Policy SER9 - West Great Wakering

To propose building on Green Belt Land to the west end of Great Wakering is scandalous and flies in the face of preserving what little tracts of Green Belt Land that are left around the village.
A proposal to add large numbers of properties to the existing build plans for Star Lane would also place an intolerable burden on the existing facilities in the village. The proposals, it is suggested, could add upwards of 1000 to 1500 souls to the village population. The village Medical Centre, Junior School and other commercial facilities within the village simply will not cope with such a large influx of numbers.

The roads infrastructure around the village are now quite narrow. Parking is already at a premium throughout the village and access and egress along and around the village roadways is already slow and somewhat restricted.

The existing water and sewerage support services throughout Great Wakering are already stretched. Adding upwards of over 1500 souls to that demand would create potentially massive problems in that regard.

At any given time, there are a number of existing dwellings on the property market within the village boundaries. The proposals would also not necessarily guarantee 'affordable' housing in the village. One only has to look at the development of so called 'affordable' housing adjacent to Asda's in Shoeburyness to witness such. Even small properties there are now selling for around and in excess of £250K !

I strongly object to the housing planned for this area, as this is a small village and with an influx of new residents, I do believe that the village would struggle to cope with the extra demands placed on the local schools and doctor's surgery. The volume of traffic will greatly increase, which I believe has already increased too much along the High Street anyway. I also know that crime and anti-social behaviour would increase. Great Wakering is relatively crime free, which is why I choose to live here and I know the area is not routinely policed and due to a lack of policing resources, this village is unlikely to ever be routinely policed! The village atmosphere would be ruined. I moved to Great Wakering for the peace and quiet, the open space and country feel, as well as all the interesting and historical buildings. There are already enough 'new build' estates and I would hate to see more, whereby the village would end up having no charm or individuality!
Having lived in Westcliff for many years and seen it turn into somewhat of a 'guetto', I would hate to see Great Wakering be developed further, go downhill and end up with the same problems and over population seen in Southend, Westcliff and Shoebury. The previous development of flats/housing on the High Street (opposite Little Wakering Road) were left empty for some time and I still don't believe they are full to capacity now. Having been looking for a house recently, there are numerous houses for sale, which are not selling, so do we really need any further housing in this area?...I think not!!

The land to the West of Little Wakering Road is used at present to grow food, sustain wildlife and provide a boundary for Great Wakering. The need for highway access to the south will create traffic problems on Southend Road and back into Star Lane and the High Street, which already suffer at peak times. The road in general are unsuitable, the High Street does not accomodate large volumes of traffic and in most places if a car is parked, which they have to for access then jams are caused as the road is too narrow for passing. The roundabout at the top of Star Lane and Southend Road sees numerous accidents, especially in the height of Summer and in Winter, feeding more traffic onto here would increase the problems and decrease air quality.
The green belt area, the field has a wealth of wildlife which I have seen and photograph from my back door, which overlooks the field - foxes, badger, shrew, mice, blue tit, coal tit,great tit, long tailed tit, magpie, blackbird, songthrush,starlings, sparrow, chaffinch, greenfinch,black cap, red-legged partridge, pheasant, great black-backed gull, common gulls, robin, wren, accento, pied wagtail, meadow pipit, housemartin, skylark, collared dove, wood pigeon, dunnock, a pair of herons and hunting kestral.
Great Wakering is a village, with the proposal to the south we will become part of Shoebury and thereby Thorppe Bay and Southend, the sprawl of the large suburb without distinct areas and villages.The road network will not sustain the housing. There are not the shops available in the West and South of the village to provide for further housing.
The public transport servvice is threatened so may not be here for an influx of new families, so adding to road congestion.

I am against any future development in Great Wakering and especially in the Green belt.

The village is losing its identity with the increased number of new houses and will soon become just a suburb of Southend. The majority of people chose to live in the Great Wakering area because of village nature and the fact that it is quiet and not congested, with plenty of fields and open spaces. This is something I feel should be strongly protected.

The infrastructure and services have not been improved even after the recent new housing developments have been completed. The high street is becoming a dangerous place to walk with children because of the narrow nature and the number of cars. The school run is very chaotic with many cars parking and mounting pavements when I walk my child to school. Any new housing can only make this worse.

