MM29

Formal Objection to Allocations Document modification - Ref: MM29

In conjunction with MM20 (5% cap removal) this 30 metre (instead of 60 metre) limitation on distance from residential building is effectively encouraging an increase in the number of units to be built.

I therefore object to the Inspector's proposal to change from 60 metres to 30 metres limitation because: -

A. The effectively undefined number of units to be built will make it very nigh impossible to plan/cater for infrastructure (in all respects) needs.

B. It will encourage developers to 'creep' ever closer to the only remaining Farmland/Greenbelt buffer to the west of Rayleigh - east of Rawreth.

C. The sheer scale of the site will negatively impact both Rawreth Lane and London Road in respect of years of construction site traffic and subsequent ongoing mass domestic traffic usage.

D. The RDC Plan, as it stood, is at best a vague concept, I see no meaningful study work on the various impacts and have no confidence in profit driven Developers doing anything but exploiting this even lesser restriction.

I object to the proposed reduction of the distance of the residential development from the high voltage pylon lines to "further than 30 metres", rather than 60 metres, as I also object to increasing the proposed site boundary entailing further loss of green belt agricultural land. All for the purposes of ensuring there is a road within the development (though it cannot be excluded it is also to allow the possibility of more than 550 homes given the proposed removal of the 5% cap (MM20).

With regards to elements of the Sustainability Appraisal of the Allocations Submission Document, it is difficult to see how losing further greenbelt land currently in agricultural use - by turning it into allotments in order to better accommodate a road (or provide more room for more houses if the 5% cap is removed) within the site - provides a "more robust greenbelt boundary" than its predecessor. By definition greenbelt land for agricultural use is already there and is in itself a "greenbelt boundary". This is dishonest tautology. It is quite simply further loss of greenbelt land and on the basis it is difficult to see why it is assessed with a "+" in the Assessment of MM22, MM25, MM26, MM27, MM29 and MM20 in the Sustainability Appraisal of the Allocations Submission Document. The judgement that "it will also protect unwanted expansion into the Green Belt" is incorrect, since on current example the existing Green Belt is not protecting unwanted expansion into the Green Belt and the rules can simply be re-written or overturned at any future date.

Also, it is difficult to see how "the addition of a strong green buffer along the western boundary will have a positive impact on landscape". Open agricultural land is clearly more aesthetically pleasing than allotments, which typically result in unattractive and obtrusive features such as growing frames, sheds etc. This would be contrary to Policy/Paragraph 3.43 which states that "development must not adversely impact on the setting of the [grade II listed] building" ('Barn approximately 40 metres east of Rawreth Hall, Rawreth'). It is also inconsistent with the comments in Policy/Paragraph 3.46 which states: "A green buffer to the west of the site should have a positive impact on the approach into Rayleigh from this direction. There is an opportunity for the development of landmark buildings towards the western end of the site taking into account the principles of the Essex Design Guide whilst being sensitive to the neighbouring landscape. Design throughout the development should be of high quality."

A row of allotments does not imply a "positive impact on the approach into Rayleigh from this direction" or "being sensitive to the neighbouring landscape".

Again the judgement that this would provide a more defensible Green Belt boundary using permanent features are flimsy at best and Landscaping should be a "-" on its own, rather than offset by "++".

I do strongly support the view contained within the Sustainability Appraisal of the Allocations Submission Document on MM22, MM25, MM26, MM27, MM29 and MM20 which concludes under 8. Landscape & Townscape and 11. Land & Soil that "Both options perform less well than the baseline option of not allocating the site." On this basis a decision should be taken to reject these proposed changes and the proposed increase to the area of the site should be rejected. The argument that "it will ensure a stronger Green Belt boundary along the north eastern boundary to the site" is also contradictory by definition and lacks logic and honesty (i.e. how can the loss of a further 30m existing Green Belt boundary to build a road help to gain a "stronger Green Belt boundary"?!).

The consideration in this paragraph indicates that the re-siting of the Rayleigh Town Sports and Social Club, decided by RDC to facilitate the proposed housing development is unsustainable. The number of pylons present and high level of flooding in the immediate vicinity make this unsuitable for the purpose of the club; to provide sporting opportunities to all. It will possibly suit a new shiny social facility but at the expense of the young sports people it currently serves. Any move west across the A1245 would necessitate crossing a fast dual carriageway, impossibly dangerous for the young cyclist/pedestrians.