Policy SER6 - South West Hullbridge

Regarding neighbourhood shops in Hullbridge most are struggling at the moment because of ASDA in Rawreth Lane which has hit local shopkeepers quite bad. More shops in this area will only see our local shops closing down.

A development of this nature will be detrimental to the village of Hullbridge. The facilities (ie sewerage, drainage, roads, medical centre) will not be able to cope with such large influx. The road system is totally unsuitable, new main roads would have to be installed. The present school would be inadequate. Flooding is a major problem in that area, so largescale drainage systems would have to be implemented.

1. The development would be outside of existing village and would be detrimental to the current community.

2. No way could our existing roads cope with additional traffic.

3. With the amount of flooding in the proposed area, our drainage and sewerage already stretched to capacity would be non sustainable.

4. Because the development will be split between Rawreth and Hullbridge we will have no community cohesion.

5. Our school and meadical practice would be unable to cope.

Facilities not at all substantial enough, to warrant housing.

eg Flood plain - Watery Lane floods when any substantial rainfall
Roads
Transport
Schools
Lack of work facilities

- Watery Lane is below sea level (newlyn base)
- Surface water pumps break down (I cite junction A127/A1245) causing traffic restrictions
- Land slopes from Windermere Avenue to Watery Lane. Concreting over this land needs run-off facilities to be supplied.


1. Development is detrimental to the current Community

The site is not properly integrated with the existing village of Hullbridge. A "green buffer" is to exist "in perpetuity between new and existing developments".
The 3.6 hectares of natural green space will only be directly accessible from the new development.
This development as proposed, as evidenced above, will not promote community cohesion but will in fact be creating a separate village to Hullbridge destroying the current community feeling that exists.

2. Highways

Although mention of limited highway improvements is in the report no detail is given as there is no Core Strategy Transport Assessment from Essex County Council or elsewhere. The only Transport Impact Assessment required will be developer funded and relate only to SER6, without taking into account either highway issues or other developments (eg SER1) elsewhere in the District. No assessment of road improvements required has been made and Ferry Road, onto which much of the new traffic will go, has not been mentioned in the report.
At present Rawreth Lane is at, or near, capacity and when Watery Lane is closed, a common occurrence, traffic backs up along Downhall Road and Rawreth Lane towards Rayleigh and Hullbridge Road and Lower Road towards Hockley and Rochford making journeys to or from Rayleigh or Chelmsford difficult.
No impact on the district has been made with regard to the Fairglen Interchange (A127/A130/A1245) which lies just outside the District but which has a profound knock on effect when flooded with cars moving to either London Road or Rawreth Lane, to roads affected by SER6 and also, more directly by SER1.
It is stated that highway improvements should be made to accompany the development of the site, this will be too late as improvements must be made first given the current state of the highways network.

3. Sewage/Drainage

The sewage system within Hullbridge is already at or near capacity. Although mentioned in the report no assessment of needs has been made.
Part of the area proposed is prone to flooding. It is not shown as flood risk however as it is farmland and no claims have been made against insurance. Flood Risk is based on insurance claims made.

4. Rawreth

Approximately one third, or around 6.2 hectares, of development SER6b (the second phase) will be in Rawreth, not Hullbridge. This also relates to point one above about community cohesion.
If the residents of the housing in SER6b live in Rawreth they will not be a part of Hullbridge, they will be represented by Rawreth Parish Council and Downhall and Rawreth District Councillors. They will pay a Parish Precept to Rawreth but get the facilities of Hullbridge. Such a separation will again not foster Community Cohesion and does more to encourage the new development as a separate community.

5. Youth

Hullbridge has a Youth Centre which is currently underused; additional investment should be made to facilities there or at the Skate Park in the recreation ground rather than have additional facilities which will be underutilised.

6. Neighbourhod Shops

The suggestion that additional neighbourhood shops are required suggests a proper review has not been done of A1 use in Hullbridge, which then gives a concern about the report as a whole. With a population of around 7,300 Hullbridge has three supermarkets; The Co-op, One Stop (owned by Tescos) and Budgens as well as a number of other independent shops including a butcher and a greengrocer etc. Hullbridge is more than adequately served by shops.
Hullbridge is short of other business premises such as office or studio facilities.

I strongly believe that the DPD is unsound for several reasons, not least the apparent lack of consideration given to the vast problems that will be caused in respect of flooding, sewage and road access to the immediate area. You need to be a resident of the area to fully appreciate just how bad these problems already are and, indeed, how severe they will become should the development go ahead.

Firstly, it is common knowledge that Watery Lane and the surrounding area is consistently flooding and given the amount of rainfall over the past 12 months, Watery Lane itself has been constantly impassable to traffic and thus closed for long periods. It is particularly bad on the bends at the Hullbridge end of the road.

Secondly, in relation to sewage problems, if you live along the south western boundary of Hullbridge, the proposed development area, the smell form the sewage plant at the Hullbridge end of Watery Lane when the wind is blowing in a certain direction is very strong and can only be described as 'disgusting'.

Given the aforementioned flooding and sewage concerns, with the development of a further 500 houses in the area, these problems will be hugely exacerbated. Even if as rumoured, 'ponds' will be created in the Rawreth area to take any excess water, this will be nowhere near efficient enough to take the extra water and indeed the sewage which is already at maximum capacity. People living in Lower Road and the roads behind it (such as ourselves) have had the misfortune of seeing their gardens flooded or at best, heavily saturated, almost constantly since last summer (please find enclosed photos of our garden after a heavy downpour last summer).

Thirdly, there is the considerable problem as to how the local road infrastructure will cope with the influx of a further 1000 vehicles locally (given the average of 2 per household). Lower Road and Watery Lane are already over-used as a 'rat-run' to get to the A130 for Chelmsford and in the opposite direction, for motorists avoiding the A127 to Southend. Where is all this traffic going to go? Lower Road and Hullbridge Road are consistently at a standstill whenever Watery Lane is closed due to flooding as the traffic has no alternative route.

With further regard to the actual location of the site, it is my understanding that one-third of the site will actually be located in the Rawreth area but will benefit from the facilities in Hullbridge. The conclusion being that this part of the development will almost become a separate community and therefore do nothing to enhance the current excellent community spirit of Hullbridge itself.

It is also my understanding that a suggestion has been made that additional neighbourhood shops will be required. This would indicate the total absence of a proper and thorough review of the local area. With a population of approximately 7,500 Hullbridge already has 3 supermarkets as well as independent shops such as a butcher, greengrocer and bakers, which is more than adequate. The area is also woefully shot of offices and other business premises, another reason why any additional shops would struggle to survive alongside the existing ones.

Also, additional investment would be put to better use if facilities at the skate park and the currently under-used youth centre were vastly improved instead of creating more facilities which are obviously not needed given current usage.

In conclusion, I believe the DPD to be unsound because it has not been positively prepared, cannot possibly be justified and will certainly not be effective.

2. Highways

Although mention of limited highway improvements is in the report no detail is given as there is no Core Strategy Transport Assessment from Essex County Council or elsewhere. The only Transport Impact Assessment required will be developer funded and relate only to SER6, without taking into account either highway issues or other developments (eg SER1) elsewhere in the District. No assessment of road improvements required has been made and Ferry Road, onto which much of the new traffic will go, has not been mentioned in the report.
At present Rawreth Lane is at, or near, capacity and when Watery Lane is closed, a common occurrence, traffic backs up along Downhall Road and Rawreth Lane towards Rayleigh and Hullbridge Road and Lower Road towards Hockley and Rochford making journeys to or from Rayleigh or Chelmsford difficult.
No impact on the district has been made with regard to the Fairglen Interchange (A127/A130/A1245) which lies just outside the District but which has a profound knock on effect when flooded with cars moving to either London Road or Rawreth Lane, to roads affected by SER6 and also, more directly by SER1.
It is stated that highway improvements should be made to accompany the development of the site, this will be too late as improvements must be made first given the current state of the highways network.

If they do not live in Hullbridge they have no idea about traffic - flooded roads etc. Traffic comes into Hullbridge to cut out speed cameras on A127 plus big lorry's.

1. Development is detrimental to the current Community

The site is not properly integrated with the existing village of Hullbridge. A "green buffer" is to exist "in perpetuity between new and existing developments".
The 3.6 hectares of natural green space will only be directly accessible from the new development.
This development as proposed, as evidenced above, will not promote community cohesion but will in fact be creating a separate village to Hullbridge destroying the current community feeling that exists.

2. Highways

Although mention of limited highway improvements is in the report no detail is given as there is no Core Strategy Transport Assessment from Essex County Council or elsewhere. The only Transport Impact Assessment required will be developer funded and relate only to SER6, without taking into account either highway issues or other developments (eg SER1) elsewhere in the District. No assessment of road improvements required has been made and Ferry Road, onto which much of the new traffic will go, has not been mentioned in the report.
At present Rawreth Lane is at, or near, capacity and when Watery Lane is closed, a common occurrence, traffic backs up along Downhall Road and Rawreth Lane towards Rayleigh and Hullbridge Road and Lower Road towards Hockley and Rochford making journeys to or from Rayleigh or Chelmsford difficult.
No impact on the district has been made with regard to the Fairglen Interchange (A127/A130/A1245) which lies just outside the District but which has a profound knock on effect when flooded with cars moving to either London Road or Rawreth Lane, to roads affected by SER6 and also, more directly by SER1.
It is stated that highway improvements should be made to accompany the development of the site, this will be too late as improvements must be made first given the current state of the highways network.

