off-set for part of its length removed, such that the Green Belt boundary/allocated site would be as shown on the plan at Figure 1 overleaf:

Figure 1 - Green Belt boundary using pylon line.
However, to properly comply with the NPPF and the adopted Core Strategy, then as per our submissions above the Green Belt boundary should be defined for the long-term, taking account of physical features, and provide the flexibility necessary to ensure that the requirements of the Core Strategy can be met. The proposed alternative boundary is shown on Figure 2 overleaf.

Figure 2 - NPPF and Core Strategy compliant boundary.
Of course, it does not follow that the proposed housing itself would extend to the west of the Pylon line, even with the proposed revised boundary. The Concept Statement requires a green buffer to the west of the development, and even though excluded from the Green Belt, there is no reason why the land between the pylons and the revised boundary cannot stay open and used for such purposes.
However, the revision of the Green Belt boundary in the manor suggested will:
(a) accord with the criteria in the NPPF for definition of boundaries having regard to physical features and permanence;

(b) provide flexibility, should there be a need for additional development (whether as a result of a shortfall in housing, or, as per our separate objections to Policy NEL1, a shortfall in commercial land to meet the Core Strategy requirement);


(c) will ensure that all infrastructure associated with the development can be provided within the area excluded from the Green Belt (including the means of access from London Road, which is proposed west of the pylon line, and the link road between London Road and Rawreth Lane, which is also likely to run west of the pylons at least in part);

(d) would enable open spaces uses such as any relocated playing fields (and associated parking areas/buildings) to be provided within the excluded area; and

(e) will allow a comprehensive approach to Masterplanning which recognises at least the potential need to allow for flexibility, rather than relying on ad hoc additional releases in the event of a shortfall in delivery.
Paragraphs 3.24-3.25 - Open Space Requirements
We do not disagree with the need for appropriate open space provision, or for open space suitable for the various uses set out. However, the level of prescription set out in these two paragraphs is excessive, and unnecessarily curtailing on the design solution. It would be more appropriate (i.e. Justified) to aggregate the open space areas together in to a general quantum to be provided to meet the end users suggested, and then allow the Masterplan to determine the best configuration for the site.
Paragraph 3.27 - Access and traffic distribution (and Figure 7)
In advance of more detailed traffic modelling, it is inappropriate to be precise about the split of traffic between the northern and southern access points. Whilst there is no objection as such to the inclusion of the proportions suggested as a guide, there is no substantive evidence at the moment to justify a definitive approach (Justified), and the text should be caveated with the addition of "subject to more detailed testing through the site Masterplan and application stages".
In addition, we note that the first sentence of this paragraph is potentially confusing as to whether the Council is seeking two points of access from both London Road and Rawreth Lane, or two points of access overall (the latter is correct). Clarification of the text would assist successful delivery by avoiding confusion (Effective).
Finally, we are not aware that there is any substantive evidence underpinning the suggestion of two points of access to London Road. It is unclear as to what the function of a 'circular link' might be. This text should be deleted if it is not Justified.
Paragraph 3.35 - Green Buffer and Allotments
Whilst understanding that the Council desire for the Green Belt beyond the development to be protected, there is no justification that we are aware of as to why such greenspace should be publically accessible or form parkland.
The preceding paragraphs establish the quantum of formal/informal open space necessary to meet the needs of residents from the development, and therefore there is no quantitative need for additional publically accessible greenspace above and beyond that provided within the site.
If the objective is to maintain a green buffer, then the retention of land in agricultural use would be equally effective.
Whilst no objection is therefore raised to the provision of a 'green buffer' to the west of the development, which would be provided by the Green Belt, we do not consider that a requirement for additional publically accessible greenspace has been Justified.
Finally, we note that the end of this paragraph refers to the fact that allotments 'may' be provided within this buffer. In our view, there may be more appropriate locations for the provision of allotments (for example, within the buffer that will be needed between the new development and Rawreth Industrial Estate, where it would be accessible to new and existing residents), and we would question whether such a use would actually be desirable in landscape terms on the western fringe of the development. Whilst accepting that this paragraph says 'may' only, it would be more appropriate (i.e. Justified) to split the reference to allotments in to a new paragraph, and make clear that there are other locations within the site where the allotments may be provided.
Paragraph 3.37 - Relocation and replacement of existing playing fields
We note that this paragraph states that the existing playing fields "should" be relocated, and that the revised facility should be within 340 metres of the existing site.
Taking the latter point first, a radius of 340 metres from the existing site, even taking the central point from the north-western tip of the existing site, results in an extremely limited search area for a replacement facility. The options are essentially limited to putting the replacement facility either:
(a) On the adjoining land to the north, which would seem a little pointless;
(b) Under the pylon lines immediately to the west; or
(c) Partially in the floodplain of the brook.
In addition to the above, any replacement facility within that radius will be on land that would require reprofiling to make it level, whereas the existing site is already flat.
In the light of the above, we would suggest that the 340 metre limitation is not appropriate. We understand that it is based on not wishing to locate the facility substantially further away from those who currently walk to the site, but in practice the alternative siting options within that radius are all constrained, and will require extensive works.
Moreover, given the limitations on the alternative siting options, the cost of replacement, and the desire of the Council not to move the pitches further away from existing residents, it seems the most appropriate option may well be to leave the pitches in their current location.
It will also be important to ensure that any decision to relocate the pitches does not result in the unnecessary delay of the development itself, given the limited time available for the commencement and completion of the 550 units by 2021.
Whilst recognising that a replacement structure built to BREEAM Very Good criteria would be a benefit to the Sports and Social Club, we query whether this should be a requirement of the development, as opposed to an objective that the land owner (i.e. Rochford District Council) and the developer might seek to achieve.
In the light of the above, we consider the following amendments necessary to ensure this paragraph meets the Justified and Effective tests (alterations in italics):
"The playing fields to the south of the site along London Road may be relocated as part of the development. A replacement sports field with new ancillary facilities together with a new club house would be required to be provided ahead of any removal of the existing facility so as to ensure the continued and uninterrupted operation of this valuable community facility. It will be necessary to ensure however that any relocation does not delay or prejudice the implementation of the development in accordance with the timescale set out in the adopted Core Strategy. The Council will encourage any new structure to be built to the BREEAM (Very good) standard thus providing a new, efficient and environmentally friendly establishment which will be of great advantage to the community as a whole and to the operators of the Sports and Social club. The location of any replacement facility should be established within the Masterplan to be prepared for the site, and should be informed by consultation with the existing users. Additionally any new facility should be well connected to the pedestrian and cycling network.

Paragraph 3.45 - Retail/Neighbourhood centre, and commercial uses.
Given the existence of a neighbourhood parade to the south, a local petrol filling station shop, a local Tesco extra, and most significantly Asda to the east, it is unlikely that a neighbourhood parade of shops within this development would be viable. In order to be Justified, reference to such a facility should be change to "could be integrated" rather than "should be integrated".
However, it would be appropriate to include within the mix of uses an allowance for some small-scale business use, particularly in the light of the lack of deliverability of the proposed commercial allocation south of London Road (see our separate representations to NEL1). An element of commercial/business use within this broad location would help achieve a sustainable mix of uses, help to create vitality across the whole of the Masterplan area, and allow full use of land within the allocated area in locations that might be unsuitable for other reasons for residential use.

