Our Environment

Representation ID: 37086

Received: 07/03/2018

Respondent: Historic England

Representation Summary:

Full text:

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

Thank you for consulting Historic England on Rochford District Council's Local Plan
Issues and Options stage. As the Government's adviser on the historic environment
Historic England is keen to ensure that the protection of the historic environment is
fully taken into account at all stages and levels of the local planning process.
Therefore we welcome the opportunity to comment on the Issues and Options. We
have now had the opportunity to review the documents and can provide the following substantive comments.

Comments on Issues and options

District Characteristics: The Environment

We are pleased to see reference to the District's rich and varied historic environment
in this section. The supporting text acknowledges the District's rural, coastal
characteristics as well as that of its settlements, it is important to note however that
rural and coastal areas are rich in their own sorts of cultural heritage and that it is not just towns and conservation areas that constitute the historic environment.

Please note that the term Scheduled Monuments should be used rather than
Scheduled Ancient Monuments. This term better reflects that not all scheduled
monuments are ancient.

Vision

The Plan's strategic policies will derive form the Vision and so there needs to be
sufficient aspirations in the Vision for the maintenance and enhancement of the
historic environment as a strand in the pursuit of sustainable development as defined by paragraph 14 of the NPPF. This will help ensure that the associated strategic policies incorporate a positive and clear strategy to deliver the conservation and enjoyment of the historic environment (as linked to paragraphs 126 and 157 of the NPPF).

The Vision is extremely succinct and includes no high level consideration of the
historic environment. It is noted that the Vision is supported by a number of key
themes on the following page of the consultation document. The environment theme
does address the need to conserve and enhance the built, natural and historic
environments which is welcomed; however we recommend that this is better
reflected in the Vision itself and not just in supporting themes.

Strategic Objectives and Priorities

Strategic Priority 5 seeks to conserve and enhance the natural and historic
environment, including landscape. This priority is supported by Objective 21 which
seeks to preserve and enhance the quality of the district's built and historic
environment. We are pleased to see these strategic level objectives within the Plan
and request that they carried through into further drafts.

SP1.3: How do we plan for and facilitate the delivery of our need for new homes
over the next 20 years within the district?

When exploring housing growth options, the capacity for the area to accommodate
new housing development whilst maintaining its historic environment should be a key consideration so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Where less successful neighbourhoods are proposed for redevelopment opportunities for enhancement should be outlined as a priority.

Allocation of new housing sites should be considered in the most sustainable
locations and should get the right densities and character appropriate to the area.
This approach will require a careful and detailed analysis of locations to ensure that
distribution of housing is appropriate. The historic environment is a critical factor in
this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. We hope that the distinctive qualities of individual settlements will be taken into account when
determining where development should take place. Conservation Area Appraisals
should be used to help assess suitability for development.

Section 6.48 of the consultation outlines a number of growth options. The district
contains many areas of historic interest with sensitive landscape settings. From a
historic environment perspective, it is difficult to rank the options in order of
preference given the range and distribution of heritage assets that could be affected.
Each option will have an impact on heritage assets, and it will depend to some extent on where site allocations are identified and the quantum of development as well as its design. Each option considered should include appropriate reference to the historic environment. It will be important to preserve settlement character and to avoid coalescence with neighbouring settlements. Growth options within existing
settlement centres should reflect the scale and character of the surrounding
townscape.

Before options can be considered further it is important to know whether or not
adequate land to meet the Objectively Assessed Need (OAN) can be identified
through the Call for Sites process and what implications this may have upon the
historic environment. It is noted that one of the options being considered is a new
settlement. In principle this idea could be an effective way of delivering the required
growth across the district in a sustainable way, but this is dependent on the
soundness of any future site allocations for a new settlement. Landscape and
heritages assets should be considered from the outset when determining the location
of a new settlement in order to ensure that development can be delivered whilst
having regard to the these assets. It is expected that strategic new settlement
policies makes reference to the historic environment and the need for its
conservation or enhancement. Without this being demonstrated in the identification
and justification of sites, and in the wording of the policies the Plan will be unsound.
It is essential that the local plan should contain a framework to guide how the
boundaries and extent of a new settlement will be determined in the emerging
development plan documents as the Plan process progresses. A Historic Impact
Assessment (HIA) should be undertaken in accordance with our advice note 'Site
Allocations in Local Plans' for each of the proposed broad locations to be taken
forward to determine the appropriateness or otherwise of the locations for
development, the extent of the development and therefore potential capacity of the
sites, the impacts upon the historic environment (considering each asset and its
setting and its significance), impacts of development upon the asset and any
potential mitigation measures necessary to accompany the proposals.

SP3.1: How can we prioritise and deliver improvements to the strategic and
local highway network over the next 20 years?

We support the provision of sustainable transport improvements in principle but we
do not advocate any specific options. Transport infrastructure provision has the
potential to impact on the historic environment in both a positive and negative way.
Upgrades to transport networks for example will need to be carefully planned to avoid harm to heritage assets and maximise opportunities for enhancement. Any schemes promoted through the Local Plan will need to assess the potential heritage impacts. All proposed transport infrastructure schemes and route options should take into consideration theirs impacts on heritage assets and their setting, alongside
archaeological potential. We expect any Transport Appraisals to address the impact
upon the historic environment. Paragraph 132 of the NPPF states that significance
can be harmed or lost through development within the setting of a heritage asset.
These matters will be material to the further drafting of transport policy and the
selection of routes.

SP3.3: How do we support and deliver improvements to the communications
infrastructure across the district over the next 20 years?

Telecommunications

Advanced, high quality communications infrastructure is essential for sustainable
growth. The development of high speed broadband technology and other
communications networks also play a vital role in enhancing provision of local
community facilities and services. However, the siting and location of
telecommunications equipment can affect the appearance of the public realm,
streetscene, the historic environment and wider landscapes. The consideration of
their positioning is therefore important, particularly in conservation areas. Paragraph
43 of the National Planning Policy Framework (NPPF) states that local planning
authorities, in preparing local plans, should support the expansion of electronic
communications networks, including telecommunications and high speed broadband
but that they should aim to keep the numbers masts and sites to a minimum
consistent with the efficient operation of the network.

The NPPF goes on to state that where new sites are required, equipment should be
sympathetically designed and camouflaged where appropriate. Crucially, the NPPF
identifies the protection and enhancement of the historic environment as being a key
strand in what it defines sustainable development (paragraph 7). We would therefore urge the emerging Local Plan, to ensure that any telecommunications policies include a provision for the protection of the historic environment and a requirement for applicants to consider the siting, design and positioning of equipment in this context. Telecommunications policies should have regard to the wider townscape and historic environment.