3. Sewage/Drainage

The sewage system within Hullbridge is already at or near capacity. Although mentioned in the report no assessment of needs has been made.
Part of the area proposed is prone to flooding. It is not shown as flood risk however as it is farmland and no claims have been made against insurance. Flood Risk is based on insurance claims made.

4. Rawreth

Approximately one third, or around 6.2 hectares, of development SER6b (the second phase) will be in Rawreth, not Hullbridge. This also relates to point one above about community cohesion.
If the residents of the housing in SER6b live in Rawreth they will not be a part of Hullbridge, they will be represented by Rawreth Parish Council and Downhall and Rawreth District Councillors. They will pay a Parish Precept to Rawreth but get the facilities of Hullbridge. Such a separation will again not foster Community Cohesion and does more to encourage the new development as a separate community.

5. Youth

Hullbridge has a Youth Centre which is currently underused; additional investment should be made to facilities there or at the Skate Park in the recreation ground rather than have additional facilities which will be underutilised.

6. Neighbourhod Shops

The suggestion that additional neighbourhood shops are required suggests a proper review has not been done of A1 use in Hullbridge, which then gives a concern about the report as a whole. With a population of around 7,300 Hullbridge has three supermarkets; The Co-op, One Stop (owned by Tescos) and Budgens as well as a number of other independent shops including a butcher and a greengrocer etc. Hullbridge is more than adequately served by shops.
Hullbridge is short of other business premises such as office or studio facilities.

1. Development is detrimental to the current Community

The site is not properly integrated with the existing village of Hullbridge. A "green buffer" is to exist "in perpetuity between new and existing developments".
The 3.6 hectares of natural green space will only be directly accessible from the new development.
This development as proposed, as evidenced above, will not promote community cohesion but will in fact be creating a separate village to Hullbridge destroying the current community feeling that exists.

2. Highways

Although mention of limited highway improvements is in the report no detail is given as there is no Core Strategy Transport Assessment from Essex County Council or elsewhere. The only Transport Impact Assessment required will be developer funded and relate only to SER6, without taking into account either highway issues or other developments (eg SER1) elsewhere in the District. No assessment of road improvements required has been made and Ferry Road, onto which much of the new traffic will go, has not been mentioned in the report.
At present Rawreth Lane is at, or near, capacity and when Watery Lane is closed, a common occurrence, traffic backs up along Downhall Road and Rawreth Lane towards Rayleigh and Hullbridge Road and Lower Road towards Hockley and Rochford making journeys to or from Rayleigh or Chelmsford difficult.
No impact on the district has been made with regard to the Fairglen Interchange (A127/A130/A1245) which lies just outside the District but which has a profound knock on effect when flooded with cars moving to either London Road or Rawreth Lane, to roads affected by SER6 and also, more directly by SER1.
It is stated that highway improvements should be made to accompany the development of the site, this will be too late as improvements must be made first given the current state of the highways network.

3. Sewage/Drainage

The sewage system within Hullbridge is already at or near capacity. Although mentioned in the report no assessment of needs has been made.
Part of the area proposed is prone to flooding. It is not shown as flood risk however as it is farmland and no claims have been made against insurance. Flood Risk is based on insurance claims made.

4. Rawreth

Approximately one third, or around 6.2 hectares, of development SER6b (the second phase) will be in Rawreth, not Hullbridge. This also relates to point one above about community cohesion.
If the residents of the housing in SER6b live in Rawreth they will not be a part of Hullbridge, they will be represented by Rawreth Parish Council and Downhall and Rawreth District Councillors. They will pay a Parish Precept to Rawreth but get the facilities of Hullbridge. Such a separation will again not foster Community Cohesion and does more to encourage the new development as a separate community.

5. Youth

Hullbridge has a Youth Centre which is currently underused; additional investment should be made to facilities there or at the Skate Park in the recreation ground rather than have additional facilities which will be underutilised.

6. Neighbourhod Shops

The suggestion that additional neighbourhood shops are required suggests a proper review has not been done of A1 use in Hullbridge, which then gives a concern about the report as a whole. With a population of around 7,300 Hullbridge has three supermarkets; The Co-op, One Stop (owned by Tescos) and Budgens as well as a number of other independent shops including a butcher and a greengrocer etc. Hullbridge is more than adequately served by shops.
Hullbridge is short of other business premises such as office or studio facilities.

1. What is proposed in the document is about two new developments without any connection to the community they will be part of.

2. In deciding the facilities it doesn't take into account existing facilities.

3. Detail of the new road improvements are not included.

4. The document doesn't regard essential requirements of an increase in population e.g. Employment, Medical Care and Education.

5. The fact that part of the new development is in Rawreth has not been commented on.

1. Development is detrimental to the current Community

The site is not properly integrated with the existing village of Hullbridge. A "green buffer" is to exist "in perpetuity between new and existing developments".
The 3.6 hectares of natural green space will only be directly accessible from the new development.
This development as proposed, as evidenced above, will not promote community cohesion but will in fact be creating a separate village to Hullbridge destroying the current community feeling that exists.

2. Highways

Although mention of limited highway improvements is in the report no detail is given as there is no Core Strategy Transport Assessment from Essex County Council or elsewhere. The only Transport Impact Assessment required will be developer funded and relate only to SER6, without taking into account either highway issues or other developments (eg SER1) elsewhere in the District. No assessment of road improvements required has been made and Ferry Road, onto which much of the new traffic will go, has not been mentioned in the report.
At present Rawreth Lane is at, or near, capacity and when Watery Lane is closed, a common occurrence, traffic backs up along Downhall Road and Rawreth Lane towards Rayleigh and Hullbridge Road and Lower Road towards Hockley and Rochford making journeys to or from Rayleigh or Chelmsford difficult.
No impact on the district has been made with regard to the Fairglen Interchange (A127/A130/A1245) which lies just outside the District but which has a profound knock on effect when flooded with cars moving to either London Road or Rawreth Lane, to roads affected by SER6 and also, more directly by SER1.
It is stated that highway improvements should be made to accompany the development of the site, this will be too late as improvements must be made first given the current state of the highways network.

3. Sewage/Drainage

The sewage system within Hullbridge is already at or near capacity. Although mentioned in the report no assessment of needs has been made.
Part of the area proposed is prone to flooding. It is not shown as flood risk however as it is farmland and no claims have been made against insurance. Flood Risk is based on insurance claims made.

4. Rawreth

Approximately one third, or around 6.2 hectares, of development SER6b (the second phase) will be in Rawreth, not Hullbridge. This also relates to point one above about community cohesion.
If the residents of the housing in SER6b live in Rawreth they will not be a part of Hullbridge, they will be represented by Rawreth Parish Council and Downhall and Rawreth District Councillors. They will pay a Parish Precept to Rawreth but get the facilities of Hullbridge. Such a separation will again not foster Community Cohesion and does more to encourage the new development as a separate community.

5. Youth

Hullbridge has a Youth Centre which is currently underused; additional investment should be made to facilities there or at the Skate Park in the recreation ground rather than have additional facilities which will be underutilised.

6. Neighbourhod Shops

The suggestion that additional neighbourhood shops are required suggests a proper review has not been done of A1 use in Hullbridge, which then gives a concern about the report as a whole. With a population of around 7,300 Hullbridge has three supermarkets; The Co-op, One Stop (owned by Tescos) and Budgens as well as a number of other independent shops including a butcher and a greengrocer etc. Hullbridge is more than adequately served by shops.
Hullbridge is short of other business premises such as office or studio facilities.

I write in relation to Rochford District Council's current consultation on the emerging Site Allocations Development Plan Document Submission Draft (2013). This representation has been prepared by Strutt and Parker LLP on behalf of H R Philpot and P W Robinson and Son.

H R Philpot and Sons and P W Robinson are local landowners with interest to the west of Hullbridge. Their land as shown on figure 1 had previously been promoted at both Core Strategy and Site Allocations stage by Bidwells. Strutt and Parker have now been appointed to promote land to the west of Hullbridge on their behalf and act as their planning agent.

Policy SER6

This representation is made specifically in relation to policy SER6, which relates to land at South-West Hullbridge. Our clients fully support this policy, which is considered for the purposes of this consultation to be 'sound.' The policy meets all of the tests identified in the National Planning Policy Framework (NPPF) for emerging Development Plans, in that it is considered to be fully justified, effective and consistent with national policy.

The principle of allocating this area of land was established as part of the adopted Core Strategy (policies H2 and H3), which make provision for a minimum of 500 dwellings to be delivered at land at south- west Hullbridge over the Development Plan period. The Site Allocations plan seeks to clearly define the boundaries for the south- west Hullbridge site allocation. The proposed boundaries are fully supported and provide a logical expansion to Hullbridge. In particular the proposed residential allocation SER 6b is well related to the existing north and west development boundaries of Hullbridge and Hullbridge village centre. It will provide both a sustainable expansion to the village, which has a limited impact on the countryside.