Policy SER1 North of London Road, Rayleigh (and supporting text)
Introduction
Our clients, Countryside Properties, control land between London Road and Rawreth Lane to the west of Rayleigh, and are committed to the delivery of a high quality sustainable urban extension in this location, in accordance with the Adopted Core Strategy. They are in the process of drawing up their Masterplan proposals for the site.
We support much of the Site Allocations DPD as it relates to site SER1, and the Council's broad vision for the area is essentially the same at the vision that Countryside Properties has for the area. However, there are specific elements of the site allocation and the Concept statement with which we disagree. In particular, and as discussed further below, we do not agree that the western extents of the proposed allocated area for a logical boundary to the development, provides the necessary flexibility that the Masterplan requires (as per our representations elsewhere), or provides an appropriate long term Green Belt boundary, having regard to paragraph 85 of the NPPF.
Representations
Paragraphs 3.17, 3.19, 3.20 and Figure 6 - Site Capacity, Reserve Land/Flexibility and Green Belt Boundary
We agree that the quantum of development and list of land uses identified in the Concept Statement is capable of delivery within the area of land shown in Figure 6. We do not seek to suggest that the quantum of land proposed for allocation is, per se, insufficient for the stated purposes.
However, we do not consider that the boundary shown for the proposed allocation (which in effect defines the new boundary to the Green Belt) is the most appropriate (and therefore Justified), will enable the full requirements of the Core Strategy to be delivered (Effective/Positively Prepared), or that it is consistent with the objectives for the long-term protection of the Green Belt (compliant with National Policy). We consider these matters further below.
Paragraph 85 of the NPPF sets out 6 requirements for LPAs when defining boundaries, and we consider these each in turn, and in the context of the above:
(i) Ensure consistency with the Local Plan Strategy for meeting identified requirements.
Figure 6 is labelled "residential area pre 2021" and in so far as the Core Strategy requires development of 550 homes in this area by 2021, it is consistent with the Core Strategy.
However, as previously discussed, the Core Strategy requires flexibility from the growth locations so that they can potentially accommodate additional development, to make up for shortfall elsewhere. Unnecessarily constraining the development area removes the flexibility that the Core Strategy requires, and therefore the allocation is not consistent with the LP strategy, as adopted in the CS.
Furthermore, the Core Strategy itself only covered a 13 year period to 2025, and, in advance of the promised Core Strategy review, there can be no certainty at this stage as to where further development may be accommodated in the medium term (i.e. beyond the remaining 12 years covered by the Core Strategy).
(ii) Not include land which is it unnecessary to keep permanently open.
It will be evident that the boundary shown on Figure 6 on the western side of the proposed allocation is arbitrary in nature. Since the pylons are likely to remain, the Council has broadly used this as a boundary to the western extent of the development, and in the Concept statement, the Council refers to a need for a 'green buffer' on the western side of the development. It will be seen that towards the southern half of the site, the pylon line is used as the extent of the development, whereas to the north of the area, the development edge is set back some 60m from the Pylon line. Following the terminology used in the NPPF it is difficult to see why this thin strip of land between the pylons and the edge of the development is "necessary to be kept permanently open" on the north side of the site, whereas on the south side of the site there appears to be no such need. Taking in to account also that there will remain a substantial area open, undeveloped land to the west of the Pylon line, the 'necessity' for retaining this strip of land is further diminished.
A common application of logic to the definition of the Green Belt boundary would be that, if the pylon line is to be used as the physical marker for the Green Belt boundary, that marker is used consistently for the western edge.
There is no definitive guidance on appropriate off-set distances from power lines. From a Masterplan and from a marketing perspective, Countryside Properties are proposing to leave a separation of around 30 metres. There is no justification that we are aware of for a 60m off-set.
(iii) Where necessary, identify in their plans areas of 'safeguarded land' between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period.
For the reasons given elsewhere in our submissions i.e. this is an instance where the Site Allocations only has a relatively short time horizon (up to 2025), and where it is acknowledged that an early review of the Core Strategy is required in order to extend the life of the plan and render it NPPF-compliant in terms of housing requirement, this is a situation whereby the LPA should be looking to identify safeguarded land to ensure that Green Belt boundaries set now will endure beyond the length of the Plan period.
Indeed, in this instance, the setting of a Green Belt boundary to 2021 (which is what Figure 6 is stated to be) ignores the fact that additional land may well be required to be brought forward within the lifetime of this Plan, in order to meet a likely lack of delivery elsewhere in the area.
(iv) Make clear that safeguarded land is not allocated for development at the present time.
A simple alteration to the Concept Statement could make clear that any safeguarded land is not allocated for development.
(v) Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
For the reasons given above, there can be no certainty that the Green Belt boundary as proposed might not need to be altered within the current Plan period to cater for lack of delivery elsewhere, since the 5% flexibility allowance is insufficient, let alone certainty that it would not need to be altered at the end of the Plan period.
(vi) Define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
We accept that the lack of substantial boundaries on the ground does represent a challenge to defining the Green Belt boundary in this location, but the NPPF nevertheless states that this should be achieved.
As stated above, if the pylons are to be used as the new Green Belt boundary, then this should be applied consistently, and the off-set on the northern side, which follows no feature whatsoever, removed and the line redrawn westwards to the pylons.
However, there are physical features on the ground that could be used in this instance, and taking in to account also the need for some flexibility in the site area, and the need to define a Green Belt boundary that may endure, a more appropriate (and therefore Justified) Green Belt boundary can be set, which would also then be consistent with National Policy.
In accordance with our comments above, at the very least, if the pylon line is to be used as a physical marker for the Green Belt boundary, then it should be applied consistently, and the arbitrary 60m off-set for part of its length removed, such that the Green Belt boundary/allocated site would be as shown on the plan at Figure 1 overleaf:

Figure 1 - Green Belt boundary using pylon line.
However, to properly comply with the NPPF and the adopted Core Strategy, then as per our submissions above the Green Belt boundary should be defined for the long-term, taking account of physical features, and provide the flexibility necessary to ensure that the requirements of the Core Strategy can be met. The proposed alternative boundary is shown on Figure 2 overleaf.

Figure 2 - NPPF and Core Strategy compliant boundary.
Of course, it does not follow that the proposed housing itself would extend to the west of the Pylon line, even with the proposed revised boundary. The Concept Statement requires a green buffer to the west of the development, and even though excluded from the Green Belt, there is no reason why the land between the pylons and the revised boundary cannot stay open and used for such purposes.
However, the revision of the Green Belt boundary in the manor suggested will:
(a) accord with the criteria in the NPPF for definition of boundaries having regard to physical features and permanence;

(b) provide flexibility, should there be a need for additional development (whether as a result of a shortfall in housing, or, as per our separate objections to Policy NEL1, a shortfall in commercial land to meet the Core Strategy requirement);


(c) will ensure that all infrastructure associated with the development can be provided within the area excluded from the Green Belt (including the means of access from London Road, which is proposed west of the pylon line, and the link road between London Road and Rawreth Lane, which is also likely to run west of the pylons at least in part);

(d) would enable open spaces uses such as any relocated playing fields (and associated parking areas/buildings) to be provided within the excluded area; and