SP5.4: How should we address local landscape character?

We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic environment. We welcome the forthcoming further district-level landscape character assessment as outlined within paragraph 10.40 of the supporting text. This additional evidence that will build off the existing 2006 Historic Environment Characterisation project will help identify a suitable policy approach.

SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?

The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some of these elements but there is no actual policy provision for their conservation or enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.

Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to for applicants to consider the siting, design and positioning of equipment in this
context. Telecommunications policies should have regard to the wider townscape
and historic environment.
SP5.4: How should we address local landscape character?
We are pleased to see that this section of the consultation documents recognises the
link between landscape character and the role it has to play in conserving the historic
environment. We welcome the forthcoming further district-level landscape character
assessment as outlined within paragraph 10.40 of the supporting text. This additional
evidence that will build off the existing 2006 Historic Environment Characterisation
Project will help identify a suitable policy approach.
SP5.5: How do we continue to protect and enhance our heritage and culture in
the future?
The consultation document outlines 2 options for heritage and culture:
Option A: retain existing policies that are considered to be adequate
Option B: do not have policy or guidance relating to culture and heritage
Whilst the current policies may be working unfortunately neither of these options is
appropriate and neither will constitute a positive strategy for the conservation and
enhancement of the historic environment as required by the NPPF. The existing
policies date from 2011 and therefore pre-date the NPPF, as such they will need to
be updated. The current plan has standalone policies for: CP1: Design, CP2:
Conservation Areas and CP3: Local Lists. There is no policy provision for listed
buildings, scheduled monuments, archaeology, historic or designed landscape,
setting etc. It is noted that the supporting text of the current plan does address some
of these elements but there is no actual policy provision for their conservation or
enhancement. We request that these policies are revised and expanded upon to
reflect the objectives of the NPPF, not doing this would risk the forthcoming plan
being unsound. I am happy to comment on any policy wording before the next draft
of the plan is issued.
Some local authorities bring forward one or two overarching policies on the historic
environment, others prefer to have a standalone policy for each aspect e.g. listed
buildings, conservation, non-designated heritage assets, heritage at risk etc. Either
approach can be acceptable if worded correctly, I would say that the key issue to avoid is having an overemphasis on one aspect of the historic environment and not
others. The current plan has a policy on conservation areas but not listed buildings
for example which can create ambiguity for readers and decision makers.

General comments on historic environment policies:

We request the term "historic environment" is used rather than "heritage and culture" when referring to a standalone policy covering these areas. The historic environment is considered the most appropriate term to use as a topic heading as it encompasses all aspects of heritage, for example the tangible heritage assets and less tangible cultural heritage as well as designated and non-designated heritage assets.

The conservation and enhancement of the historic environment can bring a range of
multi-faceted benefits which can help achieve spatial planning goals. Recognising the
role the historic environment has to play in creating locally distinct places can help
improve economic prospects for places within the Plan area, can help improve wellbeing for local residents, and promotes an understanding of local history and identity.

It is important to see the opportunities that some developments may have in
enhancing the historic environment through public realm improvement, allowing
public access or better revealing significance. A coordinated appreciation of the
historic environment which addresses both the heritage assets themselves and their
setting will reinforce their integrity and therefore will help ensure that historic places
and spaces continue to provide long term public benefits. An integrated approach to
policy preparation that recognises the social, economic and environmental
dimensions of the historic environment and which seek to conserve this irreplaceable
resource will improve the ability of the Plan to protect and enhance the historic
environment.

Non-designated heritage assets:

The consultation document makes reference to non-designated heritage assets
which is welcomed. The compilation of Local Lists is encouraged as it is a good way
of keeping track of the condition of the historic environment. We are pleased to see
that the current plan has a standalone policy which addresses locally listed buildings
and we hope to this something similar carried forward into the new plan.
Whilst it is correct to say that local listings are non-statutory; it is also important to
highlight the requirements within the NPPF regarding non-designated heritage
assets. In national policy terms, 'non-designated heritage assets' (including those on
a local list) are recognised as having a degree of significance meriting consideration
in planning decisions. Paragraph 135 of the NPPF states that the effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect
directly or indirectly non-designated heritage assets, a balanced judgement will be
required having regard to the scale of any harm or loss and the significance of the
heritage asset. Reference in the local plan to the NPPF in this respect will better
reflect the NPPF and improve the soundness of the plan.

Climate change and energy efficiency

Listed buildings, buildings in conservation areas and scheduled monuments are
exempted from the need to comply with energy efficiency requirements of the
Building Regulations where compliance would unacceptably alter their character or
appearance. Special considerations under Part L of the Building Regulations are also
given to locally listed buildings, buildings of architectural or historic interest within
registered parks and gardens and the curtilages of scheduled monuments, and
buildings of traditional construction with permeable fabric that both absorbs and
readily allows the evaporation of moisture. It is recommended take emerging policies relating to climates change and energy efficiency in historic buildings are formulated with this in mind.

The design and siting of some energy efficiency equipment can have impacts upon
the character and appearance of historic places and upon the setting of heritage
assets. Again it is recommended that consideration is given to the continued need to
conserve and enhance the historic environment when developing these types of
policies. Policies which promote or encourage a blanket approach to energy
efficiency technology for should be avoided without some sort of qualification with
regards to heritage assets and their settings.

Setting

We expect to see appropriate references to setting in policies. As with assessing the
impact of site allocations on setting, with a site specific allocation, it is important to
understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations.
This involves more than identifying known heritage assets within a given distance,
but rather a more holistic process which seeks to understand their significance and
value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.

Design

We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific
requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic
environment and reflect local character and distinctiveness. This should not stymie
contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design.

D.P1.5: How do we deal with applications for basements within the existing
residential area in the future?

Basement developments in both rural and urban areas can have implications for the
historic environment which should be articulated in the forthcoming plan if basement
developments are becoming more common place and if a basement policy can be
justified.

It is important to be aware that basement development and subterranean works
brings the specific risk of disturbing archaeology. There are also problems when
considering subterranean developments within the curtilage of or setting of listed
buildings as careful consideration will need to be given to the need to avoid loss of
and disturbance to historic fabric, as well as how the basement level will accessed
and arranged. Underpinning of a listed building or structure such as listed garden
wall for example, will have significant impacts upon the historic footings and
foundations similarly linking the basement to the original property will be problematic.