The land under the control of our clients covers an area of 38.6 hectares and is located immediately adjacent to the west boundary of SER6b. It also extends north and adjoins the existing west development boundary of the village. Our client's site is very well related to the existing residential development in Hullbridge. Once SER6b has been completed our clients land will have a continuous eastern frontage with the development boundary for Hullbridge. The location of the site is shown on figure 1.

It is considered that when Rochford District Council undertake a review of the Core Strategy and Site Allocations Plan that our clients site should be allocated for a residential lead development. Our client's site is considered to be without question the most suitable site to deliver the medium to longer term growth in Hullbridge. This is based on its very sustainable location in close proximity to the village centre and being well enclosed in the countryside by the development and growth area boundaries to the east and by the river Crouch to the north.

It is appreciated that the review of the Local Plan will be sometime in the future and will be dependent on the speed that the current allocations are completed and the level of demand for new housing. However, in accordance with the NPPF it is appropriate for the Council to consider both the medium and longer term housing needs of the District. On this basis Rochford District Council should be informed that our client's site is fully deliverable and available for residential use. In the event that any of the allocated sites within the Site Allocations Plan prove not to be deliverable or if there is a requirement for additional housing within the District prior to the completion of the current plan period, our clients would be prepared to engage with the Council in relation to the early delivery of land to the west Hullbridge.

In summary policy SER 6 is fully supported and the proposed boundaries of this site are considered to be fully supported and justified in planning policy terms. I must also note that the land is ready and available. The landowners are as one and the site can be delivered accordingly should additional land be required.

We do not consider it necessary to speak at the Examination in Public but would ask that you take this representation into consideration prior to the adoption of the Site Allocations Plan.

1.1 The Hanover Land Trust makes the following Representation regarding Rochford District Council's Planning Policy SER6 on the basis that it is not effective and therefore is unsound. This is on the basis of the recent exclusion of part of Preferred Option SWH4 known as Site 17 in the Council's 'call for sites', in regard to perceived economic and other factors.

1.2 For instance there appears to be no clear Transport Strategy for this locality and indeed for the overall district in conjunction with adjacent areas immediately outside the Hullbridge boundary.

1.3 The County Council, together with Rochford District Council and their planners have established that to make SER6 a sustainable development, that major Infra-Structure Improvements will need to be implemented in the locality of the existing triple road junction of Lower Road, Hullbridge Road and Watery Lane (which floods), situated to the south of SER6 and north west of Site 17.

1.4 The items of major Infra-Structure necessary for SER6 to succeed comprises, Highway improvements, possibly incorporating a roundabout and an additional access road into SER6, Surface water drainage, domestic drainage, an integrated Sustrans Bridleway/cycle route and better public transport provision.

1.5 The Hanover Land trust and its partner Swan Housing Association believes that SER6 as it stands is insufficient to supply all the housing and the necessary funding which will be required under any Section 106 agreement needed, to help provide the above improvements.

1.6 To assist in mitigation this unfavourable projection, The Hanover Land Trust moves that as part of Site 17 is already partly developed with five dwellings, which are contained separately within Site 17, an expired planning consent and another part being White Land within the Town Planning envelope; That Site 17 should be included in Planning Policy SER6a.

1.7 If the remainder of Site 17 were to be removed from the greenbelt to be included in Planning Policy SER6, the conveniently placed five and a half acre site which contains the main surface water drainage route would be a useful supplementary component to help fulfil the Council's aspirations in this locality.

1.8 Site 17 was officially 'Screened In' in the ADPD Evidence Base and fulfilled all required criteria, rendering it technically qualified for the Council's proposals, the Respondents strongly feel the Council and their planners have inadvertently overlooked the opportunity to utilise and capitalise on this potentially important adjunct to SER6 by finally assigning most of Site 17 as greenbelt over and above some of the prime agricultural land designated as SER6b.

1.9 After many years of campaigning to promote development on Site 17, The Hanover Land Trust and Swan Housing Association consider it would be grossly unfair and an injustice, if the Council/Planners at some future date, when implementing SER6 needed to secure Site 17 for supplementary infra-structure projects, without the economic support of some new housing development within the Site 17 drainage perimeter.

1.10 Finally, it should be stated that if Site 17 were in retrospect to be included in Planning Policy SER6, The Hanover Land Trust and its partner Swan Housing Association is ready and able to participate in regard to assisting the Council's intentions for South-West Hullbridge.

Note: Documents referred to in completing this Representation form:

1. Representation Submission Form
2. Local Development Framework Core Strategy Submission Document (with proposed minor amendments highlighted)
September 2009 (amended September 2011)
3. Local Development Framework Allocations DPD Discussion and Consultation Document Regulation 25, dated February
2010.
4. Have your say- Rochford District Core Strategy Schedule of Minor Amendments (2011) consultation.
5. Rochford Core Strategy DPD - Schedule of changes dated 17. 11. 2010.
6. Localism Act 2011 Chapter 20.

Foreword to our submission of the accompanying Representation Form.

Whilst we recognise that the documents referred to above sets out a strategy for an efficient development, we are not satisfied that the following items are sufficiently identified and highlighted in respect of the infrastructure works necessary prior to any development works on the 22 Ha site in Hullbridge identified as 'Site option SWH1' on pages 34 & 35 in the Local Development Framework-February 2010, Allocations DPD Discussion and Consultation Document Regulation 25.

We commence our submission with our comments on the first four pages of the Introduction of the Representation Form

Page 1 Item 2. Legal compliance of section 20(5)(a) of the Compulsory Purchase Act 2004.

Item 2.1 We are unable to find the reason for the Inspector's need to check the Legal Requirements of the Compulsory Purchase Act when there is no mention of possible Compulsory Purchase of the land or property in question in respect of the proposed development/s.

We request clarification of this statement.
Page 2

Item 2.1 (5th bullet point) - Localism Act 2011 chapter 20.

Although the 'words' localism Act is stated in this paragraph, the due additional number (2011) and 'words' 'Chapter 20' is not indicated. Bear in mind that this 'Act' was not brought into force till 2011, the community would not have been aware of the policies which the community could take advantage of as the Core Strategy and Allocations DPD Documents were not published till 2009 and 2010 and 2011.



1

Page 2 (cont Foreword (cont

In view of this very important issue having some long lasting effect in the Hullbridge Community (specifically), we have referred to the Localism Act 2011 (chapter 20) the clauses referred to are as follows and applied generally to this whole representation:

Community Rights to challenge - Part 5, Chapter 2, Clauses 81 to 86.

Plans and Strategies - Part 6, Chapter 1, clauses 109 to 113.

Neighbourhood Planning - Part 6, chapter 3, clauses 116 to 121.

Consultation - Part 6, chapter 4, clause 122

Item 3.1

Positively prepared.

In view of our observation that not enough planning has been done towards Preparatory and Enabling Infrastructure works prior to any development as mentioned above.
We ask you to include a clause to this affect to allay our fears that the existing infrastructure is inadequate to allow the necessary connections to any new development. To that extent we are not satisfied that enough consideration has been given to this issue.

Justified.

In view of past experience, we hope that you will amend the policies, add or delete certain policies which need addressing according to our submission hereby made, and particularly where we require satisfaction that you have made the amendments in accordance with our reflection to the Localism Act 2011 chapter 20 stated above.

According to the Localism Act 2011, there is supposed to be transparency and consultation with the community, we hope our voice will be heard and an appropriate response received.

Page 3
'Effective'

With regard to all 4 items we are unable to find appropriate information in respect of the Preparatory/ Enabling works necessary to accommodate the general infrastructure works necessary for the new development.

We are not convinced that the planning issues referred to generally satisfy the Planning requirements, in particular the preparatory and enabling infrastructure works necessary prior to any new development taking place, which should also include the necessary 'flood' defences and improvement of Watery Lane, therefore we request a new policy be added to the Discussion and Consultation document to allow discussion by the the Hullbridge community, all in accordance with the policies stipulated in the Localism Act 2011 as referred to above.

The third item "delivery partners........" this seems to imply that a partnership has been formed between the RDC and A.N. Other. We are unable to find information in respect of this clause or policy.

We request a Policy inserted in the Document explaining the whole meaning of this policy and if this partnership is now Legal Conformity.

With respect to "coherence with the strategies ................." we require a policy statement explaining if all neighbouring 'authorities' have been consulted and what the results are of this consultation.

'Consistent with National Policy'
The items referred to in this presentation can imply reasons for a delay to allow further consultation, in view of new Government legislation which was not available at the time/s of formulation, i.e. the Localism Act 2011 Chapter 20.


2

Page 4 General advice

Item 4.1 The issues referred to in this Representation including information given in the 'Foreword Notes' at the start of this representation will provide you with ample reasons for a change to the DPD, we hope you will kindly take this into consideration.