Barrow Hall road is very narrow and in some places two cars can only just pass each other. Southend Road is also a dangerous road with many accidents and additional housing will only add to it. It is becoming very difficult for residents to get "past" Southend and out to work as the roads are so congested and more housing this side of Southend will make it work.

The Great Wakering School is already oversubscribed with class sizes above average and in my sons case they already have 32 pupils which I believe is above the recommended size.

It is very disappointing that the local council / Government do nothing about the half of Great Wakering which at risk of flooding due to poorly maintained sea defences but are happy to add more housing without improving the circumstances for people who already live in the area. It seems like the rights of potential new residents are being put before local residents who are have lived for many years in the area and are "Great Wakering".

I have only lived in Wakering for 4 years although my wife & family have lived here for more than 70 years, with time before that in Foulness. We moved here, onto the High Street, for the village life.
I have read the online submissions for both development SER9 & BFR1. My fears are below.
The current services cannot cope at present, the doctor's surgery car park is full & overflowing to the High Street & blocking access to adjacent houses.
The school is at capacity.
The local shop, Co-op, is always busy at the weekend & evenings as it is not big enough.
The water management, delivery & waste, Gas & Electivity are not adequate.
Cars speed down the High Street which is narrow & the Zebra crossing outside the doctors' is ignored.
The submissions I have read mention frequently about how people will be encouraged to walk & cycle more but in reality this wont happen which leads to more traffic problems.
There is also mention of the sports centre & possibilty of an adult education community centre being built. The Sports centre closed about 18 months ago as it could not be sustained & I cannot see it opening again or a community centre being sustained.
Above all I fear that any development will change the characteristics of Wakering & having seen this happen in other Southend areas I feel it should be rejected.

I object to this developement because with every new house constructed it erodes further the village identity. Size matters. The village community feeling and well being
will cease if the population becomes too large. To say nothing of the inferstructure not being able to cope. The school is overcrowded with insuficient places for all the
village children now. It cant possibly cope with 500 [conservative est.] more children, or more cars dropping them off in the already busy highstreet. If the Doctors surgery
can cope with the number of new patients, which I doubt,trying to book an early appointment is impossible,whilst trying to park there is also fraught with frustration. The cars stretch from the surgery carpark down the highstreet into the recreation ground carpark or that of theExhibition inn. To be able to cope both these institutions would need to expand which would further damage the village identity. Finally,33 years ago I chose to live in a country village for its community spirit, isolation, tranquility and uninterupted views of the fields and wildlife on greenbelt land that I believed to be safe from developement. No longer!. Surely, now you can build almost anywhere it would be more sensible to build where it affects no one but creates a new community with its own identity and spirit. I would be gratefull if you could inform me of the best
way to prevent this or any subsequent developements. Terry Stubbs.

This area is green belt land and has been so for a long time it protects a village community that would be lost if proposed building would take place there is nothing in the village for young people to do now the infrastructure could not cope with these extra houses keep our village a village!,,,,,,

"The Core Strategy (Policy H3) identifies that the sites in this general location should have the capacity to accommodate a minimum of 250 dwellings during the plan period. The sites identified in Figure 15 are capable of providing 250 dwellings at a density of 30 dwellings per hectare, plus a flexibility allowance of 5%, if required."
The two sites are owned by different companies. This policy document should identify how many dwellings should be provided on each site to provide clarity on what is required, otherwise this leaves the policy open to dispute between the land owners/developers and the District Council as to what was intended.

"The road to the south of the industrial estate (which is located within the Green Belt) provides access/egress to the adjacent Local Wildlife Site which would need to be considered. Development of the site should not restrict existing vehicular/pedestrian access/egress to the Local Wildlife Site. However, the potential to utilise the existing access/egress for the Local Wildlife Site (which is in the Green Belt) to enable a combined access/egress point for these development should be explored."
In addition SER9b states
"Access/egress to the land within Policy SER9b should not go through the Local Wildlife Site but should be provided to the north east corner of the southern section of the industrial estate, if delivered prior to the northern section."
The "road/track" to the south of the industrial estate (in Green Belt) which provides access/egress to the Local Wildlife Site is only used by fishermen and is only used on average by a maximum of 3 vehicles per day via a padlocked gate. This locking is necessary to prevent the dumping of cars in the lakes and also vandals/car thieves setting light to stolen vehicles in a quiet area.
This "road/track" runs in an easterly direction from Star Lane along the southern edge of the south industrial estate (Brickworks Site) for about 200metres before entering the wildlife site when it becomes unmade, it then forks, north in the direction of SER9b, north east to the large lake and continues east to the small car park.
There is no visibility splay at this access/egress and it is very dangerous when exiting onto Star Lane.
If this existing access/egress is to be used as a combined access/egress to BFR1 (north and south industrial estates), SER9b and NEL3 then disruption to the wildlife site must be carefully considered.
In order to minimise disruption to the wildlife site then access from the "road/track" to BFR1 and SER9b must be shortly (within 50 metres) after the junction with Star Lane otherwise there will be major disruption to the wildlife site. A visibility splay will need to be created by using part of the industrial estate south (Brickworks site). This will also have an impact on the roads in BFR1 as they will carry the traffic to SER9b and eventually the industrial estate north when this is developed.
If this is also to serve NEL3 then the noise/pollution of lorries using this access/egress needs to be considered plus would this make a bad neighbour situation with lorries turning within several metres of dwellings?

