National Picture

Paragraph 4.3. "Through the Growth Deal, SELEP can direct Government monies towards specific projects across the LEP area - including schemes to deliver new homes, jobs and infrastructure - which can competitively demonstrate a growth return for the investment." My comment is that the criterium 'can competitively demonstrate' pushes investment towards homes and jobs at the expense of infrastructure, as it is easier to demonstrate growth from the former than the latter. But, adequate infrastructure is a necessary enabler of growth. If you use an unsuitable analysis method, you get the wrong answer.

Paragraph 4.5. The words "we must not over-burden investment in business." are meaningless and make the whole sentence incomprehensible. Delete these and the first word "Whilst" and the sentence makes sense.

Paragraph 4.13. The word "however" occurs twice in one sentence, which is incorrect.

Paragraphs 4.13 and 4.15. If Castle Point and Southend really are unable to meet their housing obligations then perhaps RDC could offer them some land in the extreme south east of the district, which is reasonably near Shoebury rail station, provided that central government funds the much needed relief road from the A130 to Shoebury, crossing the Crouch somewhere between Hullbridge and Fambridge and crossing the Roach. Southend and Castle Point would pay for the necessary flood defences for the new homes.

Twenty two Strategic Objectives is far too many! The document would be more convincing if you called the five Strategic Priorities the five Strategic Objectives and put the other points under them as numbered bullet points. Many of these are not strategic and they are not objectives; they are job descriptions of what the council is expected to do.

Putting homes and jobs first might be what central government want but it is not what the existing residents want. These two are interdependent - build more homes and you have to create jobs for the people to work in; create more jobs and then you cannot fill the jobs until you have built homes for the workers. The first priority should be what you have at number three: transport, waste management, and flood risk. You can forget about telecoms, water supply, wastewater and the provision of minerals and energy as these will all be provided by the private sector.

In paragraph 3.3 "The area home to around 3,320 businesses...." the verb "is" is missing.

Paragraph 3.5 "The workplace and resident earnings in the district are below average compared to Essex and the UK." This is not true. It is true for workplace earnings but not for resident weekly earnings which at 670.9 are higher than Essex (594.0) and UK (539). The statement is also inconsistent with the first sentence of the next paragraph "The area is a generally prosperous part of the country,"

Paragraph 3.14 "'green part' of the South Essex". The word "the" is superfluous.

Figure 5: Ecological Map of the District. I think this is a bit out of date. Should not the whole of the eastern side of Wallasea island be shown as a local wildlife site? Also metropolitan green belt and sites of special scientific interest are shaded in the same colour.

The summary of statistics in paragraph 3.20 is muddled. "The proportion of residents aged 20 to 64 is expected to remain relatively stable over the next 20 years." is inconsistent with "An increase in the older proportion of residents compared to the rest of the population has the potential to lead to a smaller workforce and higher dependency needs."

Paragraph 4.3. "Through the Growth Deal, SELEP can direct Government monies towards specific projects across the LEP area - including schemes to deliver new homes, jobs and infrastructure - which can competitively demonstrate a growth return for the investment." My comment is that the criterium 'can competitively demonstrate' pushes investment towards homes and jobs at the expense of infrastructure, as it is easier to demonstrate growth from the former than the latter. But, adequate infrastructure is a necessary enabler of growth. If you use an unsuitable analysis method, you get the wrong answer.

Paragraph 4.5. The words "we must not over-burden investment in business." are meaningless and make the whole sentence incomprehensible. Delete these and the first word "Whilst" and the sentence makes sense.

Paragraph 4.13. The word "however" occurs twice in one sentence, which is incorrect.

Paragraphs 4.13 and 4.15. If Castle Point and Southend really are unable to meet their housing obligations then perhaps RDC could offer them some land in the extreme south east of the district, which is reasonably near Shoebury rail station, provided that central government funds the much needed relief road from the A130 to Shoebury, crossing the Crouch somewhere between Hullbridge and Fambridge and crossing the Roach. Southend and Castle Point would pay for the necessary flood defences for the new homes.

Twenty two Strategic Objectives is far too many! The document would be more convincing if you called the five Strategic Priorities the five Strategic Objectives and put the other points under them as numbered bullet points. Many of these are not strategic and they are not objectives; they are job descriptions of what the council is expected to do.

Putting homes and jobs first might be what central government want but it is not what the existing residents want. These two are interdependent - build more homes and you have to create jobs for the people to work in; create more jobs and then you cannot fill the jobs until you have built homes for the workers. The first priority should be what you have at number three: transport, waste management, and flood risk. You can forget about telecoms, water supply, wastewater and the provision of minerals and energy as these will all be provided by the private sector.

Paragraph 6.12. "Affordability can be measured by comparing the lowest 25% of earnings to the lowest 25% of house prices, which gives an affordability ratio." This is written the wrong way round and would give a ratio of 0.103. It should be written "Affordability can be measured by comparing the lowest 25% of house prices to the lowest 25% of earnings, which gives an affordability ratio."

Tell Us More SP1.1: Affordable homes and ageing population.
Surely the district council's responsibility is restricted to ensuring that sufficient land is available for development and that there are no unreasonable planning hurdles put in the way of developers. The net completions graph shows that the actual number of houses built depends on the overall state of the economy and the economics of the housing market. The district council has no control over either of these. Central government has only minor influence, even if they think otherwise.

6.30 Option: A Option C sounds like a good idea but will not work. If you are thinking of the children of existing residents then in many cases those children who would like to buy a home here will not currently be residents here. They may be renting elsewhere (in my case in South Woodham Ferrers and the Isle of Man). You would have to come up with a definition of something like a "right to residence" rather than "resident". The whole concept is fraught with difficulties.

6.21 Option: C Market forces will sort out what gets built and options D and E are then irrelevant.

6.33 Option: A

If there is a particular requirement for providing additional assistance for certain sectors of the population then try persuading central government to allow you to increase the rates paid by everybody already in the district and put that money away, securely, in a fund earmarked for that purpose.

Tell Us More SP1.2: Care homes Option: A

Paragraph 6.45. I do not agree with this statement: "We need to demonstrate that we have considered all the options before considering the Green Belt."

The original idea of the Green Belt has become distorted over time. The idea was that existing towns and cities would be surrounded by a belt of green land to prevent urban sprawl. (It is usually cheaper to build on greenfield instead of brownfield sites and so without this "belt" developments will always expand outwards, leaving a neglected and eventually derelict inner core, as in many USA cities.) In Rochford District we have a lot of Green Belt land which is not a belt around anything - it is just a vast expanse of undeveloped land.

Instead of infilling within existing developments and nibbling away at what really is the green belt immediately adjacent to them, something a lot more radical is needed and if central government are going to keep handing down housing targets then they must be prepared to provide the necessary infrastructure. It is this:
Build the relief road previously mentioned from the A130 to Shoebury, crossing the Crouch somewhere between Hullbridge and Fambridge and crossing the Roach. It needs to be a high capacity dual carriageway feeding directly onto the A130 and not at Rettendon Turnpike. The Fairglen interchange needs to be substantially improved (not the current inadequate proposals) to handle the extra traffic between the A130 and the A127 in both directions. The new road needs direct exits to both Battlesbridge and Shoebury stations and 2 or more exits to allow new developments to be built on this huge area of green land which is not green belt at all. A bus service will provide transport from the new developments to both stations. Obviously, schools, health, drainage, and power infrastructure will be needed as well but it will be cheaper to provide it out here than adding to existing conurbations. Flooding is an issue but the existing villages have to be protected against flooding anyway.

Tell Us More SP1.3: New homes ...
Option: E All of the other options are just short-term tinkering.

Tell Us More SP1.4: Good mix of homes
Option: A (The policy on affordable housing in conjunction with market forces takes care of this.) Option E is also worth considering but will only be viable if option E has been chosen in SP1.3.

I do not agree with the statement "This approach would therefore not be appropriate." in Option I. What justifies the "therefore"? It would be sensible to adopt option I and not have a specific policy. If you want to build bungalows you will probably have to accept a lower density than the current minimum, if you want to have an area of affordable housing then a good way to keep the costs down is to go for a higher density. Not to have a specific policy does not mean that there is no policy at all. Why constrain yourselves unnecessarily?

Paragraph 6.70 "There is no need has been identified..." remove "There is"

Tell Us More SP1.5: Gypsys and Travellers Option B

Tell Us More SP1.6: Houseboats Option B

Tell Us More SP1.7: Business needs Options B, C, and E

Tell Us More SP1.8: New Jobs Options B, D, E, F

Tell Us More SP1.9: Southend airport Implement all options A, B, C, D

Paragraph 6.127 "The availability of broadband in more rural areas is a constraint to the development of tourism in the district; nowadays visitors need access to promotional and other material electronically to help them navigate around (although paper copies are still
important)." This is just not true. Do you mean broadband or do you mean 3G/4G phone coverage? Local businesses need broadband, tourists do not.

Tell Me More SP1.10: Tourism and rural diversification Option B

Tell Us More SP2.1: Retail and leisure Options A, B, C, D If it ain't broke, don't fix it!

Tell Us More SP2.2 Local facilities
This is outside of the council's sphere of influence and so there is no point in worrying about it. Pubs and local shops will close if there is insufficient trade to keep them going, while in new developments business will spring up once there is sufficient demand provided planning restrictions do not get in the way. Options A and B.

Tell Us More SP3.1 Roads
Paragraph 8.1 "The equality of infrastructure in terms of services and facilities is challenging across the district given that we have such a large rural area to the east, which can mean that isolation becomes an issue." If you embrace my previous suggestion and with Southend and Castle Point persuade central government to fund the new road, the large area to the east will no longer be rural and isolated. In paragraph 8.10 "It also includes
the area to the south of the River Roach in proximity to Great Wakering." you identify exactly the problem that this would address.

Paragraph 8.12 mentions a requirement for a bypass around Rayleigh but there is nowhere to build such a bypass even if it could be justified and funded. Part of the problem in Rayleigh is that in the evening rush hour the A127 towards Southend is so congested that traffic turns off either at the Weir or Fairglen interchange and diverts through Rayleigh. Also, traffic coming down the A130 and heading for Southend finds it quicker to divert through London Road, Rayleigh town centre, and Eastwood Road than to queue for the Fairglen interchange and Progress Road. A bypass is needed not around Rayleigh but from the A130 to the eastern side of Southend.

Paragraph 8.17 "upgrades have been completed at the Rayleigh Weir junction". Is there any evidence that these 'upgrades' have made any difference whatsoever? Local people think not. If they have not been completed, do not say so.

Option C would be better than nothing. The others are only tinkering around the edges of the problem. What is really needed - although outside of RDC's control - is improvements to the strategic road network.

Paragraph 8.21. Option A is marginally better than doing nothing.

Tell Us More SP3.2: Sustainable travel
Paragraph 8.27. "Encouraging cycling within and through Rayleigh town centre are, in particular, supported to drive improvements to local air quality in this area, for example improved cycling storage." This is wishful thinking. Rayleigh is on top of a hill, of the four approaches, three involve cycling up hill in poor air quality. There are a few diehard cyclists (like my son) but normal people will not be influenced by improved cycle storage.

Paragraph 8.31. "study recommends several mitigation measures ..." These measures are just tinkering and are completely inadequate. More traffic lights are needed and some pedestrian crossings need to be moved or removed. I submitted a comprehensive plan for this previously and I shall submit it again as an appendix to this document.

Paragraph 8.34. "We could consider setting a more challenging mode share, for example 30/30/40 (public transport/walking and cycling/private vehicle)." This is wishful thinking. You can set what mode share you like but you cannot influence it.

Options A, C, and E are sensible. B will not help, D is impractical

Tell Us More SP3.3: Communications infrastructure Option B

Tell Us More SP3.4: Flood risk Options A and C

Tell Us More SP3.5: Renewable energy Option A

Tell Us More SP3.6: Planning Option A

Tell Me More SP4.1: Health Option D

Tell Me More SP4.2 Community facilities Option B

Tell Us More SP4.3: Education Option A and B

Tell Us More SP4.4: Childcare Option A and B

Tell Me More SP4.3: Open spaces and sports. [this number has been repeated]
These do not look like options. You seem to want to do all of them. What is there to choose?

Tell Me More SP4.4 Indoor sports and leisure [this number has been repeated] Option A

Tell Me More SP4.5: Young people Option A

Tell Me More SP4.6 Play spaces
Paragraph 9.57. "In order to reduce the amount of greenfield (undeveloped) land...." I do not entirely agree with this premise and think you should reconsider it. Most of the district is greenfield. Surely, building on some of that is better than trying to squash more and more development into the existing towns and villages. People in new houses can access their gardens every day, they possibly only 'go out east' to look at a field once or twice a year.
Option A

Paragraph 10.6 "A fundamental principle of the Green Belt is to keep a sense of openness between built up areas." Yes, that is what the green belt is for. However, most of the metropolitan green belt in Rochford District is maintaining a sense of openness between the built up areas to the west and the sea to the east.

Tell Us More SP5.1 Green belt vs homes Option B

Tell Us More SP5.2 Protecting habitats
Option A but leave it as it is; do not waste your time and our money worrying about climate change or wildlife corridors. There are plenty of wildlife pressure groups to do that. Also, implement options C, D, E, F, and H. Do not waste your time and our money with G.

Tell Us More SP5.3 Wallasea Island Options A and B

Tell Us More SP5.4 Landscape character
Paragraphs 10.35 to 10.45 - two and a half pages (!) written by someone who has gone overboard extolling the virtues of the countryside. I love the countryside and particularly the coastline and mudflats but this reads as though RDC councillors from the east have too much influence and want to protect their backyards (NIMBY) while pushing all the development to the west where, in fact, the majority of ratepayers actually live.
Options A and B

Tell Us More SP5.5 Heritage and culture Option A

Tell Us More SP5.6 Building design
I question whether there is any justification for doing this. Why not just follow the national guidelines, Essex Design Guide, and building regulations? Option A and K

Tell Us More SP5.7 Air quality
None of the actions proposed will make a significant difference to air quality. The biggest improvement will come from the gradual replacement of older vehicles with new ones built to a higher emissions standard and, ultimately, the introduction of hybrid and electric vehicles.

Air quality now has increased importance. The EU is threatening to fine our government because its plans to improve air quality in a large number of cities and towns are inadequate. Just waiting and hoping that things get better will not do!

If you want to do anything in a faster time frame than that then steps must be taken to: reduce traffic congestion; avoid building new homes in areas that are already congested; build new homes in areas where the air quality is good.

I refer you again to the plan that I append to this document to significantly reduce congestion and improve air quality in Rayleigh town centre. This could be achieved in much less time than waiting for all the existing vehicles to be replaced.

You may as well stay with option A since options B and C will make no difference.

Tell Us More D.P1.1 Affordable homes Option F What happened to options A to E?

Tell Us More D.P1.2 Self build
You are making a mountain out of a molehill on this. No policy is needed. Anyone wishing to self build will have to find a plot of land first. They will then have to apply for planning permission and meet building regulations the same as anybody else would. All the council has to do is NOT to discriminate against such applications. From the self-builders point of view, negotiating the VAT maze is far more of a problem. New builds are zero rated but everything they buy will have VAT on it. The only way to claim back the VAT is to form a company and register it for VAT but that is difficult when it has no trading history and will only complete one project. This is all for central government to sort out, not local councils.
Option D

Tell Us More D.P1.3 Rural exception sites
Paragraph 11.16 "with the publication of the Housing White Paper in February 2017 the definition of what constitutes affordable homes could be amended" This is clearly out of date and needs updating. Was the paper published last year? Was the definition amended?

There is no point in wasting time and effort worrying about a situation that has not arisen yet and may not arise. Since there are so many possible variables in the circumstances any such policy would have to be extremely comprehensive. Wait until a planning application is made and then assess it on its merits. If there is no formal policy in place then this would have to be debated by the Development Committee. You could meet the NPPF requirement by putting a reference to rural exception sites on the council's website.
Option H

Tell Us More D.P1.4 Annexes and outbuildings
Option B which should say "...rely on case law", not "reply on case law".

Tell Us More D.P1.5 Basements
Option A

Tell Us More D.P1.6 Rebuilding in the green belt
Option B

Tell Us More D.P1.7 Agricultural occupational homes
Paragraph 11.42 ".... applications for the removal of agricultural occupancy conditions will not, therefore, be permitted except in the most exceptional circumstances." Are you sure this is sensible? If an agricultural home becomes empty would you rather let it remain empty and possibly become derelict than allow a non-agricultural worker to move into it? Option A

Tell Us More D.P1.8 Brownfield land in the green belt
Option B

Tell Us More D.P1.9 Extending gardens in the green belt
Option A

Tell Us More D.P1.10 Parking and traffic management
Options A and B

Tell Us More D.P1.11 Home businesses
A thriving home business could cause parking issues in the immediate area but it also provides local employment thereby reducing commuting out of the area. Also, noise and pollution issues have to be considered. This requires each case to be assessed on its own merits. Option A

Tell Us More D.P1.12 Altering businesses in the green belt
Option A

Tell Us More D.P1.13 Advertising and signage
Option A

Tell Us More D.P1.13 Light pollution [this number has been repeated]
Option B

Tell Us More D.P1.14 Contaminated land
Option A

The introduction is too verbose and will deter people from reading the whole document. A professional editor should have been employed to précis it down to a length that people will be willing to read. Some of the rest of the document is better but would still benefit from editing.

There are too many spelling, grammatical, and punctuation errors to make it worthwhile proof-reading this initial draft until it has been edited.



Interim Sustainability Appraisal

The first ten pages have been constructed by concatenating standard paragraphs, with minimal editing, in the same way than an accountant or surveyor prepares a report.

The rest of it consists of extracts from the Issues and Options document with meaningful, but not particularly incisive, comments.

Preparing this document was a legal requirement but it does not add much to the sum total of human knowledge.




Appendix

A proposal for the reduction of traffic congestion in central Rayleigh and consequent improvement of air quality

Air pollution is an acknowledged problem in central Rayleigh and just today the high court have ruled that the government must do more to reduce it, particularly NOx emissions from diesel vehicles. A major cause of air pollution in Rayleigh is traffic queuing on Crown Hill and creeping forward one vehicle at a time - engines continually running and repeated hill starts which are particularly bad for NOx emissions. Many recent cars and buses have automatic engine stop when stationary so that if traffic is held at a red light emissions will be significantly reduced. This feature will become commonplace over the next few years.

The pedestrian crossing at the top of Crown Hill and the mini roundabout at its junction with the High Street must be eliminated in order to cure this problem. This proposal achieves that and improves traffic flow in Websters Way as well as eliminating most traffic from the central part of the High Street.