Item 4.2 This Representation has been written under the direction of a number of residents of Hullbridge whose names and addresses are set out on a separate page and I have been authorised as their agent for this purpose.

END OF FOREWORD


Ref. Local Development Framework Core Strategy Submission Document (with proposed minor amendments highlighted) September 2009 (amended September 2011).

We submit that a statement be inserted in this section in respect of the Preparatory and Enabling infrastructure works be implemented prior to any new development works taking place in Hullbridge and our reasons are given below.

Page 38/39 -Vision

Short Term.

Preparatory and Enabling Infrastructure works:

Flood defences. Terrain susceptible to Flood

Development costs will have to take into account deep piling foundations due to the flood terrain in the whole designated new development area of Hullbridge (Site SWH1- see page 34).

We submit that a policy be inserted into the LDF Document that the environment agency is consulted and to confirm that adequate measures will be taken to develop flood defences in the vicinity of this development in Hullbridge prior to any housing development taking place.

The flood defences construction should include flood relief measures in watery lane and surrounding area, with adequate drainage facilities to remove surface water to a 'reservoir' or suitable 'collection point', and to upgrade the existing drainage system.

We require a new policy be inserted in the LDF Document to address this 'flood' area, by consulting with the Insurance industry in respect of properties being built in this green belt land.

In view of the statement made in the 'introduction pages' in respect of entering into 'Partnership' ( refer to page 3-'effective') we consider it is imperative that a policy to this effect should be inserted in the LDF Document to make it clear that all insurance aspects have been considered, what the risks are likely to be, and what the implications will be to the cost and sale/ rent prices of the properties in the new development area.

We request a further policy to address the Legal arguments in relation to the above.

Watery Lane

This lane has always been susceptible to flood, causing severe traffic congestion that use this lane every rush hour with or without warning notices being in place, used as a short cut to the A130 and/or detour to surrounding main roads, the records from the River and Environment Authority must bear witness.
This lane is inadequate for traffic, is subject to weight restrictions, width restrictions and weak bridges. The Satellite Navigation system directs all traffic through Watery Lane.
There is no mention in any of the documents that watery lane should be a 'priority' improvement, as a main access road to and from Hullbridge, and submit to you that this road be converted to 'Road' status allowing for extensive improvement and to allow access to the new development on 22 Ha green belt land.

We request a policy be included in the LDF Core Strategy Document in this respect.

3
Ref. LDF/Core Strategy Submission Document (with proposed minor amendments highlighted) (cont.

Preparatory and Enabling Infrastructure works (cont):

Drainage- surface and foul water

We are not confident with your statement made on page 34 of the Allocations DPD (LDF) February 2010 document which states specifically that, (hereby reproduced) 'The Core Strategy Submission Document requires that the following infrastructure is implemented alongside any development in this location: local highway capacity and infrastructure improvements, public transport infrastructure and service improvements, enhancements and links to pedestrian, cycle and bridle network, and (A) Sustainable Urban Drainage Systems all of which this site has the capacity to provide. (B) The site would afford good opportunities for the creation of a strong defensible green belt boundary.

We submit that the highlighted sections of the above statement (A) should be changed to state that the preparatory and enabling drainage works be completed prior to any new development, to allow adequate connections to the existing drainage system of the Hullbridge site, and (B) if the existing green belt has been encroached now, how can we be
certain that this will not be repeated in the future.

We require amendments to this policy to confirm that no encroachment will take place in the future of the green belt land, the changes required to this policy are consistent with the policies stated in the Localism Act as referred to above.

Existing roads and pathways

The existing roads, particularly Malyons Lane and Windermere Avenue, which are being put forward to be the access roads to the new development we maintain are inadequate for this purpose. Both these roads need improvement to a much higher standard to allow the increase in vehicular traffic which will emanate from the 500 unit development (some 1000 vehicles).
Proper drainage system must be constructed to accommodate the distribution of the surface water.
Standard pathways to be constructed to improve the environment and safety of the community, present state of pathways are inadequate. The walkways on Ferry road have long been in need of extensive improvement, the uneven surfaces are plain to see.

We request that the RDC review the strategy for the short, medium and long term to satisfy the needs of Hullbridge, and change the policy statement to state that preparatory and enabling works be done in advance of the commencement of the development.

Access Roads

As stated above, Malyons Lane and Windermere Avenue are designated as access roads to the new estate which will be inadequate for purpose at present.
Road lighting must be improved to the existing network prior to any further development taking place.

We would like an amendment to the existing statements in respect of roads and to include additional/alternative routes to the new development to eradicate possible blockage of vehicular traffic access, preferably via Watery lane, which will allow watery lane to be upgraded to 'road' status, thereby alleviating any congestion or other problems to occur in the future.

Services

Water, Electric, gas and general communication networks improvements must be made to the existing network prior to new developments to allow connection from the new development.
The existing services require improvement and preparatory works should be done to accommodate future housing development.

We have not been advised of the preparation and enabling works necessary for all the existing services, including consultation with existing facilities and services such as Medical, Educational, Environment, flood containment, transport and highways agency for the proposed development in Hullbridge.

We request a new policy should provide for a programme of Preparatory and Enabling works be stated in the Local Development Framework Document.
4
Ref. LDF/Core Strategy Submission Document (with proposed minor amendments highlighted) (cont.

The Density of dwellings development on 'Site SWH1'.

Our observation of the important aspects of the documents mentioned above also indicates the following:
LDF Allocations DPD February 2010, area allocation SWH1- Appendix 2, Schedule of site areas indicates 22 Hectares for Hullbridge area. And the policy statement in the LDF / Allocations DPD Document, with particular reference to Option SW1 on page 34, specifically states that "The core strategy Submission Document requires that the following infrastructure is implemented alongside any development in this location".

We are not confident with your statement within that paragraph that "this site has the capacity to provide", and no
confidence that the existing services are able to contain additional capacity to allow connection from any new development, without the existing infrastructure improvements in preparation for the additional population.

We are not confident that your calculations for the proposed development has taken into consideration the impact of the 500 unit development on the existing number of units (3100) and the percentage this represents, approximately 16% , with the corresponding impact this will have on the existing community of some 7300 which will increase by approximately 2000 residents (500 x 4 persons per property) = 27% over existing population.

Page 34 of the LDF Allocations DPD Discussion and Consultation Document February 2010, states that this area of green belt land is required for A) 500 dwellings, B) Public open space, C) play space and D) Youth, leisure and community facilities.

We are unable to find a space distribution schedule to allow for all the items mentioned above, and we cannot find any information which provides the density for dwellings per hectare.

However, we set out a mathematical exercise to determine the use of 22 hectares as follows:
Ha
A. 500 Dwellings = say 85% x 22 Hectares = 18.70
B. Public open space = say 7.5% x 22 Ha = 1.65
C. Play space = say 5% x 22 Ha = 1.10
D. Youth, leisure facilities = say2.5% x 22 Ha= 0.55
Total distribution of space = 22.00

The requirement is that 35% of the proposed dwellings need to be 'affordable units' which may be 2 to 3 story units (175 flats), therefore 500 less 175 = 325 units may be low level homes (2 floors) and 175 units may be built within high level development (3 to 4 storey).
The calculations are interpreted thus: 325 dwellings (low rise) to be built on 13.09 Ha
175 dwellings (high rise ) to be built on 5.61 Ha
Total hectares = 18.70 Ha

We are concerned that the density in accordance with the exercise given above will be much greater than what would be considered normal in rural areas. There is concern on the impact of such a density and will impact on congestion and affordability (freehold or rent) and may have a divisive community affect where the new will be compared with the older properties, human nature will take its course and cause problems for the future.

In terms of Area allocation as described in the Allocation DPD LDF Document February 2010, Appendix 2, Schedule of site areas , Hullbridge reference SWH1 is placed tenth for the number of dwellings to be built, of a total number of 37 sites and is 'high' in encroachment of 'green belt area'.

Employment

With respect to employment, it may be advisable to include a policy to ensure that employment be given to suitable residents, knowing that if this development takes place our community can have the benefits from this project.

Green belt land use.

We read with interest that after the said use, subject to any Compulsory Purchase Order which may be necessary for any reason, that the policy suggests that the remaining green belt in this area will be strengthened in safeguards, the same policy existed before the encroachment of this green belt land but RDC were able to find a way of over-riding that policy, how can the RDC convince the community of Hullbridge that the same may not occur in the future.

5
Ref. LDF/Core Strategy Submission Document (with proposed minor amendments highlighted) (cont.

Generally

We consider the whole question of development in this area needs reviewing and all the necessary institutions should be consulted including the Insurance industry, Legal profession, Highways agencies and the companies supplying the services (we need satisfaction that the 'capacity' for all services are in place to connect to the new development), if not arrangements will be made through the planning authorities to provide additional services.
We consider this 'additional' policy will be extremely important for the satisfactory delivery of the new dwellings, and to satisfy the policies stated in the Localism Act 2011.

End of Preparatory and Enabling Infrastructure Works
_____________________________________________________________________________________








































6

Reference to LDF (September 2009 (amended Sept. 2011) Core Strategy Submission Document (with proposed minor amendments highlighted).