(e) will allow a comprehensive approach to Masterplanning which recognises at least the potential need to allow for flexibility, rather than relying on ad hoc additional releases in the event of a shortfall in delivery.
Paragraphs 3.24-3.25 - Open Space Requirements
We do not disagree with the need for appropriate open space provision, or for open space suitable for the various uses set out. However, the level of prescription set out in these two paragraphs is excessive, and unnecessarily curtailing on the design solution. It would be more appropriate (i.e. Justified) to aggregate the open space areas together in to a general quantum to be provided to meet the end users suggested, and then allow the Masterplan to determine the best configuration for the site.
Paragraph 3.27 - Access and traffic distribution (and Figure 7)
In advance of more detailed traffic modelling, it is inappropriate to be precise about the split of traffic between the northern and southern access points. Whilst there is no objection as such to the inclusion of the proportions suggested as a guide, there is no substantive evidence at the moment to justify a definitive approach (Justified), and the text should be caveated with the addition of "subject to more detailed testing through the site Masterplan and application stages".
In addition, we note that the first sentence of this paragraph is potentially confusing as to whether the Council is seeking two points of access from both London Road and Rawreth Lane, or two points of access overall (the latter is correct). Clarification of the text would assist successful delivery by avoiding confusion (Effective).
Finally, we are not aware that there is any substantive evidence underpinning the suggestion of two points of access to London Road. It is unclear as to what the function of a 'circular link' might be. This text should be deleted if it is not Justified.
Paragraph 3.35 - Green Buffer and Allotments
Whilst understanding that the Council desire for the Green Belt beyond the development to be protected, there is no justification that we are aware of as to why such greenspace should be publically accessible or form parkland.
The preceding paragraphs establish the quantum of formal/informal open space necessary to meet the needs of residents from the development, and therefore there is no quantitative need for additional publically accessible greenspace above and beyond that provided within the site.
If the objective is to maintain a green buffer, then the retention of land in agricultural use would be equally effective.
Whilst no objection is therefore raised to the provision of a 'green buffer' to the west of the development, which would be provided by the Green Belt, we do not consider that a requirement for additional publically accessible greenspace has been Justified.
Finally, we note that the end of this paragraph refers to the fact that allotments 'may' be provided within this buffer. In our view, there may be more appropriate locations for the provision of allotments (for example, within the buffer that will be needed between the new development and Rawreth Industrial Estate, where it would be accessible to new and existing residents), and we would question whether such a use would actually be desirable in landscape terms on the western fringe of the development. Whilst accepting that this paragraph says 'may' only, it would be more appropriate (i.e. Justified) to split the reference to allotments in to a new paragraph, and make clear that there are other locations within the site where the allotments may be provided.
Paragraph 3.37 - Relocation and replacement of existing playing fields
We note that this paragraph states that the existing playing fields "should" be relocated, and that the revised facility should be within 340 metres of the existing site.
Taking the latter point first, a radius of 340 metres from the existing site, even taking the central point from the north-western tip of the existing site, results in an extremely limited search area for a replacement facility. The options are essentially limited to putting the replacement facility either:
(a) On the adjoining land to the north, which would seem a little pointless;
(b) Under the pylon lines immediately to the west; or
(c) Partially in the floodplain of the brook.
In addition to the above, any replacement facility within that radius will be on land that would require reprofiling to make it level, whereas the existing site is already flat.
In the light of the above, we would suggest that the 340 metre limitation is not appropriate. We understand that it is based on not wishing to locate the facility substantially further away from those who currently walk to the site, but in practice the alternative siting options within that radius are all constrained, and will require extensive works.
Moreover, given the limitations on the alternative siting options, the cost of replacement, and the desire of the Council not to move the pitches further away from existing residents, it seems the most appropriate option may well be to leave the pitches in their current location.
It will also be important to ensure that any decision to relocate the pitches does not result in the unnecessary delay of the development itself, given the limited time available for the commencement and completion of the 550 units by 2021.
Whilst recognising that a replacement structure built to BREEAM Very Good criteria would be a benefit to the Sports and Social Club, we query whether this should be a requirement of the development, as opposed to an objective that the land owner (i.e. Rochford District Council) and the developer might seek to achieve.
In the light of the above, we consider the following amendments necessary to ensure this paragraph meets the Justified and Effective tests (alterations in italics):
"The playing fields to the south of the site along London Road may be relocated as part of the development. A replacement sports field with new ancillary facilities together with a new club house would be required to be provided ahead of any removal of the existing facility so as to ensure the continued and uninterrupted operation of this valuable community facility. It will be necessary to ensure however that any relocation does not delay or prejudice the implementation of the development in accordance with the timescale set out in the adopted Core Strategy. The Council will encourage any new structure to be built to the BREEAM (Very good) standard thus providing a new, efficient and environmentally friendly establishment which will be of great advantage to the community as a whole and to the operators of the Sports and Social club. The location of any replacement facility should be established within the Masterplan to be prepared for the site, and should be informed by consultation with the existing users. Additionally any new facility should be well connected to the pedestrian and cycling network.

Paragraph 3.45 - Retail/Neighbourhood centre, and commercial uses.
Given the existence of a neighbourhood parade to the south, a local petrol filling station shop, a local Tesco extra, and most significantly Asda to the east, it is unlikely that a neighbourhood parade of shops within this development would be viable. In order to be Justified, reference to such a facility should be change to "could be integrated" rather than "should be integrated".
However, it would be appropriate to include within the mix of uses an allowance for some small-scale business use, particularly in the light of the lack of deliverability of the proposed commercial allocation south of London Road (see our separate representations to NEL1). An element of commercial/business use within this broad location would help achieve a sustainable mix of uses, help to create vitality across the whole of the Masterplan area, and allow full use of land within the allocated area in locations that might be unsuitable for other reasons for residential use.