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

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

The allocation of land, under Policy SER9, to the west of Little Wakering Road (SER9a) is unsound because, compared to land to the west of Alexandra Road, it is relatively remote from village services and facilities, and does not provide a defensible Green Belt boundary along its extensive western edge. Development in this location would be harmfully intrusive into open countryside. Furthermore, the allocation of two separate sites under this proposed policy (i.e. land to the south of High Street (SER9b) and land to the west of Little Wakering Road (SER9a)) would create a segregated form of development and would therefore have a negative impact on community cohesion.

Rather than releasing Green Belt land at SER9a, the land to the west of Alexandra Road should be allocated as an extended part of site SER9b. The land to the west of Alexandra Road, which was considered by the Council at Discussion & Consultation stage as part of Option WGW3, would form a logical and contiguous extension to SER9b. This land would also be sited closer to the village centre than either SER9a or SER9b, and would provide a highly defensible Green Belt boundary on all sides by virtue of the existing development and other features.

Option WGW3 included three separate and unrelated plots in the general location of West Great Wakering. These plots were (i) land to the west of Alexandra Road, (ii) land to the south of Star Lane brickworks, and (iii) a small plot to the north of the Star Lane Industrial Estate. The latter now forms part of plot SER9b. The overt disadvantages of releasing land to the south of Star Lane brickworks had a distorting impact on the overall case (or score) for this option. The sustainability appraisal in respect of WGW3 is therefore misleading and flawed.

By virtue of its contiguous relationship with SER9b, development of the land to the west of Alexandra Road would not be segregated or dispersed in terms of community cohesion. It would form part of SER9b, and would offer easy accessibility to the village centre and other facilities. Development here would assist in community integration, and would support local businesses. No other available Green Belt site in the west Great Wakering 'search zone' scores as well in sustainability and integration terms. Self-evidently, site SER9a is unsustainable by comparison.

The Sustainability Report issued at 'Discussion & Consultation' correctly states that 'the site to the west of Alexandra Road would relate well with Option WGW1 and provide an alternative access route from the site'.

SER 9 West Great Wakering

The respondent fully supports the allocation SER9, in particular sub-allocation SER9b. The respondent owns the land identified as SER9b, as well as a significant land interests to the south and east of the allocation. In the interest of clarity, the respondent has included an ownership plan within a promotion document attached to these representations.

The wider ownership of land in this area, which includes the Local Wildlife Site (R25 Star Lane Pits), affords the respondent a certain amount of flexibility and opportunity, to not only deliver the new housing area, but also the required employment land, secure the wildlife area and potentially provide new areas of public open space.

Site SER9b
Allocation of this land for new housing is fully supported. The site is ideally located just south of the urban edge with a direct link to Great Wakering, High Street. There are no environmental or other reasons why this land cannot be developed for housing. The land is available, deliverable and fully developable with no impediments.

The site area extends to some 8.5 hectares. The Council anticipates that this site, along with allocation SER9a shall together deliver 250 residential units, plus a flexibility allowance of 5%. The delivery of these units is to be held back, in accordance with Core Strategy Policy H3, until post 2021, unless required in order to be brought forward earlier to maintain a 5 year supply of deliverable housing.

The Council is advised that this land will be maintained in agricultural use until it is required for housing. However, the respondent will adopt a flexible approach to land management so that the land can be made available sooner, if supply does not keep pace with the Council's housing trajectory.