From layout terms, the creation of an additional storey below a property can be as
equally harmful to internal plan form, layout, hierarchy and character as adding one
above a property. Even smaller works such as a lightwell serving a basement in nondesignated heritage asset can emphasis the existence of an additional storey below ground therefore allowing what historically was a two storey building for example to be read as a three storey building. Alterations such as this can have major implications upon the character of an area.

Omitting specific reference to archaeology and other heritage assets from the policy
is likely to make it harder for applicants to make successful planning applications and for the council to make informed decisions. It also increases the risk of delays during the planning and building phases of developments if significant archaeology is
discovered, which has not been identified at the appropriate stage of the process. We would emphasise the importance of the early assessment of archaeological potential to ensure applicants give this adequate consideration.

As the consultation documents acknowledges, robust evidence will be required to
support this policy. Evidence is required to inform the policy and to demonstrate how
issues associated with the subterranean development and the historic environment
can be addressed by the policy. For example, the method of excavation,
construction, and piling/underpinning can have considerable repercussions on the
structural integrity of above ground structures within or adjacent to the site and below ground archaeology as well as the wider historic environment. Associated activities such as pumping ground water out of a basement dig can impact upon the wider water table resulting in displacement of water or even dewatering which, depending on the underlying geological conditions, can have serious impacts upon foundations.

Ideally there should be evidence to show how the Council has considered these sorts
of issues and how the policy has been tailored to address them. It may be that the
Council intends to provide a Supplementary Planning Document which contains this
information. If an SPD is being considered it should be referred to in the Plan itself
and appear as a monitoring indicator.

D.P1.8: How do we address applications for the development of Brownfield
Land in the Greenbelt in the future?

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. This is equally applicable to the
assessment of urban brownfield sites. It advocates a number of steps, including
understanding what contribution a site, in its current form, makes to the significance
of the heritage asset/s, and identifying what impact the site might have on
significance. This could be applied to the assessment and selecting of sites within a
plan (see section on site allocations below).

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If brownfield sites are to be brought forward using the Brownfield Register System we would expect to see reference in the Notes column of the Register (Part 2) to the
need to conserve and seek opportunities to enhance the on-site or nearby heritage
assets and their setting, the need for high quality design and any other factors
relevant to the historic environment and the site in question.

Developments of brownfield sites within the greenbelt should be sensitive to their
surroundings to ensure the inherent character of the place is conserved.

D.P1.11: How do we continue to support the growth of home businesses
across the district?

When considering a policy on home businesses it is important to considered whether
or not the scale and nature of the business will result in a change of the primary use
of the property as can have implication on the wider character of the area. Physical
changes such as the encroachment of signage/advertisements in residential or
domestic areas can erode the established character of neighbourhood and result in
visual clutter.

Site Allocations

The consultation document does not contain any potential site allocations. It is noted
that the SHELAA (2017) appendices do contain a list of sites from the Call for Sites
process. Appendix C contains the results and outlines the site details of each site but
this runs to over 1100 pages. It is therefore not practicable or possible for us to
comment on this raw data in the absence of a short list of prospective sites. The
template used in the SHELAA appendix C is helpful and does contain much of the
information that we would expect to inform a site specific policy if the site were to
come forward as an allocation. However, it is advised that the templates better
address the historic environment by referring to issues such as setting, whether or
not there is a listed building near, or if the site is within a conservation area etc.
We have the following general comments to make on the site allocation process
which I hope will be of use:

Historic England advocates a wide definition of the historic environment which
includes not only those areas and buildings with statutory designated protection but
also those which are locally valued and important, as well as the landscape and
townscape components of the historic environment. The importance and extent of
below ground archaeology is often unknown, although information in the Historic
Environment Record (HER) will indicate areas of known interest, or high potential
where further assessment is required before decisions or allocations are made.
Conservation and archaeology staff within the relevant councils should be consulted
on matters relating to archaeology, landscape/townscape and the historic
environment generally.

We often find that while some of the sites in the Plan identify heritage assets as
potential constraints, this is not consistently done for all sites and all heritage assets.

There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified.

It should be noted that there are areas of archaeological interest beyond scheduled
monuments and historic landscape issues beyond registered historic parks &
gardens. Wider archaeological and landscape/townscape impacts are important
considerations and need to be factored into site assessment. The possible
cumulative impact of a number of site allocations in one location could also cause
considerable harm to the historic landscape/townscape.

All sites should be scoped for archaeological potential before taking them forward to
the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best
practice guidance so that impacts can be assessed at the earliest opportunity.

Assessing sites

Our advice note 3 on site allocations in local plans sets out a suggested approach to
assessing sites and their impact on heritage assets. It advocates a number of steps,
including understanding what contribution a site, in its current form, makes to the
significance of the heritage asset/s, and identifying what impact the allocation might
have on significance. This could be applied to the assessment and selecting of sites
within a plan.

In essence, it is important that you
a) Identify any heritage assets that may be affected by the potential site allocation.
b) Understand what contribution the site makes to the significance of the asset
c) Identify what impact the allocation might have on that significance
d) Consider maximising enhancements and avoiding harm
e) Determine whether the proposed allocation is appropriate in light of the NPPFs
tests of soundness

In assessing sites it is important to identify those sites which are inappropriate for
development and also to assess the potential capacity of the site in the light of any
historic environment (and other) factors.

If a site is allocated, we would expect to see reference in the policy and supporting
text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. We recommend that Heritage Impact Assessments (HIAs) are carried out to support major allocations. HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
Paragraph 157 of the National Planning Policy Framework requires Local Plans to
provide detail with site allocations where appropriate (fifth bullet point), with the
Planning Practice Guidance stating "where sites are proposed for allocation,
sufficient detail should be given to provide clarity to developers, local communities
and other interests about the nature and scale of development (addressing the 'what, where, when and how' questions)" (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).

Assessment criteria

Many authorities include a distance based criteria to assess impact on the historic
environment. It is important to understand the significance of any heritage assets,
and their settings, that would be affected by a potential site allocation. This involves
more than identifying known heritage assets within a given distance, but rather a
more holistic process which seeks to understand their significance and value. Whilst
a useful starting point, a focus on distance or visibility alone as a gauge is not
appropriate. Site allocations which include a heritage asset (for example a site within
a Conservation Area) may offer opportunities for enhancement and tackling heritage
at risk, while conversely, an allocation at a considerable distance away from a
heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms.