Policy SER1 North of London Road, Rayleigh (and supporting text)
Introduction
Our clients, Countryside Properties, control land between London Road and Rawreth Lane to the west of Rayleigh, and are committed to the delivery of a high quality sustainable urban extension in this location, in accordance with the Adopted Core Strategy. They are in the process of drawing up their Masterplan proposals for the site.
We support much of the Site Allocations DPD as it relates to site SER1, and the Council's broad vision for the area is essentially the same at the vision that Countryside Properties has for the area. However, there are specific elements of the site allocation and the Concept statement with which we disagree. In particular, and as discussed further below, we do not agree that the western extents of the proposed allocated area for a logical boundary to the development, provides the necessary flexibility that the Masterplan requires (as per our representations elsewhere), or provides an appropriate long term Green Belt boundary, having regard to paragraph 85 of the NPPF.
Representations
Paragraphs 3.17, 3.19, 3.20 and Figure 6 - Site Capacity, Reserve Land/Flexibility and Green Belt Boundary
We agree that the quantum of development and list of land uses identified in the Concept Statement is capable of delivery within the area of land shown in Figure 6. We do not seek to suggest that the quantum of land proposed for allocation is, per se, insufficient for the stated purposes.
However, we do not consider that the boundary shown for the proposed allocation (which in effect defines the new boundary to the Green Belt) is the most appropriate (and therefore Justified), will enable the full requirements of the Core Strategy to be delivered (Effective/Positively Prepared), or that it is consistent with the objectives for the long-term protection of the Green Belt (compliant with National Policy). We consider these matters further below.
Paragraph 85 of the NPPF sets out 6 requirements for LPAs when defining boundaries, and we consider these each in turn, and in the context of the above:
(i) Ensure consistency with the Local Plan Strategy for meeting identified requirements.
Figure 6 is labelled "residential area pre 2021" and in so far as the Core Strategy requires development of 550 homes in this area by 2021, it is consistent with the Core Strategy.
However, as previously discussed, the Core Strategy requires flexibility from the growth locations so that they can potentially accommodate additional development, to make up for shortfall elsewhere. Unnecessarily constraining the development area removes the flexibility that the Core Strategy requires, and therefore the allocation is not consistent with the LP strategy, as adopted in the CS.
Furthermore, the Core Strategy itself only covered a 13 year period to 2025, and, in advance of the promised Core Strategy review, there can be no certainty at this stage as to where further development may be accommodated in the medium term (i.e. beyond the remaining 12 years covered by the Core Strategy).
(ii) Not include land which is it unnecessary to keep permanently open.
It will be evident that the boundary shown on Figure 6 on the western side of the proposed allocation is arbitrary in nature. Since the pylons are likely to remain, the Council has broadly used this as a boundary to the western extent of the development, and in the Concept statement, the Council refers to a need for a 'green buffer' on the western side of the development. It will be seen that towards the southern half of the site, the pylon line is used as the extent of the development, whereas to the north of the area, the development edge is set back some 60m from the Pylon line. Following the terminology used in the NPPF it is difficult to see why this thin strip of land between the pylons and the edge of the development is "necessary to be kept permanently open" on the north side of the site, whereas on the south side of the site there appears to be no such need. Taking in to account also that there will remain a substantial area open, undeveloped land to the west of the Pylon line, the 'necessity' for retaining this strip of land is further diminished.
A common application of logic to the definition of the Green Belt boundary would be that, if the pylon line is to be used as the physical marker for the Green Belt boundary, that marker is used consistently for the western edge.
There is no definitive guidance on appropriate off-set distances from power lines. From a Masterplan and from a marketing perspective, Countryside Properties are proposing to leave a separation of around 30 metres. There is no justification that we are aware of for a 60m off-set.
(iii) Where necessary, identify in their plans areas of 'safeguarded land' between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period.
For the reasons given elsewhere in our submissions i.e. this is an instance where the Site Allocations only has a relatively short time horizon (up to 2025), and where it is acknowledged that an early review of the Core Strategy is required in order to extend the life of the plan and render it NPPF-compliant in terms of housing requirement, this is a situation whereby the LPA should be looking to identify safeguarded land to ensure that Green Belt boundaries set now will endure beyond the length of the Plan period.
Indeed, in this instance, the setting of a Green Belt boundary to 2021 (which is what Figure 6 is stated to be) ignores the fact that additional land may well be required to be brought forward within the lifetime of this Plan, in order to meet a likely lack of delivery elsewhere in the area.
(iv) Make clear that safeguarded land is not allocated for development at the present time.
A simple alteration to the Concept Statement could make clear that any safeguarded land is not allocated for development.
(v) Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
For the reasons given above, there can be no certainty that the Green Belt boundary as proposed might not need to be altered within the current Plan period to cater for lack of delivery elsewhere, since the 5% flexibility allowance is insufficient, let alone certainty that it would not need to be altered at the end of the Plan period.
(vi) Define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
We accept that the lack of substantial boundaries on the ground does represent a challenge to defining the Green Belt boundary in this location, but the NPPF nevertheless states that this should be achieved.
As stated above, if the pylons are to be used as the new Green Belt boundary, then this should be applied consistently, and the off-set on the northern side, which follows no feature whatsoever, removed and the line redrawn westwards to the pylons.
However, there are physical features on the ground that could be used in this instance, and taking in to account also the need for some flexibility in the site area, and the need to define a Green Belt boundary that may endure, a more appropriate (and therefore Justified) Green Belt boundary can be set, which would also then be consistent with National Policy.
In accordance with our comments above, at the very least, if the pylon line is to be used as a physical marker for the Green Belt boundary, then it should be applied consistently, and the arbitrary 60m off-set for part of its length removed, such that the Green Belt boundary/allocated site would be as shown on the plan at Figure 1 overleaf:

Figure 1 - Green Belt boundary using pylon line.
However, to properly comply with the NPPF and the adopted Core Strategy, then as per our submissions above the Green Belt boundary should be defined for the long-term, taking account of physical features, and provide the flexibility necessary to ensure that the requirements of the Core Strategy can be met. The proposed alternative boundary is shown on Figure 2 overleaf.

Figure 2 - NPPF and Core Strategy compliant boundary.
Of course, it does not follow that the proposed housing itself would extend to the west of the Pylon line, even with the proposed revised boundary. The Concept Statement requires a green buffer to the west of the development, and even though excluded from the Green Belt, there is no reason why the land between the pylons and the revised boundary cannot stay open and used for such purposes.
However, the revision of the Green Belt boundary in the manor suggested will:
(a) accord with the criteria in the NPPF for definition of boundaries having regard to physical features and permanence;

(b) provide flexibility, should there be a need for additional development (whether as a result of a shortfall in housing, or, as per our separate objections to Policy NEL1, a shortfall in commercial land to meet the Core Strategy requirement);


(c) will ensure that all infrastructure associated with the development can be provided within the area excluded from the Green Belt (including the means of access from London Road, which is proposed west of the pylon line, and the link road between London Road and Rawreth Lane, which is also likely to run west of the pylons at least in part);

(d) would enable open spaces uses such as any relocated playing fields (and associated parking areas/buildings) to be provided within the excluded area; and

(e) will allow a comprehensive approach to Masterplanning which recognises at least the potential need to allow for flexibility, rather than relying on ad hoc additional releases in the event of a shortfall in delivery.
Paragraphs 3.24-3.25 - Open Space Requirements
We do not disagree with the need for appropriate open space provision, or for open space suitable for the various uses set out. However, the level of prescription set out in these two paragraphs is excessive, and unnecessarily curtailing on the design solution. It would be more appropriate (i.e. Justified) to aggregate the open space areas together in to a general quantum to be provided to meet the end users suggested, and then allow the Masterplan to determine the best configuration for the site.
Paragraph 3.27 - Access and traffic distribution (and Figure 7)
In advance of more detailed traffic modelling, it is inappropriate to be precise about the split of traffic between the northern and southern access points. Whilst there is no objection as such to the inclusion of the proportions suggested as a guide, there is no substantive evidence at the moment to justify a definitive approach (Justified), and the text should be caveated with the addition of "subject to more detailed testing through the site Masterplan and application stages".
In addition, we note that the first sentence of this paragraph is potentially confusing as to whether the Council is seeking two points of access from both London Road and Rawreth Lane, or two points of access overall (the latter is correct). Clarification of the text would assist successful delivery by avoiding confusion (Effective).
Finally, we are not aware that there is any substantive evidence underpinning the suggestion of two points of access to London Road. It is unclear as to what the function of a 'circular link' might be. This text should be deleted if it is not Justified.
Paragraph 3.35 - Green Buffer and Allotments
Whilst understanding that the Council desire for the Green Belt beyond the development to be protected, there is no justification that we are aware of as to why such greenspace should be publically accessible or form parkland.
The preceding paragraphs establish the quantum of formal/informal open space necessary to meet the needs of residents from the development, and therefore there is no quantitative need for additional publically accessible greenspace above and beyond that provided within the site.
If the objective is to maintain a green buffer, then the retention of land in agricultural use would be equally effective.
Whilst no objection is therefore raised to the provision of a 'green buffer' to the west of the development, which would be provided by the Green Belt, we do not consider that a requirement for additional publically accessible greenspace has been Justified.
Finally, we note that the end of this paragraph refers to the fact that allotments 'may' be provided within this buffer. In our view, there may be more appropriate locations for the provision of allotments (for example, within the buffer that will be needed between the new development and Rawreth Industrial Estate, where it would be accessible to new and existing residents), and we would question whether such a use would actually be desirable in landscape terms on the western fringe of the development. Whilst accepting that this paragraph says 'may' only, it would be more appropriate (i.e. Justified) to split the reference to allotments in to a new paragraph, and make clear that there are other locations within the site where the allotments may be provided.
Paragraph 3.37 - Relocation and replacement of existing playing fields
We note that this paragraph states that the existing playing fields "should" be relocated, and that the revised facility should be within 340 metres of the existing site.
Taking the latter point first, a radius of 340 metres from the existing site, even taking the central point from the north-western tip of the existing site, results in an extremely limited search area for a replacement facility. The options are essentially limited to putting the replacement facility either:
(a) On the adjoining land to the north, which would seem a little pointless;
(b) Under the pylon lines immediately to the west; or
(c) Partially in the floodplain of the brook.
In addition to the above, any replacement facility within that radius will be on land that would require reprofiling to make it level, whereas the existing site is already flat.
In the light of the above, we would suggest that the 340 metre limitation is not appropriate. We understand that it is based on not wishing to locate the facility substantially further away from those who currently walk to the site, but in practice the alternative siting options within that radius are all constrained, and will require extensive works.
Moreover, given the limitations on the alternative siting options, the cost of replacement, and the desire of the Council not to move the pitches further away from existing residents, it seems the most appropriate option may well be to leave the pitches in their current location.
It will also be important to ensure that any decision to relocate the pitches does not result in the unnecessary delay of the development itself, given the limited time available for the commencement and completion of the 550 units by 2021.
Whilst recognising that a replacement structure built to BREEAM Very Good criteria would be a benefit to the Sports and Social Club, we query whether this should be a requirement of the development, as opposed to an objective that the land owner (i.e. Rochford District Council) and the developer might seek to achieve.
In the light of the above, we consider the following amendments necessary to ensure this paragraph meets the Justified and Effective tests (alterations in italics):
"The playing fields to the south of the site along London Road may be relocated as part of the development. A replacement sports field with new ancillary facilities together with a new club house would be required to be provided ahead of any removal of the existing facility so as to ensure the continued and uninterrupted operation of this valuable community facility. It will be necessary to ensure however that any relocation does not delay or prejudice the implementation of the development in accordance with the timescale set out in the adopted Core Strategy. The Council will encourage any new structure to be built to the BREEAM (Very good) standard thus providing a new, efficient and environmentally friendly establishment which will be of great advantage to the community as a whole and to the operators of the Sports and Social club. The location of any replacement facility should be established within the Masterplan to be prepared for the site, and should be informed by consultation with the existing users. Additionally any new facility should be well connected to the pedestrian and cycling network.