Master Planning
In addition to the allocations for housing on site's SER9, additional allocations for housing and employment land are identified in Great Wakering. These sites, namely BFR1 - Star Lane Industrial Estate and Farmer Brickworks and NEL3 New Employment Land are clustered together and need to be considered jointly.

The respondent has produced some master plans for the area to illustrate the sites in context and to demonstrate indicatively, how the Green Belt release for SER9b could be developed. The master plans are provided within a Promotion Document or they will be provided separately as part these representations, to illustrate specific matters of interest.

Master Plan One
Master Plan One, illustrates how the combined sites could be built out as the Allocations DPD envisages.

The Master Plan illustrates 185 dwellings on allocation SER9b at a density of 22 dwellings per hectare (dph). Whilst the layout is indicative of a likely scheme, it is an 'every house' layout, which incorporates each and every requirement as set out in the submission document. The layout incorporates precisely the amount of semi-natural and formal open space, the required LAPs and LEAPS, as well as stated connectivity requirements and landscape buffers.

The density of 22 dph is considered to be appropriate to the site's context and proximity to the wildlife site. It is also appropriate to the Council's anticipated housing requirements for this area. It is noted that SER9 anticipates 30 dph across both allocations which combine to a total 13.5 hectares. At 30 dph, delivery on a combined SER9 allocation would be 405 units, which is clearly more than envisaged.

At 22 dph, site SER9b as shown on the Master Plan can provide 185 units on approximately 8.5 hectares and SER9a at 4.5 hectares could deliver approximately 100 units, thus a total of 285 units could be achieved. Whilst 285 is more than the 250 envisaged, when one considers the additional 5% and the likelihood of a Core Strategy review, prior to 2021 where some additional housing numbers are likely, then 285 units from these allocations is not unreasonable.

The layout shown on the indicative Master Plans for SER9b, whilst illustrative, incorporates the design requirements set out in the Council's Concept Statement. The principle vehicular access is as required taken from the redevelopment of the Former Brickworks site. At the present time, it is not clear whether the Council has received a suitable layout, as part of the planning application for the Brickworks, which is suitable and capable of serving an additional 185 residential units on SER9b. The respondent has taken advice from Transportation Consultants in relation to alternative access strategies. It is quite possible that some of the site could be served from the High Street or from an access south of the Brickworks. A paper from the respondent's Transport Consultant is attached to these representations, which explores the options.

Star Lane Pits Local Wildlife Site (LOWS)
The LOWS is of course an important resource, which needs to be protected in the long term. The respondent has recently undertaken a Phase One Habitat Survey to assess the site's overall quality and whether these are opportunities to improve its richness through better management. A summary paper is attached to these representations from the respondent's ecologist. The respondent would be willing to develop a better management plan for the wildlife site, which enhances its quality and ensures that it is able to co-exist alongside housing development and thrive in the long term.

Employment Allocation NEL 3
It can be seen on Master Plan One that provision is made for allocation NEL 3 for a new employment site as a green belt release to replace Star Lane Industrial Estate. The new industrial site is accessed as required from a single access/egress onto Star Lane. The site area of 2.5 Ha and its general position have been interpreted from the plan in the Allocations DPD. Provision is also made for pedestrian links between the industrial land and SER9b, which in turn connect with the High Street. The pedestrian link, which is shown to the west of the wildlife site, is through scrub land and spoil heaps from the adjacent former brickworks. This land has no ecological value.

Master Plan Two
Master Plan Two is the same as Master Plan One with respect to the potential treatment of allocation SER9b. However, it has been prepared to illustrate the flexible approach that the respondent can facilitate to ensure that the comprehensive development of the area could be achieved, whilst responding to changes in circumstances.

The respondent has strong reservations in relation to the delivery of new housing on Star Lane Industrial Estate as anticipated by allocation BFR1.

These reservations reflect the site's multiple ownership and mix of freehold and leasehold tenure. It is considered most unlikely that collectively the occupiers of the estate will act as one and choose to relocate. It is also unlikely that NEL3 would be constructed without the industrial units being pre-let.

In the event of the existing industrial estate not being redeveloped when or as anticipated, Master Plan Two illustrates additional housing on north of NEL3 to compensate for the housing not coming forward on the brownfield allocation. This option is just that, an option for the Council to consider if development does not emerge as anticipated. If however the existing industrial site is redeveloped, then the respondent can deliver NEL 3 as required and as illustrated on Master Plan One. If the brownfield development does not come forward as and when anticipated, then alternative provision for housing could be made available as shown on Master Plan Two to maintain a five year housing land supply.