Local Plan Evidence on the Historic Environment

Rochford District Council has a very useful Historic Environment Characterisation
Project (March 2006) and we are pleased to see that this document forms part of the
evidence base for the Local Plan along with existing Conservation Area Appraisals
and Management Plans. Generally the type and range of evidence is useful but all
the documents listed are now rather dated with the majority being over ten years old and pre-dating the NPPF. It would be helpful if an updated topic paper could be
pulled together to better reflect the current condition of the District's historic
environment, outlines current challenges/pressures on the historic environment within the district, and that reflects current national policy. This could perhaps supplement the landscape characterisation work that the Council is also intending to undertake.

Having up-to-date evidence to support the plan policies will improve its soundness in
line with paragraph 158 of the NPPF.

Monitoring

We recommend indicators to measure how successful historic environment policies
are. These can include preparation of a local list, completion of conservation area
action plans and management plans, reduction in the number of assets that are
classified as heritage at risk.

Glossary

Glossaries should include consistent definitions for all heritage assets mentioned in
the local plan. These would typically include:
Listed Buildings
Scheduled Monuments
Conservation Areas
Registered Parks and Gardens
Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage
Assets / Locally Listed Buildings

Mapping

We recommend that designated heritage assets are marked on maps, where
appropriate.

Comments on Interim SA Report Oct 2017

The SA Objectives are generally appropriate and acknowledge that the historic
environment is formed by tangible heritage assets and less tangible elements such
as landscape character and associations of place. We have no other comments to
make with regard to the Sustainability Appraisal Interim Report which is well written and which will hopefully lead to a robust local plan that makes a positive provision for the historic environment.

Conclusion

In preparation of the forthcoming Local Plan we encourage you to draw on the
knowledge of local conservation officers, the county archaeologist and local heritage
groups.

These comments have been written in line with the current NPPF, this document is in
the process of being revised. The plan should reflect the policies of the new NPPF
once it has been revised and published later this year.

Please note that absence of a comment on an allocation or document in this letter
does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic
environment or is devoid of historic environment issues. Where there are various
options proposed for a settlement, identification of heritage issues for a particular
allocation does not automatically correspond to the support for inclusion of the
alternative sites, given we have not been able to assess all of the sites.
Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals,
which may subsequently arise where we consider that these would have an adverse
effect upon the historic environment. We hope that the above comments of
assistance.

Comment

Issues and Options Document

Representation ID: 37235

Received: 06/03/2018

Respondent: Hullbridge Residents Association

Representation Summary:

Page 12 and 13. Our Environment. Clause 3.13
We take issue with your statement describing the Flood Area.
Statements made by the Environment Department, Highways and Water Authorities suggesting assessments made in 2011 and 2014 that these were 'insufficient' at the time and further assessments are required to be made. We disagree, Hullbridge is not a 'sparsely populated' area. Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. The fear is that with further land being put forward for development this flood issue is likely to get worse over the next 20 years. It seems that RDC do not keep records of 'public health issues, and any complaints are ignored. Hullbridge community historical representatives have records to prove the issues and have consistently investigated complaints. The Hullbridge Parish Council deny this is their problem. Foul sewers are grossly overloaded. A full upgrade of the drainage

Section 3 (cont.

system is well overdue, neglected over 50 years, and may become the best investment Hullbridge ever had.

Full text:

*THIS REPRESENTATION INCLUDES SEVERAL ATTACHMENTS*

New Local Plan 2018. Issues and Options Documents

The Hullbridge Residents Association have viewed the Issues and Options Document and are pleased to give the views of the 5385 (extrapolated) Residents. This submission is also considered to be our Statement of Community Involvement.

Section 1. Introduction
1.1 States this is a new document, yet information has been repeated from documents produced previously in 2011/2012.
We understand the need for additional homes but we are concerned that 'Infrastructure' always seems to be a secondary consideration, when it should be the first.

Page 1. Clause 1.2
HRA produced and delivered to RDC a 45-page document pertaining to the Core Strategy, Land Development Framework and National Planning Policy Framework for a previous development, and altogether we submitted some 525 issues (un-answered) in criticism of the documents presented by RDC. Our main criticism lies with the lack of proper consultation and transparency, fearing another regretful experience, although we are asked to rely on the statements made by the Councillors that close consultation must be observed, we hope this will be recognised and our 'professional' views taken into consideration. We disagree with a statement made in clause 1.2 on page 1. Very few opportunities were given to the community to 'have their say'.

24 Sites.
To demonstrate our reasons for our rejection to allow developments of dwellings on the plans indicating 24 sites submitted for development and will apply the following clauses of the NPPF and CS:

NPFF - Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 - Promoting Sustainable Transport.
NPPF 5 - Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 - Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 - Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making - Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
Section 1 (cont).

NPPF Decision taking - Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests -

Drainage
Sustainable drainage systems;
The existing drainage system needs substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works.

Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 we take the clause 1.7 on page 2 seriously and we are hoping that RDC will engage in speaking with HRA who represent the majority of the Hullbridge community.

Clauses 1.8 & 1.9.
A plan indicating 24 additional sites in Hullbridge has been viewed by HRA. We consider the 24 sites will provide 2518 dwellings at a minimum density of 30 dwellings per hectare which has the potential of housing some 10,000 persons.
Having examined the plan we found that 6 sites are within the Rawreth Parish but not indicated in this section of this document namely- CFS006, CFS149, CFS099, GY 01, GY 02 and CFS 138. The total areas equate to 58.4 hectares = 1773 homes. 2 Sites are designated as Gipsy Sites providing a minimum of 18 homes. Our concerns are that this clause does not suit the "appropriate balance" between the environmental, economical and social factors stated in these clauses. These developments cannot be approved without consideration for the infrastructure. Sustainability of the infrastructure is the main ingredient to a successful community. HRA have been consistent in mentioning that the existing drainage and road network is in urgent need of maintenance and upgrading as lack of investment over the last 50 years has contributed to the reason for "Not fit for purpose" statements made by HRA previously.

Clause 1.10 is of special interest as it mentions "on-going consultation" at every stage. We did not have the opportunity to discuss 'The Draft Scoping Report which was published on the RDC websites, residents, businesses and other 'stakeholders' on the RDC mailing list were not consulted (HRA is a Stakeholder).

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this 'Act' to be included as it supports Human Rights.

Clause 1.15 suggests 'ultra-co-operation' with other Local Authorities but this statement is contradicted by statements made in the media some time ago of major disagreements particularly on the Southend Airport proposals.

Clause 1.16. Only one 'workshop' was set up in Hullbridge Community Centre but not followed up. The attendance was low because it was held at a time during working hours, with majority of the residents working away from home. The Q & A sessions were set to suit the Councillor's knowledge of planning and who could not answer questions put to him by a professional member of the community.

Clause 1.17 HRA have particular knowledge that the Parish Council do not have the ability to conduct a 'neighbourhood plan' without assistance from external Consultants but the costs to implement this are prohibitive.