Paragraph 3.45 - Retail/Neighbourhood centre, and commercial uses.
Given the existence of a neighbourhood parade to the south, a local petrol filling station shop, a local Tesco extra, and most significantly Asda to the east, it is unlikely that a neighbourhood parade of shops within this development would be viable. In order to be Justified, reference to such a facility should be change to "could be integrated" rather than "should be integrated".
However, it would be appropriate to include within the mix of uses an allowance for some small-scale business use, particularly in the light of the lack of deliverability of the proposed commercial allocation south of London Road (see our separate representations to NEL1). An element of commercial/business use within this broad location would help achieve a sustainable mix of uses, help to create vitality across the whole of the Masterplan area, and allow full use of land within the allocated area in locations that might be unsuitable for other reasons for residential use.

Policy SER1 North of London Road, Rayleigh (and supporting text)
Introduction
Our clients, Countryside Properties, control land between London Road and Rawreth Lane to the west of Rayleigh, and are committed to the delivery of a high quality sustainable urban extension in this location, in accordance with the Adopted Core Strategy. They are in the process of drawing up their Masterplan proposals for the site.
We support much of the Site Allocations DPD as it relates to site SER1, and the Council's broad vision for the area is essentially the same at the vision that Countryside Properties has for the area. However, there are specific elements of the site allocation and the Concept statement with which we disagree. In particular, and as discussed further below, we do not agree that the western extents of the proposed allocated area for a logical boundary to the development, provides the necessary flexibility that the Masterplan requires (as per our representations elsewhere), or provides an appropriate long term Green Belt boundary, having regard to paragraph 85 of the NPPF.
Representations
Paragraphs 3.17, 3.19, 3.20 and Figure 6 - Site Capacity, Reserve Land/Flexibility and Green Belt Boundary
We agree that the quantum of development and list of land uses identified in the Concept Statement is capable of delivery within the area of land shown in Figure 6. We do not seek to suggest that the quantum of land proposed for allocation is, per se, insufficient for the stated purposes.
However, we do not consider that the boundary shown for the proposed allocation (which in effect defines the new boundary to the Green Belt) is the most appropriate (and therefore Justified), will enable the full requirements of the Core Strategy to be delivered (Effective/Positively Prepared), or that it is consistent with the objectives for the long-term protection of the Green Belt (compliant with National Policy). We consider these matters further below.
Paragraph 85 of the NPPF sets out 6 requirements for LPAs when defining boundaries, and we consider these each in turn, and in the context of the above:
(i) Ensure consistency with the Local Plan Strategy for meeting identified requirements.
Figure 6 is labelled "residential area pre 2021" and in so far as the Core Strategy requires development of 550 homes in this area by 2021, it is consistent with the Core Strategy.
However, as previously discussed, the Core Strategy requires flexibility from the growth locations so that they can potentially accommodate additional development, to make up for shortfall elsewhere. Unnecessarily constraining the development area removes the flexibility that the Core Strategy requires, and therefore the allocation is not consistent with the LP strategy, as adopted in the CS.
Furthermore, the Core Strategy itself only covered a 13 year period to 2025, and, in advance of the promised Core Strategy review, there can be no certainty at this stage as to where further development may be accommodated in the medium term (i.e. beyond the remaining 12 years covered by the Core Strategy).
(ii) Not include land which is it unnecessary to keep permanently open.
It will be evident that the boundary shown on Figure 6 on the western side of the proposed allocation is arbitrary in nature. Since the pylons are likely to remain, the Council has broadly used this as a boundary to the western extent of the development, and in the Concept statement, the Council refers to a need for a 'green buffer' on the western side of the development. It will be seen that towards the southern half of the site, the pylon line is used as the extent of the development, whereas to the north of the area, the development edge is set back some 60m from the Pylon line. Following the terminology used in the NPPF it is difficult to see why this thin strip of land between the pylons and the edge of the development is "necessary to be kept permanently open" on the north side of the site, whereas on the south side of the site there appears to be no such need. Taking in to account also that there will remain a substantial area open, undeveloped land to the west of the Pylon line, the 'necessity' for retaining this strip of land is further diminished.
A common application of logic to the definition of the Green Belt boundary would be that, if the pylon line is to be used as the physical marker for the Green Belt boundary, that marker is used consistently for the western edge.
There is no definitive guidance on appropriate off-set distances from power lines. From a Masterplan and from a marketing perspective, Countryside Properties are proposing to leave a separation of around 30 metres. There is no justification that we are aware of for a 60m off-set.
(iii) Where necessary, identify in their plans areas of 'safeguarded land' between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period.
For the reasons given elsewhere in our submissions i.e. this is an instance where the Site Allocations only has a relatively short time horizon (up to 2025), and where it is acknowledged that an early review of the Core Strategy is required in order to extend the life of the plan and render it NPPF-compliant in terms of housing requirement, this is a situation whereby the LPA should be looking to identify safeguarded land to ensure that Green Belt boundaries set now will endure beyond the length of the Plan period.
Indeed, in this instance, the setting of a Green Belt boundary to 2021 (which is what Figure 6 is stated to be) ignores the fact that additional land may well be required to be brought forward within the lifetime of this Plan, in order to meet a likely lack of delivery elsewhere in the area.
(iv) Make clear that safeguarded land is not allocated for development at the present time.
A simple alteration to the Concept Statement could make clear that any safeguarded land is not allocated for development.
(v) Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
For the reasons given above, there can be no certainty that the Green Belt boundary as proposed might not need to be altered within the current Plan period to cater for lack of delivery elsewhere, since the 5% flexibility allowance is insufficient, let alone certainty that it would not need to be altered at the end of the Plan period.
(vi) Define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
We accept that the lack of substantial boundaries on the ground does represent a challenge to defining the Green Belt boundary in this location, but the NPPF nevertheless states that this should be achieved.
As stated above, if the pylons are to be used as the new Green Belt boundary, then this should be applied consistently, and the off-set on the northern side, which follows no feature whatsoever, removed and the line redrawn westwards to the pylons.
However, there are physical features on the ground that could be used in this instance, and taking in to account also the need for some flexibility in the site area, and the need to define a Green Belt boundary that may endure, a more appropriate (and therefore Justified) Green Belt boundary can be set, which would also then be consistent with National Policy.
In accordance with our comments above, at the very least, if the pylon line is to be used as a physical marker for the Green Belt boundary, then it should be applied consistently, and the arbitrary 60m off-set for part of its length removed, such that the Green Belt boundary/allocated site would be as shown on the plan at Figure 1 overleaf:

