MM20
Object
Allocations: Schedule of modifications
Representation ID: 32802
Received: 03/12/2013
Respondent: Mrs Christine Paine
Objection to removal of 5% cap in development North of London Road
I object to the removal of the 5% flexibility cap on the following grounds
Building more than the 550 houses plus 5% will impact severly on the quality of life not only for residents in the new properties, but for existing residents of the area/It makes all previous public consutations which were based on 550 plus maximum of 5% unsound and completely negates all previous evidence for sustainability. It is imperative that the residents, both current and those to come, have confidence that this development will not result in the greenbelt being overtaken by an unlimited urban sprawl and if the 5% cap is removed this confidence is also removed.
Object
Allocations: Schedule of modifications
Representation ID: 32803
Received: 08/12/2013
Respondent: Rochford District Residents
Deletion of the Cap means that any site may now deliver 30 houses per Hectare but the Sustainability Appraisals do not support such density.
As new Sustainability Appraisals would now be required and this could cause the CS to stall and I would recommend that the 5% Cap is retained.
The CS including the Cap and subject to defined housing numbers was previously consulted upon and another public consultation must be undertaken that states what the impact of deleting the Cap. This is not made clear and deletion of the Cap under these circumstances would render the decision Unsound.
Mr. Smith. I attended Day 1 of this PE and gave you an explanation of why in each Location/Site Allocated the Council had adopted a max 5% Cap. I note from your Interim Letter/Report that you require the Council to delete this in every instance by Modification to render the CS Sound. Please consider this representation an objection to apply to every instance of deletion without limitation.
You mention the "early" Revision of The Core Strategy which was determined to be required by Ms. Graham in 2011; Your Quotation is "the Council is committed to an early review of the Core Strategy which is due to begin in 2014" (EXA175a).
You state that the Council will commence the Revision of The Core Strategy in January 2014 and I would say that by referring to this that obviously see some reliance and relevance to this in the findings of your Interim Report.
Officers have opined that the Revision of The Core Strategy can only be taken forward with the publication of the SHMA 2013. This has not taken place and I think you need to be cautious with assuming that there will be an "early" Revision of The Core Strategy. Perhaps you need to discuss this further with the Council or make a further requirement with dates.
As to the 5% Cap if the "early" Revision of The Core Strategy were to be proceeding with greater commitment from the Council then I believe that you could reverse your decision and retain the cap because of the greater assurance that could be given to providing the 5 year supply because concerns over certain Sites could be put aside with replacements that will come forward.
Furthermore I believe that to have deleted the Cap in all Locations and Allocated Sites means that any site may now deliver 30 houses per Hectare, which I believe to be the maximum density determined by the Government but the Sustainability Appraisals do not support such density. Mr. Smith, you drew attention to this issue in EXA 167 "The Council should also bear in mind the possible need for further Sustainability Appraisal" and whilst this quotation was not made in that exact context the issue is of equally direct and determinative in relationship to deletion of the Cap.
As new Sustainability Appraisals would now be required and this could cause the CS to stall and I would recommend that the 5% Cap is retained.
In addition as the CS including the Cap and subject to defined housing numbers was previously consulted upon surely a further public consultation must be undertaken that makes it quite clear what the impact of deleting the Cap will have. This is not made clear in this Consultation and deletion of the Cap under these circumstances would be legally flawed and render the decision Unsound.
Object
Allocations: Schedule of modifications
Representation ID: 32810
Received: 19/12/2013
Respondent: Rawreth Parish Council
Having studied the Inspectors interim report Rawreth Council strongly oppose the removal of the 5% flexibility capping as the removal of the 5% capping would leave no control over specific development sizes and would take away Localism.
In addition, removing the cap makes the previous public consultations unsound as the evidence base for sustainability was based on specific numbers. As Members of the public were consulted on a specified number of houses being built and this is then allowed to increase by an uncapped amount this rendering the process unsound. In addition by removing the cap and thus increasing the number of homes that can be built on specific sites the quality of life for residents both existing and new is diminished.
Allocations Submission Document: Consolidated list of modifications
On behalf of Rawreth Parish Council I confirm that this letter is a formal response and representation of the Councils views with regards to the Allocations submission Document, following the interim report on the soundness of the plan issued by Mr David Smith BA(HONS) DMS MRTPI of the Planning Inspectorate .
Having studied the Inspectors interim report Rawreth Council strongly oppose the removal of the 5% flexibility capping as the removal of the 5% capping would leave no control over specific development sizes and would take away Localism.
In addition, removing the cap makes the previous public consultations unsound as the evidence base for sustainability was based on specific numbers. As Members of the public were consulted on a specified number of houses being built and this is then allowed to increase by an uncapped amount this rendering the process unsound. In addition by removing the cap and thus increasing the number of homes that can be built on specific sites the quality of life for residents both existing and new is diminished.