Section 1 (cont).

HRA offered to do the Neighbourhood Planning Group adopting the CPALC 'Constitution', but were rejected without considering our professional expertise. HRA provided the appropriate clauses via the Localism Act that if the Parish Council were unable to conduct this duty, then, provided there was ample
scope for this, it could be carried out by a local community group. The Parish Council are on record of having admitted they are not equipped financially or in 'the know' how to deal with the complexities of large scale developments. HRA have consistently provided ample evidence of professionalism since 2013.
HRA, team members are professionally qualified having worked in a professional capacity in most types of construction development and refurbishment work.

A Neighbourhood Development Order would not be able to fulfil the requirements of large-scale developments, particularly by a Parish Council who would be out of their depth and the District Council would not be able to sustain the financial burden that would entail.
We refer to the Laws empowering the community to use the Freedom of Information Act, Localism Act (2011). The National Planning Policy Framework as prescribed by the Communities and Local Government Act (March 2012) which also provides the framework with which local people can produce their own Distinctive Local and Neighbourhood Plans which affect the needs and priorities of their communities (April 2012). Particularly where it is proven that the Statutory Consultee (The Parish Council) are restricted in 'consultation' through lack of Planning knowledge and the lack of finance to employ the necessary professionals, and where it is proven that HRA, having the professional members who have proved their worth through the submissions made in respect of the previous outline planning approval for 500 dwellings with a total of 525 issues presented with the help of the regulations stipulated in the Core Strategy, Land Development Framework, NPPF etc as mentioned above.
Planning law requires that applications for planning permission must be determined in accordance with the development plan, unless material considerations indicate otherwise and includes the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies - Part 6, Chapter 1, clauses 109 to 113,. Neighbourhood Planning - Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation - Part 6, chapter 4, clause 122.

This implies that the core strategy should be relevant, sustainable and 'Fit for Purpose':
* Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning has been carried in accordance with the Core Strategy was adhered to. We hope that those policies will be repeated.
* Justified.
In view of the aforesaid we do not believe there was any justification to provide more dwellings on Green Belt land particularly as the Core Strategy expressly stipulates that Green belt land should only be used as a last resort, many issues which we have demonstrated have not been addressed sufficiently.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
* Effective
The conditions for the development of the 24 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
* Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the National Planning Policy Framework. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government legislation, i.e. the Localism Act 2011 Chapter 20.

Section 1 (cont).

Our 45 page submission in 2013 suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we have been listened to, not merely placing this document on RDC website. We require RDC Planning/Legal department to clarify.
Clauses 1.18 and 1.19 speaks of 'community-led planning' which is of interest to HRA but we were ignored. We have consistently placed great emphasis on 'community cohesion'. Which makes for good public awareness.

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that proposals within the New Local Plan can be supported by robust, up-to-date information when RDC are suffering a shortage of staff and funding to support Parish Councils to administer the Local Plan.

Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund.
The Council will seek to fund this through a 'Community levy'. This implies that the RDC are not protecting the community. What assessments are made to prove the viability?

The Essex County Council document "Greater Essex Growth" states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and 'Community Infrastructure Levy' will fall way short of expectations and other Government Funding will be in 'shortfall' to the tune of £ Billions (report produced by AECOM) who also produced the RDC "Sustainability Analysis", please explain why they did not cite this issue.

HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations and should not be an 'extra' burden which the authorities neglected to set aside funding for in the past. If this is allowed to come into force this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. This could be an 'Infrastructure Congestion Levy (ICL).

Section 2. Pages 6 & 7. Tell Us Your Views.
We look forward to cohesive engagement throughout the timetable stated on page 7 clause 2.5 on the delivery of the New Local Plan. The HRA have the authority from the community of 5385 adults (97% extrapolated) who should be consulted and our views taken seriously to make the necessary amendments.

Section 3 Page 8. Rochford Characteristics.
Introduction. Item 3.1 No comment.
.
Page 9. Item 3.2. 24 Sites additional development Land.
The Land Mass measured and stated in this clause we find is possibly out of date because several hectares have already been built on since 2012 which should have been taken into consideration thus reducing the Land Mass area. Your review and consultation is necessary.

We have viewed the map showing 24 sites on MAP A of RDC Strategic Housing & Employment Land availability 2017 - Appendix B.

Section 3 (cont

The result of our examination provides the following information:
The total measure of 24 sites = 84 hectares (approximately) which will provide a capacity of 2517 dwellings at 30 dwellings per hectare. The range in terms of 30 to 60 dwellings per hectare can provide a range of 2517 to 5040 dwellings.

Boundary Line.
Further examination of the same map indicates that a large proportion of the land lies in the adjoining Rawreth Parish.
The result provides the following information:
The total measure of 6 sites = 59 hectares (approximately) will provide a capacity of 1773 dwellings at 30 dwellings per hectare. The range in terms of 30 to 60 dwellings per hectare can provide a range of 1773 to 3540 dwellings.
In our examination of the New Local Plan Document, we are unable to find any explanation for omitting this 'division'.
Using our previous submission in relation to the Boundary Line indicated in the Ordinance Survey shown and confirmed by the Local Boundary Commission correspondence on a new development recently given "Outline Planning Approval" for a development in Malyons Farm in Hullbridge Essex. We corresponded with Rochford District Council who on this issue but they refused to accept the existence of the Boundary line. At a meeting with Barratts (incumbent developer) we are informed that RDC will make arrangements to have the Council Tax collected by Hullbridge on behalf of Rawreth Parish without explanation about the differing postal address, and whether or not Rawreth will be amalgamated with Hullbridge but there is no correspondence from the Local Boundary Commission acknowledging this possible change. We can only assume that the same principle will apply on this land mentioned above which resides in Rawreth Parish, if so, this will be in conflict with the Boundary Commission England and the National Planning Policy Framework regulations.
We ask RDC for an urgent review of this New Local Plan.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. "Travel to work outflows and inflows".
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure with the lack of improvement known to be evident in the whole district, where 'grid-lock' occurs on all local roads.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest these statements are using out-of-date information transferred from 2011, therefore a review is necessary. What guarantees will the prospective developers give to employ local skills. Bring back the paid 'apprenticeships' for all persons up to the age of 20.