Figure 1 - Green Belt boundary using pylon line.
However, to properly comply with the NPPF and the adopted Core Strategy, then as per our submissions above the Green Belt boundary should be defined for the long-term, taking account of physical features, and provide the flexibility necessary to ensure that the requirements of the Core Strategy can be met. The proposed alternative boundary is shown on Figure 2 overleaf.

Figure 2 - NPPF and Core Strategy compliant boundary.
Of course, it does not follow that the proposed housing itself would extend to the west of the Pylon line, even with the proposed revised boundary. The Concept Statement requires a green buffer to the west of the development, and even though excluded from the Green Belt, there is no reason why the land between the pylons and the revised boundary cannot stay open and used for such purposes.
However, the revision of the Green Belt boundary in the manor suggested will:
(a) accord with the criteria in the NPPF for definition of boundaries having regard to physical features and permanence;

(b) provide flexibility, should there be a need for additional development (whether as a result of a shortfall in housing, or, as per our separate objections to Policy NEL1, a shortfall in commercial land to meet the Core Strategy requirement);


(c) will ensure that all infrastructure associated with the development can be provided within the area excluded from the Green Belt (including the means of access from London Road, which is proposed west of the pylon line, and the link road between London Road and Rawreth Lane, which is also likely to run west of the pylons at least in part);

(d) would enable open spaces uses such as any relocated playing fields (and associated parking areas/buildings) to be provided within the excluded area; and

(e) will allow a comprehensive approach to Masterplanning which recognises at least the potential need to allow for flexibility, rather than relying on ad hoc additional releases in the event of a shortfall in delivery.
Paragraphs 3.24-3.25 - Open Space Requirements
We do not disagree with the need for appropriate open space provision, or for open space suitable for the various uses set out. However, the level of prescription set out in these two paragraphs is excessive, and unnecessarily curtailing on the design solution. It would be more appropriate (i.e. Justified) to aggregate the open space areas together in to a general quantum to be provided to meet the end users suggested, and then allow the Masterplan to determine the best configuration for the site.
Paragraph 3.27 - Access and traffic distribution (and Figure 7)
In advance of more detailed traffic modelling, it is inappropriate to be precise about the split of traffic between the northern and southern access points. Whilst there is no objection as such to the inclusion of the proportions suggested as a guide, there is no substantive evidence at the moment to justify a definitive approach (Justified), and the text should be caveated with the addition of "subject to more detailed testing through the site Masterplan and application stages".
In addition, we note that the first sentence of this paragraph is potentially confusing as to whether the Council is seeking two points of access from both London Road and Rawreth Lane, or two points of access overall (the latter is correct). Clarification of the text would assist successful delivery by avoiding confusion (Effective).
Finally, we are not aware that there is any substantive evidence underpinning the suggestion of two points of access to London Road. It is unclear as to what the function of a 'circular link' might be. This text should be deleted if it is not Justified.
Paragraph 3.35 - Green Buffer and Allotments
Whilst understanding that the Council desire for the Green Belt beyond the development to be protected, there is no justification that we are aware of as to why such greenspace should be publically accessible or form parkland.
The preceding paragraphs establish the quantum of formal/informal open space necessary to meet the needs of residents from the development, and therefore there is no quantitative need for additional publically accessible greenspace above and beyond that provided within the site.
If the objective is to maintain a green buffer, then the retention of land in agricultural use would be equally effective.
Whilst no objection is therefore raised to the provision of a 'green buffer' to the west of the development, which would be provided by the Green Belt, we do not consider that a requirement for additional publically accessible greenspace has been Justified.
Finally, we note that the end of this paragraph refers to the fact that allotments 'may' be provided within this buffer. In our view, there may be more appropriate locations for the provision of allotments (for example, within the buffer that will be needed between the new development and Rawreth Industrial Estate, where it would be accessible to new and existing residents), and we would question whether such a use would actually be desirable in landscape terms on the western fringe of the development. Whilst accepting that this paragraph says 'may' only, it would be more appropriate (i.e. Justified) to split the reference to allotments in to a new paragraph, and make clear that there are other locations within the site where the allotments may be provided.
Paragraph 3.37 - Relocation and replacement of existing playing fields
We note that this paragraph states that the existing playing fields "should" be relocated, and that the revised facility should be within 340 metres of the existing site.
Taking the latter point first, a radius of 340 metres from the existing site, even taking the central point from the north-western tip of the existing site, results in an extremely limited search area for a replacement facility. The options are essentially limited to putting the replacement facility either:
(a) On the adjoining land to the north, which would seem a little pointless;
(b) Under the pylon lines immediately to the west; or
(c) Partially in the floodplain of the brook.
In addition to the above, any replacement facility within that radius will be on land that would require reprofiling to make it level, whereas the existing site is already flat.
In the light of the above, we would suggest that the 340 metre limitation is not appropriate. We understand that it is based on not wishing to locate the facility substantially further away from those who currently walk to the site, but in practice the alternative siting options within that radius are all constrained, and will require extensive works.
Moreover, given the limitations on the alternative siting options, the cost of replacement, and the desire of the Council not to move the pitches further away from existing residents, it seems the most appropriate option may well be to leave the pitches in their current location.
It will also be important to ensure that any decision to relocate the pitches does not result in the unnecessary delay of the development itself, given the limited time available for the commencement and completion of the 550 units by 2021.
Whilst recognising that a replacement structure built to BREEAM Very Good criteria would be a benefit to the Sports and Social Club, we query whether this should be a requirement of the development, as opposed to an objective that the land owner (i.e. Rochford District Council) and the developer might seek to achieve.
In the light of the above, we consider the following amendments necessary to ensure this paragraph meets the Justified and Effective tests (alterations in italics):
"The playing fields to the south of the site along London Road may be relocated as part of the development. A replacement sports field with new ancillary facilities together with a new club house would be required to be provided ahead of any removal of the existing facility so as to ensure the continued and uninterrupted operation of this valuable community facility. It will be necessary to ensure however that any relocation does not delay or prejudice the implementation of the development in accordance with the timescale set out in the adopted Core Strategy. The Council will encourage any new structure to be built to the BREEAM (Very good) standard thus providing a new, efficient and environmentally friendly establishment which will be of great advantage to the community as a whole and to the operators of the Sports and Social club. The location of any replacement facility should be established within the Masterplan to be prepared for the site, and should be informed by consultation with the existing users. Additionally any new facility should be well connected to the pedestrian and cycling network.