1. Close the High Street to traffic between the Crown and Half Moon/ Church. Allow access for taxis to the existing taxi lagoon only. Allow access for delivery vehicles but perhaps only at specified times. This will be a shared space and so 10 MPH speed limit.
2. Block off access from Bellingham Lane and Church Street to the High Street.
3. Replace the mini roundabout at the Crown Hill / High Street junction with a swept bend with limited access to and from the High Street (see 1) with give way lines on the outside of the bend.
4. Replace mini roundabouts at the High Street / Eastwood Road and Eastwood Road/ Websters Way junctions with traffic lights.
5. Replace the zebra crossing at the top of Crown Hill with a light controlled pedestrian crossing.
6. Remove the pedestrian crossing outside the Spread Eagle. This is no longer needed as people can cross from The Crown to the taxi lagoon.
7. Replace the zebra crossing across Eastwood Road outside Marks and Spencer with a light controlled pedestrian crossing.
8. Replace the zebra crossing across Websters Way near to Eastwood Road with a light controlled pedestrian crossing.
9. Arrange for coordinated control of the two new sets of traffic lights, and the four light controlled pedestrian crossings (Crown Hill, Websters Way, and two in Eastwood Road). *
10. Remove the pedestrian crossing in the centre of the High Street as it is no longer needed.
11. Remove the traffic lights at the Junction of Websters Way and High Street and the pedestrian crossing across the High Street as they are no longer needed. Retain the pedestrian crossing across Websters Way. This junction becomes a swept bend and will be free flowing for traffic except when pedestrians are crossing.
12. Access for wedding cars and hearses to the church will be unaffected except that they will have to use London Hill instead of Bellingham Lane to/from Church Street.
13. Access to the Mill Hall and its car parks will be via London Hill and Bellingham Lane. A new exit will be required from the windmill car park to London Hill adjacent to Simpsons solicitors. **
14. Provide parking for disabled people in Bellingham Lane between the Mill hall and its previous junction with the High Street. Create a small turning circle where the junction used to be.
15. Create a layby in Websters Way for buses heading for Hockley or Bull Lane.
16. The loading bay outside Wimpy will become the bus stop for the No 9 bus.
17. The No 1 bus is a problem as it will no longer be able to stop in the High Street or Websters Way and the first stop in the High Road is too far from the town centre. A new bus layby will be needed outside Pizza Express. ***
18. Install traffic lights at the junction of Downhall Road and London Road, incorporating the existing light controlled pedestrian crossing.
19. Install traffic lights at the junction of London Hill and London Road / Station Road. Traffic lights will not be needed at the junction of The Approach and London Road if the lights either side of this junction are phased correctly.

* There are potentially some problems which arise because there will be traffic lights at junctions where the limited space available prohibits the use of a right turn lane or a left filter lane and there are pedestrian crossings nearby. The traffic lights at High Street / Eastwood Road and Eastwood Road / Websters Way will each need to have a phase when traffic from all three directions is stopped and both the adjacent pedestrian crossings are open for pedestrians. This phase will only need to occur when a pedestrian has requested it at either of the adjacent crossings. When there is a lot of pedestrian traffic it will be necessary to synchronise both junctions so that the "all traffic stopped" phase occurs at both junctions at the same time.

** Some drivers will complain that in order to get to the Mill Hall they have to go down Crown Hill and up London Hill, although they could park in Websters Way car park or the market car park and walk. However, people approaching Rayleigh along the London Road will have easier access to the Mill Hall car parks and will not enter the town centre at all, reducing congestion and pollution.

*** Considering traffic coming up Crown Hill, it will be advantageous to arrange that when the pedestrian crossing on Crown Hill goes red to stop traffic there is a delay of several seconds before the light at the High Street/ Eastwood Road junction and the Eastwood Road pedestrian crossing turn red. This should empty this section of road and allow a bus in the layby to pull out without disrupting the traffic flow up Crown Hill.

Dear Sirs/Madam
I write with much concern over the proposed New Local Plan for up to 7500 houses in this area! I believe the building that is currently going on in this area is far greater than the infrastructure can cope with!
I realise there is a need for more housing but with some of the affordable housing being around £350,000 how is this going to help our young people? If affordable housing is necessary why are houses worth up to a million pounds being built in this area particularly in Hall Road? I also believe that many of the houses being built in Hall Road are for a London Borough which I find completely unacceptable as we are grinding to a halt locally if this is so why are we committing to other boroughs? Surely common sense tells us that with all the traffic jams and problems in the area at the moment we cannot carry on building at this rate and also house people from London Boroughs! I believe the large building projects should be taken away from the South East altogether! This area of the country is simply FULL UP!!
We also have the huge industrial estate being built at the airport at the moment and goodness only knows how much extra traffic that will bring into the area aside from the delivery lorries which this site will bring there will be thousands of workers and customers! New jobs to the area you say - well that is if we can actually drive on our roads to reach it - perhaps drones are the answer!!!
If you happen to live in this area you will be aware of the chaos that is caused by even the refuge collections every week! Simply vans delivering to the local businesses in Hockley, which cannot park, can cause several miles of traffic queueing back in all directions! Road works of course are a necessity but can cause absolute chaos especially at time when it has been decided to dig up all surrounding roads at the same time!! It is not unusual to take an hour to drive from Rayleigh to Ashingdon which is of course before this housing phase is complete!
I also understand that all the various infills of flats and houses don't get counted in the big scheme of things? Is this correct and why are they not??
I would also be interested in knowing how the infrastructure would be improved because apart from knocking down half the houses on the main roads I fail to see what can be done! Local flooding can also be a problem and will not be helped by continued building on such a scale!
I am fed up with being told about Government policy - I don't believe anyone in the local planning office could actually justify what is about to be thrust upon us!
Our local hospitals, doctor surgeries, schools are not coping now so how on earth will they cope with everything that is proposed in this phase so I believe the allocation for the next phase should be dramatically cut and certainly avoid any further building directly adjacent to the Rayleigh to Hockley main road and also the main Ashingdon Road!!

NEW LOCAL PLAN my views

We are being overwhelmed with new-build houses. The selling price of these houses is beyond the reach of nearly all constituents of Rochford District and their relatives and friends.

As a result of this over-building, our environment is suffering gross pollution (not only from cars): I myself suffer from a lung infection and my only way of preventing further decline in health is to move away from the area. I chose to move to Hawkwell in 1963 when I could walk across the main road (B1013) without even looking; this remained the case for about 15 years when I moved away to live in South Woodham Ferrers.

Subsequently I moved back to Hawkwell in 1999 to find Hawkwell had changed only a little but this was to change radically in the next 12 years. In the past 5 years, traffic and pollution have increased 4-fold. It sometimes takes 10 minutes to pull out of my driveway onto the road due to traffic, a lot of which is only 'passing through' and should properly be using the A127! The road congestion cannot be avoided and with it comes pollution.

Councils are being blackmailed by Parliament to build regardless of the cost to our health and well-being. Our MPs are failing us. They have not stood together and said: "stop", they must now do so.

About 6 years ago, in response to the request of Hawkwell Parish Council and in conjunction with other concerned parishioners, we produced the Hawkwell Parish Plan (copies were handed to Rochford District Council members) showing what it was that Hawkwell parishioners wanted; to get a good idea of what was need in 2012 and beyond, it is necessary to read the conclusions of the plan. It was not necessary to build very many houses - the need was for hundreds and not the thousands of houses which are being built now: all this latter does is to encourage people to move out of London to live in Rochford District, it does not improve or even maintain the lot of our existing parishioners.

It is my view that those elected to serve the community are failing us badly in all aspects of local life here; this applies at government, county and district levels.

Dear Sir/ Madam

With respect to the above mentioned plans please see below my objections and comments to the above mentioned plan

I've lived in Rayleigh for the best part of 60 years and seen changes good and bad. Rarely have I involved myself in local politics although I must confess to having strongly objected to the London Road/ Rawreth Lane proposals for many reasons. This process did make me realise that mass developments such as these need heavy scrutiny and the need for individuals and local communities to stand up and state their alternative views and hope that the voice of reason is carried.

I would like to see a 20 year plan for Rayleigh and the surrounding area that considers the following;

Decision makers putting the wishes and concerns of the local community at the forefront of all large scale planning applications/options.

A strong focus given to the impact of increased traffic flow that would result from any large scale future planning applications/developments. This should take into account both congestion problems together with health and pollution issues.

Property developments only to be considered as and when sufficient infrastructure is already in place (or proven it will be in an acceptable timeframe) and considered adequate to cope with the consequences of any such developments.

All decisions should keep in mind the need to avoid developments that support or negatively influence the culture of anti-social behaviour. Presently this is moving very quickly in the wrong direction in Rayleigh and as such gives rise to much concern. The mid and long term effects of this should not be under-estimated and is an important consideration if we are to maintain Rayleigh as a desirable place to live or visit.

Where there is insufficient room for new or very much improved roads then no large scale developments should be permitted.

There should be no intrusion into designated "green belt" areas, it was labelled green belt for a reason and those reasons still hold good today. We need to keep in mind that our trees and vegetation are linked to an important eco system that benefits us all.

MOST IMPORTANTLY I WOULD LIKE TO SEE LOCAL GOVT STAND UP TO THE CENTRAL GOVT. WHO ARE IMPOSING THESE QUOTAS AND CHALLENGE THEM WHEN IT CAN BE DEMONSTRATED THAT IN ALL PROBABILITY THE PROPOSALS WILL RESULT IN A NEGATIVE IMPACT TO THE EXISTING RESIDENTS/ENVIRONMENT.

I believe in a democratic society local councils should have a moral duty to support and stand up for the desires and wishes of the local communities they represent rather than accept any ill thought -out and unwelcome impositions of central government.

As long as I can remember Rayleigh has always been a desirable place to live. At the moment however it is on the cusp of slip sliding away into something far less desirable. Now is the time to reject what is not in our best long term interests and for the local Council to submit a more acceptable and realistic planning proposal that fits with the wishes of the local community and takes into account the foregoing objections and comments.

para 1.1 future 'of' our district.
par 1.3 'Silent' is ambiguous and subjective. How long is silent... a day... a month... a year...? How long is it before a local plan is deemed to be silent and therefore, could be ignored?
footnote 2 p1 typo
para 1.13 This is subjective. I'm sure what is valued by myself may not necessarily be valued by the council. Needs to consider emotional needs of landscape and not those of someone walking around with a clipboard.
para 1.14 Who does the Planning Inspector work for?
para 1.21 What happens if that fund is insufficient to meet the baseline infrastructure requirements?
para 3.2 Is there a map available of these designated areas?
para 3.3 The area 'is' home...
para 3.3 Contradicts with the characteristics of our district that have just been described. How can a district with very low unemployment and deprivation levels be a target area for improvement and regeneration? Why is our district not an exception within South Essex?
para 3.12 What plans and which schools? These need to be included or referred to in the document if not already done so.
para 3.14 We should be trying to keep it that way. This statement contradicts with the desire to build 7.5K houses.
para 3.14 This is a positive. Nothing wrong with this.
para 3.15 What are these actions and are they considerate with the desire to build 7.5k houses in the district?
para 3.16 Seems to contradict with the desire to build 7.5 houses
Our Communities p14 Re point 3, building more 4/5 bed houses does not address the concern of affordability, the new builds along Hall Road being a case in point - This is not sustainable development
para 3.22 Agreed. The developments at Hall Road and Folly Lane have not helped this trend.
para 4.4 I consider this a dangerous approach to take. It suggests that housing needs are being put before all other needs. I get the idea of 'policy off' and the requirement to identify housing need but this cannot be done in isolation. All needs must be considered, as a whole, if this is to work.
para 4.4 Again, has to be affordable and sustainable. No point in building 4/5 bed properties for 500k as will not meet objectives and will just add to an ageing population.
Challenge before para 4.6 The challenge will be delivering business that can afford to pay wages that allow residents to live in the district. This comes back to affordable housing. Your figures show that most residents commute to London; that is where the higher wages are paid.
para 4.6 Typo : Need to need to.
para 4.6 It is also critical if 7.5k homes are going to be built. They go hand in hand. Can't have one without the other which is what we're starting to see at Hall Road and Folly Lane where additional infrastructure is not being provided.
Challenge before para 4.7 It has to be long term strategic thinking, not short term for a short term quick hit win. Pride and self gain have to be put to one side and everyone needs to buy in to the long term vision, including developers, builders and land owners. This cannot be about personal gain and profit. If this isn't sustainable and the infrastructure isn't in place, we will have a post war planning disaster on our hands, which future generations will be left to deal with, by which time it will be too late.
Challenge before 4.8 Depends on who the neighbours are, and how similar the issues and challenges they face, are to those of our district. I would always encourage communication, collaboration and idea sharing but it has to be meaningful and strategic and not just doing it for the sake of it.
para 4.9 What is a sub-regional housing market area?
para 4.10 What about utilities infrastructure (energy) and education?
para 4.13 What does this mean in real terms? Does the burden fall on our district to meet the shortfall e.g. 7.5 k becomes 8k?
para 4.15 Typo... 'its'
Our Draft Vision before para 5.10 I support the Vision. However, the Vision should refer to affordable homes.
Strategic Objective 7I would like to see more support for local start ups instead of being swamped by more super brands like Sainsburys and Costas, to the detriment of local businesses.
p29 Tell Us More: I'm supportive of all the objectives but it is a balancing act between them.
People have to work in London because that is where most of the jobs are and which pay the wages to pay for the cost of an average size house in our district.
Creating jobs in the region that can pay equivalent wages is always going to be a challenge unless housing becomes more affordable for future generations.
I'm supportive of more play spaces. These are disappearing or access to them being removed.
Building 7.5k houses is in contradiction with the environmental objectives to a degree.
Tell Us More SP1.1 Everyone involved in this process needs to be mindful that this isn't about profit. It cannot be solely about profit if it is to be sustainable.
It needs a complete change of mindset from developers, builders and architects that this isn't about personal gain but about the future of our district.
I struggle to see, that in the current economic climate, a global development corporation would buy in to this ethos.
Figure 9: What region is this for? Our district or the East of England?
What is the scale along the y axis?
para 6.6 Excessive market level housing will drive up the cost of affordable housing, to the point where what was once affordable housing, no longer is.
para 6.7 Type : in 'for' the form
Table 2 What size are the homes? 10 bedroom mansions or one bed flats?
para 6.10 Not sure I understand what this statement is saying. What happens if the 'need' and 'target' differ significantly?
para 6.12 Not a sustainable approach.
para 6.13 Feels like a get out clause so that affordable housing can be conveniently ignored.

Issues and Options Document

In paragraph 3.3 "The area home to around 3,320 businesses...." the verb "is" is missing.

Paragraph 3.5 "The workplace and resident earnings in the district are below average compared to Essex and the UK." This is not true. It is true for workplace earnings but not for resident weekly earnings which at 670.9 are higher than Essex (594.0) and UK (539). The statement is also inconsistent with the first sentence of the next paragraph "The area is a generally prosperous part of the country,"

Paragraph 3.14 "'green part' of the South Essex". The word "the" is superfluous.

Figure 5: Ecological Map of the District. I think this is a bit out of date. Should not the whole of the eastern side of Wallasea island be shown as a local wildlife site? Also metropolitan green belt and sites of special scientific interest are shaded in the same colour.

The summary of statistics in paragraph 3.20 is muddled. "The proportion of residents aged 20 to 64 is expected to remain relatively stable over the next 20 years." is inconsistent with "An increase in the older proportion of residents compared to the rest of the population has the potential to lead to a smaller workforce and higher dependency needs."

Paragraph 4.3. "Through the Growth Deal, SELEP can direct Government monies towards specific projects across the LEP area - including schemes to deliver new homes, jobs and infrastructure - which can competitively demonstrate a growth return for the investment." My comment is that the criterium 'can competitively demonstrate' pushes investment towards homes and jobs at the expense of infrastructure, as it is easier to demonstrate growth from the former than the latter. But, adequate infrastructure is a necessary enabler of growth. If you use an unsuitable analysis method, you get the wrong answer.

Paragraph 4.5. The words "we must not over-burden investment in business." are meaningless and make the whole sentence incomprehensible. Delete these and the first word "Whilst" and the sentence makes sense.

Paragraph 4.13. The word "however" occurs twice in one sentence, which is incorrect.

Paragraphs 4.13 and 4.15. If Castle Point and Southend really are unable to meet their housing obligations then perhaps RDC could offer them some land in the extreme south east of the district, which is reasonably near Shoebury rail station, provided that central government funds the much needed relief road from the A130 to Shoebury, crossing the Crouch somewhere between Hullbridge and Fambridge and crossing the Roach. Southend and Castle Point would pay for the necessary flood defences for the new homes.

Twenty two Strategic Objectives is far too many! The document would be more convincing if you called the five Strategic Priorities the five Strategic Objectives and put the other points under them as numbered bullet points. Many of these are not strategic and they are not objectives; they are job descriptions of what the council is expected to do.

Putting homes and jobs first might be what central government want but it is not what the existing residents want. These two are interdependent - build more homes and you have to create jobs for the people to work in; create more jobs and then you cannot fill the jobs until you have built homes for the workers. The first priority should be what you have at number three: transport, waste management, and flood risk. You can forget about telecoms, water supply, wastewater and the provision of minerals and energy as these will all be provided by the private sector.

Paragraph 6.12. "Affordability can be measured by comparing the lowest 25% of earnings to the lowest 25% of house prices, which gives an affordability ratio." This is written the wrong way round and would give a ratio of 0.103. It should be written "Affordability can be measured by comparing the lowest 25% of house prices to the lowest 25% of earnings, which gives an affordability ratio."

Tell Us More SP1.1: Affordable homes and ageing population.
Surely the district council's responsibility is restricted to ensuring that sufficient land is available for development and that there are no unreasonable planning hurdles put in the way of developers. The net completions graph shows that the actual number of houses built depends on the overall state of the economy and the economics of the housing market. The district council has no control over either of these. Central government has only minor influence, even if they think otherwise.

6.30 Option: A Option C sounds like a good idea but will not work. If you are thinking of the children of existing residents then in many cases those children who would like to buy a home here will not currently be residents here. They may be renting elsewhere (in my case in South Woodham Ferrers and the Isle of Man). You would have to come up with a definition of something like a "right to residence" rather than "resident". The whole concept is fraught with difficulties.

6.21 Option: C Market forces will sort out what gets built and options D and E are then irrelevant.

6.33 Option: A

If there is a particular requirement for providing additional assistance for certain sectors of the population then try persuading central government to allow you to increase the rates paid by everybody already in the district and put that money away, securely, in a fund earmarked for that purpose.

Tell Us More SP1.2: Care homes Option: A

Paragraph 6.45. I do not agree with this statement: "We need to demonstrate that we have considered all the options before considering the Green Belt."

The original idea of the Green Belt has become distorted over time. The idea was that existing towns and cities would be surrounded by a belt of green land to prevent urban sprawl. (It is usually cheaper to build on greenfield instead of brownfield sites and so without this "belt" developments will always expand outwards, leaving a neglected and eventually derelict inner core, as in many USA cities.) In Rochford District we have a lot of Green Belt land which is not a belt around anything - it is just a vast expanse of undeveloped land.