Page 8

Schedule of changes.

Item 1.6.1 to 1.6.3.

We give notice that all the items mentioned will be referred to as issues in the appropriate Sections:
Housing, Character of place. Green Belt, Environmental issues, Community infrastructure, leisure and tourism, Transport, Economic Development and retail.

Items 1.7 to 1.13

We state that insufficient time was set aside for community consultation and we hope our representation will allow further consultation before the Documents are handed over to the Government Inspector for approval particularly to the advent of the Localism Act 2011 Chapter 20.

Page 19

LAA2 Priority 3. Refer also to Page 87 Policy 3. Page 91 policies 9.15, 9.16 and 9.18.

We are concerned that with the Primary Care Trust being abolished, the Role of Care Strategy will be detrimentally affected.

We suggest an amendment, insertion and appropriate explanation as to any alternative arrangements that the NHS may apply through their future planning procedures which may take the place of the services previously supplied.

Page 22

Provision of additional Gypsy sites.

Policy 1.25
We are concerned why are Travellers/Gypsies are provided with facilities and amenities without any financial contribution being made or that any legislation provision to observe what is required by laws in force for the general population of the UK.
How and by what means are the required budgets set aside for this financial assistance to facilitate the services required for each site, we presume the provision is made via the tax payers.

A fundamental review of this policy is required and a new policy set out for this purpose and the policies referred to below should also be explained with full consultation with the Hullbridge Community in accordance with the requirements set out in the Localism Act 2011.

Refer also to Page 54-Policies 4.45 to 4.47. Page 55-Policy H7.

Having studied the proposals and amendments we consider there is some confusion in the number allocation stated.

Page 54-Policy 4.46. This policy does not provide the principles of allocation of 3 pitches in 2006.

Page 54-Policy 4.47. This policy does not provide the principles of planning permission being given in 2010 for 7 pitches and what criteria used.

Page 55-Policy H7. How were the principles of allocation of additional 15 pitches arrived at in 2011, this is not explained.

Page 142 Policy H7 (5th column).





7
Reference to LDF (September 2009 (amended Sept. 2011) Core Strategy Submission Document etc. (cont.

Page 22 (cont.

Provision of additional Gypsy sites (cont.

Policy 1.25 (cont

Due to some confusion which has arisen in respect of the compound annual increment of 3% evaluating to 15 in 2011 from a base line of 3 or 10.

We are unable to find a policy which will provide a guarantee that no expansion will take place as it did in the Basildon site. We are extremely concerned that the same problem will arise as that for Basildon, along with the financial consequences .

We are unable to find a policy which provides for dismantling the sites after the Travellers/Gypsies have gone from the site and indeed there does not seem to be a 'time frame' for the use of these sites.

We recommend a re-evaluation of the above policies and amend or provide new policies in the LDF document, and to take into consideration proper consultation with the community in accordance with policies stipulated in the Localism Act mentioned above.

Page 24

Policy 1.29 Affordable Housing. Refer also to RDC policy 4.15 page 47.

In view of the difficult building development situation due to the flooding aspects of this area, including 'watery lane', environmental issues as mentioned on page 3 under 'infrastructure preparatory and enabling works' it is very difficult to believe the evaluation of 80% of the market rent or sale price will be achievable, given that there is great doubt that the properties would be adequately insurable. The building costs with the proper safeguards against flood will make the rent or purchase prices out of reach with the present problems of gaining mortgages, we are not confident that Insurance Companies will be able to provide 'reasonable' comprehensive insurance premiums.

We are unable to find a policy that provides information about risk assessments and analysis, having been made to include the flood defences, and a comparison schedule of possible environmental changes that have been predicted for the foreseeable future.

We respectfully request this policy is reviewed and the Hullbridge community are consulted in accordance with the policies stated in the Localism Act 2011 referred to on page 2 of this submission.

Policy 1.29 Strategic Market Housing assessments. Refer also to RDC policy 4.15 page 47.

In view of the out of date information, given that this assessment was made in 2010, it is likely that the financial 'affordability' situation would have changed, therefore we consider a review is now necessary which may have some implication on affordability.

Page 26

Policy 1.29 Environment and Flood

We submit, as you did on 11th May 2011, that the case law applied to the historical environmental assessments, a policy review needs to be applied for the future years in view of the important new environmental knowledge gained recently, as witnessed, the risk assessments should be highlighted before any authoritative positive decision is made.

Similarly the Sustainable Appraisal was prepared and consulted in June and July 2011, again, as above, there are mitigating circumstances to request a review in light of the new environmental issues which will affect the development as referred to on Page 23 Policy 1.29 mentioned above.





8
Reference to LDF (September 2009 (amended Sept. 2011) Core Strategy Submission Document etc. (cont.

Page 30

Policy 2.29 East of England plan is revoked

We are unable to find the meaning of this paragraph under the heading of 'The east of England Plan has been Revoked', in reference to the Rochford Core Strategy DPD, schedule of changes dated 17.11.10, it is not understood, and goes on to explain this represents 'Option 1' but does not indicate the actual 'revocation'.

In briefly scanning this document, we are unable to see what other 'options' were taken into consideration and does not provide any information regards the methods or reasons for the adoption of 'Option 1'.

We are unable to find reasons for the change of 'development years' from 2001 to 2021 and 2011-2031, and we presume that the 'additional' 810 and 618 units (policy 2.31) are included in the 2001 to 2011 appraisal!

We request a revision and expansion of the wording of this policy to make it more understandable.

Policy 2.31

The revoked E of E Plan states 810 and 618 dwellings were completed between 2001 and 2008, are these figures included in the overall 3800 dwellings mentioned above or are these numbers excluded in which case the wording of this clause requires amendment.

Page 31

Policy 2.35

The phrase indicates additional 131 dwelling per annum to be developed, we presume the total number over and above the 190 dwellings planned will be 321. This figure equates to 6420 dwellings over 20 years (2011 - 2031).
The Thames Gateway South Essex Strategic Housing market Assessment notes a need for at least 35% of these developments need to be 'affordable' which equates to 2247 dwellings.

Taking into consideration the calculations provided below, we respectfully request an overall amendment to make clear exactly the number of dwellings to be built as this may affect the distribution of dwellings to be built, the normal density of development is not given.

The following Policies are brought down to try to understand what this proposal indicates.

Pages 30 and 31. Representing:

Policy 2.29. Housing required = 3800 over a 20 year period from 2011 to 2031 = average 190 per annum.

Policy 2.31. Revoked E o E plan = 810 completions between 2001 to 2006 = 810 and completions between 2006 to 2008 = 618. Total completions between 2001 to 2008 = 1428.
Calculations: 3800 less 1428 completions = 2372

Policy 2.32. Continuous delivery of homes to at least 2026.
Calculations 2009 to 2026 = 17 years @ 190 pa = Total 3230 homes to be built by 2026 (2031 ?)
Assuming no new homes built between 2009 and 2015 = 6 yrs @ 190 pa = 1140 new homes suggests a shortfall ?

Add 131 net additional dwellings pa. (Commencement date is given as 2015)

Calculations:
A) Policy 2.31. Remaining houses assumed to be built = 2372 + 1140 (shortfall policy 2.31) = 3512
(Assumed to be built between 2015 and 2031 = 16 years) add 131 @ 16 = 2096 + 3512 = 5618 new homes.
B) (As above but built between 2015 and 2026 = 11 years) add 131 @ 11 = 1441 + 3512 = 4953 new homes.

We consider the above policies are confusing and request an amendment to give complete clarity.


9
Reference to LDF (September 2009 (amended Sept. 2011) Core Strategy Submission Document etc. (cont.

Page 37

Policy 3.1 to 3.3

With reference to the CSS Documented (amended September 2011) this page states policy or clauses numbered 2.67 to 2.73 and 3.1 to 3.3 are not indicated. Page 38 of the CSS document refers to the 'Vision' statement which we presume are what you mean as 'additional text', please clarify and amend accordingly.

Page 38/39

Vision (Ref. LDF/CSS Document (amended September 2011).

Page 39, policy 4.2

The E of E Plan (2008), having been revoked, why does RDC insist that 'Option 1' is deemed to be the most appropriate, without providing any information on alternatives that may have or should have been considered. We request an urgent review on this policy issue before any ratification takes place, and indeed to have proper consultation with the local population in accordance with the Localism Act.
Our statement above in respect of page 29 policies 2.29, 2.31 and page 30 policy 2.35 confirms our request for an urgent review of these policy statements.

Page 39

Policy 4.3

RDC allocation is based on meeting 'current and future' needs, but the repetition of the words 'balanced with sustainability considerations' needs explanation, in our view the words are vague, and according to your population figures you indicate an increase of 5,700 (87,000-81,300) by 2021. However if we consider the figure of 3800 units x average of 4 persons = 15,200, so how have you calculated your increased population figures?

We request a fundamental review of this policy statement consistent with the general policy to consult with the Hullbridge community in accordance with statements made in the main documents and the Localism Act.

Page 39, 40,

Policies 4.4, 4.6 and Table.