Both Master Plan options also include a significant area of approximately 5.4 Ha of new Public Open Space to the south of the wildlife site. The respondent would welcome a discussion as to the provision of this additional land to meet existing and planned open space needs.

Consultations
During November 2012, the respondent provided Great Wakering Parish Council with a brochure document (enclosed with these representations) which introduce the landowners and tabled two preliminary and basic Master Plans. A briefing meeting was held with the Parish Council on the 28th November 2012, at which the respondent explained the likely approach to the allocations. The Parish Council were responsive to the proposals in principle and raised no fundamental objections. Parish Councillors had some concerns regarding education provision in the village and leisure facilities and it was explained to them that suitable provision would need to be made alongside new housing development through s106 agreements.

The respondent intends to continue an informal dialogue with the Parish Council as proposals evolve.

The plans mentioned have had to be emailed to the Council separately.

Great Wakering is Village, if you build these houses the whole character of Great Wakering will change, the end of the village you are trying to 'build' on does not have any infrastructure. To say the developers have to put it in is not enough. Deals are always done by companies building the developments and councils so the building goes ahead come what may.
We are constantly denied any more public transport in Gt Wakering. When the star Lane houses have been built the spare capacity at the school will be used up and the same at the doctors surgery.

You propose to put housing estates up behind peoples back gardens - how can that be right?
Little Wakering Road is totally unsuitable to take anymore traffic and the Catholic Church on the said road is used 5 days a week by Poppets playgroup and would not be useable as a building site access point as suggested.

RDC provide very little for Gt Wakering, yes, we have good rubbish collection but that is were it ends. The sports centre has been closed, yes you are doing a new facility at the local school BUT that will not be big enough for all these new residents as well. You wanted to close the public toilets, more people will need more public facilites.

What is a green belt? If the council can come along and build on it when they fancy what is the point in designating it green belt.

This corner of Essex has not had any additions to the road structure since the Dualling of the A127 in the thirties.
250 dwellings will mean at least 500 extra cars, as there are no jobs locally they will commute to their place of work this brings no value to the community.
Add this commute to the Schoolrun and the roads will gridlock between 8 and 9 in the morning.
The Greenbelt needs to be preserved as stated in the RDC policy document PPG 2 not destroyed.
A large Housing Ghetto will not improve the quality of living in Wakering.

SER9a. Even with a field behind our property the garden is often water logged, building new properties will add to this problem. No realistic local amenities, the Co-op is too far for some to walk to, and too small to cope with the population Wakering already has. The public transport in Wakering is not good enough, and cars are necessary if you want to get anywhere on time, more houses = more pollution. The local school is fit to bursting, and the 'local' secondary school is in Rochford. The local sports centre has recently been closed, leaving only the park, which is fine for walking a dog, or a game of football, but for the community as a whole it is lacking in things to do. The reason people move to Wakering in the first place is because it is a rural area. Will these properties be built for local people? What sort of people will be moving in? From a personal point of view our property will be de-valued, we will have to live next to a building site for months on end, and our view (the reason for buying our house in the first place) will be ruined, will our council tax reduce to show this? We live in the district of Rochford (high council tax), we have a shoebury post code (high insurance costs), our full address states we are in Southend, we get the worst aspects of both councils, it feels that because we are on the outskirts of Rochford we are forgotten and treated poorly, only remembered when yet more homes are required. Has it not occured to anyone that derelict properties and buildings should be renovated first before building on our green land?

In respect of this proposed allocations; SER9a would square of the existing settlement and SER9b be would be developed to the rear of the High Street; resulting in a cohesion extension to the existing settlement. However, there is a concern that the proposed 250 dwellings, when combined with the dwellings proposed at the Star Lane Industrial Estate, would result in a significant increase to the existing settlement.

The proposal to increase the housing stock in large numbers to the west of Gt. Wakering is neither justified nor effective. The Government state that this recession/period of austerity (economic policy) will continue for the next 10 years. The housing market especially for 1st time buyers is moribund whereas the proposal to build some 140 plus properties on the site of the defunct 'Star Lane' brickworks is about the most that village requires. However, there are no plans to significantly improve the local infrastructure, (it is already taking traffic from Rochford to the new developments in Shoebury along basically country lanes eg Shopland Road). More houses, much more children, more vehicles, how can this village contend with the proposed (DPD) increase levels?