Instead of infilling within existing developments and nibbling away at what really is the green belt immediately adjacent to them, something a lot more radical is needed and if central government are going to keep handing down housing targets then they must be prepared to provide the necessary infrastructure. It is this:
Build the relief road previously mentioned from the A130 to Shoebury, crossing the Crouch somewhere between Hullbridge and Fambridge and crossing the Roach. It needs to be a high capacity dual carriageway feeding directly onto the A130 and not at Rettendon Turnpike. The Fairglen interchange needs to be substantially improved (not the current inadequate proposals) to handle the extra traffic between the A130 and the A127 in both directions. The new road needs direct exits to both Battlesbridge and Shoebury stations and 2 or more exits to allow new developments to be built on this huge area of green land which is not green belt at all. A bus service will provide transport from the new developments to both stations. Obviously, schools, health, drainage, and power infrastructure will be needed as well but it will be cheaper to provide it out here than adding to existing conurbations. Flooding is an issue but the existing villages have to be protected against flooding anyway.

Tell Us More SP1.3: New homes ...
Option: E All of the other options are just short-term tinkering.

Tell Us More SP1.4: Good mix of homes
Option: A (The policy on affordable housing in conjunction with market forces takes care of this.) Option E is also worth considering but will only be viable if option E has been chosen in SP1.3.

I do not agree with the statement "This approach would therefore not be appropriate." in Option I. What justifies the "therefore"? It would be sensible to adopt option I and not have a specific policy. If you want to build bungalows you will probably have to accept a lower density than the current minimum, if you want to have an area of affordable housing then a good way to keep the costs down is to go for a higher density. Not to have a specific policy does not mean that there is no policy at all. Why constrain yourselves unnecessarily?

Paragraph 6.70 "There is no need has been identified..." remove "There is"

Tell Us More SP1.5: Gypsys and Travellers Option B

Tell Us More SP1.6: Houseboats Option B

Tell Us More SP1.7: Business needs Options B, C, and E

Tell Us More SP1.8: New Jobs Options B, D, E, F

Tell Us More SP1.9: Southend airport Implement all options A, B, C, D

Paragraph 6.127 "The availability of broadband in more rural areas is a constraint to the development of tourism in the district; nowadays visitors need access to promotional and other material electronically to help them navigate around (although paper copies are still
important)." This is just not true. Do you mean broadband or do you mean 3G/4G phone coverage? Local businesses need broadband, tourists do not.

Tell Me More SP1.10: Tourism and rural diversification Option B

Tell Us More SP2.1: Retail and leisure Options A, B, C, D If it ain't broke, don't fix it!

Tell Us More SP2.2 Local facilities
This is outside of the council's sphere of influence and so there is no point in worrying about it. Pubs and local shops will close if there is insufficient trade to keep them going, while in new developments business will spring up once there is sufficient demand provided planning restrictions do not get in the way. Options A and B.

Tell Us More SP3.1 Roads
Paragraph 8.1 "The equality of infrastructure in terms of services and facilities is challenging across the district given that we have such a large rural area to the east, which can mean that isolation becomes an issue." If you embrace my previous suggestion and with Southend and Castle Point persuade central government to fund the new road, the large area to the east will no longer be rural and isolated. In paragraph 8.10 "It also includes
the area to the south of the River Roach in proximity to Great Wakering." you identify exactly the problem that this would address.

Paragraph 8.12 mentions a requirement for a bypass around Rayleigh but there is nowhere to build such a bypass even if it could be justified and funded. Part of the problem in Rayleigh is that in the evening rush hour the A127 towards Southend is so congested that traffic turns off either at the Weir or Fairglen interchange and diverts through Rayleigh. Also, traffic coming down the A130 and heading for Southend finds it quicker to divert through London Road, Rayleigh town centre, and Eastwood Road than to queue for the Fairglen interchange and Progress Road. A bypass is needed not around Rayleigh but from the A130 to the eastern side of Southend.

Paragraph 8.17 "upgrades have been completed at the Rayleigh Weir junction". Is there any evidence that these 'upgrades' have made any difference whatsoever? Local people think not. If they have not been completed, do not say so.

Option C would be better than nothing. The others are only tinkering around the edges of the problem. What is really needed - although outside of RDC's control - is improvements to the strategic road network.

Paragraph 8.21. Option A is marginally better than doing nothing.

Tell Us More SP3.2: Sustainable travel
Paragraph 8.27. "Encouraging cycling within and through Rayleigh town centre are, in particular, supported to drive improvements to local air quality in this area, for example improved cycling storage." This is wishful thinking. Rayleigh is on top of a hill, of the four approaches, three involve cycling up hill in poor air quality. There are a few diehard cyclists (like my son) but normal people will not be influenced by improved cycle storage.

Paragraph 8.31. "study recommends several mitigation measures ..." These measures are just tinkering and are completely inadequate. More traffic lights are needed and some pedestrian crossings need to be moved or removed. I submitted a comprehensive plan for this previously and I shall submit it again as an appendix to this document.

Paragraph 8.34. "We could consider setting a more challenging mode share, for example 30/30/40 (public transport/walking and cycling/private vehicle)." This is wishful thinking. You can set what mode share you like but you cannot influence it.

Options A, C, and E are sensible. B will not help, D is impractical

Tell Us More SP3.3: Communications infrastructure Option B

Tell Us More SP3.4: Flood risk Options A and C

Tell Us More SP3.5: Renewable energy Option A

Tell Us More SP3.6: Planning Option A

Tell Me More SP4.1: Health Option D

Tell Me More SP4.2 Community facilities Option B

Tell Us More SP4.3: Education Option A and B

Tell Us More SP4.4: Childcare Option A and B

Tell Me More SP4.3: Open spaces and sports. [this number has been repeated]
These do not look like options. You seem to want to do all of them. What is there to choose?

Tell Me More SP4.4 Indoor sports and leisure [this number has been repeated] Option A

Tell Me More SP4.5: Young people Option A

Tell Me More SP4.6 Play spaces
Paragraph 9.57. "In order to reduce the amount of greenfield (undeveloped) land...." I do not entirely agree with this premise and think you should reconsider it. Most of the district is greenfield. Surely, building on some of that is better than trying to squash more and more development into the existing towns and villages. People in new houses can access their gardens every day, they possibly only 'go out east' to look at a field once or twice a year.
Option A

Paragraph 10.6 "A fundamental principle of the Green Belt is to keep a sense of openness between built up areas." Yes, that is what the green belt is for. However, most of the metropolitan green belt in Rochford District is maintaining a sense of openness between the built up areas to the west and the sea to the east.

Tell Us More SP5.1 Green belt vs homes Option B

Tell Us More SP5.2 Protecting habitats
Option A but leave it as it is; do not waste your time and our money worrying about climate change or wildlife corridors. There are plenty of wildlife pressure groups to do that. Also, implement options C, D, E, F, and H. Do not waste your time and our money with G.

Tell Us More SP5.3 Wallasea Island Options A and B

Tell Us More SP5.4 Landscape character
Paragraphs 10.35 to 10.45 - two and a half pages (!) written by someone who has gone overboard extolling the virtues of the countryside. I love the countryside and particularly the coastline and mudflats but this reads as though RDC councillors from the east have too much influence and want to protect their backyards (NIMBY) while pushing all the development to the west where, in fact, the majority of ratepayers actually live.
Options A and B

Tell Us More SP5.5 Heritage and culture Option A

Tell Us More SP5.6 Building design
I question whether there is any justification for doing this. Why not just follow the national guidelines, Essex Design Guide, and building regulations? Option A and K

Tell Us More SP5.7 Air quality
None of the actions proposed will make a significant difference to air quality. The biggest improvement will come from the gradual replacement of older vehicles with new ones built to a higher emissions standard and, ultimately, the introduction of hybrid and electric vehicles.

Air quality now has increased importance. The EU is threatening to fine our government because its plans to improve air quality in a large number of cities and towns are inadequate. Just waiting and hoping that things get better will not do!

If you want to do anything in a faster time frame than that then steps must be taken to: reduce traffic congestion; avoid building new homes in areas that are already congested; build new homes in areas where the air quality is good.

I refer you again to the plan that I append to this document to significantly reduce congestion and improve air quality in Rayleigh town centre. This could be achieved in much less time than waiting for all the existing vehicles to be replaced.

You may as well stay with option A since options B and C will make no difference.

Tell Us More D.P1.1 Affordable homes Option F What happened to options A to E?

Tell Us More D.P1.2 Self build
You are making a mountain out of a molehill on this. No policy is needed. Anyone wishing to self build will have to find a plot of land first. They will then have to apply for planning permission and meet building regulations the same as anybody else would. All the council has to do is NOT to discriminate against such applications. From the self-builders point of view, negotiating the VAT maze is far more of a problem. New builds are zero rated but everything they buy will have VAT on it. The only way to claim back the VAT is to form a company and register it for VAT but that is difficult when it has no trading history and will only complete one project. This is all for central government to sort out, not local councils.
Option D

Tell Us More D.P1.3 Rural exception sites
Paragraph 11.16 "with the publication of the Housing White Paper in February 2017 the definition of what constitutes affordable homes could be amended" This is clearly out of date and needs updating. Was the paper published last year? Was the definition amended?

There is no point in wasting time and effort worrying about a situation that has not arisen yet and may not arise. Since there are so many possible variables in the circumstances any such policy would have to be extremely comprehensive. Wait until a planning application is made and then assess it on its merits. If there is no formal policy in place then this would have to be debated by the Development Committee. You could meet the NPPF requirement by putting a reference to rural exception sites on the council's website.
Option H

Tell Us More D.P1.4 Annexes and outbuildings
Option B which should say "...rely on case law", not "reply on case law".

Tell Us More D.P1.5 Basements
Option A

Tell Us More D.P1.6 Rebuilding in the green belt
Option B

Tell Us More D.P1.7 Agricultural occupational homes
Paragraph 11.42 ".... applications for the removal of agricultural occupancy conditions will not, therefore, be permitted except in the most exceptional circumstances." Are you sure this is sensible? If an agricultural home becomes empty would you rather let it remain empty and possibly become derelict than allow a non-agricultural worker to move into it? Option A

Tell Us More D.P1.8 Brownfield land in the green belt
Option B

Tell Us More D.P1.9 Extending gardens in the green belt
Option A

Tell Us More D.P1.10 Parking and traffic management
Options A and B

Tell Us More D.P1.11 Home businesses
A thriving home business could cause parking issues in the immediate area but it also provides local employment thereby reducing commuting out of the area. Also, noise and pollution issues have to be considered. This requires each case to be assessed on its own merits. Option A

Tell Us More D.P1.12 Altering businesses in the green belt
Option A

Tell Us More D.P1.13 Advertising and signage
Option A

Tell Us More D.P1.13 Light pollution [this number has been repeated]
Option B

Tell Us More D.P1.14 Contaminated land
Option A

The introduction is too verbose and will deter people from reading the whole document. A professional editor should have been employed to précis it down to a length that people will be willing to read. Some of the rest of the document is better but would still benefit from editing.

There are too many spelling, grammatical, and punctuation errors to make it worthwhile proof-reading this initial draft until it has been edited.



Interim Sustainability Appraisal

The first ten pages have been constructed by concatenating standard paragraphs, with minimal editing, in the same way than an accountant or surveyor prepares a report.

The rest of it consists of extracts from the Issues and Options document with meaningful, but not particularly incisive, comments.

Preparing this document was a legal requirement but it does not add much to the sum total of human knowledge.




Appendix

A proposal for the reduction of traffic congestion in central Rayleigh and consequent improvement of air quality

Air pollution is an acknowledged problem in central Rayleigh and just today the high court have ruled that the government must do more to reduce it, particularly NOx emissions from diesel vehicles. A major cause of air pollution in Rayleigh is traffic queuing on Crown Hill and creeping forward one vehicle at a time - engines continually running and repeated hill starts which are particularly bad for NOx emissions. Many recent cars and buses have automatic engine stop when stationary so that if traffic is held at a red light emissions will be significantly reduced. This feature will become commonplace over the next few years.

The pedestrian crossing at the top of Crown Hill and the mini roundabout at its junction with the High Street must be eliminated in order to cure this problem. This proposal achieves that and improves traffic flow in Websters Way as well as eliminating most traffic from the central part of the High Street.

1. Close the High Street to traffic between the Crown and Half Moon/ Church. Allow access for taxis to the existing taxi lagoon only. Allow access for delivery vehicles but perhaps only at specified times. This will be a shared space and so 10 MPH speed limit.
2. Block off access from Bellingham Lane and Church Street to the High Street.
3. Replace the mini roundabout at the Crown Hill / High Street junction with a swept bend with limited access to and from the High Street (see 1) with give way lines on the outside of the bend.
4. Replace mini roundabouts at the High Street / Eastwood Road and Eastwood Road/ Websters Way junctions with traffic lights.
5. Replace the zebra crossing at the top of Crown Hill with a light controlled pedestrian crossing.
6. Remove the pedestrian crossing outside the Spread Eagle. This is no longer needed as people can cross from The Crown to the taxi lagoon.
7. Replace the zebra crossing across Eastwood Road outside Marks and Spencer with a light controlled pedestrian crossing.
8. Replace the zebra crossing across Websters Way near to Eastwood Road with a light controlled pedestrian crossing.
9. Arrange for coordinated control of the two new sets of traffic lights, and the four light controlled pedestrian crossings (Crown Hill, Websters Way, and two in Eastwood Road). *
10. Remove the pedestrian crossing in the centre of the High Street as it is no longer needed.
11. Remove the traffic lights at the Junction of Websters Way and High Street and the pedestrian crossing across the High Street as they are no longer needed. Retain the pedestrian crossing across Websters Way. This junction becomes a swept bend and will be free flowing for traffic except when pedestrians are crossing.
12. Access for wedding cars and hearses to the church will be unaffected except that they will have to use London Hill instead of Bellingham Lane to/from Church Street.
13. Access to the Mill Hall and its car parks will be via London Hill and Bellingham Lane. A new exit will be required from the windmill car park to London Hill adjacent to Simpsons solicitors. **
14. Provide parking for disabled people in Bellingham Lane between the Mill hall and its previous junction with the High Street. Create a small turning circle where the junction used to be.
15. Create a layby in Websters Way for buses heading for Hockley or Bull Lane.
16. The loading bay outside Wimpy will become the bus stop for the No 9 bus.
17. The No 1 bus is a problem as it will no longer be able to stop in the High Street or Websters Way and the first stop in the High Road is too far from the town centre. A new bus layby will be needed outside Pizza Express. ***
18. Install traffic lights at the junction of Downhall Road and London Road, incorporating the existing light controlled pedestrian crossing.
19. Install traffic lights at the junction of London Hill and London Road / Station Road. Traffic lights will not be needed at the junction of The Approach and London Road if the lights either side of this junction are phased correctly.

* There are potentially some problems which arise because there will be traffic lights at junctions where the limited space available prohibits the use of a right turn lane or a left filter lane and there are pedestrian crossings nearby. The traffic lights at High Street / Eastwood Road and Eastwood Road / Websters Way will each need to have a phase when traffic from all three directions is stopped and both the adjacent pedestrian crossings are open for pedestrians. This phase will only need to occur when a pedestrian has requested it at either of the adjacent crossings. When there is a lot of pedestrian traffic it will be necessary to synchronise both junctions so that the "all traffic stopped" phase occurs at both junctions at the same time.

** Some drivers will complain that in order to get to the Mill Hall they have to go down Crown Hill and up London Hill, although they could park in Websters Way car park or the market car park and walk. However, people approaching Rayleigh along the London Road will have easier access to the Mill Hall car parks and will not enter the town centre at all, reducing congestion and pollution.

*** Considering traffic coming up Crown Hill, it will be advantageous to arrange that when the pedestrian crossing on Crown Hill goes red to stop traffic there is a delay of several seconds before the light at the High Street/ Eastwood Road junction and the Eastwood Road pedestrian crossing turn red. This should empty this section of road and allow a bus in the layby to pull out without disrupting the traffic flow up Crown Hill.

Introduction

Para 1.15 Response: The Borough Council welcomes the acknowledgement of the importance of working in partnership and the important role that the Association of South Essex Local Authorities has in providing the guidance and framework for the preparation of local plans in south Essex through the preparation of a Joint Spatial Plan.

Spatial Challenges

Rochford Challenge - how do we deliver new jobs that residents can access?

Following Para 4.5 Response: The Borough Council considers it essential that the Rochford District works closely with the Borough to ensure the effective delivery of employment provision to meet future needs in both Southend and Rochford and welcomes the comments that it needs 'to work closely with our neighbouring areas to ensure that our plans across the sub-region take into consideration future projected growth in homes and jobs'.

Rochford Challenge - how do we deliver infrastructure to support new homes and jobs?

Following Para 4.6 Response: The Borough Council considers it essential that proposals for infrastructure provision are developed in partnership with neighbouring authorities, particularly Southend Borough.

Rochford Challenge - how do we work with our neighbours to meet the requirements of the Duty to Co-operate?

Following Para 4.7 Response: The Borough Council considers it essential that Rochford District continues to work closely with Southend and other south Essex Local Authorities as part of the Association of South Essex Local Authorities and through cooperation on plan making issues of mutual interest and value.

Rochford Challenge - how do we work with our neighbouring areas to address strategic, cross boundary issues, and in particular any unmet need for new homes and jobs?

Following Para 4.17 Response: The Borough Council considers that joint working as part of the Association of South Essex Local Authorities is an effective way to address strategic cross boundary issues, particularly unmet need for new homes and jobs and through cooperation on plan making issues.

Southend is a land constrained authority and may not be able to meet local housing needs in full and therefore continued cooperation is required with Rochford Council and the other authorities of South Essex to ensure that housing need can be met across the housing market area.

Given the extensive boundary between Rochford and Southend and numerous shared assets, joint working between the authorities will be essential to consider strategic issues, particularly around London Southend Airport and environs, building upon the existing Joint Rochford and Southend Area Action Plan.

Rochford Challenge - how do we work with other areas, such as London, to address strategic, cross boundary issues, and in particular any unmet need for new homes and jobs?

Following Para 4.18 Response: The Borough Council considers that the most effective way of working with other areas such as London, is to engage with them as a member of the Association of South Essex Local Authorities.

Vision and Strategic Objectives

Response: The Borough Council welcomes the approach put forward as part of the vision and key themes particularly the recognition in the strategic objectives of the need to work with neighbouring authorities in south Essex and to continue to support 'London Southend Airport as a thriving regional airport, serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park'.
However, under the key theme of 'environment' the Borough Council is concerned to ensure that the new local plan takes into full account the identified development needs in the sub-region, particularly in relation to housing provision. As currently drafted 'we have retained our open character and extensive Metropolitan Green Belt designation, whilst providing for the needs of future communities, as far as possible', implies that the there is little scope for meeting future needs outside the current urban areas. The Borough Council considers that this aspect of the theme should be redrafted to recognise the importance of meeting future development needs.