There is a change in years from 2001-2021 to 2011-2031 and the units stated on page 29, policy 2.31 are included in the overall 3,800 units.
In respect of 'Allocation of land' - an explanation of the distribution of units between 'brown field land', 'white land' and 'Greenbelt land' is required along with the density of development per acre/hectare in accordance with the types of development, we are unable to find reference to this distribution.
We are concerned that the utilisation of derelict and abandoned land has been fully explored and taken into consideration in the overall Plan.

Our calculation assessment of the figures provided in the Table suggests encroachment on green belt land will be approximately 105% on 1243 units, how is this justified?

We request a complete review of the above policy statements with appropriate consultation with the Hullbridge community as stated before.









10
Reference to LDF (September 2009 (amended Sept. 2011) Core Strategy Submission Document etc. (cont.

Page 42

Policies 4.16 and 4.17

We are not satisfied or indeed confident that you have fulfilled your obligation to explore every avenue to find land that may be laying derelict, brown field land etc, before encroachment on green belt land for development.
A full review of this policy statement to satisfy the clauses which require consultation and to amend the contents of this statement, will be of immense benefit to all concerned.

Page 44

Policy 4.25.

The statements in this policy conflict with policy statements made above in respect of annual average units expected to be developed and that exact figures would be determined through the allocations Development Plan Document. In reading the allocation document which does not indicate a date of preparation and does not give us confidence that the numbers have been properly determined.

A full review of this policy statement to satisfy the clauses which require consultation and to amend the contents of this statement will be of immense benefit to all concerned.

Pages 44 to 46

Policy 4.25

Makes reference to 'contribution through windfall', please expand the terms of this policy statement to allow the community to understand the full meaning which we find is not clearly presented.

Page 46

Policy 4.30

The indicative aim for the district as a whole is set at 35% in the Viability Study Report and is not considered impractical, an explanation or justification is required in the reasoning for this?

An expansion of this statement is desirable and is considered important for the community to understand fully and to be allowed to discuss in accordance with the requirements of the Localism Act 2011.

Pages 49 to 50

Policy 4.46 & 4.47 & Policy H7

How is any requirement for gypsy and traveller accommodation justified, especially in respect to the financial constraints we are required to maintain in the forthcoming years, and to whom will the financial burdens fall.

We are unable to find the written matter explaining Policy H7, please review this statement and amend accordingly.









11
Reference to Local Development Framework Core Strategy Submission Document (with proposed minor amendments highlighted) September 2009 (amended September 2011) (cont.

Other business

In our observing the document we are unable to find any references to 'Risk assessment' for flood, The Environment,
Infrastructure, Watery Lane, Density, Drainage, Main services, Roads, Access- (e.g. to and from Hullbridge), Schools, Medical services, public services including Fire, Police, Health and Safety, Employment, Local Financial Economy, Commercial and Industrial development.

Investment

Please explain how 'investment' can be attracted in this area, and how a Domestic Development will have the capacity to attract 'investment'.

We wonder how 'Social Affordable Housing' can be purchased, and what guarantees will be provided to ensure that the housing is 'ear marked' for the indigenous population of Essex and not for 'economic migrants', particularly in light of difficulty in obtaining mortgages.

We request an additional policy that the partnership arrangement which may be made, if not already made, but not stated in the LDF Document, will not be a Private Finance Initiative arrangement between the District Council and the proposed Developer in view of what has been stated above,

General

We have searched the two documents for a statement that there will not be another review to build new homes before 2031, we request such a statement be included in the main document.

Traffic congestion - We feel that the traffic already generated from Hullbridge is a problem and that building 500 more houses in Hullbridge with the average of two cars per household. This would bring Hullbridge Road to a standstill at peak time and if there is an incident such as Watery Lane being closed due to flooding as an example.

Travel and employment - Due to the number of people who live in Hullbridge compared to the number who work in Hullbridge there would have to be extra bus services for them to commute to the nearby towns or train stations. Although as with ourselves and the majority of Hullbridge residents we travel to work by car or van, therefore confirming my first point.

Crime and disturbance - Currently we have low crime rate in Hullbridge and the fear we have is that crime could increase due to the number of residents if the 500 houses are built.

Flood - The area that you are proposing to build these 500 houses often floods and this could cause major problems within the community and have a profound effect on the insurance policies due to claims that would be taken out. This would also cause a big problem to the access to Watery Lane that has always been closed due to flooding ever since we have lived here, no matter what repairs are done to the road way.

1) The site is not properly integrated with the existing village of Hullbridge. (A Green buffer) is to exist in perpetuity between new and existing developments. The 3.6 hectares of natural green space will only be directly accessible from the new development. This development as proposed , as evidenced above, will not promote community cohesion bur will in fact be creating a separate village to Hullbridge destroying the current community feeling that exists

2) The sewage system within Hullbridge is already at or near capacity. Although mentioned in the report no assessment of need has been made. Part of the area proposed is prone to flooding. It is not shown as flood risk however as it is farmland and no claims have been made against insurance and flood risk is based on insurance claims made.

3) Although mention of limited highway improvements is in the report no detail is given as there is no Core Strategy Transport Assessment from Essex County Council or elsewhere. The only Transport impact Assessment required will be developer funded and relate only to SER6, without taking into account either highway issues or other developments (eg SER1) elsewhere in the district. No assessment of road improvements required has been made and Ferry Road, onto which much of the new traffic will go, has not been mentioned in the report. At present Rawreth Lane is at, or near capacity and when Watery Lane* is closed, a common occurrence mostly due to flooding, traffic backs up along Downhall Road and Rawreth Lane towards Rayleigh and Hullbridge Road and Lower Road towards Hockley and Rochford making journeys to and or from Rayleigh or Chelmsford difficult. No impact on the district has been made with regard to the Fairglen Interchange (A127/A130/A1245) which lies just outside the district but which had a profound knock on effect when flooded , causing cars to move either to London Road or Rawreth Lane, two roads affected by SER6 and also more directly by SER1. It is stated that highway improvements should be made to accompany the development of the site, this will be too late as improvements must be made first given the current state of the highways network.
* Watery Lane is a minor road, narrow and with many sharp bends, therefore the increased traffic caused by the development of SER6, SER1 and Southend Airport without any other developments will make this narrow road as busy as any A road in the area.

DPD Totally Unsound

Sewerage and drainage I feel has reached its capacity levels. The ground is currently saturated and will only get worse. We already have flooding in the surrounding areas of Watery Lane. The land would be a developers nightmare and too costly for the end result. There will be too much pressure put on surrounding roads and Watery Lane is already unsuitable without road traffic. We do not have enough educational facilities or local shopping facilities. This development will be the 'kiss of death' to this so far unspoilt area and community by building effectively 500 cardboard boxes ie affordable housing.

The Local Authority have not demonstrated that they have shown to have provided independent examination of the issues surrounding the infrastructure, S20(5)(a) Compulsory Purchase Act 2004.

I cannot see from the Local Authority website that a Sustainability Appraisal Report has been undertaken.

With regard to preparing the plan positively, this has not been demonstrated as any development in the Hullbridge area is not sustainable becuase of the lack of infrastructure.

As to the DPD being justifiable the Local Authority must show credible evidence as to improvements to the infrastructure.

1. Development is detrimental to the current Community

The site is not properly integrated with the existing village of Hullbridge. A "green buffer" is to exist "in perpetuity between new and existing developments".
The 3.6 hectares of natural green space will only be directly accessible from the new development.
This development as proposed, as evidenced above, will not promote community cohesion but will in fact be creating a separate village to Hullbridge destroying the current community feeling that exists.

2. Highways

Although mention of limited highway improvements is in the report no detail is given as there is no Core Strategy Transport Assessment from Essex County Council or elsewhere. The only Transport Impact Assessment required will be developer funded and relate only to SER6, without taking into account either highway issues or other developments (eg SER1) elsewhere in the District. No assessment of road improvements required has been made and Ferry Road, onto which much of the new traffic will go, has not been mentioned in the report.
At present Rawreth Lane is at, or near, capacity and when Watery Lane is closed, a common occurrence, traffic backs up along Downhall Road and Rawreth Lane towards Rayleigh and Hullbridge Road and Lower Road towards Hockley and Rochford making journeys to or from Rayleigh or Chelmsford difficult.
No impact on the district has been made with regard to the Fairglen Interchange (A127/A130/A1245) which lies just outside the District but which has a profound knock on effect when flooded with cars moving to either London Road or Rawreth Lane, to roads affected by SER6 and also, more directly by SER1.
It is stated that highway improvements should be made to accompany the development of the site, this will be too late as improvements must be made first given the current state of the highways network.

3. Sewage/Drainage

The sewage system within Hullbridge is already at or near capacity. Although mentioned in the report no assessment of needs has been made.
Part of the area proposed is prone to flooding. It is not shown as flood risk however as it is farmland and no claims have been made against insurance. Flood Risk is based on insurance claims made.