Paragraph 3.45 - Retail/Neighbourhood centre, and commercial uses.
Given the existence of a neighbourhood parade to the south, a local petrol filling station shop, a local Tesco extra, and most significantly Asda to the east, it is unlikely that a neighbourhood parade of shops within this development would be viable. In order to be Justified, reference to such a facility should be change to "could be integrated" rather than "should be integrated".
However, it would be appropriate to include within the mix of uses an allowance for some small-scale business use, particularly in the light of the lack of deliverability of the proposed commercial allocation south of London Road (see our separate representations to NEL1). An element of commercial/business use within this broad location would help achieve a sustainable mix of uses, help to create vitality across the whole of the Masterplan area, and allow full use of land within the allocated area in locations that might be unsuitable for other reasons for residential use.

Policy SER1 North of London Road, Rayleigh (and supporting text)
Introduction
Our clients, Countryside Properties, control land between London Road and Rawreth Lane to the west of Rayleigh, and are committed to the delivery of a high quality sustainable urban extension in this location, in accordance with the Adopted Core Strategy. They are in the process of drawing up their Masterplan proposals for the site.
We support much of the Site Allocations DPD as it relates to site SER1, and the Council's broad vision for the area is essentially the same at the vision that Countryside Properties has for the area. However, there are specific elements of the site allocation and the Concept statement with which we disagree. In particular, and as discussed further below, we do not agree that the western extents of the proposed allocated area for a logical boundary to the development, provides the necessary flexibility that the Masterplan requires (as per our representations elsewhere), or provides an appropriate long term Green Belt boundary, having regard to paragraph 85 of the NPPF.
Representations
Paragraphs 3.17, 3.19, 3.20 and Figure 6 - Site Capacity, Reserve Land/Flexibility and Green Belt Boundary
We agree that the quantum of development and list of land uses identified in the Concept Statement is capable of delivery within the area of land shown in Figure 6. We do not seek to suggest that the quantum of land proposed for allocation is, per se, insufficient for the stated purposes.
However, we do not consider that the boundary shown for the proposed allocation (which in effect defines the new boundary to the Green Belt) is the most appropriate (and therefore Justified), will enable the full requirements of the Core Strategy to be delivered (Effective/Positively Prepared), or that it is consistent with the objectives for the long-term protection of the Green Belt (compliant with National Policy). We consider these matters further below.
Paragraph 85 of the NPPF sets out 6 requirements for LPAs when defining boundaries, and we consider these each in turn, and in the context of the above:
(i) Ensure consistency with the Local Plan Strategy for meeting identified requirements.
Figure 6 is labelled "residential area pre 2021" and in so far as the Core Strategy requires development of 550 homes in this area by 2021, it is consistent with the Core Strategy.
However, as previously discussed, the Core Strategy requires flexibility from the growth locations so that they can potentially accommodate additional development, to make up for shortfall elsewhere. Unnecessarily constraining the development area removes the flexibility that the Core Strategy requires, and therefore the allocation is not consistent with the LP strategy, as adopted in the CS.
Furthermore, the Core Strategy itself only covered a 13 year period to 2025, and, in advance of the promised Core Strategy review, there can be no certainty at this stage as to where further development may be accommodated in the medium term (i.e. beyond the remaining 12 years covered by the Core Strategy).
(ii) Not include land which is it unnecessary to keep permanently open.
It will be evident that the boundary shown on Figure 6 on the western side of the proposed allocation is arbitrary in nature. Since the pylons are likely to remain, the Council has broadly used this as a boundary to the western extent of the development, and in the Concept statement, the Council refers to a need for a 'green buffer' on the western side of the development. It will be seen that towards the southern half of the site, the pylon line is used as the extent of the development, whereas to the north of the area, the development edge is set back some 60m from the Pylon line. Following the terminology used in the NPPF it is difficult to see why this thin strip of land between the pylons and the edge of the development is "necessary to be kept permanently open" on the north side of the site, whereas on the south side of the site there appears to be no such need. Taking in to account also that there will remain a substantial area open, undeveloped land to the west of the Pylon line, the 'necessity' for retaining this strip of land is further diminished.
A common application of logic to the definition of the Green Belt boundary would be that, if the pylon line is to be used as the physical marker for the Green Belt boundary, that marker is used consistently for the western edge.
There is no definitive guidance on appropriate off-set distances from power lines. From a Masterplan and from a marketing perspective, Countryside Properties are proposing to leave a separation of around 30 metres. There is no justification that we are aware of for a 60m off-set.
(iii) Where necessary, identify in their plans areas of 'safeguarded land' between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period.
For the reasons given elsewhere in our submissions i.e. this is an instance where the Site Allocations only has a relatively short time horizon (up to 2025), and where it is acknowledged that an early review of the Core Strategy is required in order to extend the life of the plan and render it NPPF-compliant in terms of housing requirement, this is a situation whereby the LPA should be looking to identify safeguarded land to ensure that Green Belt boundaries set now will endure beyond the length of the Plan period.
Indeed, in this instance, the setting of a Green Belt boundary to 2021 (which is what Figure 6 is stated to be) ignores the fact that additional land may well be required to be brought forward within the lifetime of this Plan, in order to meet a likely lack of delivery elsewhere in the area.
(iv) Make clear that safeguarded land is not allocated for development at the present time.
A simple alteration to the Concept Statement could make clear that any safeguarded land is not allocated for development.
(v) Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
For the reasons given above, there can be no certainty that the Green Belt boundary as proposed might not need to be altered within the current Plan period to cater for lack of delivery elsewhere, since the 5% flexibility allowance is insufficient, let alone certainty that it would not need to be altered at the end of the Plan period.
(vi) Define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.
We accept that the lack of substantial boundaries on the ground does represent a challenge to defining the Green Belt boundary in this location, but the NPPF nevertheless states that this should be achieved.
As stated above, if the pylons are to be used as the new Green Belt boundary, then this should be applied consistently, and the off-set on the northern side, which follows no feature whatsoever, removed and the line redrawn westwards to the pylons.
However, there are physical features on the ground that could be used in this instance, and taking in to account also the need for some flexibility in the site area, and the need to define a Green Belt boundary that may endure, a more appropriate (and therefore Justified) Green Belt boundary can be set, which would also then be consistent with National Policy.
In accordance with our comments above, at the very least, if the pylon line is to be used as a physical marker for the Green Belt boundary, then it should be applied consistently, and the arbitrary 60m off-set for part of its length removed, such that the Green Belt boundary/allocated site would be as shown on the plan at Figure 1 overleaf:

Figure 1 - Green Belt boundary using pylon line.
However, to properly comply with the NPPF and the adopted Core Strategy, then as per our submissions above the Green Belt boundary should be defined for the long-term, taking account of physical features, and provide the flexibility necessary to ensure that the requirements of the Core Strategy can be met. The proposed alternative boundary is shown on Figure 2 overleaf.