Delivering Homes and Jobs

Para 6.3 Response: Whilst local job growth outside of the main centres should be promoted in sustainable locations and for certain 'bad-neighbour' or 'large footprint' land uses, significant job growth should be prioritised at those major centres that are supported by an adequate resident workforce population and are well served by frequent and extensive public transport, thus facilitating sustainable commuting patterns.

Para 6.29 Response: Detailed scrutiny will be required of the Environmental Capacity Study 2015. Rochford has one of the lowest population densities in the County and the conclusion that there may not be environmental capacity to meet housing need is surprising. The emphasis should be on sustainable development and a balance of social, economic and environmental considerations.

Para. 6.60 Response: Retention of a density policy advocating 30 dwellings per hectare (dph) is overly restrictive with higher densities likely to be sustainable and appropriate in many circumstances, particularly on brownfield land and in areas in close proximity to public transport. A blanket density of 30 dph is not likely to facilitate efficient use of land.

Response: The recognition of the need to work with neighbouring local Authorities in meeting future housing needs is welcomed by the Borough Council and the second option of working 'with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met' is supported. The Borough Council also welcomes the recognition that the Green Belt needs to be reassessed as part of the new local plan preparation process. In relation to business needs the Borough Council considers it important that the current employment growth policy is updated to reflect future needs, broadband provision and speed is improved and that the need for supporting sustainable travel options and promoting highways improvements as part of any scheme is essential (paragraph 6.96 options two, three and five).

London Southend Airport

Response: The Borough Council welcomes the recognition of the need to continue to support the growth potential of London Southend Airport. It supports options three and four (paragraph 6.117) to retain the policies contained in the JAAP and to seek to improve surface access to the Airport.

Supporting Commercial Development

Response: The Borough Council considers it essential that local retail policy is developed in accordance with the sub-regional strategy that will emerge as part cooperation across South Essex. The Borough Council therefore supports option 5 (paragraph 7.20) to review current action area policies to take into account the provisions of the sub-regional retail strategy.

Delivering Infrastructure
Highway Infrastructure

Response: The Borough Council welcomes the recognition of the need for highway improvements to support economic growth in the sub-region and supports the first option in paragraph 8.21 to 'support improvements to the strategic highway network.'

Sustainable Travel

Response: The Borough Council welcomes the recognition of the need to work in partnership to improve sustainable travel facilities and supports option 1 paragraph 8.37 to improve connectivity across the wider South Essex area. It would prefer to see the option for taking forward SERT (option 2 paragraph 8.37) retained pending further sub-regional work on the development of a Joint Spatial Plan.
Renewable Energy Generation
Response: The Borough council supports option 2 paragraph 8.66 to install new electric vehicle charging points in appropriate areas across the Rochford District. New public fast charging points in all areas of South Essex are crucial components to encourage the adoption of the electric car which the Borough Council sees as a realistic method of reducing air pollution in South Essex leading to the subsequent removal of AQMAs in both Rochford and Southend. Southend Borough council supports the installation of a wide network of electric chargers and fast chargers to aid with maintaining good quality air for the residents.
Supporting Health, Community and Culture

Response: The Borough Council considers it to be essential that partnership working to deliver appropriate future health care facilities continues with health organisations and providers and as part of the wider joint working of the Association of South Essex Local Authorities. The Borough Council supports the options 2 and 4 (paragraph 9.11)to ensure that land is specifically allocated for healthcare facilities and future planning policy builds on the existing healthcare policy to address wider health and well-being issues.

Protecting and Enhancing the Environment
Green Belt

Response: The Borough Council welcomes the recognition that Green Belt policy will need to be reviewed objectively as part of local plan preparation. The Borough Council considers that this should be undertaken in partnership and as part of the wider south Essex planning work. It is considered that option 2 (paragraph 10.16) to 'amend the current Green Belt policy in the Core Strategy' should be the preferred option.

Biodiversity, Geology and Green Infrastructure

Response: The Borough Council supports options 1 and 8 (paragraph 10.27) to protect and enhance the sites of nature conservation importance and to develop greenways providing for important walking and cycling corridors which promote biodiversity and connectivity of habitats.

Landscape Character

Response: The Borough Council considers that a landscape assessment should be undertaken in partnership as an integral part of the Green Belt assessment referred to above.

Detailed Policy Considerations
Mix of Affordable Homes

Response: The Borough Council considers it essential that a clear and objective policy is retained to meet affordable housing taking into account any possible future changes in national planning policy - options 6 and 7 (paragraph 11.5).

1. INTRODUCTION

Rochford District Council (RDC) is currently consulting on the Draft New Local Plan Issues and Options (the Draft Local Plan) Regulation 18 document. This consultation represents the first stage in preparing a new Local Plan for the District of Rochford. Once prepared, the Local Plan will include the required strategies, policies and proposals to guide future planning across the District; and will replace the current suite of Adopted Development Plans (up to 2025).

Essex County Council (ECC) supports the preparation of a new Local Plan for RDC and welcomes the opportunity to comment on the Issues and Options consultation. A Local Plan by setting out a specific vision and policies for the long-term planning and development of the District can provide a platform from which to secure a sustainable economic, social and environmental future to the benefit of residents, businesses and visitors.

A robust long-term strategy will provide a reliable basis on which RDC, ECC and its partners may plan and provide future service provision and required community infrastructure for which they are responsible. ECC will also use its best endeavours to assist on strategic and cross-boundary matters under the duty to cooperate, including engagement and co-operation with other organisations for which those issues may have relevance.

2. ECC Interest in the Issues and Options Consultation

ECC aims to ensure that local policies and related strategies provide the greatest benefit to deliver a buoyant economy for the existing and future population that live, work, visit and invest in Essex. As a result ECC is keen to understand, inform, support and help refine the formulation of any development strategy and policies delivered by Local Planning Authorities. Involvement is necessary and beneficial because of ECC's roles as:
a. a key partner within Greater Essex, the Association of South Essex Local Authorities (ASELA) and, Opportunity South Essex Partnership (OSE); promoting economic growth, regeneration, infrastructure delivery and sustainable new development;
b. major provider and commissioner of a wide range of local government services throughout the county;
c. the strategic highway and transport authority, including responsibility for the delivery of the Essex Local Transport Plan; Local Education Authority including early years and childcare; Minerals and Waste Planning Authority; Lead Local Flood Authority; lead advisors on public health; and adult social care in relation to the securing the right housing mix which takes account of the housing needs of older people; and d. as an infrastructure funding partner, that seeks to ensure that the proposals are realistic and do not place an unnecessary (or unacceptable) cost burden on ECC's Capital Programme.

3. DUTY TO CO-OPERATE

The duty to cooperate (the Duty) was introduced by the Localism Act in November 2011. The Act inserted a new Section 33A into the Planning and Compulsory Purchase Act 2004. This placed a legal duty on all local authorities and public bodies (defined in regulations) to 'engage constructively, actively and on an ongoing basis' to maximise the effectiveness of local and marine plan preparation relating to strategic cross boundary matters, and in particular with County Councils on strategic matters.

The National Planning Policy Framework (NPPF) provides detail on how strategic planning matters should be addressed in local plans (paragraphs 178-181). Local planning authorities are expected to work 'collaboratively with other bodies to ensure that strategic priorities across local authority boundaries are properly coordinated and clearly reflected in individual local plans' (paragraph 179). 'Strategic priorities' to which local planning authorities should have particular regard are set out in paragraph 156 of the NPPF.

Specific guidance on how the Duty should be applied is included in the Planning Practice Guidance (the PPG). This makes it clear that the Duty requires a proactive, ongoing and focussed approach to strategic matters. Constructive cooperation must be an integral part of plan preparation and result in clear policy outcomes which can be demonstrated through the examination process.

The PPG makes it clear that the Duty requires cooperation in two tier local planning authority areas and states 'Close cooperation between district local planning authorities and county councils in two tier local planning authority areas will be critical to ensure that both tiers are effective when planning for strategic matters such as minerals, waste, transport and education.
ECC will use its best endeavours to assist RDC on strategic and cross-boundary matters under the duty, including engagement and co-operation with other organisations for which those issues may have relevance e.g. Highways England. In accordance with the Duty, ECC will contribute cooperatively to the preparation of a new Rochford Local Plan, particularly within the following broad subject areas,
 ECC assets and services. Where relevant, advice on the current status of assets and services and the likely impact and implications of proposals in emerging Local Plans for the future operation and delivery of ECC services.
 Evidence base. Guidance with assembly and interpretation of the evidence base both for strategic/cross-boundary projects, for example, education provision and transport studies and modelling.
 Sub-regional and broader context. Assistance with identification of relevant information and its fit with broader strategic initiatives, and assessments of how emerging proposals for the District may impact on areas beyond and vice-versa.
 Policy development. Contributions on the relationship of the evidence base with the structure and content of emerging policies and proposals.
 Inter-relationship between Local Plans. Including the Essex Minerals Local Plan Adopted 2014 and the Essex and Southend-on-Sea Waste Local Plan Adopted 2017.

ECC acknowledges and supports the production of a new Local Plan by RDC ensuring an up-to-date Local Plan. This can facilitate new job opportunities, attract investment in new and improved infrastructure, protect the environment and ensure new homes meet the needs of a growing population, which are sustainably located, and achieve the right standards of quality and design.

RDC has already undertaken work with ECC under the Duty to Co-operate during the past year, in addition to the joint and regular meetings established with the South Essex authorities, including RDC and ECC, through specific South Essex Strategic Planning DTC Groups for Members and Officers respectively to explore cross boundary matters.

The on-going duty to co-operate work that RDC has undertaken with ECC to date is acknowledged and this consultation provides the first opportunity for ECC to review the emerging issues and options in their entirety. ECC shall continue to work with RDC and provide as appropriate the latest ECC strategies and evidence to inform and shape the draft Local Plan, which will require further changes as the spatial strategy emerges and the site allocations are considered and assessed both individually and cumulatively, to test and establish the infrastructure requirements. This includes but is not limited to ECC service areas such as Highways; Infrastructure Planning; Education and Early Years and Child Care provision; Independent Living; Flood and Water Management; Public Health; and Minerals and Waste Planning. ECC will continue to work with RDC in respect of the evidence base to contribute cooperatively with RDC in the preparation of the new Local Plan through to examination.

4. ECC RESPONSE TO DRAFT NEW LOCAL PLAN ISSUES AND OPTIONS CONSULTATION DOCUMENT (DECEMBER 2017)

ECC's response to the draft Plan Issues and Options consultation document is set out below and corresponds to the format and chapters within the consultation document, however this is preceded by a summary of the key issues.

4A Summary

 Duty to co-operate. In accordance with provisions of the Localism Act 2011, ECC will contribute cooperatively with RDC in preparation of the new Local Plan. This will primarily cover an assessment of the impact on the transport and highway network (as Local Highway Authority), the need to ensure additional school places (as Education Authority), consideration of surface water management (as Lead Local Flood Authority), and links to minerals and waste planning (as Minerals and Waste Planning Authority) as well as advice on Public Health as the Lead advisor.
ECC notes that the Issues and Options consultation is primarily thematic and does not present options covering spatial proposals or site allocations. In moving forward the focus will need to be on the further assessment of the spatial options and emerging spatial strategy, which will vary according to the location, nature and mix of new developments being considered. ECC wish to be proactively engaged with the assessment of the spatial options and site allocations, given the importance of infrastructure provision and funding to the Draft Plan, which will vary for each spatial option and site allocations, given their respective individual and cumulative infrastructure requirements, generating their own, individual and cumulative impacts and opportunities on the delivery of ECC service areas. This will be essential to enable ECC to continue to inform and identify the issues and opportunities for ECC services, to ensure the Local Plan is deliverable, in accordance with the tests of Soundness and that the right infrastructure is in place at the right time.
A particular focus will be the impacts of any proposed new large urban extensions or new settlements to assist RDC determine an appropriate strategy if those options progress as part of its preferred growth and development strategy.
In addition to the above ECC will continue to contribute co-operatively with RDC through the wider collective South Essex arrangements, to address cross boundary strategic planning and infrastructure matters, through the Association of South Essex Local Authorities (ASELA), and the emerging South Essex 2050 vision associated work streams, and preparation of a South Essex Joint Strategic/Spatial Plan (JSP);and through the South Essex Transport Board and the Opportunity South Essex Partnership (OSE). With the exception of the formation of ASELA and the preparation of a JSP, the majority of the issues and options identified have regard to this wider engagement.
 Housing provision. ECC acknowledges RDC is seeking to meet housing needs in full over the plan period. However, ECC acknowledges highway and transportation constraints, and in its role as Highway Authority will provide the necessary assessments to determine impacts (including cross boundary impacts) and mitigation measures, as RDC seeks to adopt a preferred growth and development strategy. The new Local Plan should also emphasise the need to provide infrastructure (secured through developer funding) as part of any new housing proposals. ECC welcomes the importance and consideration given to the provision of adult social care and extra care (encompassing aged and vulnerable people), within ECC's Independent Living programme.
 Infrastructure Provision and Funding. ECC agrees that Infrastructure is critical to support sustainable growth and it will be essential to ensure RDC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future. We welcome the acknowledgement of ECC's role in the provision of Local and Strategic infrastructure. Further comments are provided on the spatial strategy and on the implications for ECC services and infrastructure, ranging from large urban extensions to less growth at settlements lower in the settlement hierarchy

ECC will take a pro-active position to engage with RDC to ensure the delivery of new homes and employment is at the right location and of an appropriate scale to identify and deliver the necessary level of infrastructure investment, as part of a viable and deliverable plan. ECC seeks clarification on the size of residential sites / extensions being considered when compared to large residential urban extensions / new settlements.

ECC wish to explore and understand the potential implications of the nature and scale of developments on financial contributions, given the pooling of contributions under the CIL Regulations and hence potential viability and delivery issues which will be very different for each of the spatial options being considered. As outlined in 4.6 above, the new Local Plan should emphasise the need to provide infrastructure (secured through developer funding) as part of any new development proposals, to ensure the new plan is both viable and deliverable. Given the importance of infrastructure provision and funding for the new Local Plan, ECC wishes to work with RDC to ensure the necessary infrastructure funding (including all funding streams) and delivery evidence is fully considered as part of the assessment of all the spatial options. This is to ensure the preferred strategy is viable, deliverable and sound.
 Transport and highways. ECC, will work with RDC (in consultation with Southend on Sea and the South Essex authorities) to enable further transport and highway impact assessments to be undertaken to inform the preparation of the RDC Local Plan and in accordance with the ASELA workstreams and JSP.
There is overall support for proposals promoting the importance and need for improvements to the A127 Strategic Road Network, however greater emphasis should be placed on the role and importance of sustainable travel as part of a long term integrated transport solution, including walking, cycling, bus and rail. Adequate transport and highway provision will need to be evidenced including transparency of funding, viability and deliverability to unlock sustainable growth in new homes and employment, at a scale necessary to bring forward the level of investment needed to provide significant improvement to the highway and transport infrastructure.
In respect of the A127/A130 Fairglen Interchange, ECC would not support any new development and employment allocations (beyond the current adopted Local Plan employment allocations) until the proposed long term transport scheme for the junction is implemented. ECC supports the need for a range of highways and sustainable transport improvements to existing employment areas including, London Southend Airport and the airport business park and will continue to seek funding through bids to Central Government, SELEP and S106 contributions.
 Sustainable transport. ECC recommend greater emphasis is placed on sustainable transport including passenger transport as part of a wider sustainable growth strategy to underpin future development opportunities and to ensure an integrated transport package of solutions are developed for the District and in respect of its relationship and connectivity to Southend, South Essex, Essex and London.
 Minerals and Waste Planning. ECC will engage with RDC in the site assessment process to ensure new allocations appropriately address the minerals and waste safeguarding policy requirements within the adopted Essex Minerals Local Plan and the Essex and Southend-on-Sea Waste Local Plan. ECC wishes to draw attention to the dual requirements of these Local Plans concerning minerals and waste safeguarding, operations, sustainable use of minerals in construction, and the location of waste management uses within employment areas.
 Flood and Water Management. ECC wish to work with RDC to provide points of clarification and to ensure the most up to date evidence is used to underpin the preparation of the Local Plan including the strategy and site assessments. This will include reference to the Environment Agency's revised climate change allowances and the subsequent revisions to the South Essex Surface Water Management Plans, due to be published in 2018.
 Economic Growth. ECC welcomes proposals to ensure the protection and provision of suitable employment land and appropriate uses within the District, with the pre-eminent importance of London Southend Airport to the economy whilst seeking opportunities for rural diversification, tourism, retail, leisure, and town centres, to meet the life cycle needs of business including "Grow on Space" and development of skills and training opportunities.
ECC welcomes and supports the importance and economic role played by London Southend Airport as an international gateway, and the A127 corridor and London-Southend Victoria railway line for connectivity with South Essex, the rest of Essex and London. A key priority will be to enable investment in infrastructure and economic growth, including, for example, the A127 including passenger transport and ultrafast broadband, as well as developing options to support the alignment of skill provision to meet the local needs in accordance with the Economic Plan for Essex (2014) and the National Industrial Strategy The provision of jobs and infrastructure to support economic growth will be essential, including the need to provide social, physical and green infrastructure and are also being explored by ASELA through the Industrial Strategy workstream and the JSP.
 Superfast Broadband ECC recommend upgrading all broadband references to "ultrafast broadband" to promote the Governments next broadband programme; and refer to the BT Open Reach policy for providing FTTP connections on new development of houses of 30+units, free of charge to the developer https://www.ournetwork.openreach.co.uk/property-developers/site-registration.aspx
 Education ECC Support the use of ECC Planning School information and recommend a number of updates to reflect ECC's change in policy and standards (minimum size of new schools and use of ECC model infrastructure delivery policy). ECC wishes to engage with RDC as the new Local Plan progresses to preferred options stage to enable appropriate "scenario testing" of the preferred options for education requirements.
ECC will continue to work with RDC to ensure education needs are appropriate and adequately assessed as preparation of the new Local Plan continues. ECC will undertake a further assessment of the potential delivery and resource requirements for accommodating anticipated pupil change through "scenario testing" as and when RDC confirms its preferred spatial option for growth and development and the specific sites.
In respect of Special Education Needs, this should be acknowledged in the new Local Plan, and sites allocated specifically provision for children/young people with Special Educational Needs either within the existing school provision or the wider community. ECC wish to engage with RDC to identify requirements and opportunities.
 Early Years and Childcare. In addition to the above, support the use of the ECC evidence, however recommend a number of changes to explicitly refer to "Early Years and Childcare provision" and for consistency in approach. There will be a need to update the EYCC information to ECC
 Skills. ECC will engage with RDC and can provide advice and updates, including on the full range of post 16 education and training provision and on the revisions to the ECC Developers' Guide to Infrastructure Contributions, to include the need for large scale developments to adopt an Employment and Skills Plan; and reference to the new Essex Employment and Skills Board's 2017-18 as an evidence base and the seven priority sectors. ECC wish to work with RDC to identify and promote opportunities for skills and training development to align skills with jobs.
 Public Health. ECC welcome and are supportive of the links and inclusion of health and well-being throughout the Issues and Options Report; and offer support to assist the preparation of the Local Plan, for example the development of the health and well-being policy, greater involvement with employment opportunities for local residents; support for skills, training, education and employment opportunities; improvements to air quality.
ECC support and welcomes consideration on phasing and release of affordable housing; use and application of the revised Essex Design Guide, including key concepts for inclusive and adaptable housing (e.g.. dementia friendly principles and social cohesion); housing mix, provision for older people (including care homes) and active design principles including active and sustainable travel principles.
ECC recommend use and reference to the revised Essex Design Guide within the new Local Plan design policies and the supporting text.
ECC wish to work with RDC to provide support and advice in respect of the Health and Well-being policy; policies on "fast food" outlets; Education, Skills and Employment policies and the Good Design policies.
 Independent Living Support the general approach and inclusion of and reference to ECC's Independent Living Programme for Older People and Adults with Disabilities.
 Environment (natural, built and historic), ECC welcomes the broad approaches to protect and enhance the environment, and recommends a more holistic approach and links to the wider objectives of promoting growth and healthy communities, which can be provided through the natural environment, be it green infrastructure for climate change mitigation and adaption, building design and efficiency, creation and accessibility to open spaces, green spaces (including greenways and green corridors). ECC wishes to explore these opportunities and cross benefits further as incorporated within the revised Essex Design Guide (2018) and to ensure the biodiversity and geodiversity evidence base is up to date and consistent with the NPPF.
In respect of the Historic environment further consideration and assessment is required on conservation areas and listed buildings and the archaeological and historic records of designated and non- designated sites. ECC welcomes the opportunity to explore this further with RDC to ensure the evidence base is up to date and consistent with the NPPF.
 Sustainability Appraisal ECC considers the SA to be a good example of an initial Regulation 18 'Issues and Options' appraisal, exploring the sustainability considerations of a wide range of strategic options and assessing them to the same level of detail. However, ECC recommends that a number of the options within the SA/SEA are expanded to reflect the ranges in the Issues and Options consultation Report.