4. Rawreth

Approximately one third, or around 6.2 hectares, of development SER6b (the second phase) will be in Rawreth, not Hullbridge. This also relates to point one above about community cohesion.
If the residents of the housing in SER6b live in Rawreth they will not be a part of Hullbridge, they will be represented by Rawreth Parish Council and Downhall and Rawreth District Councillors. They will pay a Parish Precept to Rawreth but get the facilities of Hullbridge. Such a separation will again not foster Community Cohesion and does more to encourage the new development as a separate community.

5. Youth

Hullbridge has a Youth Centre which is currently underused; additional investment should be made to facilities there or at the Skate Park in the recreation ground rather than have additional facilities which will be underutilised.

6. Neighbourhod Shops

The suggestion that additional neighbourhood shops are required suggests a proper review has not been done of A1 use in Hullbridge, which then gives a concern about the report as a whole. With a population of around 7,300 Hullbridge has three supermarkets; The Co-op, One Stop (owned by Tescos) and Budgens as well as a number of other independent shops including a butcher and a greengrocer etc. Hullbridge is more than adequately served by shops.
Hullbridge is short of other business premises such as office or studio facilities.

We are the owners of a property in Windermere Avenue Hullbridge.

We have viewed the local authority planning and green belt policies and are comforted by the local authority attitude to preserve green belt land and limit development to indentified sites.

As council tax payers we are further comforted that the local authority planning controls are reasonable and shows care for their community.

The development would fly in the face of the local authority green belt and planning policy and would tend normal minded people like us to conclude that the council considers the outline planning application to be a paper exercise with no merit.

Furthermore if the council were to grant outline or full planning permission to allow the development to proceed we would ask the council to confirm when the public consultation took place in respect of amending the green belt and planning policy?

If the public consultation has not taken place and permission is granted for the development this would be in total contravention of the current green belt and planning policy, which is available to view on the Rochford Council Web Site.

Turning now to the consideration that must also be given to the infrastructure of Hullbridge.

ROADS

The plan attached to the outline planning application shows minor roads to be constructed within the new development. Access and egress from the proposed development would be from Windermere Avenue. Part of this road is currently unadopted and not a publicly maintainable highway. Access to the proposed development would be over the un-adopted part of Windermere Avenue.

This said, whether the road is adopted or not the amount of traffic congestion, noise and pollution would be unacceptable to the current residents of Windermere Avenue.

The main road into Hullbridge is Ferry Road, which is a busy main road, and any additional traffic would cause excessive traffic congestion, noise and pollution.

In today's world most house owners have two cars some have more. With the development of additional houses there is potential for possible 500 additional vehicles using Windermere Avenue and Ferry Road.

SCHOOLS

Hullbridge has the benefit of local infant and junior school's, which has and hopefully will continue to provide education of the highest standard to the children of Hullbirdge.

This success can be in part attributed to the number of children in each class; this allows the staff to provide invaluable time and attention to each child's individual needs.

As well as providing a good standard of education which parents expect schools also have to aspire to and produce results in line with central government's policy on education particularly children at primary level.

Allowing the development would result in an influx in the amount of children attending the school and would therefore affect the numbers in each class and this would be detrimental to the education of the children who attend the school.

In addition the morale of the staff would be affected which again central government wish to avoid due to the amount of teaching staff leaving the profession because of the unacceptable numbers of children in classes.

WATER SUPPLY AND DRAINAGE

Although we have not studied in detail the water authorities plans consideration needs to be given to the location of the main sewer whether public or private and the mains water supply. The proposed development will require these facilities. Can the current sewers and mains water support the additional usage as a result of the additional 14 households?

EMERGENCY SERVICES

With the ever-increasing pressure placed on the emergency services having an additional household within the Hullbridge area would result in further work for the already overworked staff to undertake.

The Ambulance station at Southend Hospital was closed and merged with Rayleigh Ambulance station. The police would either have to come from Rochford or Rayleigh Police Stations.

Having to deal with emergency calls throughout the Southend, Rayleigh, Hullbridge and other surrounding areas does the staff really need an increase to the already widespread catchments area?

THE COUNTRYSIDE

The village of Hullbridge being steeped in history is something, which we all must aspire to maintain. Part of that history is the outstanding views of the English countryside, which we are proud to say Hullbridge benefits from greatly. This proposed development would destroy and lose the natural beauty of the fields and countryside.

The residents of Windermere Avenue and surrounding roads enjoy living in close proximity to the open countryside, which benefits from peace and quiet and the aesthetic views.

The proposed development will take place on green belt land, which benefits from natural beauty and forms the habitat of many species of wildlife, which will be affected and possibly destroyed forever.

Village life is again something, which we must be proud of and again maintain before it is lost and becomes a thing of the past.

We object to the planning application. If you require any further information please do not hesitate to contact us.

Site Context

Green Belt Land
Paragraph 2 refers to the site being agricultural land with very few buildings but nowhere in this document is there any mention of the site being currently designated as Green Belt which is stated within Strategic housing land Availability Assessment 2012.
This would seem to be a somewhat misleading omission as all new development is now controlled by the National Planning Policy Framework which has a very stringent policy on Green Belt development:-
Paragraph 87 states: "inappropriate development is by definition harmful to green belt and should not be approved except in very special circumstances".
The topography of this site is such that the height of the land northwards from Lower Road will mean that the dwellings will create an unacceptable blot on the landscape and it is for this reason that this development must be deemed to be harmful to the green belt and therefore "inappropriate" within the context of the NPPF.
It follows that a case for its approval must rely on a test of "very special circumstances'".
Paragraph 88 states:-"When considering any planning policy, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt "Very special circumstances" will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations."
It is apparent that it will be difficult if not impossible to provide evidence to show that "the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations."
Paragraph 89 states:-"A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are:-
* buildings for agriculture and forestry
* provision of appropriate facilities for outdoor sport......
* the extension or alteration of a building provided it does not result in disproportionate additions over and above the size of the original building.
* the replacement of a building, provided the new building is the same size and not materially larger than the one it replaces.
* limited infilling in villages...........

This development cannot be seen to qualify under any of these exceptions.
Paragraph 90 states:-"Certain other forms of development are also not inappropriate in Green Belt provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land in Green Belt." These are:
* mineral extraction;
* engineering operations;
* local transport infrastructure which can demonstrate a requirement for a Green Belt location;
* the re-use of buildings provided that the buildings are of permanent and substantial construction; and
* development brought forward under a Community Right to Build Order.
This development cannot be seen to qualify under any of these exceptions.

Site Capacity
Paragraph 1 states that densities will be restricted to 30 dwellings per hectare which is relatively low and would be supported by CPRE but we would question whether that level of density could support the cost of any affordable housing.
Concept Statement

Design Standards
We are pleased to see under paragraph 5 that dwellings will be built to lifetime home standards with provision for some wheelchair housing. Similarly we note under paragraph 6 that compliance is required to appropriate Code for appropriate sustainable Homes Standards. We are surprised that Rochford has not stated the minimum Code level requirement? 10% renewables should be stated as being a minimum requirement.
Green Buffer
Paragraph 9 We welcome the introduction of planting in garden areas but cannot understand how the creation of a green buffer/lung in perpetuity between new and existing development can be expected to promote integration?
Youth Community & Leisure Facilities
Paragraph 13 notes that these facilities are to be provide as part of the first phase of this development which we would assess to be circa 290 dwellings. We would question whether there is a real need for additional youth facilities as some already exist in Hullbridge and in any case would doubt whether it is realistic to assume that they could be funded by the first phase of this development

Community Infrastructure
There would not appear to be any mention within Policy SER6 about essential community buildings specifically doctors surgery and school. Has any research been done on this as I am told that exiting doctors surgeries cannot accommodate a substantial increase in patients.
Highways
Paragraph 19 of Policy SER6 states that "alongside the first phase of development local highway capacity and infrastructure improvements including improvements in Watery Lane and Watery Lane, Hullbridge Road,junction should be made."
We note also that service enhancements will be required by which we presume that upgrading of utilities and sewage systems will be needed. The Strategic Housing Land Availability Assessment 2012 identified extent of works as being low to average but it is our understanding that the sewage systems are close to capacity. What further investigations if any have been made?
Paragraph 20 says that "financial contributions towards local highway capacity and infrastructure improvements and public infrastructure improvements and service enhancements will be required".
There is no statement made about the extent of these works and it would seem that Rochford District Council will be relying on a Traffic Impact Assessment to be commissioned by a prospective developer(s). However it seems evident that the cost of these works are likely to be very significant indeed as most of the existing road networks in that area are already at a high capacity.
Flooding
Paragraph 24 says that a drainage strategy should be prepared for this site The Strategic Housing Land Availability Assessment 2012 identified risk of flooding as low for this development. There is no mention of this within Policy SER6 but has any detailed risk assessment been made?

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.

1. Development is detrimental to the current Community

The site is not properly integrated with the existing village of Hullbridge. A "green buffer" is to exist "in perpetuity between new and existing developments".
The 3.6 hectares of natural green space will only be directly accessible from the new development.
This development as proposed, as evidenced above, will not promote community cohesion but will in fact be creating a separate village to Hullbridge destroying the current community feeling that exists.