Page 12 and 13. Our Environment. Clause 3.13
We take issue with your statement describing the Flood Area.
Statements made by the Environment Department, Highways and Water Authorities suggesting assessments made in 2011 and 2014 that these were 'insufficient' at the time and further assessments are required to be made. We disagree, Hullbridge is not a 'sparsely populated' area. Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. The fear is that with further land being put forward for development this flood issue is likely to get worse over the next 20 years. It seems that RDC do not keep records of 'public health issues, and any complaints are ignored. Hullbridge community historical representatives have records to prove the issues and have consistently investigated complaints. The Hullbridge Parish Council deny this is their problem. Foul sewers are grossly overloaded. A full upgrade of the drainage

Section 3 (cont.

system is well overdue, neglected over 50 years, and may become the best investment Hullbridge ever had.

Page 14. Our Communities. The RDC figures on the population is inaccurate.
Concentrating on the Hullbridge population count for 2011 suggests 6527 but the doctors patient list suggests a population of 6858 (4.83%) (2014). HRA support from the community in 2017 suggests 7000 population (+ 6.79% on 2011). With the approved outline plans for 500 homes at 100 homes per annum proves an annual population increase from 2019 to 7400 (+11.8%), 2020 to 7800 (+16.33%), 2021 to 8200 (+20.40%), fast forward to 2023 = 9000 population (+27.50%). The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per annum. This is contrary to the Core Strategy, LDF and the NPPF clauses, and the Localism Act so much heralded by the Government for close consultation with the District Council, this has lost all its credibility. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of Population by Parish from 2011 Census.
These possible developments will increase the Hullbridge population to 19,000 within 15 to 20 years, which is contrary to the NPPF requirements and will be classified as over-population.
Hullbridge has a 'village status' which will be lost forever and become a Town with a population second only to Rayleigh. The portfolio holder, Councillor Ian Ward, stated in the '1st Local Plan meeting' in Rayleigh that things have changed and it was now paramount to 'listen' and closely 'consult and engage' with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA 'professionals' will not be heeded.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that "the proportion of residents in all demographic ranges will remain 'stable'. We advise the RDC to review all the above clauses. We suggest the whole population breakdown table of Parishes should be reviewed to reflect the current figure.

Projected Population Count.
The new Local Plan suggests 24 new sites put forward in Map A for Hullbridge/Rawreth for sale/development, equates to approximately 83 hectares at minimum 30 dwellings per hectare = 2518 dwellings.
Spread over a period of 20 years = 125 dwellings to be built per annum.
The average increased population per annum will be 5%+ reaching a maximum of 10,000 (minimum) over 20 years occupation of 2518 dwellings and the total population estimated to be about 19,000, subject to the minimum development ration of 30 dwellings per hectare but the variance which can be 30 to 60 dwellings per hectare. The effects of this 'development policy' will have consequences on the original Core Strategy through to the National Planning Policy Framework which needs to be reviewed urgently. The implications of this 'overdevelopment' is that insufficient thought is given to the road network, general infrastructure, healthcare, safety, flood, drainage, environment, travel and above all congestion of population, traffic and lack of thought given to an expansion to the road network.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date as the document is prepared using data prescribed in 2011 without some fact-finding surveys being conducted to carry out 'forward planning' especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime 'home provider'.

Section 4

Page 17 - Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.

We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of interest to the community, before finalising this document.
Consultative Objections.
We submit our "Consultative Objections" and conform to the NPPF policy stated on page 16, Clause 66, namely - 'that the Local Authority and the 'Applicants' must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.
Government Portals have indicated use of identified Brown Field Land in preference to Green Field Land and the Consultation Procedures identified in the Core Strategy & Site Allocation Documents.
The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017).

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 6 years of deliberations over the Hullbridge 'development', we are unable to state that this has been a success for the District Council with a majority of the 185 issues within our 45- page submission, presented at the time, not being satisfied by the local population and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of any future "Consultation".

We hope the current Portfolio Holder will allay the fears of the community of the lack of trust, that they are committed to meaningful consultation with the community representative and to adhere to any agreements that can be made with respect to any further developments in a congested area.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded (please refer to the HRA document submitted to Rochford District Council in April 2013). A "Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that' the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land and are being allowed to be developed disregarding all the clauses which are supposed protect the Green Belt. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.

Page 27. Clause 5.11. Homes and Jobs. Strategic Priority 1 and 2.
The homes and jobs, retail, leisure and other commercial development is the aspiration of RDC but the community do not believe that the proposed dwellings are for the indigenous population.

Section 5 (cont

The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority when it is evident that this statement only acts as a cover to succeed in making it happen.

Page 28. Cl. 5.11. Strategic Objective 13. Flood..
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints. What you do not understand is that you have a recipe for disaster in an area naturally susceptible to suface water discharge from the 'rayleigh Heights' about 65m above ground level.

Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will change the law and this will be detrimental to the community at large.
Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Page 30. Clause 6.1 - 6.4. Delivering homes and jobs. Strategic Priority 1: Homes and Jobs
We understand your commitment to deliver the above but at what expense? Refer also to Clause 5.11 above.

Page 31. Clause 6.5 Figure 9: Need for Market, Affordable & Specialist Homes.
Net housing completions 2006/7 - 2016/17.
Our statement above providing some proof that your statistics are out of date. We advise you to review and revise this statement immediately to avoid any anomalies.

Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
We have demonstrated that the figures given for homes and population are flawed.
Meaningful discussions should be allowed to provide amended statements to satisfy the community.
Advance notice. Property Insurance.
The potential Property Insurance costs against 'flood risk' and 'subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis which will be made at the required time.
An exercise on Post Codes SS5 reveals that using the 'Hawkeye' system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence - usually £2,500.00 (£1000.00 being 'Standard').
And for any areas susceptible to flood, no protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making 'flood excess' a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in 'affordability' has not been fully considered. We advise you to review and amend this statement to suit.
How can you demonstrate the 'affordability' during this financial climate, which are likely to continue for the next 10 years irrespective of the incentives given on stamp duty and directives to the lending institutions. It is obvious to most people that their children will have great difficulty to purchase their

Section 6 (cont

own homes, and the financial climate changes could be stoking up problems in the foreseeable future and this will require full understanding of financial markets.

Page 40 to 42. Clauses 6.33 to 6.37. Need for Care Homes.
We agree this policy of providing habitation for elderly and infirm. Your plans should include a separate location for 1 and 2 bedroom bungalows for the elderly and infirm.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land. We suspect that the new Land Development Framework document will allow new building on the green belt land. We suspect the NPPF' document will not be respected.