4B ECC Detailed Response to the Issues and Options Consultation

INTRODUCTION (SECTION 1)

Paragraph 1.5 ECC recommend that this paragraph is amended to clearly recognise that the Essex Minerals Local Plan 2014 (MLP) and Essex and Southend-on-Sea Waste Local Plan 2017 (WLP) form part of the statutory development plan for Rochford District. The Minerals and Waste Planning Authority (MWPA) is pleased to note that the mineral and waste plans are appropriately referenced further into the plan at relevant sections and shown to have relevance to Rochford, but it may be beneficial to qualify the extent of the Development Plan at the outset.

Paragraph 1.12 ECC welcomes and supports the preparation of a Draft Habitat Regulations Assessment to inform and accompany the preparation of the draft Local Plan

TELL US YOUR VIEWS (SECTION 2)

Next Steps

ECC service areas and functions would wish to work with RDC in the preparation of the Local Plan as it progresses to assess the suggested sites and the selection of preferred sites, with regards to the impact and opportunities on ECC services and infrastructure, to ensure sites selected are sustainable. Details on this are set out in Section 2A above and throughout the response below.
ECC as the MWPA is keen to enter into engagement with RDC with regard to proposed site allocations considered through the Local Plan process. This is to ensure that any future site allocations made by RDC appropriately address mineral and waste safeguarding matters in line with adopted policies. ECC recommend early engagement within the site assessment process, for effective collaboration and consistency across the wider Development Plan. Further details of the policy requirements are set out in the Essex Minerals Local Plan Adopted 2014 and the Essex and Southend-on-Sea Waste Local Plan Adopted 2017 For the avoidance of doubt, the considerations that may arise from the MWPA in relation to these sites would be as informatives only; there is no intention to influence the site assessment process and/or any scoring mechanism designed by RDC.

OUR CHARACTERISTICS (SECTION 3)

Figure 1 ECC recommends that the content of this map is reviewed to ensure it clearly presents the local and strategic context and characteristics of the district. For example greater use of graphics and annotations including:
 Annotations for the strategic road network (A127, A130 and A13), with specific emphasis on the A127 as the key strategic highway route for Rochford will demonstrate its importance within the local highway network 9
 The London - Victoria Railway line and stations should be clearly annotated, as well as inclusion of the wider network for context, for example the C2C line from Southend to London Fenchurch Street.
 Inclusion / indication of the existing bus networks and connectivity with surrounding areas, to demonstrate the passenger transport services within the area.
The above provides background and context for the Highway and Transportation network (including Sustainable travel) within the district and wider connectivity, including strengths and areas for improvement, and the need for the provision of sustainable access. This would also provide context for the national and local pictures presented in section 4 and the relationship with London (and the rest of Essex).

Our Economy

Paragraph 3.8 ECC recommend that reference is made to the wider rail network and specifically Cross Rail, which connects to the London - Victoria Line at Shenfield and will link to the wider London, and west of London, area.
Paragraphs ECC considers greater emphasis should be placed on the relationship
3.7 - 3.8 and connectivity between the District, Southend, South Essex, Essex and London, including the 2011 data presented in Figures 2 and 3. Whilst the data is of assistance, it is recommended that the mode of transport used to make journeys is also presented. This additional information would be required to inform the base assumptions for likely future modal choice that would arise as a consequence of further development. Equally this could help to demonstrate where the more significant concentration of improvements may be required to promote suitable sustainable cross boundary transport provision, which could affect the levels of car journeys undertaken by encouraging modal shift.
Paragraph 3.12 ECC consider that there is an opportunity to promote the potential benefits / outcomes for the local economy arising from improvements to the transport network, for example greater connectivity for residents and businesses, or an increase in flight destinations served by London Southend Airport.
Paragraph 3.14 ECC recommends the inclusion and reference to the Outer Thames Estuary SPA list of European sites.

Our Communities

Paragraph 3.23 ECC notes that this paragraph seeks to set out the Education provision across the district however there is no reference to either Early Years and Childcare (EYCC) or Special Education Needs (SEN) provision. ECC recommends that EYCC is incorporated and set out in Strategic Priority 4.4 and paragraphs 9.30 to 9.36 and SEN is referred to in Strategic Priority 4.3 and paragraphs 9.17 - 9.29.

Key Community Characteristics
ECC recommends greater recognition is given to the role and contribution of Passenger Transport, in respect of both existing and new provision of services to support the ageing population. ECC wish to explore this further with RDC in the preparation of the Local Plan, to promote an inclusive strategy for existing and new residents.
OUR SPATIAL CHALLENGES (SECTION 4)
ECC General Comment
ECC notes that this section sets out the National and South Essex picture and relationship to London, however it is recommended that this is expanded to provide a specific "county policy context." ECC welcomes the reference to ECC services throughout the document, however the inclusion of a wider "County Policy Context" would provide a clear and strategic policy framework, reflecting two tier context and delivery of ECC services and functions. ECC can provide appropriate supporting text links to relevant ECC policies and strategies. It is also recommended that within the wider context reference is also made to the adjoining Essex authorities outside the "South Essex" area including Maldon DC given the importance of the River Crouch.
ECC recommends that the following ECC policies and strategies are included and referred to within a new "county policy" context and delivery proposals:
 Essex Vision and Priorities 2017/21
 Essex Organisation Strategy, 2017 - 2021
 Economic Plan for Essex (2014)
 Children in Essex get the best start in life 2014-2018.
 People in Essex enjoy good health and wellbeing 2014-2018
 People in Essex have aspirations and achieve their ambitions through education, training and life-long learning 2014-2018
 People in Essex can live independently and exercise choice and control over their lives 2014-2018.
 Essex Transport Strategy, the Local Transport Plan for Essex (June 2011)
 ECC's Passenger Transport Strategy - Getting Around In Essex 2015.
 A127 Corridor for Growth - An Economic Plan 2014
 Essex children and Young People's Strategic Plan 2016 Onwards (2016)
 Essex Early Years and Childcare Strategy 2015-2018
 Commissioning school places in Essex 2017-2022
 Essex County Council Local and Neighbourhood Planners' Guide to School Organisation
 ECC Independent-Living-Programme-Position-Statement October 2016
 ECC Developers' Guide to Infrastructure Contributions (2016)
 Essex Minerals Local Plan Adopted 2014
 Essex and Southend-on-Sea Waste Local Plan Adopted 2017
 ECC Sustainable Urban Drainage Design Guide 2016
 Greater Essex Growth & Infrastructure Framework (2016)
 Superfast Essex Broadband

National Picture

Paragraph 4.3 ECC advises that the SELEP Strategic Economic Plan is now due to be completed during 2018.

Paragraph 4.5 ECC welcomes and is supportive of increasing employment opportunities for the District and would wish to engage with RDC to explore these opportunities further. This is consistent with ECC's Essex Outcomes Framework, through the development of the Essex Economic Growth Strategy and, the Economic Plan for Essex, including South Essex as one of four growth corridor. These corridors collectively form the locations for housing and employment, to secure future growth. These roles are based on location characteristics, local economic history and linkages to surrounding areas. Critically, these corridors will provide a mix of housing, which will allow new and existing residents to stay and develop in the District / County. ECC is a partner of the Association of South Essex Local Authorities (ASELA), which extends beyond the SELEP federated area of South Essex, to include Brentwood BC. ECC supports the emerging 'South Essex 2050 Ambition' for the area and the commencement of a Joint Spatial Plan (JSP) to provide a framework for the future growth ambitions of the area. ECC recommend that the role of ASELA and the emergent JSP is taken into account in the preparation of the Local Plan

ECC can provide additional information on the Essex Growth Commission Report (2017), ECC's Grow on Space study, as well as the specific economic strategies and engagement being developed by ECC and with partners, including OSE, promoting economic growth, regeneration, infrastructure delivery and sustainable new development, and having regard to the National Industrial Strategy.
ECC would welcome the opportunity to provide additional information in respect of the health profiles for the District, to assist with the identification of skills, training and employment opportunities, as well as the development of a health impact assessment process for developments.

ECC also considers there to be an opportunity to explore and promote opportunities in the area for employees and residents, with greater emphasis placed on accessibility and promotion of passenger transport as part of a wider package of transport solutions, and to optimise and improve the current passenger transport accessibility to the area.

Paragraph 4.6 ECC welcomes the reference that "infrastructure is critical to support sustainable economic growth" and the recognition of the need to work with partners, including ECC, under the duty to co-operate, to deliver Strategic and Local infrastructure.

ECC has provided further information throughout this response to inform the preparation of the new Local Plan, as it relates to ECC services and functions, to ensure are appropriately considered within the Local Plan. ECC recognises the need for essential infrastructure to be identified, to support the level of proposed growth within the Issues and Options consultation. ECC has and will continue to work with RDC to identify the appropriate infrastructure requirements and mitigation measures which need to be developed, including the preparation of the Infrastructure Delivery Plan, before the plan progresses to the Preferred Options stage,. This is explored further within the respective strategic priorities, themes and options below.

ECC recommends that RDC refer to the "ECC's Developers' Guide to Infrastructure Contributions" (2016), for details of the necessary contributions required from new development for the provision of essential infrastructure, to inform the ongoing evidence base and the delivery and viability assessments.

Paragraph 4.10 ECC welcomes the reference to minerals and waste as a strategic, cross boundary matter subject to the Duty and ECC is keen to enter into engagement with RDC with regard to proposed site allocations considered through the Local Plan process and that this is undertaken at the site assessment stage of the Local Plan, as referred to above under "Tell Us Your Views".

Paragraph 4.17 ECC recommends that the "Challenge" on how to deliver infrastructure to support new homes should also seek to incorporate new open space Suitable Accessible Natural Greenspace (SANG) as part of new residential developments to avoid recreational impacts on European sites in accordance with the Habitat Regulations. Further details on this aspect are incorporated within the revisions to the Essex Design Guide (revised EDG) to be published February 2018.
Please also refer to ECC comments in respect of paragraph 9.42 (options for Open space and outdoor recreation) and paragraph 10.29 (options for Greenways)

OUR VISION AND OBJECTIVES (SECTION 5)

Draft Vision

Paragraph 5.9 ECC is supportive of the emerging draft vision which is considered in accordance with the NPPF and the three dimensions for sustainable development; and ECC welcomes the inclusion and reference to health.

Strategic priorities

1. The homes and jobs needed in the area
2. Provision of retail, leisure and other commercial development
3. Provision of infrastructure, including transport, digital, flood risk, coastal management, minerals and energy
4. Provision of Health, security, community and cultural infrastructure and other local facilities, including EYCC, Education and Youth Facilities
5. Climate Change and Environmental protection and mitigation

It is noted that the Strategic Objectives in support of Strategic Priorities 1, 2, 4 and 5, do not refer to or recognise the role of sustainable transport to deliver these Strategic Priorities. ECC recommends further consideration is given to incorporate the principles of sustainable transport and travel within the new Local Plan in accordance with the Essex Local Transport Plan.

Strategic Objectives

SP1 The homes and jobs needed in the area

SO1 ECC support the objective to facilitate the delivery of sufficient, high quality and sustainable homes, combined with SO6 for all homes and commercial buildings to be built to the highest attainable quality, design and sustainability standards.
SO3 ECC welcomes the positive move towards supporting sustainable travel, however this only refers to improvements for new developments, whereas opportunities should be sought to overcoming existing shortfalls in sustainable connectivity.
SO5 ECC is supportive to the inclusion of skills, training, education and employment, and ECC Public Health would welcome the opportunity to work with RDC to explore the employment opportunities for residents. ECC considers that this could be included and assessed as part of the Health Impact Assessment process for developments, skills, training and employment opportunities.
ECC recommends this Strategic Objective amended to specifically refer to EYCC provision alongside the provision of good schools.
SO6 ECC support the objective for all homes and commercial buildings to be built to the highest attainable quality, design and sustainability standards in combination with SO1.
ECC recommends ECC recommends that these strategic objectives should also include consideration for new housing and commercial development to have reasonable access to green spaces. ECC can provide examples, where distance standards have been applied to protect and promote an accessible network of green space, including for example the Bristol Parks and Green Space Strategy 2008, with walking distance/ time to parks and green space. https://www.bristol.gov.uk/policies-plans-strategies/bristol-parks-and-green-space-strategy .
This would provide a cross over benefit between a number of the Strategic Priorities including SP1 (SO1 and 6); SP3 (SO 9 and 11), and SP4 (SO15 and 16).

SP 2 Provision of retail, leisure and other commercial development

SO 8 ECC suggest the objective should include accessibility to services and green spaces.

SP3 Provision of infrastructure, including transport, digital, flood risk, coastal management, minerals and energy

SO 9 ECC recommends that the reference to "broadband" is replaced by "Ultrafast Broadband". ECC acknowledges the current rollout programme is "Superfast Broadband", however it is recommended that the draft new Local Plan should refer to "Ultrafast Broadband" to reflect the Government's next roll out initiative, thereby providing longevity to Local Plan policy and distinguishing new provision from the "standard broadband" which is not considered fast enough. This should be applied throughout the document

SO 9 & 11 ECC recommends that these strategic objectives should also include consideration for new housing and commercial development to have reasonable access to green spaces. Please refer to ECC's comments to SO6 above and the Bristol Parks and Green Space Strategy example.

SO11 ECC support this Strategic Objective which also supports "air quality".

SO12 ECC welcomes the reference to 'encouraging adherence to the waste hierarchy' and making 'best use of mineral deposits' but considers that these statements could be afforded slightly more clarity. Supporting the waste hierarchy and ensuring a sustainable use of minerals requires that existing facilities and infrastructure are safeguarded to ensure that they are able to continue to make their planned contribution to the mineral and waste strategies operating in the County. Whilst already covered by MLP Policy S8 and WLP Policy 2, it is considered beneficial for this to be incorporated into the Rochford LP objectives. ECC suggests amendments to SO12 as follows:

"SO12: To plan for effective waste management by encouraging adherence to the waste hierarchy, working with Essex County Council to make best use of mineral deposits resources and mineral and waste facilities, including safeguarding resources and infrastructure, supporting renewable energy generation and energy efficiency as part of all new homes and commercial premises developed, as well as supporting efficient water use."

The requirement to safeguard mineral development is recognised in paragraph 10.21 and therefore the proposed modification is in accordance with that recognition. There is however no similar recognition for waste facilities, which the proposed modification to Strategic Objective 12 would then cover.

SO13 ECC can advise that any new plans for coastal change management should also involve the other partners of the Essex Coastal Forum, given that the Forum has the responsibility for policy changes to the Essex and South Suffolk Shoreline Management Plan

SP4 Provision of Health, security, community and cultural infrastructure and other local facilities, including EYCC, Education and Youth Facilities

SO15 ECC supports this strategy, which is supportive of the England Coast Path being created by Natural England, to be subsequently implemented by Essex Highways, for the economic and health benefits of the community and is consistent with the other Strategic Objectives.

SO 15 ECC support this strategy which would also support air quality, but should be amended to specifically include reference to "air quality".

SO 15 & 16 ECC recommends that these strategic objectives should also include consideration for new housing and commercial development to have reasonable access to green spaces. Please refer to ECC's comments to SO6 above and the Bristol Parks and Green Space Strategy example.

SP5 Climate Change and Environmental protection and mitigation

SO19 ECC supports the inclusion of this objective and strategic priorities for conservation and enhancements for the natural environment which is considered to be in accordance with NPPF (paragraph 156), however ECC recommends that the objectives should be further amended, to include policies which seek to minimise the impacts to biodiversity in accordance with paragraph 117 of the NPPF. Please refer to ECC in paragraph 10.1 below for further details on this matter.

SO22 ECC welcomes the objective, however recommend that "Green (and Blue) Infrastructure" is specifically referenced within the objective to read as follows:
"To mitigate and adapt to the forecasted impacts of climate change, including the water environment, air quality, biodiversity, flooding and green and blue infrastructure, support more efficient use of energy and natural resources and facilitate an increase in the use of renewable and low carbon energy facilities."
This is considered necessary to recognise the important role of this infrastructure for climate change mitigation and adaption, through micro-climate control, water management (SUDS), air quality, carbon sequestration and reduce biodiversity loss, which in turn strengthens communities through improved health and wellbeing and building resilience.

DELIVERING HOMES & JOBS (SECTION 6)

ECC General Comments

ECC recommend all references to the provision and requirements for future broadband are prefaced by "Ultrafast". ECC acknowledges the current rollout programme is "Superfast Broadband", however it is recommended that the draft new Local Plan should refer to "Ultrafast Broadband" to reflect the Government's next roll out initiative, thereby providing longevity to Local Plan policy and distinguishing new provision from the "standard broadband" which is not considered fast enough, this also applies to paragraph 6.127.