2. Highways

Although mention of limited highway improvements is in the report no detail is given as there is no Core Strategy Transport Assessment from Essex County Council or elsewhere. The only Transport Impact Assessment required will be developer funded and relate only to SER6, without taking into account either highway issues or other developments (eg SER1) elsewhere in the District. No assessment of road improvements required has been made and Ferry Road, onto which much of the new traffic will go, has not been mentioned in the report.
At present Rawreth Lane is at, or near, capacity and when Watery Lane is closed, a common occurrence, traffic backs up along Downhall Road and Rawreth Lane towards Rayleigh and Hullbridge Road and Lower Road towards Hockley and Rochford making journeys to or from Rayleigh or Chelmsford difficult.
No impact on the district has been made with regard to the Fairglen Interchange (A127/A130/A1245) which lies just outside the District but which has a profound knock on effect when flooded with cars moving to either London Road or Rawreth Lane, to roads affected by SER6 and also, more directly by SER1.
It is stated that highway improvements should be made to accompany the development of the site, this will be too late as improvements must be made first given the current state of the highways network.

3. Sewage/Drainage

The sewage system within Hullbridge is already at or near capacity. Although mentioned in the report no assessment of needs has been made.
Part of the area proposed is prone to flooding. It is not shown as flood risk however as it is farmland and no claims have been made against insurance. Flood Risk is based on insurance claims made.

4. Rawreth

Approximately one third, or around 6.2 hectares, of development SER6b (the second phase) will be in Rawreth, not Hullbridge. This also relates to point one above about community cohesion.
If the residents of the housing in SER6b live in Rawreth they will not be a part of Hullbridge, they will be represented by Rawreth Parish Council and Downhall and Rawreth District Councillors. They will pay a Parish Precept to Rawreth but get the facilities of Hullbridge. Such a separation will again not foster Community Cohesion and does more to encourage the new development as a separate community.

5. Youth

Hullbridge has a Youth Centre which is currently underused; additional investment should be made to facilities there or at the Skate Park in the recreation ground rather than have additional facilities which will be underutilised.

6. Neighbourhod Shops

The suggestion that additional neighbourhood shops are required suggests a proper review has not been done of A1 use in Hullbridge, which then gives a concern about the report as a whole. With a population of around 7,300 Hullbridge has three supermarkets; The Co-op, One Stop (owned by Tescos) and Budgens as well as a number of other independent shops including a butcher and a greengrocer etc. Hullbridge is more than adequately served by shops.
Hullbridge is short of other business premises such as office or studio facilities.

I consider the DPD to be unsound because:

1. The current roads are already at full capacity, flooding that occurred before Christmas, coupled with an accident grounded this area to a complete halt, resulting in mass loss of earnings.

2. Extra retail and youth provisions are not needed, listed below are the youth opportunities up-to-date.
Boys brigade
Girls brigade
Scouts
Judo
Skate boarding rink
BMX Track
Youth Shelter
Football ground
Others

3. Road building is not the best way to reboot the economy, it has shown the complete reverse.

4. To build on part of Rawreth will fragment our community.

5. The gamble on growth does not warrant the destruction of our countryside, which we need as a fundamental part of life.

I consider the plan SER6 to be completely floored and unacceptable as I believe that not enough research has taken place and the full environmental impact assessment has not been properly addressed.

Presently, Hullbridge has approximately 7,500 inhabitants in 2,500 dwellings. The plan for a further 500 houses (20% increase) will equate to 1,500 extra people (20% increase from current numbers).

Common sense states that it will probably mean at least another 750 cars for the village.

At the time of writing, Watery Lane has been closed for approximately 1 month due to persistent flooding. This is not just a winter problem; it has been closed on may occasions during the summer as well. The junction of Hullbridge Rd and Rawreth Lane, quite simply can't cope at the moment when Watery Lane is closed, so an additional 750 cars will just compound the problem. I wonder what, if any, thought has been given to other local road junctions and their ability to handle so much 'new traffic' if this plan is allowed to go ahead.

The topography of the land in general is the root cause of the flooding. This cannot be changed. Watery Lane's height is below that of the surrounding fields and in addition water runs down from Windermere Avenue to Lower Road compounding the regions problem and this is where the houses are to be built.

I don't think that proper research has taken place, as I am sure that a full Health Impact Assessment would fail as Rochford District Council is fully aware of the problems with foul smells that emanate from the sewage treatment works in Watery Lane. I along with my neighbours have complained numerous times throughout this summer and previous summers, when the wind has been in a south westerly direction. There has always been a weak excuse from the water company as to why they have contaminated the atmosphere. This new proposed development is within 600-800 yards of the treatment works.....bad planning!

To allow an access point to the proposed new development via Malyons Lane is ludicrous. The junction of Malyons Lane and Ferry Road is on hill. This would become an accident black spot. If any development does eventually take place, NO vehicular access at all, must be allowed from Ferry Road. It's a very busy, poorly surfaced roads, which alas is already some sort of 'speed track'.

To plan for 35% of the new dwellings to be of 'affordable housing' is far too high. High concentrations, of affordable housing regrettably brings many social problems, just look at many of the affordable housing estates that were built in Shoeburyness in the 1980's to see their failings.

I am a neighbourhood officer and therefore have many dealings with the police. I was interested to read within the plan that 'The provision of leisure facilities should be determined in consultation with the Council at the planning application stage'. Unless there are strict contractual legally binding clauses, built into this plan, forcing the developers to greatly enhance the very limited facilities for youths and provide quality new facilities, the anti-social behaviour and crime rate will soar!

Lack of sewerage requirements. When Watery Lane is closed, due to flooding off the fields, getting out of Hullbridge (Rawreth Lane) is ridiculous, many tailbacks with more housing it will be impossible to move. Local avenues will be used and Ferry Road is busy enough already.

On looking through the points in the list of examples, starting with lack of sewerage requirements. Then of land flooding not from a river but from local fields. Then there is the access by roads, because half of Hockley some of Rayleigh and all of Hullbridge traffic can be clocked in on bad days. This planned building program will also conjest local avenues in Hullbridge that are only just big enough for residents.

The road system is unable to cope with even the smallest upset. When Watery Lane is closed due to flooding or accidents (a frequent occurence) gridlock ensues on the Hullbridge Road, 500 new houses will mean at least 1000 more cars, probably more. Taken with the other large scale developments proposed (Hockley Centre), or approved (600 houses - Hall Road, Rochford) this is the policy of inconsideration for local residents needs to travel (work, health, shopping etc).

Sewage

In the last 18 months there have been two llarge sewage blowouts next to my property. One was virtually under my garage and the other was in the carpark of the Anchor Public House. These were caused by the main sewer and pumping house being unable to cope with the strain of pumping the waste up Ferry Road to the Watery Lane Sewage works. Swamping this creaking system with the sewage from another 500 houses is insane. This should ensure that Watery Lanes frequent flooding will not just be rain water.

Boundaries

Apparently a large part of this development will come under Rawreth Parish and District Councils although they will be using Hullbridge facilities. This splitting of the community cannot be a good thing.

I consider the DPD to be unsound because:
a) The current road system is already at full capacity, this was bourne out just prior to Chrismtas (2012) when the area - Hullbridge, Rayleigh, Rochford, Hawkwell, Rawreth was gridlocked due to flooding and an accident. To overburden the area with even more traffic would be ludicrous.
b) Although the proposed development is not on the flood plain, surface flooding occurs regularly. The idea that is proposed to pump to holding tanks in Rawerth would create even more development and pumping into a little river is not an option.
c) Not all the development would be situatred in Hullbridge, therefore not all could be integrated into the community unless major boundary changes are made.
d) Extra retail shops and youth provisions are not required as Hullbridge already has sufficient.
e) The sewage system is already at full capacity, therefore, it would require major investment to upgrade before any development could be made.

The DPD site will over populate the area which is already over populated. The development will destroy the current community feeling that we have. It will create a separate village to Hullbridge which is not wanted.

The Highways will not be able to stand the volume of traffic that already exists when Watery Lane is closed due to flooding which happens on a regular basis. Traffic backs up along Lower Road, Ferry Road, Downhall Road and Rawreth Lane. More houses will create how many more cars.

The sewerage/drainage system cannot cope with the volume of houses we already have. The pumping station is nearly always manned for one problem or the other. It will certainly not be able to take more houses. Part of the area proposed is already prone to flooding. Insurance on these properties will be expensive! Who wants them?

Hullbridge youths have no where to go already. Bring in more bored youths and you will be creating a major problem within our village. Why not spend money on investing in the Youth Centre and facilities for the young that we already have we have sufficient supermarkets for the population that we have. We live here for the lifestyle that we want for our families. By doing this development on top of the plans you have for Hall Road, Rectory Road and Hockley is just not acceptable - no one wants it. It is all for profit to line pockets - not for our benefit at all. Listen to the residents do the decent thing and leave us alone.

Youth facilities should be sorted before developments begin. Schools should be provided as Hullbridge Infrant and Junior Schools have now amalgamated and all the Junior Schools in Rayleigh are full. Also more doctors need to be provided.

Where are the contributions to come from to provide the work proposed in 3.181?