Yours faithfully
Mrs Hayley Bloomfield
On behalf of Rawreth Parish Council
Object
Allocations: Schedule of modifications
Representation ID: 32819
Received: 20/12/2013
Respondent: Mr J Cripps
The original proposal of 550 +5% will clearly adversely impact the traffic flow both during years of construction and the subsequent ongoing domestic usage.
I therefore object to the Inspector's proposal to remove the 5% cap on units as it is clearly going to make the vehicle loading even worse and is unsustainable because:-
A. The existing roads will be gridlocked at rush hour periods.
B. Tailbacks will create highway hazards at the junctions with the A1245.
C. The local infrastructure (in all respects) will not be able to cope with an effectively undefined number increase in loading, namely - Schools/Doctors/Public Services and shrinking Emergency Services.
D. The proposed site already contains 3.1 hectares of land designated as Flood Plain thus limiting the number of 'legally built' unit locations - any increase in numbers will inevitably encroach on that unsuitable zone.
E. The RDC plan as it stood is a vague conceptual outline, I see no meaningful study work on the various impacts - to remove the 5% cap (a modicum of control) is, in my view, quite negligent of the Inspector.
Formal Objection to Allocations Document modification - Ref: MM20
Both Rawreth Lane and London Road will be the route of vehicle traffic to and from the proposed mass housing (550 units +5% in Rayleigh) and indirectly to/from the proposed mass housing in Hullbridge (500+) and in due course a further 200+ units on what is now Rawreth Industrial Estate.
Both these roads are already overloaded for the existing volume of traffic and are effectively at a crawl during morning and evening rush hour periods.
The original proposal of 550 +5% will clearly adversely impact the traffic flow both during years of construction and the subsequent ongoing domestic usage.
I therefore object to the Inspector's proposal to remove the 5% cap on units as it is clearly going to make the vehicle loading even worse and is unsustainable because:-
A. The existing roads will be gridlocked at rush hour periods.
B. Tailbacks will create highway hazards at the junctions with the A1245.
C. The local infrastructure (in all respects) will not be able to cope with an effectively undefined number increase in loading, namely - Schools/Doctors/Public Services and shrinking Emergency Services.
D. The proposed site already contains 3.1 hectares of land designated as Flood Plain thus limiting the number of 'legally built' unit locations - any increase in numbers will inevitably encroach on that unsuitable zone.
E. The RDC plan as it stood is a vague conceptual outline, I see no meaningful study work on the various impacts - to remove the 5% cap (a modicum of control) is, in my view, quite negligent of the Inspector.
Object
Allocations: Schedule of modifications
Representation ID: 33089
Received: 12/01/2014
Respondent: Mr Nick Matthews
This proposes a further loss of 8.7 hectares of open green belt agricultural land which was not deemed necessary at the time of the original document and is trying to be pushed through now at a later stage via the back door. Where will the upwards creep stop? Furthermore, the proposed change is detrimental to paragraph 3.44 in the Local Development Framework Allocations Submission Document since it further erodes the green buffer between the proposed development and the Grade II Listed Building and hence adversely impacts on the setting of the Grade II listed building.
This proposes a further loss of 8.7 hectares of open green belt agricultural land which was not deemed necessary at the time of the original document and is trying to be pushed through now at a later stage via the back door. Where will the upwards creep stop? Furthermore, the proposed change is detrimental to paragraph 3.44 in the Local Development Framework Allocations Submission Document since it further erodes the green buffer between the proposed development and the Grade II Listed Building and hence adversely impacts on the setting of the Grade II listed building.
This land (once part of Rawreth Hall Manor) is of historic interest. It was once owned by the King's cook in 1266, one of the Speakers of the House of Commons (in 1413) and was granted by King Henry VIII in 1525 to Cardinal Wolsey (see The History and Antiquities of the County of Essex by Rev. Philip Morant, Vol 1 (1763-1768), Pages 284-285.
One of the fields proposed to be used was called Hanging Hill so a full and detailed archaeological study of the land should be undertaken to ensure nothing of historical importance or value is lost.
Object
Allocations: Schedule of modifications
Representation ID: 33435
Received: 16/01/2014
Respondent: Rayleigh Town Council
Rayleigh Town Council has expressed disappointment and has concerns about the removal of the 5% cap on housing numbers as recommended by the inspector since this could lead to an almost unlimited open ended increase in numbers at other sites in the case of a shortfall at some sites.
This is the response to the consultation by Rayleigh Town Council:
Rayleigh Town Council has expressed disappointment and has concerns about the removal of the 5% cap on housing numbers as recommended by the inspector since this could lead to an almost unlimited open ended increase in numbers at other sites in the case of a shortfall at some sites.
Comment
Allocations: Schedule of modifications
Representation ID: 33436
Received: 17/01/2014
Respondent: Great Wakering Parish Council
We would like to express our concern at your proposal to remove the 5% cap for residential extensions (Policy SER1-9).
Dear Sirs
We refer to your letter ref ALLSOM261113 dated 26th November, 2013 in respect of the above.
We would like to express our concern at your proposal to remove the 5% cap for residential extensions (Policy SER1-9).