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, Here it is evident that the option may be for up to 60 homes per hectare. RDC have recently suggested that they may reduce the number of available sites put forward but will possibly increase the density. We proved that this doubling of homes will cause even greater strain and stress on the Hullbridge community and the infrastructure. The community suggest a review of this policy for Hullbridge with the argument that the road network does not allow for this type of over development. We have always emphasised that the existing infrastructure is inadequate. Can we persuade you to take appropriate action as given in our letter to the Managing Director Mr. S. Scrutton as follows:
That RDC take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to date, on the grounds that the previous planning regime's over the last 30 years or more neglected to deal with the drainage and traffic problems. Please read this in conjunction with page 5. Clause 1.21.

Page 46. Clause 6.49. Good mix of homes.
We are not sure that the present 'mix' has been thought out properly, with the 'cost' of homes being identified as 'expensive' is it right that the 1 to 4 bed homes in percentage terms is A) 3 beds, B) 4+ beds, C) 2 beds and D) 1 bed homes.
We note a conflict in statement that under clause 6.51 it states that the demand is greater for 1 and 2 bed homes yet the above percentages prove to be different. Please amend the statement.

Page 49. Clause 6.58. Type and size of new homes.
Due to the change of cost considerations should you consider amending the clauses to suit the financial environment for affordable cost-related dwellings and the hierarchy for dwellings should be in the following order A) 2-bed. B) 3-bed. C) 1-bed. D) 4-Bed. The financial purchase prices will fluctuate.

Page 51 to 54. Table 7. Clause 6.66 to 6.78. Gipsy and Travellers sites.
The community ask, how can the law justify providing 'valuable' sites to people who have no respect for the community who are forced to 'pay' indirectly for this 'provision', and using other sites which became public knowledge, the devastation it caused to the local community. No one is given the opportunity to understand this Law that in wider terms seem to force the community to pay 'however indirectly' by their Council Tax to pay for the site and the amenities provided, in some cases occupied illegally and without planning approval as reported by the media. The mere mention of these circumstances affect home values, security, illegal extraction of 'services by illegal connections to neighbour services and being a law unto themselves etc.

Page 57 -60. Clause 6.87 to 6.96 Meeting Business needs.

Section 6 (cont

HRA wrote in our last submissions that we required guarantees from the 'developers and businesses to give the local community first option for jobs, we look forward to dialogue with all the businesses to set out some rules allowing the local population consideration. Our business survey seems to be the first of its kind and has been well received by the businesses visited. See HRA Business survey.

Section 7.
Page 71 - 77. Clause 7.1 - 7.27 Supporting Commercial Development. See Business Survey.
Considering the existing Hullbridge businesses we are unable to identify how these existing businesses can expand to support the needs of the expanding population. Will the RDC identify some of these sites for commercial or industrial purposes, which can provide jobs for the local population. Clauses 7.21 seems to give the impression that the Supermarket and town centres serve the community without need to provide land for 'business' premises, but there are some folk who are unable to get to these larger shops etc due to illness or other infirmity or no means of public transport.
There may be scope for an 'advice centre' 'assist in mental incapacity' or 'club' to assist these folk.

Section 8.
Page 78 Clause 8.1. Delivering Infrastructure.
Strategic Priority 3. As stated before, the existing infrastructure is in urgent need of planners' attention to create improvement, and there is no 'strategy' is in place to provide this urgent work to be carried out, before any development takes place.
We wrote to Mr. S. Scrutton to take advantage of part of the £866m the Government has set aside for LA infrastructure work. Hullbridge community are concerned that this will continue to be ignored, and will cause problems for the future, the costs will be the main cause of dissatisfaction in the ability of the RDC to adhere to the CS, LDF and NPPF clauses and again as experience suggests the Highways, Environment and Water Authorities will ignore it.

Local Highways Capacity and Infrastructure. Clause 8.3
LDF Development Management Submission Document- Section 5- Transport page 73.
Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the 'Planning approval' given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not 'fit for purpose'.
We must emphasise that setting out the 24 sites for development will only make matters worse for access purposes.
Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, but ignored. Watery lane and Hullbridge Road are identified as traffic congestion points in clauses 8.13 to 8.15. HRA have mentioned this consistently since 2013, but we were and are ignored by all the authorities. We demand the upgrade which was promised for discussion by the Planning Inspector.
People find themselves obliged to use this road because Rawreth Lane (to the South of Hullbridge), is the only other means of access, but continually congested with traffic also joining from Hockley via Rayleigh. The Hullbridge community are concerned that this will continue to be ignored, and will cause problems for the future, the costs will be the main cause of dissatisfaction in the ability of the RDC to adhere to the CS, LDF and NPPF clauses and again, the Highways, Environment and Water Authorities will ignore it.
We request that RDC contact the SAT NAV services to remove Watery Lane as a general thoroughfare or to emphasise this is "weight restricted" and only just wide enough to suit farm vehicles etc.
There are some big obstacles to be overcome with just a single access into the village and hardly any room to improve the road network, Hullbridge will become the most
Section 8 (cont

congested 'town' in Essex and 'over populated' causing infringement of clauses in the CS, LDDF and NPPF.

This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification.

Page 81. Clause 8.13 to 8.15. Congestion and access impositions.
HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not 'fit for purpose', we reject the statement that Watery Lane is NOT part of the "Strategic Highways Network", which is in conflict against other statements made above, and request an urgent meeting with the Highways Agency and Environment Departments of Essex County Council to review this part of the document.
We need to point out dissatisfaction expressed from the discussions held at the 'workshop' mentioned in clause 8.13. We hope this New Local Plan will allow closer consultation.

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, and Ambulance services and will not be suitable for for constant construction site traffic for next 20 years..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out recently as required by the Core Strategy and the NPPF documents. Further consideration must be given for 'transparency' as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which will be caused by both existing and any future construction work

Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
Presently the transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on there are going to be future major problems with the increased population with insufficient public transport. We think the policies being put forward seems to be for the benefit of the 'short term', to save money.
Please refer to LDF Allocations Submission Document Page 60 Cl 3.177 and Cl 3.178
Transport Impact Assessment should be carried out prior to any development and all side roads should be 'sign posted' NT SUITABLE FOR SITE TRAFFIC'. This also applies to the development taking place in Malyons Farm.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause it does not fill us with confidence that something will be done to provide good quality air. It has been reported recently in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded ibn and around the Rayleigh area. It has also been stated that record amounts of carbon dioxide have been recorded in 2017 and is on the rise, the highest it has been in the last 4 years.
Air quality is lacking in both depth and detail which means the RDC 'evidence base' on the subject of traffic is lacking. Please explain your remedy? This pollution issue has been apparent for many years but has been ignored for too long. The community now demand action to remedy this issue.