In my opinion this aspect calls into question both the effectiveness and the soundness of the proposals for this village up to 2021 and beyond.

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.

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.

Cogent supports the proposed allocation of land to the west of Little Wakering Road, identified as SER9a within the Allocations DPD for residential use. The site has the potential to make an important contribution towards meeting the growth and sustainable development needs of Great Wakering and Rochford District as a whole in the short term. In this regard we note that the Foulness and Great Wakering Ward has been identified as being a primary recipient of in-migration to the Borough.

We note that SER9a is currently identified as a potential allocation in conjunction with land identified as SER9b, to the south of the High Street. In accordance with the previous representations submitted on behalf of Cogent regarding the Allocations DPD, we can confirm the continued availability of the wider land parcel to the west of SER9a. The wider site is considered to be a suitable alternative location for housing and employment land should the need be identified and alternative locations (i.e. to SER9b and/or NEL3) be determined to be either unacceptable to the local community or less sustainable.

A plan showing the boundaries of SER9a and the wider land parcel is provided as Appendix One for reference. The plan seeks to illustrate the potential benefits of extending the proposed allocation to, as a minimum, improve access arrangements to the site from the south in accordance with the supporting text of the policy. It also confirms the extent of land under the control of Cogent should a suitable alternative location for housing or employment provision be required.

We can confirm that, should the circumstances arise where development of the site would be supported prior to 2021, then the site can be defined as both deliverable and developable in accordance with the National Planning Policy Framework (NPPF).

Cogent has undertaken a review of the Rochford housing land supply. It is concerned that the Council may not be able to identify a five year supply of deliverable housing sites that accords with the NPPF and recent appeal decisions.

Furthermore, Cogent is concerned that the housing provision targets contained within the Core Strategy, and by extension within the housing land supply numbers, do not meet the requirement of the NPPF to meet the 'full objectively assessed needs for market and affordable housing' (paragraph 47).

Such concerns with housing land supply are magnified where delivery from identified sites is constrained and levels of in-migration are comparatively high. The SADPD includes a number of examples of where housing land supply is likely to be constrained, but we draw particular attention to the identified constraints at SER9b.

Cogent is concerned that the other proposed allocations in West Great Wakering - SER9b and NEL3 - are likely to be constrained by wildlife and other ecological matters related to the Star Lane Local Wildlife Site, would contribute to the potential coalescence of between Great Wakering and Shoeburyness and would encourage development in a locally sensitive landscape.

Cogent supports the proposed allocation of land to the west of Little Wakering Road, identified as SER9a within the Allocations DPD for residential use. The site has the potential to make an important contribution towards meeting the growth and sustainable development needs of Great Wakering and Rochford District as a whole in the short term. In this regard we note that the Foulness and Great Wakering Ward has been identified as being a primary recipient of in-migration to the Borough.

We note that SER9a is currently identified as a potential allocation in conjunction with land identified as SER9b, to the south of the High Street. In accordance with the previous representations submitted on behalf of Cogent regarding the Allocations DPD, we can confirm the continued availability of the wider land parcel to the west of SER9a. The wider site is considered to be a suitable alternative location for housing and employment land should the need be identified and alternative locations (i.e. to SER9b and/or NEL3) be determined to be either unacceptable to the local community or less sustainable.

A plan showing the boundaries of SER9a and the wider land parcel is provided as Appendix One for reference. The plan seeks to illustrate the potential benefits of extending the proposed allocation to, as a minimum, improve access arrangements to the site from the south in accordance with the supporting text of the policy. It also confirms the extent of land under the control of Cogent should a suitable alternative location for housing or employment provision be required.

We can confirm that, should the circumstances arise where development of the site would be supported prior to 2021, then the site can be defined as both deliverable and developable in accordance with the National Planning Policy Framework (NPPF).

I feel this proposed development plans for Great Wakering are unsound on the grounds that the land is grade 1 farmland of the highest quality. Also there is a large natural gas main running as shown on map indicated by dotted lines. I understand that no new development can be built within 400m.

The local primary school at this time is bursting at the seams with children being ferried to other schools.

The roads from this village are inadequate to deal with the amount of traffic out of this area without the possiblity of extra housing.