Figure 2 - NPPF and Core Strategy compliant boundary.
Of course, it does not follow that the proposed housing itself would extend to the west of the Pylon line, even with the proposed revised boundary. The Concept Statement requires a green buffer to the west of the development, and even though excluded from the Green Belt, there is no reason why the land between the pylons and the revised boundary cannot stay open and used for such purposes.
However, the revision of the Green Belt boundary in the manor suggested will:
(a) accord with the criteria in the NPPF for definition of boundaries having regard to physical features and permanence;

(b) provide flexibility, should there be a need for additional development (whether as a result of a shortfall in housing, or, as per our separate objections to Policy NEL1, a shortfall in commercial land to meet the Core Strategy requirement);


(c) will ensure that all infrastructure associated with the development can be provided within the area excluded from the Green Belt (including the means of access from London Road, which is proposed west of the pylon line, and the link road between London Road and Rawreth Lane, which is also likely to run west of the pylons at least in part);

(d) would enable open spaces uses such as any relocated playing fields (and associated parking areas/buildings) to be provided within the excluded area; and

(e) will allow a comprehensive approach to Masterplanning which recognises at least the potential need to allow for flexibility, rather than relying on ad hoc additional releases in the event of a shortfall in delivery.
Paragraphs 3.24-3.25 - Open Space Requirements
We do not disagree with the need for appropriate open space provision, or for open space suitable for the various uses set out. However, the level of prescription set out in these two paragraphs is excessive, and unnecessarily curtailing on the design solution. It would be more appropriate (i.e. Justified) to aggregate the open space areas together in to a general quantum to be provided to meet the end users suggested, and then allow the Masterplan to determine the best configuration for the site.
Paragraph 3.27 - Access and traffic distribution (and Figure 7)
In advance of more detailed traffic modelling, it is inappropriate to be precise about the split of traffic between the northern and southern access points. Whilst there is no objection as such to the inclusion of the proportions suggested as a guide, there is no substantive evidence at the moment to justify a definitive approach (Justified), and the text should be caveated with the addition of "subject to more detailed testing through the site Masterplan and application stages".
In addition, we note that the first sentence of this paragraph is potentially confusing as to whether the Council is seeking two points of access from both London Road and Rawreth Lane, or two points of access overall (the latter is correct). Clarification of the text would assist successful delivery by avoiding confusion (Effective).
Finally, we are not aware that there is any substantive evidence underpinning the suggestion of two points of access to London Road. It is unclear as to what the function of a 'circular link' might be. This text should be deleted if it is not Justified.
Paragraph 3.35 - Green Buffer and Allotments
Whilst understanding that the Council desire for the Green Belt beyond the development to be protected, there is no justification that we are aware of as to why such greenspace should be publically accessible or form parkland.
The preceding paragraphs establish the quantum of formal/informal open space necessary to meet the needs of residents from the development, and therefore there is no quantitative need for additional publically accessible greenspace above and beyond that provided within the site.
If the objective is to maintain a green buffer, then the retention of land in agricultural use would be equally effective.
Whilst no objection is therefore raised to the provision of a 'green buffer' to the west of the development, which would be provided by the Green Belt, we do not consider that a requirement for additional publically accessible greenspace has been Justified.
Finally, we note that the end of this paragraph refers to the fact that allotments 'may' be provided within this buffer. In our view, there may be more appropriate locations for the provision of allotments (for example, within the buffer that will be needed between the new development and Rawreth Industrial Estate, where it would be accessible to new and existing residents), and we would question whether such a use would actually be desirable in landscape terms on the western fringe of the development. Whilst accepting that this paragraph says 'may' only, it would be more appropriate (i.e. Justified) to split the reference to allotments in to a new paragraph, and make clear that there are other locations within the site where the allotments may be provided.
Paragraph 3.37 - Relocation and replacement of existing playing fields
We note that this paragraph states that the existing playing fields "should" be relocated, and that the revised facility should be within 340 metres of the existing site.
Taking the latter point first, a radius of 340 metres from the existing site, even taking the central point from the north-western tip of the existing site, results in an extremely limited search area for a replacement facility. The options are essentially limited to putting the replacement facility either:
(a) On the adjoining land to the north, which would seem a little pointless;
(b) Under the pylon lines immediately to the west; or
(c) Partially in the floodplain of the brook.
In addition to the above, any replacement facility within that radius will be on land that would require reprofiling to make it level, whereas the existing site is already flat.
In the light of the above, we would suggest that the 340 metre limitation is not appropriate. We understand that it is based on not wishing to locate the facility substantially further away from those who currently walk to the site, but in practice the alternative siting options within that radius are all constrained, and will require extensive works.
Moreover, given the limitations on the alternative siting options, the cost of replacement, and the desire of the Council not to move the pitches further away from existing residents, it seems the most appropriate option may well be to leave the pitches in their current location.
It will also be important to ensure that any decision to relocate the pitches does not result in the unnecessary delay of the development itself, given the limited time available for the commencement and completion of the 550 units by 2021.
Whilst recognising that a replacement structure built to BREEAM Very Good criteria would be a benefit to the Sports and Social Club, we query whether this should be a requirement of the development, as opposed to an objective that the land owner (i.e. Rochford District Council) and the developer might seek to achieve.
In the light of the above, we consider the following amendments necessary to ensure this paragraph meets the Justified and Effective tests (alterations in italics):
"The playing fields to the south of the site along London Road may be relocated as part of the development. A replacement sports field with new ancillary facilities together with a new club house would be required to be provided ahead of any removal of the existing facility so as to ensure the continued and uninterrupted operation of this valuable community facility. It will be necessary to ensure however that any relocation does not delay or prejudice the implementation of the development in accordance with the timescale set out in the adopted Core Strategy. The Council will encourage any new structure to be built to the BREEAM (Very good) standard thus providing a new, efficient and environmentally friendly establishment which will be of great advantage to the community as a whole and to the operators of the Sports and Social club. The location of any replacement facility should be established within the Masterplan to be prepared for the site, and should be informed by consultation with the existing users. Additionally any new facility should be well connected to the pedestrian and cycling network.

Paragraph 3.45 - Retail/Neighbourhood centre, and commercial uses.
Given the existence of a neighbourhood parade to the south, a local petrol filling station shop, a local Tesco extra, and most significantly Asda to the east, it is unlikely that a neighbourhood parade of shops within this development would be viable. In order to be Justified, reference to such a facility should be change to "could be integrated" rather than "should be integrated".
However, it would be appropriate to include within the mix of uses an allowance for some small-scale business use, particularly in the light of the lack of deliverability of the proposed commercial allocation south of London Road (see our separate representations to NEL1). An element of commercial/business use within this broad location would help achieve a sustainable mix of uses, help to create vitality across the whole of the Masterplan area, and allow full use of land within the allocated area in locations that might be unsuitable for other reasons for residential use.

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 proposed allocation but would comment that the southern part of the site lies within Flood Zone 3; the development would need to be designed in order to ensure that the more vulnerable uses (e.g. residential) are not located in this area..

In addition, it would be necessary to create a defensible Green Belt boundary on the western side of the site.

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.

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.

Policy SER1 - North of London Road - Rayleigh

3.31 Transport Impact of aditional 550 properties on to the A129 London Road must be given major consideration. As is well known by RDC. This road between Carpenters Arms and Rayleigh High Street already carries a heavy volume of traffic with congestion at the junctions with Downhall Road, Crown Hill and the High Street. The effect of the 150 properties at present under construction or in the planning stage with access onto the A129 should also be considered.

There are also 3 estates with access on to the London Road, Louis Drive Estate, Little Wheatley Estate and Grange Estate, plus other minor roads.

A road widening scheme may need to be considered and provision of a suitable footpath to serve the community, facilities being suggested.