Page 90-92. Clauses 8.38 to 8.44. Communications Infrastructure.
We hope the statements made about the speed factors on "Superfast Essex" will be fulfilled to satisfy the community within a timetable to be viewed and commented on.

Section 8 (cont

Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (very frequent 25 times in 5 years), in Watery Lane, this results in accidents, causing 'gridlock' to the whole local traffic system in Hullbridge and surrounding areas.
Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 - 8.66. Renewable Energy Generation.
We agree about the 'renewable energy' 'dream' from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part of this 'dream'. The other part of this equation is trying to educate the rest of the world to accept that changes must be made with meaningful expediency. We need to know how you will fulfil these obligations given the financial constraints in the next 10 years.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
HRA previous experience suggest that the Local Authorities ignore the observations and pleas made to review the standards laid down by the NPPF, Core Strategy and LDDF to allow 'proper' consultation with those of the community who are genuinely interested in all the issues presented to them.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community find it difficult to believe that there will be any changes to allow meaningful consultation with the community. An Action Plan is required to clarify and eradicate all anomalies.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 - 9.61. Health Impact assessment- Cl 3.186
Enquiries at the Hullbridge Riverside Health Centre suggested that the Practice did not have any advance information about the Malyons Lane development. An increase in the population will mean a proportional increase in number of Doctors. We (HRA) brought to the authorities' attention various anomalies in the financial accountability in assessing the "Contributions" without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 'contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. AS HRA have been active on this issue it would be in the interests of all partries to consult and agree a course of action.

Section 10
Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts but there is conflict in these statements by resistance to make appropriate assessments of ground water levels, flood impact, coastal changes, changes to biodiversity and with developments in areas vulnerable to the above issues.

Page 121 - 141. Clause 10.5 - 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the green belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
Section 10 (cont

3. Assist in safeguarding the countryside from 'encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Promoting a Green District.
The proposed developments sites are in Green Belt, we are not convinced that the Core Strategy is encouraging the conservation or prevention of erosion of the Green Belt.

Page 122. Clause 10.8 Inappropriate development.
Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document (Issues and Options) to make sure any potential developers take this into consideration. It may be appropriate to classify this as "Special Measures" and allow the intervention of a Planning Inspector to adjudicate.

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes
In HRA discussions with a possible developer we were advised that the RDC stated that the Core Strategy and the land Development Framework were 'out of date' therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, can we deduce there has been no change in the above named main documents as such?
We respectfully request a complete review and amendment to suit up-to-date information, for 2018, of the Core Strategy, Land Development Framework and National Planning Policy Framework documents. Can Rochford District Council provide evidence that these documents have been amended to suit present day and future activities? The NPPF clauses states that merging of towns and villages should be resisted.
We anticipate difficulties by the people under 40 years of age being unable to afford purchase or rental prices of homes, all as predicted by the media. HRA look forward to view your policies to allow us to advise a number of young folk asking us for advice and we are creating a 'List of people' requesting to be placed on this list, which will be forwarded to you.
Please take into consideration many Planning Ministers and indeed our Prime Minister stating on the media that Green Belt Development must remain sacrosanct. Once again we respectfully request RDC do not ignore our plea for transparency and fairness invoking the NPPF and LDF clauses as appropriate.

Page 155. Clause 11.45 Brownfield Sites.
As we (HRA) have emphasised before, clauses 11.45 and 11. 46 are taken into consideration that all Brownfield sites must be used first in preference to Green Belt development.
Our experience has been, to date, on a site recently given outline approval, that 11 Brownfield sites had
been put forward for development but ignored in favour of 23.4 hectares of Greenbelt farmland.
We agree that NPPF paragraph 89 and Policy DM10 on brownfield development and should be taken into consideration when producing these documents.
We refer you to the 'ambitious' clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside - Vision.
Short term. The first paragraph stipulates the "openness and character" of the Rochford Green belt continues to be protected, but small areas released for development are not being protected.

Page 156. Extensions etc. No comment

Page 157. Parking Standards etc. Cl 11.54 to 11.57. see above.

Page 164. Contaminated land. Cl 11.77 to 11.81.
Section 11 (cont

All sites must be assessed for flood, contamination and environmental issues. These sites will need an environmental study and specific action plans produced to decide appropriate measures for supervisory treatment.

Other issues.
Core Strategy Clause 3.158- SITE CAPACITY (Core Strategy Policy H2 and H3)
This clause is suggesting a minimum 2518 dwellings in Hullbridge on Green Belt land (24 sites) is included in the "Sites for development" call by RDC to be considered during a plan period of 2023 to 2030 at a minimum density of 30 dwellings per hectare.
HRA predicted, in 2013 (see our 45 page submittal document to RDC) that further sites will be classified as a 'sustainable development site' which implies that more Green Belt land will be sought. This will be contradictory to the policy of "maintaining the Green Belt" as stipulated throughout the Core Strategy and indeed by Government statements.
This further development will not promote 'Community Cohesion' and are not convinced that this development will be for our indigenous population, but to accommodate the London 'overspill'.

Flood implications
Refer to Core Strategy and LDF Submission Document
Policy ENV3 - Flood Risk page 85.

We are concerned that these 'sites' may be classified as 'sustainable Development' over a period of 10 to 20 'disruptive' years, on top of the present development which are programmed to be developed for the next 6-7 years, as presumed under clauses 1.30 to 1.32, there can be implication from a Risk Analysis in respect of flood, refer to National Planning Policy

LDF Cl 3.177 and 3.178 Page 60. Promoting a Green District and LDF Management Submission Document-Clause 3 page 33- The Green Belt and Countryside - Vision.
The proposed development 'sites' are in green belt, we are not convinced that the Core Strategy is encouraging the conservation or prevention of erosion of the Green Belt.
We refer you to the 'ambitious' clauses stipulated in the

Allocation Submission Document Allocation Development Plan
Greenbelt and Brownfield land - see Evidence base Document.
Call for sites - Appendix 1. Page 14 Clause 2.1 Brownfield sites - policy ED3.
The core strategy previously identified 12 sites for potential development of which 8 are Brownfield sites. The sites are as follows: No's 10,15,17-19, 66, 115, 124,127.
Site no. 66 is the proposed development for Hullbridge. This is Greenbelt grade 2 agricultural land which according to the Core Strategy should have been protected against any development.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)

The 'Localism Act' was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. The Core Strategy and Allocations DPD Documents which were published in 2009, 2010 and 2011. This act stipulates that the Local community has: the 'right to challenge' ( Part 5, Chapter 2, Clauses 81 to 86).

Note:
The Business Surveys and the Statement of Community Involvement are stated on separate sheets.