Paragraph 6.4 ECC notes that Green infrastructure is only mentioned in its wider District context. However, due to the rural nature of the district ECC would recommend that localised Green Infrastructure (GI) design principles are incorporated as part of a proposed housing development, specifically large developments such as Garden Communities and Urban Extensions. The would be in accordance with the NPPF and the Core Planning Principles on conserving and enhancing the natural environment, including the following statement in Paragraph 114 that Local Planning Authorities should "Set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure."
ECC recommends that this principle is also incorporated within Strategic Priority SP5.2 to protect, manage and enhance important habitats, nature conservation areas, geo-diversity and greenways

SP1.1 Need for Market, Affordable and Specialist Homes

Paragraph 6.30 Options on how to meet Objectively Assessed Need for housing:
A. Seek to provide as much for the district as possible, subject to environmental constraints;
B. Work with neighbouring authorities to ensure housing need across the South Essex strategic housing market is effectively met; or
C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first come basis first-served basis for a limited period of time

ECC Comments

Options A-C: ECC does not consider these options as presented to be mutually exclusive and would expect RDC to explore all options (and combinations) when planning to meet housing need. ECC would anticipate that RDC would seek to comply with the "Mechanism for the Consideration of Unmet Housing Need", as endorsed by the Essex Planning Officers Associations in September 2017, which comprises all Local Planning authorities within Greater Essex (including RDC)

Affordable Homes

Paragraph 6.31 Options for the affordable housing threshold:
A. Reduce the threshold for provision a part of a scheme (potentially in line with emerging national policy);
B. Retain the current threshold for the provision of affordable homes as part of a development scheme;
C. Do not have a policy threshold for the provision of affordable homes (potentially rely on emerging national policy and guidance to set the minimum threshold)

ECC Comments

ECC does not consider Options A and B, as presented to be mutually exclusive and would expect a combination of options to support the delivery of affordable housing within the district. ECC considers that additional sensitivity analysis of the thresholds would be appropriate to ensure they are effective and viable.
ECC recommend that consideration is given to the phasing and release of affordable homes on new development sites. This would enable the affordable homes provision to be both inclusive and adaptable throughout the life-course and further details are incorporated within the revised EDG. This is a key concept within the EDG to incorporate wider design feature such as dementia friendly principles (as promoted by the RTPI) and ECC's Independent Living Programme both of which should be considered. Furthermore the location of properties within new developments should seek to ensure social cohesion within the communities, including the reduction of social isolation (in accordance with NPPF paragraph 50).

ECC recommend that further consideration is given to locational "accessibility" in the provision of affordable housing. For example, to ensure the affordable housing provision is located with good passenger transport and a range of sustainable travel modes, to ensure social inclusion. This is to minimise the risk of a broad spread of affordable housing in low numbers located in relatively inaccessible areas, with limited to no potential to secure improvements in passenger transport provision. Further details are available within ECC's "Passenger Transport Strategy - Getting Around In Essex" (2015).

In respect of identification of "key worker homes" and supporting the needs of healthcare providers ECC considers that this could also be addressed via within the provision of affordable homes. .ECC recommends RDC engage with healthcare employers on their current workforce strategies so as to support recruitment and retention of healthcare staff. ECC would welcome the opportunity to assist with this stakeholder engagement.

ECC does not support Option C for the reasons stated within the justification, it is considered contrary to the NPPF (paragraph 50, third bullet 3) where authorities are required to set policies, where there is an identified need for affordable housing and the emerging vision and strategic objectives of the draft Local Plan, for example SO2 "To plan for the mix of homes needed to support our current and future residences, in particular viably addressing affordability issues and supporting our again population "
Paragraph 6.32 Options for the proportion of affordable homes to be provided:
D. Retain the current affordable homes requirement of 35% where a scheme meets the threshold, subject to viability;
E. Increase the proportion of homes that we require developers to provide as affordable housing, subject to viability

ECC Comments

Options D-E: ECC does not consider these options as presented to be mutually exclusive and would expect a consistent approach to be developed in principle, to support the delivery of the appropriate proportion of affordable housing, based on robust evidence ECC consider additional sensitivity analysis of the thresholds would be appropriate to ensure they are effective and viable.

Please refer to ECC's comments to paragraphs 6.30-6.31 above, which equally apply to these options. For example ECC recommend that consideration is given to the phasing and release of affordable homes on new development sites. This would enable the affordable homes provision to be socially inclusive and adaptable, as set out in the revised EDG, which now includes wider design features such as dementia friendly principles, to ensure social cohesion within the communities, including the reduction of social isolation for specialist housing, and including independent living units for older people and adults with disabilities.

ECC consider the provision of specialist housing including ECC's Independent Living Programme for Older People and Adults with Disabilities, to be within the definition of "affordable housing" and it should be included within the appropriate housing mix (see paragraph 6.33 below).

Homes for Older People and Adults with Disabilities

Paragraph 6.33 Options for the Provision of Homes for Older People and Adults with Disabilities:
A. Continue the current approach to applications for specialist homes - on an ad hoc basis as applications are received based on available evidence
B. Include a policy on housing mix which requires the provision of specialist homes, such as wheelchair accessibility (part M Category 3), independent living units, sheltered and extra-care housing, over a certain threshold.

ECC Comments

ECC welcomes the acknowledgement of and reference to ECC's Independent Living (IL) Programmes for Older People and Adults with Disabilities to support the provision of specialist housing, based on evidence and in accordance with the NPPF and national policy.

ECC supports a revised version of Option B, to ensure the positive provision of specialist housing to meet the needs of residents, in accordance with ECC's strategies, guidance and evidence including:
 ECC's IL Programmes for Older People and Adults with Disabilities , for the respective demand and need for units across Essex by district, for example the IL Position Statement for Older People (2016) identified a shortfall of 129 units (19 rental and 110 ownership) required in the District for the period 2015 and 2020
 ECC Developers' Guide to Infrastructure Contributions (2016) (for securing the appropriate funds) and regard to the revised EDG for appropriate locational and design guidance

ECC can provide updates on the demand and need for IL units for both Older People and Adults with Disabilities, and would welcome the opportunity to engage with RDC, on an ongoing basis to ensure the most up to date information is available to inform and shape the preparation of the Local Plan.

SP1.2 Care Homes

Paragraph 6.35 ECC welcomes the reference to and ongoing engagement with ECC and would wish to maintain this engagement to inform the requirements and provision within the preparation of the Local Plan

Paragraph 6.36 Options for providing care homes in the district:
A. Continue the current approach to applications for specialist homes - on an ad hoc basis as applications are received based on available evidence.
B. Include a policy on housing mix which requires the provision of specialist homes, such as wheelchair accessibility (part M Category 3), independent living units, sheltered and extra-care housing, over a certain threshold

ECC Comments

Options A-B: ECC would anticipate combination of options (including the option in paragraphs 6.30-6.35) to support and ensure the appropriate mix of provision including care homes in accordance with the NPPF and based on evidence.
ECC recommend that consideration is given to the need to ensure provision is accessible, appropriate and inclusive to ensure integration within the community and has regard to the health and social care requirement a set out in the revised EDG and the details set out above in response to Paragraph 6.33, options for the provision of specialist housing.

ECC would welcome the opportunity to engage with RDC on these matters further to ensure the preparation of a legally compliance, effective and sound local plan.

SP1.3. Delivering our Need for Homes

ECC General Comment

The Issues and Options within this section provide a clear overview of the key planning issues facing the District and what the new Local Plan should address in respect of meeting the needs for homes. However, it is recommended that further consideration should be given to the following.
 Infrastructure provision and funding. The new Local Plan should ensure there are clear policies for the full provision, enhancement and funding of infrastructure arising from planned development. Mechanisms include planning obligations, the use of a Community Infrastructure Levy (CIL), and the ability to negotiate specific contractual obligations for major strategic sites, in accordance with the Garden City principles defined by the Town and Country Planning Association (or subsequent updated guidance) and wider definition of sustainable development outlined in the NPPF. This will ensure the delivery of sustainable development in accordance with the NPPF, including the three dimensions to achieve sustainable development (paragraphs 6 -10), the presumption in favour of sustainable development (paragraph 14) and the 12 core planning principles (paragraph 17).

At the heart of the NPPF is a presumption in favour of sustainable development. For plan-making this means local planning authorities should positively seek opportunities to meet the development needs of their area, and Local Plans should boost significantly the supply of housing to ensure the full objectively assessed needs for housing over the plan period. The NPPF includes the delivery of sufficient community and cultural facilities and services to meet local needs as a core planning principle.

There is a clear expectation that local authorities should make provision for funding for new school places from Section 106 contributions and CIL. ECC alone does not have the capital resources to fund the construction of early years' and child care places, primary schools or secondary schools. There appears to be a view developing that the provision of sufficient school places is the sole responsibility of ECC assisted by the DfE in the form of 'basic need' funding, as the District and Borough councils are not the local education authority. The expectation is that the DfE will fund any shortfall in school places that result from large new housing developments.

ECC wish to draw attention to paragraph 72 of the NPPF, which states 'The Government attaches great importance to ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities.' ECC does not view financial contributions for education as optional. If this is the case then there will be no DfE and or ECC funding available, to provide all the school places required as a result of a growing school population and the need to create additional school places to meet the needs generated by new housing developments. ECC recommends that it is made clear in the new Local Plan that there is a requirement for financial contributions from developers to fund the full additional early years and childcare, primary and secondary school pupil places (including post 16) generated from new development to ensure that new housing developments are sustainable in terms of educational and childcare provision. ECC considers that this would accord with NPPF paragraph 72 and reiterates the requirements in the ECC Local and Neighborhood Planners' Guide to School Organisation and the ECC Developers' Guide to Infrastructure Contributions (2016). Further information on this issue is provided later in this response.
ECC welcomes the recognition that infrastructure is critical to support sustainable growth and to make sure RDC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future and the acknowledgement of ECC's role in the provision of Local and Strategic infrastructure. ECC wishes to be proactively engaged with the assessment of the spatial options and site allocations, given the importance of infrastructure provision and funding to the Draft Plan, which will vary for each spatial option and site allocations, given their respective individual and cumulative infrastructure requirements, generating their own, individual and cumulative impacts and opportunities on the delivery of ECC service areas.
 Flooding and its impact on development. This is broadly mentioned but will significantly influence future development locations. The main river and surface water flood risk areas should be clearly identified and the new Local Plan should provide appropriate policies in relation to flood risk. ECC is the Lead Local Flood Authority for surface water management and is revising the South Essex Surface Water Management Plan (SWMP) taking into account the recent changes in the EA's Climate Change Allowances. ECC recommends the provision of sustainable drainage systems (SuDS) and the revised SWMP as part of new development. Further information on this issue is provided later in this response.
 Broadband. While highlighted in the document, ECC recommend that "broadband" is distinguished from other telecommunications infrastructure, and specified in policy as a necessary infrastructure requirement for new development.. This will support relevant strategic and local objectives relating to economic growth particularly in rural Rochford. This will have a wider impact on growth and productivity, as increased broadband coverage will support businesses and attract investment to Essex. It also has the potential to increase opportunities for home-working and remote-working, reducing the demand on travel networks at peak periods. The importance is demonstrated by recent census returns which show that the biggest change in journey to work patterns in the last 20 years has actually been the increase in people working from home.

 Minerals and Waste provision and safeguarding requirements (please see section 2 "Tells Us Your views).

It is recommended that the above policy requirements are considered when preparing the new Local Plan and developing the overarching spatial strategy. Further information is provided below and in Sections 7 - 11.

Paragraph 6.46 ECC welcomes the positive recognition and importance placed on reducing inequalities and improving congestion levels, by ensuring the provision of new homes will include a variety of modal travel options. ECC recommends engagement and close working with ECC's Sustainable Travel Team and raising awareness of the local cycle action plans which also include some infrastructure elements

ECC recommends greater emphasis is placed on the creation of and access to more sustainable travel options within new developments, including connectivity to existing settlements for both housing and employment.

Paragraph 6.48 Options to provide a realistic strategy for delivering new homes:
A. Increase density within the existing residential area - which would require an amendment to our current density policy
B. Increase density on allocated residential sites
C. Several small extensions to the existing residential area
D. A number of fewer larger extensions to the existing residential area
E. A new settlement

ECC Comments

ECC does not consider these options as presented to be mutually exclusive. ECC would anticipate the Spatial Strategy to be developed with a range or combination of the options, based on evidence and in accordance with the NPPF and in particular the overarching principles of the NPPF.

ECC recommends that consideration is given to the wider "duty to co-operate" in emerging national policy (housing white paper) requiring local authorities (including RDC and ECC) to place greater emphasis on the development of Joint Strategic Priorities to address strategic cross boundary planning matters. The formation of ASELA to develop the South Essex 2050 vision with a set of strategic priorities and JSP will provide the context for RDC to consider the requirements of the South Essex Strategic Housing Market Area and to explore whether there are any unmet housing needs within the area.

ECC welcomes the recognition that infrastructure is critical to support sustainable growth and to make sure RDC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future, and the acknowledgement of ECC's role in the provision of Local and Strategic infrastructure. ECC wishes to be proactively engaged with the assessment of the spatial options and site allocations, given the importance of infrastructure provision and funding to the Draft Plan, which will vary for each spatial option and site allocations, given their respective individual and cumulative infrastructure requirements, generating their own, individual and cumulative impacts and opportunities on the delivery of ECC service areas.

ECC considers that any large scale housing developments will need to include appropriate infrastructure such as schools, community facilities and improvements to the roads. In contrast, a larger proportion of small scale or piecemeal developments are less likely to secure funding for the necessary infrastructure requirements. Furthermore infrastructure provision is likely to have a major impact on the phasing, delivery and viability of development(s) and this would need to be considered as part of the overall strategy.

ECC recommend consideration is given to the cumulative scale of development required to secure the necessary supporting infrastructure and the mechanisms available to secure developer contributions (be it S106 contributions, pooling of contributions or via the Community Infrastructure Levy). ECC consider this to be essential in the preparation of a new local plan, to ensure it complies with the legal duty to co-operate, meets the tests of soundness and is effective, viable and deliverable. ECC expect RDC to prepare a sound and deliverable Local Plan, having regard to the available levels and sources of investment available to deliver the supporting infrastructure.

ECC recommends consideration is also given to the respective infrastructure funding streams available to deliver and implement strategic infrastructure, be it the ECC Developers' Guide to Contributions, the Opportunity South Essex Partnership, the South Essex Local Enterprise Partnership, and Government Departments/agencies, such as the Department for Transport agencies, as well as changes in the national policy and legislation for the S106 and CIL.

ECC can advise in principle, that subject to the scale of the development being considered, Option E may have the potential to bring forward the level of investment needed to provide significant improvement to the highway and transportation infrastructure. However, in the absence of a location or scale for any new settlement ECC cannot recommend its preference for Option E over and above any other options put forward. Again, subject to the scale of development the other options including smaller size settlements may not bring the level of investment required. In essence this reflects the "critical mass" in the scale of development required to enable effective infrastructure and service planning, which it may not be possible to secure with a number of smaller developments given the effect of the CIL Regulations (Regulation 123) and the restrictions on pooling contributions.

SP1.4 Good Mix of Homes

Paragraph 6.58 Options identified in relation to the broad approach for considering the type and size of new homes:
A. Retain the current policy on types of homes, which takes a flexible, market-driven approach to types
B. Include specific reference to the size and types of homes referred to the South Essex SHMA
C. Continue to require new homes to meet the National Technical Housing Standards - nationally described space standards
D. Do not adopt specific policy on the mix of homes

ECC Comments

ECC would anticipate a strategy to be developed based on evidence and in accordance with the NPPF. Please refer to ECC's comments in response to the options in paragraphs 6.30 - 6.36 above paragraph 11.5 below which are considered relevant to this option.

ECC does not support Option D for the reasons stated in the justification, it is considered contrary to the NPPF (paragraph 50) and the emerging vision and objectives of the draft Local Plan, for example SO2 (as referred to in response to paragraph 6.31 above).

SP1.5 Gypsy, Travellers and Travelling Showpeople

Paragraph 6.78 Option identified to meet the needs of Gypsies and Travellers:
A. Retain the current criteria-based policy (Core Strategy policy H7)
B. Retain the current allocated site (Allocations Plan policy GT1)
C. Allocate a number of smaller Gypsy and Traveller pitches / sites to meet needs
D. Consider a mobile home policy for those no longer falling within the Gypsy and Traveller definition
E. Prepare a more detailed criteria-based policy
F. Do not have a policy on Gypsy and Traveller provision
ECC Comments
ECC does not consider these options to be mutually exclusive. ECC would expect RDC to develop a combination of options based on evidence and in accordance with the NPPF and the Planning Policy for Traveller sites 2015 (PPTS), requiring an inclusive approach for all gypsies and travellers, both members of the travelling and settled communities.

ECC would anticipate provision to be made for travellers who meet the planning definition, may be meet the definition or do not met the definition to be in accordance the Greater Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment 2016-2033 (GTAA) published in January 2018.
Furthermore ECC would anticipate the emerging strategy and emerging policy to take into account the Transit Recommendations within the Essex GTAA prepared by EOPA and considered to be a strategic cross boundary issue for the Greater Essex authorities.

SP1.6 Houseboats and Liveaboards

Paragraph 6.82 ECC welcome and support the commitment to work with other neighbouring authorities and relevant bodies such as the Marine Management Organisation (MMO), Natural England (NE) and the Environment Agency (EA). ECC and partners would be able to assist in monitoring and the assessment of impacts arising from the proposed approach to Houseboats and Liveaboards. This could include identifying an appropriate scale / limit for the number of houseboats that could be permitted to moor in a particular area.

Paragraph 6.83 ECC considers the statement regarding the extent of land use planning control "to only extend as far as the mean high tide" to be incorrect and should be amended. ECC can advise that Land Use planning control extends to Low Water Mark, whilst the Marine Planning system extends to High Water Spring Tide, therefore there is an overlap of the 2 planning systems in the intertidal area. This correction also provides an opportunity to work with the MMO in developing evidence and an emerging policy.

Paragraph 6.84 ECC considers further exploration of the infrastructure requirements is necessary, in addition to the reference to the need for provision of toilets for houseboats with a permanent mooring, and to also include the infrastructure provision required for boats which are moored temporarily. It is important that the boats do not discharge waste into the marine environment and hence they would need to be equipped with holding tanks and to use pump out facilities to discharge this type of waste appropriately.
Paragraph 6.86 Options to address the mooring of houseboats in the district:
A. Retain the existing policy
B. Amend the existing policy to strengthen criteria
C. Allocate specific areas of coastline where such uses may be acceptable
D. Amend the definition in the Development Management Plan

ECC Comments

ECC would anticipate a strategy to be developed based on evidence and in accordance with the NPPF and other national policy. ECC considers additional evidence and engagement is required, and recommend that this is explored further with EPOA and / or Essex Coastal Forum.

ECC welcome the consideration of the need for a policy on houseboats/ liveboards as part of the review of the current polices to ensure they are based on the most up to date evidence. This would be appropriate given the growth in occupation and experiences elsewhere in the country (especially in London) where living on a boat is proving to be an attractive proposal, and in certain areas demand has outstripped available mooring. Whilst it may be a lifestyle choice for many, the result is an increasing number of houseboats across the Essex coast, especially in areas commutable to London.

SP1.7 Meeting Business Needs;

Paragraph 6.87 ECC recommends consideration is given to the contribution made by the environmental / Green Infrastructure (GI) to provide a network of multi-functional high quality green spaces and other environmental features, which together deliver multiple environmental, social and economic benefits. ECC can provide advice and evidence from the findings of a Forestry Commission report on the economic value of Green Infrastructure, to overcome barriers to businesses, whilst improving people's quality of life, health and wellbeing, which is available here:
https://www.forestry.gov.uk/pdf/nweeconomicbenefitsofgiinvestigating.pdf/$file/nweeconomicbenefitsofgiinvestigating.pdf

Paragraph 6.92 ECC notes the emerging Local Plan seeks to facilitate a diverse, modernised economy providing high value employment, and supports this aspiration. Paragraph 6.105 states that the Economic Development Needs Topic Paper 2017 advocates employment land increases to primarily facilitate B1 and B2 uses. Whilst ECC does not object to this, it is considered important to ensure that any strategy seeking to grow the economy does not preclude opportunities for waste management, with such facilities often being sited on industrial / employment land. Whilst, waste related developments are employers in their own right, economic activity generates waste, and a cost effective, local waste solution supports economic development across the spectrum. It is recognised that there is nothing in the Issues and Options consultation that indicates such opportunities would be precluded, and indeed ECC notes the role that Rawreth and Star Lane industrial estates play in this regard, but ECC as the MWPA welcomes the opportunity to make this point. It is requested that reference is made to supporting appropriate 'sui generis' uses when defining appropriate use classes on employment land.

Paragraph 6.94 Please amend the reference to "Ultrafast broadband" for the reasons set out in response to Section 6 and paragraphs 6.96 and 6.127.

Paragraph 6.96 ECC supports this statement and the need for improvements to the highway networks / sustainable travel choices to support businesses and economic growth; and to enable people to work in the local area.

Paragraph 6.96 Options to support employment and economic growth in the district
A. Continue to support employment growth within the current employment growth policy
B. Update the current employment growth policy to include reference to broadband
C. Update the current employment growth policy to further support new businesses at each stage of their lifecycle - in particular to reflect the need for grow-on space
D. Include specific reference in the current employment growth policy to tourism; and
E. Include specific reference to supporting sustainable travel options and promoting highways improvements

ECC Comments

ECC would expect all of the options to contribute to RDC meeting its need for employment and economic growth; and would expect RDC to prepare a sound and legally compliant Local Plan, based on evidence and in accordance with the NPPF.
ECC welcomes proposals to ensure the protection and provision of suitable employment land and appropriate uses within the District, with the pre-eminence of the importance of London Southend Airport to the economy whilst seeking opportunities for rural diversification, tourism, retail, leisure, town centres, to meeting the life cycle of business needs including "Grow on Space" and development of skills and training opportunities.

ECC welcomes and supports the importance and economic role played by London Southend Airport as international gateway and the A127 corridor and London-Southend Victoria railway line for connectivity with South Essex, the rest of Essex and London. A key priority will be to enable investment in infrastructure and economic growth (for example the A127 including passenger transport; ultrafast broadband) as well as developing options to support the alignment of skill provision to meet the local needs in accordance with the Economic Plan for Essex (2014) and the Government's Industrial Strategy as are being explored by the ASELA through the Industrial Strategy workstream and the preparation of the JSP. The provision of jobs and infrastructure to support economic growth will be essential, including the need to provide social, physical and green infrastructure.

ECC recommends consideration is given to the role and contribution of waste related developments as employers in their own right, economic activity generates waste, and a cost effective, local waste solution supports economic development across the spectrum. ECC recommends the inclusion and reference to 'sui generis' uses when defining appropriate use classes on employment land (see paragraph 6.92 above and 6.105 below).

In respect of Option B and the reference to Broadband, ECC acknowledge the importance of this infrastructure to support economic growth. Please refer to ECC's comments in response to paragraph 8.44 and the options for communication and broadband provision, as well as the references above to "Ultrafast" broadband.

In respect of Option C, ECC welcomes and supports the reference to the ECC "Grow on space" report 2017 and its findings seeking to address the lifecycle needs of businesses. This is also consistent with the Essex Economic Commission.

In respect of option D and the references to rural diversification and tourism ECC considers the development and promotion of the Essex Coast Path could provide opportunities for the local economy. ECC considers there is a need to have regard to the role and contribution of the environment and in particular investment in Green Infrastructure to attract new businesses and opportunities which will help to create employment, including for example regeneration projects which together can deliver multiple environmental, social and economic benefits. Further details and examples are set out in response to paragraph 4.6 above.

In respect of Option E, ECC supports the need for a range of highways and sustainable transport improvements to existing employment areas, including London Southend Airport and the airport business park and will continue to seek funding through bids to central Government, SELEP and S106 contributions, as set out in response to SP1.3 (ECC general comment) above and Paragraph 6.48.
As explained, ECC would anticipate the inclusion and promotion of sustainable modes of travel to support the community (both residents and businesses) to be embedded in the emerging strategy in conjunction with other options, to support employment and to deliver the wider principles in the emerging vision and spatial strategy, in accordance with the Essex LTP, Economic Plan for Essex and the A127 Corridor for Growth An Economic Plan. Please also refer to ECC comments regarding Highway Infrastructure in section 8.

SP1.8 Need for Jobs;

Paragraph ECC notes that the emerging Local Plan seeks to facilitate a diverse,
6.105 modernised economy providing high value employment. This aspiration is supported. Paragraph 6.105 states that the Economic Development Needs Topic Paper 2017 advocates employment land increases to primarily facilitate B1 and B2 uses. Again, this is not objected to but it is important that any strategy seeking to grow the economy does not preclude opportunities for waste management, with such facilities often being sited on industrial / employment land. As explained in response to paragraph 6.92 & 6.96 above regarding waste management developments as employers in their own right ECC recommends that reference is made to supporting appropriate 'sui generis' uses when defining appropriate use classes on employment land.

Paragraph 6.111 Options to support economic growth in the district over the next 20 years:

A. Develop specific policies for each employment site to protect certain uses
B. Reconsider the allocation of Rawreth and Star Lane industrial estates back to employment
C. Review new employment land allocations that do not have planning permission
D. Retain current strategy and allocate additional employment land
E. Promote improvements to quality of building stock and intensification of existing sites
F. Strengthen policy stance on access improvements
G. Do not have a policy on employment land

ECC Comments

ECC does not consider these options to be mutually exclusive and would expect RDC to develop a policy based on evidence and in accordance with the NPPF and the National Planning Policy for Waste 2014 (NPPW).

ECC would expect all of the options A-F to contribute to RDC meeting its need for economic growth, taking into account ECC's comments in respect of Paragraph 6.96 above to support employment and economic growth in the district. ). ECC would expect a Rochford Employment Land Review to be prepared and for the following evidence to be taken into account -, the South Essex Economic Development Needs Assessment; the Governments Industrial Strategy, SELEPs Economic Plan, OSE economic objectives, Thames Estuary Commission, the Economic Plan for Essex and ASELA's emerging South Essex 2050 vision and emerging industrial strategy workstream and JSP.

provide an effective multi modal interchange for the Airport, with improved connectivity and realistic sustainable travel option for all users.

Paragraph 6.114 ECC supports the development of the Airport business park and the associated highway and cycling network improvements

Paragraph 6.115 ECC acknowledges the need for investment in the highway / transport network around London Southend Airport and will continue to seek funding through bids to Central Government, SELEP and S106 contributions.
ECC considers there to be a need to promote and encourage a package of sustainable travel options, for residents and businesses to travel sustainably, with the highway improvements referred to also including improvements to bus journey times and bus priority measures, to promote sustainable travel (including buses) as a realistic sustainable travel option. Further contributions through a combination of s106 and S278 and CIL funding should be secured through appropriate new developments to address the sustainable travel agenda when opportunities arise.
Paragraph 6.116 ECC acknowledges and supports the need for transportation improvements to the A127 to facilitate growth within the District and South Essex; and recommend that reference is made to the joint ECC and Southend on Sea BC A127 Route management Strategy entitled A127 Corridor for Growth - An Economic Plan 2014

Paragraph 6.117 Options in relation to London Southend Airport:
A. Retain and update the Core Strategy policy supporting London Southend Airport's growth
B. Retain the existing policy in the Allocations Plan
C. Retain the existing policies in the JAAP
D. Continue to support surface access improvements in and around London Southend Airport

ECC Comments

ECC does not consider these options to be mutually exclusive. ECC would expect RDC to develop a combination of options based on evidence and in accordance with the NPPF.

ECC recommends that RDC should consider and clarify the "in principle" inter-relationship and compatibility between the JAAP and the new emerging Local Plan. For example, is the intention to incorporate the provisions of the JAAP within the new Local Plan, or will the JAAP continue to be a separate standalone document, subject to its own review?

In respect of Option D, ECC considers that the JAAP clearly sets out the associated access improvements for London Southend Airport, and that this would be appropriate option to address the passenger transport and sustainable travel options, as part of an integrated travel solution. ECC considers there to be a need to actively promote and improve passenger transport provision and connectivity, rather than solely relying on highway improvements to provide benefits for passenger transport, as any additional highway capacity may be absorbed by continual increases in demand by motorists, in the absence of realistic alternative travel options.

SP1.10 Supporting Tourism and Rural Diversification

Paragraph 6.121 ECC notes the comments regarding the lack of rural passenger transport services. However, it is of concern that the emphasis for the solution is solely placed on improvements to roads and the cycling network. In order for RDC to improve accessibility to the rural parts of the District, whether for tourism, employment or other reasons, it is considered that the most effective and viable approach would be the development of a District transportation strategy. This would have the benefit of setting out aspirational networks for all sustainable travel options including walking, cycling and passenger transport. There are a range of options that could be considered from traditional timetabled services to demand responsive operation or a combination of services to optimise technology. ECC would wish to engage with RDC to explore the options, which could be of particular value and support for tourism and rural diversification.

ECC considers investment to improve and create new Green Infrastructure such as woodlands, nature reserves and greening town centres would be appropriate and would benefit tourism, through attracting new visitors, and support retail and tourism sectors.

ECC considers transport and accessibility to be vitally important for tourism and investing in the Green infrastructure would provide opportunities to encourage alternative modes such as walking and cycling. This would improve accessibility to green spaces, whether by the distance from home and businesses; or by the creation of green links/greenways including enhancements to the existing Public Rights of Way network (including cycleways). Thus providing alternative traffic free cycling and walking routes, as well as wildlife corridors.

ECC considers that this would need to be developed in partnership with stakeholders including ECC and public transport providers to improve the accessibility of green spaces, to be as easy as possible. ECC would welcome the opportunity to explore this further, as outlined in ECC's response to SO6 above, regarding the proximity of new developments to green space.

Paragraph 6.127 Please amend the reference to "Ultrafast broadband" for the reasons set out in response to Section 6 and paragraphs 6.94, 6.96 and 6.127.

Paragraph 6.128 Options for tourism and rural diversification:

A. Continue to support current defined forms of green tourism and rural diversification as set out in our current policies
B. Expand the current approach to include other forms of rural diversification
C. Do not support rural diversification

ECC Comments

ECC does not consider options A and B to be mutually exclusive. ECC would expect RDC to develop a combination of the options based on evidence and in accordance with the NPPF, and to evolve as part of the overarching economic growth strategy (see paragraphs 6.96 and 6.116 above).

In respect of Option B (rural diversification) ECC supports this option in principle (subject to evidence) to provide an opportunity to retain employment in the first instance which may then lead to creation of new jobs. ECC recommends that the following factors are further explored:

 Accessibility Issues - there is potential to expand the current policy approach to address accessibility issues raised by ECC (paragraph 6.121). ECC recommends further investigation is required in respect of the wider passenger transport improvements to support access to tourism and rural areas, tourism. It is considered that this could include a range from timetables to the "on demand" bus services, as realistic alternatives; which goes beyond improvements to roads and cycle networks.
 Tourism and consideration of the potential benefits of the England Coast Path, and opportunities for tourism and rural diversification including for temporary camp sites if for example there is an increase in events specifically using the coast such as Maldon District's Council annual Saltmarsh 75 event.
 Potential provision for waste management facilities suited to the rural environment (such as anaerobic digestion or composting), as part of rural diversification in accordance with NPPW

ECC recognise that Policy GB2 in the Core Strategy and Policies DM12 and DM13 in the Development Management Plan do not act to constrain the rural diversification opportunities highlighted above and a continuation of this stance may be appropriate, based on evidence.

ECC does not support Option C for the reasons stated within the justification, it is considered contrary to the NPPF (and the emerging vision and objectives for the draft Local Plan.
SUPPORTING COMMERCIAL DEVELOPMENT (SECTION 7)

SP2.1 Retail, Leisure and Town Centres

Paragraphs 7.12 In respect of the Retail and Leisure Study update 2014, ECC
and 7.17 notes the reference to "catering needs" and recommend that this should also include "A5" fast foot outlets, to avoid clustering and high concentrations of A5 premises within the district. ECC strongly recommends that RDC review the existence and pattern of A5 premises, which can be undertaken using the FEAT tool (http://www.feat-tool.org.uk/), which is a fast food tool which provides details on fast food outlets for districts including A5, fast food retailers. ECC Public Health is aware of the emerging evidence base on high energy foods and obesity, including recent publications from Public Health England for spatial planners on fast food restrictions. ECC Public Health would welcome the opportunity to provide advice and to work with RDC on this matter.

Paragraph 7.20 Options for the district's town centres:
A. Retain current Core Strategy policies
B. Retain current policies in the Rayleigh Centre Area Action Plan
C. Retain current policies in the Rochford Town Centre Area Action Plan
D. Retain current policies in the Hockley Area Action Plan
E. Review the town centre Area Action Plans
F. Do not have policies on town centres

ECC does not consider these options to be mutually exclusive. ECC would expect RDC to develop a combination of options based on evidence and in accordance with the NPPF.

As set out in response to paragraph 6.117 in respect of the JAAP, ECC recommends that RDC should consider and clarify the "in principle" inter-relationship and compatibility between these Area Action Plans and new emerging Local Plan. For example, is the intention to incorporate these Area Action Plans into the new Local Plan, or will they be separate standalone Area Action Plans subject to their own reviews?
DELIVERING INFRASTRUCTURE (SECTION 8)

SP3.1Highways Infrastructure

Paragraph 8.17 ECC welcomes and supports the references and importance given to the Essex and Southend "A127 A Corridor for Growth - An Economic Plan (2014)" and the need for investment in the highway and transportation network, in accordance with the Essex LTP. ECC will continue to seek funding through bids from central Government, SELEP and S106 contributions as appropriate (CIL?) (as stated in 6.111 above).

ECC can advise that work is progressing on the next phase of the A127 Route Management Strategy, with the Options Appraisal and Strategy Report, in conjunction with the South Essex authorities, the London Borough of Havering, Transport for London and Highways England, to promote the importance of the A127 to facilitate growth across the area. In respect of improvements to the strategic transport network, ECC can confirm that the 'short term' funded transport scheme for the A127/A130 Fairglen Interchange is planned for implementation by 2022/23. ECC is also preparing a Joint A13 Route Management Strategy with Southend on Sea BC and Thurrock BC Highway Authorities.

In moving forward it is considered that RDC's approach to the Highways and Transportation will need to take into account the ASELA South Essex 2050 vision and emerging Infrastructure workstreams and the JSP.

Paragraph 8.18 ECC welcomes the reference to work with ECC as the Highways Authority and neighbouring authorities to promote strategic and more localised improvements to the highways network. ECC will continue to work with RDC on an ongoing basis to ensure these strategic matters are addressed collectively within the respective emerging Local Plans and a wider South Essex Joint Strategic Plan.

Paragraph 8.20 Options for the Local Highway Network:

A. Retain current policies on the local highway network
B. Prioritise local highways and junctions between Rayleigh, Hockley and Rochford (B1013), to support and direct funds to improve the local highway network
C. Prioritise local highways and junctions by upgrading the east to west connection north of Rayleigh, Hockley and Rochford, to support and direct funds to improve the local highway network
D. Do not have a specific policy on the local highway network

ECC Comments

ECC does not consider these options to be mutually exclusive. ECC would expect RDC to develop a combination of options in consultation with ECC as highway and transport authority, based on evidence (including transport modelling) and in accordance with the NPPF.

ECC would anticipate the strategy for the local highways network to be a combined approach as part of an integrated package of transport solutions (including sustainable travel options) and for this to be embedded within the Local Plans' spatial strategy.

As stated in response to SP1.3 and paragraphs 6.46 and 6.113 above, ECC considers greater emphasis should be placed on an integrated transport solution, in accordance with the Essex LTP to move away from the traditional reliance on road improvements, which is only part of the solution. For example, the inclusion and promotion of sustainable modes of travel (in addition to the outcomes of the transport modelling work) would support the community (both residents and businesses) in respect of transport and travel through the main towns and improve rural transport options. There is a need to ensure the appropriate approaches for the local highway network also take into account the requirements and inter-relationship with the wider local and Strategic networks as well as cross boundary issues / impacts.

Strategic Highways Network Transport

Paragraph 8.21 ECC welcome the reference for RDC to work with ECC and Southend BC (as the Highways Authorities) in the development of a transport model for the length of the A127, however please refer to ECC's update on the A127 Route Management Strategy in paragraph 8.17 above.

ECC can advise that the A127 comprises three highway authorities (Southend on Sea, ECC and the London Borough of Havering (LBH)), as such the A127 Route Management Strategy is being extended to incorporate the LBH. Furthermore LBH and the seven south Essex authorities (including ECC) have signed a Statement of Common Ground in respect of the importance of the A127 to facilitate growth.
ECC is engaging with the South Essex authorities in respect of a potential South Essex transport model which would be consistent with ECC's aspirations for an Essex wide model, drawing on the modelling work to date. This will however need to take into account the Highways England modelling information, including for example the Lower Thames Crossing.

ECC can also advise that Highways England would wish to be engaged in emerging Local Plans, to ensure any potential "ripple effect" of development is considered in respect of their transport network, for example the M25, A12 and sections of the A13 within South Essex.

Paragraph 8.21 Options identified for the strategic highway network:
A. Support improvements to the strategic highway network
B. Do not have a specific policy on the strategic highway network

ECC Comments
ECC would expect RDC to prepare a policy approach to the strategic highway network in consultation with ECC as highway and transport authority, based on evidence (including transport modelling) and in accordance with the NPPF.
In respect of Option A, ECC would anticipate the policy for the strategic highways network to be a combined approach as part of an integrated package of transport solutions (including sustainable travel options) and moving away from the traditional reliance on road improvements, which is only part of the solution. This would be in accordance with the Essex Local Transport Plan, and the A127 and emerging A13 Route Management Strategies as set out in response to paragraphs 8.17-21 above, and in response to SP1.3, paragraphs 6.46 and 6.111.
ECC does not support Option B for the reasons stated within the justification; it is considered contrary to the NPPF, the Essex LTP and A127 Route Management Strategy and the emerging vision and strategic objectives in the draft Local Plan.

SP3.2 Sustainable Travel

Paragraph 8.22 ECC welcome the desire for a modal shift towards more sustainable ways to travel, given that car use is the dominant mode of transport. ECC recommends there to be a need to change the modal shift in the short term, with greater emphasis placed on promoting alternative travel options (walking, cycling, passenger and public transport) and given greater weight in the Local Plan, to ensure these facilities are planned in now, to enable the options and benefits to be realised during the plan period. Greater emphasis is required on an integrated transport solution, and moving away from the traditional reliance on road improvements, which is only part of the solution.

Paragraph 8.22 ECC notes the reference to the Rayleigh Town Centre AQMA, however recommend this should be expanded to include reference to the National Air Quality Plan published by DEFRA in July 2017 which designates a site on the A127 to the east of Rayleigh Weir.

Paragraph 8.24 ECC welcomes the reference to Public Transport and recognition of the importance and connectivity to the rural areas and cross boundary connections, however there is a need to recognise that Public Transport is of value to everyone (all residents and employers) and not solely to residents who do not have access to private vehicles. There is a need for a change in emphasis, with the principles of alternative sustainable travel and accessibility (including passenger transport) to be embedded within the Local Plans' emerging spatial strategy to deliver the "vision" for the district and modal shift in transport. ECC recommends that RDC actively engages and works with the local transport operators in the District as well as ECC to develop services.

For example, there is the opportunity to explore innovative ways to deliver a more demand led public transport service to broaden accessibility away from the scheduled bus service. It could bring improved frequencies and less complex journeys by being able to be more responsive to demand for specific journeys, and provide quicker interchanges between modes. How this is supported could be explored within the context of paragraph 8.30, and may have potential to form part of the solution to air quality issues identified in paragraph 8.31.

Paragraph 8.27 ECC recommend that reference is made to the Rochford Cycling Action Plan 2018; prepared by Essex Highways and further information on the Essex Cycling Strategies is available here:
http://www.essexhighways.org/getting-around/cycling/cycle-programme.aspx.
Please note for consistency of terminology the references to "Cycle "Storage" within this paragraph should be change to "Cycle "Parking".

Paragraph 8.28 For clarity, ECC recommends that greater references should be made to "cycling" and "cycling networks", to help distinguish the nature of the routes being referred to, for example by inserting "cycle" before "routes to link homes" within this paragraph.

Paragraphs ECC welcomes the reference to the positive role of "Green Infrastructure"
8.27, 8.28 within this section which highlights the high dependency on cars, and that
and 8.32 other sustainable modes of travel should be encouraged.

In respect of the approach to car use, consideration should be given to the provision for charging points for electric cars (see also comments under Renewable Energy Generation). Further consideration is required on the practicality of long term public transport provision with the likely changes in car ownership patterns in 20 years' time, arising from the Government's commitment to ban the sale of new diesel and petrol vehicles from 2040 and responses from the car industry and possible growth in the use of electric vehicles, be it hybrid or pure electric vehicles, with sales projected to increase to around 10% of new vehicles by 2025. The industry anticipate the share of Electric Vehicles will continue to rise and that by 2025 Electric Vehicles will be more affordable than internal combustion vehicles, even without Government subsidies.

The need for and provision of Electric Vehicle charging points should be explored further and ECC's Environment team wish to engage with RDC on this matter, including sharing examples of good practice in emerging and new Local Plans.
Paragraph 8.30 ECC would welcome the opportunity to work closely with RDC on the development and implementation of Travel Plans for all new developments, or extensions to existing businesses, or where the development will have a significant impact on the highway. The ECC Sustainable Travel team would welcome the opportunity to explore this further with RDC and recommend reference is made to ECC's Passenger Transport Strategy - Getting Around In Essex 2015.

Paragraph 8.33 ECC would welcome the opportunity to work with RDC to explore the issues raised (bullet points 1-6) in relation to sustainable travel choices for communities across the district, which could be addressed through the Local Plan. Further consideration is required regarding the role and importance of realistic sustainable travel options to support the growth in the District.

Key issues ECC would like to explore further with RDC include:

Fifth bullet point - ECC considers the proposal to re-route the bus services away from Marked Square in Rochford Town Centre to be unsound. The removal of buses from this key location would be contrary to the principles of sustainable and accessible communities, and the strategic objectives in the Local Plan including the need for a modal shift in transport towards realistic and sustainable travel options for all. For example; if buses could not serve this area then residents would be encouraged to travel by car, adding further traffic to the already congested road network.

Sixth & Seventh bullet point - Further clarification is required on the nature of the issues.

Paragraph 8.34 ECC supports the proposal for setting a more challenging mode share; and would wish to work with RDC to explore and develop these issues and opportunities further within the context of the emerging new Local Plan.

Paragraph 8.35 ECC welcomes the opportunity to work with RDC and partners to explore and help shape new and improved passenger transport options across the District, as part of ongoing "duty to co-operate" engagement in the preparation of the Local Plan.

Paragraph 8.36 ECC consider the reference to SERT, which concerns bus services to be unclear within this paragraph on cycling.

Paragraph 8.37 Options identified to support Sustainable Travel
A. Retain the current policy on public transport
B. Support the development of a rapid public transit system for South Essex
C. Retain the current policy on travel plans
D Lower the threshold to require travel plans to be prepared for schemes under 50 homes
E. Retain the current policy on walking and cycling
F. Do not have policies on sustainable travel

ECC Comments

ECC would expect RDC to develop a combination of options A-E, in consultation with ECC as highway and transport authority, based on evidence and in accordance with the NPPF.

ECC would anticipate the approach to support sustainable travel to be a combination of options, as part of an all-encompassing, integrated package of transport solutions (including highway network improvements) and for this to be embedded within the Local Plans.

ECC recommend RDC has regard to NPPF (section 4 Promoting Sustainable Transport and section 8 Promoting Healthy Communities), the Essex Local Transport Plan, the A127 and emerging A13 Route Management Strategies, ECC's Sustainable Travel Strategy, and evidence (including transport modelling the Cycle Action Plan and South Essex Active Travel programme), and ECC's Passenger Transport Strategy - Getting Around in Essex (2015).

In respect of Option A, ECC considers this to have the potential for greatest advantages to prepare the District for its future transportation needs, including the potential for a more demand- led model, to work alongside scheduled bus and rail services. ECC would anticipate the need to consider this as part of a wider cross boundary engagement, with neighbouring authorities, ECC and transport providers. ECC would welcome the opportunity to engage with RDC on this matter.
In respect of Option D, ECC recommend that the threshold for travel plans is considered further to take into account the thresholds within EPOA Guidance for Health Impact Assessments 2008; where active and sustainable travel is already considered. ECC is currently reviewing the EPOA Guidance for Health Impact Assessments, to ensure it is up to date and relevant. ECC would welcome the opportunity to work with RDC on the development of this aspect within the Local Plan.

In respect of Option E, ECC considers the current approach in policy T6 positively encourages people to travel sustainably.

ECC does not support Option F for the reasons stated in the Justification, it is considered contrary to national policy, the Essex Local Transport Plan, and ECC Passenger Transport Strategy and the emerging vision and strategic objectives of the draft Local Plan.

SP3.3 Communications Infrastructure,

Paragraph 8.43 ECC recommends that reference is made to the BT Openreach policy of providing FTTP connections to any new development of houses over 30 properties, free of charge to the developer. Further information is available on the BT Open reach web link: https://www.ournetwork.openreach.co.uk/property-developers/site-registration.aspx

This provides the framework for implementation of superfast broadband within new residential developments

Paragraph 8.44 Options identified for communications infrastructure:
A. Retain the existing policy on telecommunications infrastructure
B. Amend the existing policy to include specific reference to improving broadband and mobile coverage
C. Ensure that all commercial and residential developments over a certain threshold are conditioned to deliver appropriate broadband infrastructure
D. Do not have a policy on telecommunications infrastructure

ECC Comments
ECC would expect RDC to develop a combination of options A-C based on evidence and in accordance with the NPPF. ECC would anticipate the strategy for the communication infrastructure to be a combined approach embedded within the Local Plan.

As set out in response to Section 6, paragraphs 6.94, 6.96 and 6.127, ECC recommend all references to the provision of and requirements for future broadband are pre-fixed by "Ultrafast". ECC acknowledge the current rollout programme is "Superfast Broadband", however it is recommended that the draft new Local Plan should refer to "Ultrafast Broadband" to reflect the Government's next roll out initiative, thereby provide longevity in the draft Local Plan and to distinguish the standards for new provision from the "standard broadband" which is not fast enough.

ECC also recommends that reference is made to the BT Openreach policy of providing FTTP connections to any new development of houses over 30 units, free of charge to the developer. Further information is available on the BT Open reach web link: https://www.ournetwork.openreach.co.uk/property-developers/site-registration.aspx
This provides the framework for implementation of superfast broadband within new residential developments.

In respect of Option B, ECC considers this to be a positive approach to develop infrastructure resilience to support the growth ambitions within RDC. ECC recommends that the needs of both residents and businesses are incorporated within the policy requirements for good communication infrastructure provision.

ECC would welcome the opportunity to work with RDC to ensure the latest policies; guidance and evidence are taken into account to inform the principles, strategies and policies and site allocations within the emerging Local Plan.

ECC does not support Option D for the reasons stated in the justification, and considers it to be contrary to the NPPF (paragraphs 42-43) and the emerging vision and strategic objectives of the Local Plan, for example SO9.

SP3.4 Water and Flood Management,

Paragraph 8.45 ECC wish to draw RDC's attention to the requirements of NPPF paragraph 100, which requires development in areas at risk from all forms of flooding should be avoided and not just fluvial and coastal flooding. This is in line with national guidance which states:

In plan-making, local planning authorities apply a sequential approach to site selection so that development is, as far as reasonably possible, located where the risk of flooding (from all sources) is lowest, taking account of climate change and the vulnerability of future uses to flood risk. (Paragraph: 001 Reference ID: 7-001-20140306 https://www.gov.uk/guidance/flood-risk-and-coastal-change)
ECC notes that the South Essex Strategic Flood Risk Assessment 2011 is in the process of being updated given the changes to the Environment Agency (EA) climate change allowance.

ECC also recommends that the following guidance and evidence
published since 2011, should be taken into account in the preparation of
the Local Plan:
 EA - Risk of Flooding from Surface Water (RoFSW) maps;
 ECC Sustainable Urban Drainage Design Guide 2016
 ECC Essex SUDS Design Guide 2016;
 South Essex Surface Water Management Plan (2012 and emerging
revision due 2018);
 ECC Developers' Guide to Infrastructure Contributions (2016)

ECC also advises that the following Assessments and Strategies are
currently being updated and once complete should also be taken into
account as part of the Local Plan and Sustainability Appraisals evidence
base:
 The Preliminary Flood Risk Assessment for Essex; and
 The Essex Flood Risk Management Strategy
ECC would welcome the opportunity to work with RDC to ensure the latest
policies; guidance and evidence are taken into account to inform the
principles, strategies and policies and site allocations within the emerging
Local Plan.

Paragraph 8.46 & 8.48 Whilst the preferred intent of management in the Shoreline
Management Plan might be to maintain or upgrade defences along the
coast, there is no guarantee that funding will be available to deliver these
preferred policies. It is therefore appropriate that RDC seeks to secure
funding from development or other sources to potentially allow a funding
contribution towards any coast flood or erosion schemes especially given
the new approach of 'partnership funding' which now applies.

Paragraph 8.47 ECC welcome the positive consideration and approach to locate
& 8.48 development, within the lower flood risk areas, whilst taking into account
climate change, the vulnerability of future uses to flood risk and the impact
on water supply from a changing climate.

Paragraph 8.49 ECC can advise that the South Essex Surface Water Management Plan (2012) is being updated and this includes revisions to the Critical
Drainage Areas. The review is scheduled to be completed in 2018 and
ECC would welcome the opportunity to work with RDC and to provide this
additional information to inform preparation of the Local Plan, in particular
the emerging spatial strategy and the assessment of site allocations.

Paragraph 8.50 In respect of the reference to below and above ground SUDS features,
ECC's requires priority to be given to the provision of above ground
SUDS features (with the exception of soakaways) and that below ground
SUDS features should only be considered acceptable, if it is
demonstrated that above ground SUDS features are not viable. In all
cases ECC would require any features to provide acceptable levels of
water quality treatment/ storage requirements

Paragraph 8.50 & 8.51 ECC welcomes and supports the use of SUDS to alleviate flooding and that it should be incorporated in to new developments, domestic and
commercial. SUDS can provide great opportunity to improve our
environment and, linked with Green Infrastructure, could create a more
balanced and natural ecology in our communities. SUDS can help meet
the growing demands to deliver GI by creating green open spaces which
encourage biodiversity, habitats, wildlife corridors and health and
wellbeing.

Paragraph 8.51 ECC recommend that the emphasis of the statements within this
paragraph are changed, to encourage SUDS on all new developments,
including minor developments, and should not be limited to the major
developments which are subject to statutory consultation with ECC as the
LLFA.

ECC recommend that the last sentence in this paragraph should be
changed to reflect the overall requirements and application of SUDS
design principles, to read as follows:

"In some instances, financial contributions could be sought to improve
surface water drainage infrastructure through a standard CIL charge for
example (considered in detail below)."

Further information is available within the ECC Sustainable Drainage
Systems Design Guide (2016) and ECC will work with RDC on this matter
in the preparation of the Local Plan.

Paragraph 8.53 ECC welcome the positive consideration and approach to locate
development, within the lower flood risk areas, whilst taking into account
climate change, the vulnerability of future uses to flood risk and the impact
on water supply from a changing climate.
ECC recommend that reference is made to the Environment Agency's
revised climate change allowances, further details are available here:
https://www.gov.uk/guidance/flood-risk-assessments-climate-changeallowances

Paragraph 8.56 ECC recommends that new developments should be supported by
infiltration and groundwater testing. Further details are set out within the
ECC Sustainable Drainage Systems Design Guide (2016).

Paragraph 8.58 Options identified to minimise flood risk:
A. Retain the existing flood risk policy for coastal flooding
B. Revise Core Strategy policy ENV3
C. Continue to apply SUDS policies
D. Do not have a policy on flood risk

ECC Comments

ECC would expect RDC to develop a combination of options A-C based on evidence and in accordance with national policy including the NPPF.

ECC will engage with RDC on an ongoing basis in the preparation of the Local Plan to ensure it is based on the most up to date Guidance and evidence including the ECC SUDS guide, the revised South Essex Surface Water Management Plan, as well as the latest EA climate change allowances.
ECC does not support Option D for the reasons stated in the justification, it is considered contrary to national policy (including paragraphs 99-108).

SP3.5 Renewable Energy Generation

Paragraph 8.62 ECC note and support the reference to the Rayleigh Town Centre Air Quality Action Plan (AQAP) in respect of the need to explore different measures including for example provision for electric vehicles (Electric Charging Points).

Paragraph 8.64 & 8.65 ECC welcome the recognition of the need for charging points in urban centre car parks. ECC is currently preparing a strategy for Electric Vehicles and would welcome the opportunity to work with RDC, including on the need for new policies to promote the provision of Electric Charging Points for new domestic and commercial developments (see paragraphs 8.22-8.37 above). This is required to support the need for this new infrastructure with a variety of Electric Charging Points required to meet the anticipated grown in Electric Vehicles, which could not be solely met by urban car parks.

Paragraph 8.66 Options identified to support renewable energy provision within the district:
A. Retain the current policies on renewable energy
B. Include a specific policy on electric vehicle charging points
C. Do not have a policy on renewable energy

ECC Comments

ECC does not consider these options to be mutually exclusive and would expect
RDC develop a combination options A & B based on evidence and in accordance with the NPPF and other national policy.

In respect of Options A and B, ECC would support a review of the current policies and amendments to ensure they are in accordance with the most up to date evidence (including developments in technology) and national policy and guidance.

ECC consider the policy should be amended to include the provision for Electric Vehicles Charging Points. ECC would welcome the opportunity to explore these requirements further with RDC in the preparation of the local plan, including the policies and infrastructure requirements for the provision of Electric Charging Points, and consideration given to engaging the key stakeholders.

ECC does not support Option C for the reasons stated in the justification, it is considered contrary to national policy and the Essex Local Transport Plan, supporting evidence and the emerging vision for the Local Plan.

SP3.6 Planning Obligations and Standard Charges;

Paragraph 8.73 ECC welcome the reference to and identification of the issues raised in respect of the delivery of infrastructure provision associated with a large number of small sites, as set out in ECC's earlier comments in response to paragraph 6.48 (options to provide a realistic strategy for delivering homes).

ECC a statutory authority responsible for the provision of specific infrastructure in support of communities and the preparation of Local Plans, would wish to engage with RDC on an ongoing basis in the preparation of the Local Plan and Spatial Strategy, especially as the Local Plan progresses to consider specific sites and spatial strategy. ECC can also provide details of our policies, strategies, guidance and standards in respect of the delivery of specific infrastructure and the respective levels of growth required, for example:
 the ECC Developers' Guide to Infrastructure Contributions (2016); and
 the Essex County Council Local and Neighbourhood Planners' Guide to School Organisation (2018).

Please be advised that the latter Guide includes changes and updates to ECC's policy for the minimum size and land requirements for new primary and secondary school provision, please also refer to Section 8 below.

ECC can confirm that the issues do arise and that, subject to the scale of development, small schemes may not bring the level of investment required. In essence this reflects the "critical mass" in the scale of development required to enable effective infrastructure and service planning, which it may not be possible to secure with a number of smaller developments given the effect of the CIL Regs (Regulation 123) and restrictions on the pooling of contributions.

Paragraph 8.75 Options for planning obligations and standard charges:
A. Retain the existing policy and provisions in current local plan policy
B. Do not have a policy on planning obligations and standard charges

ECC Comments

ECC would expect RDC to prepare a policy for planning and obligations and standard charge, based on evidence and in accordance with the NPPF.

ECC considers there to be a requirement to retain an appropriate and up to date policy for securing the necessary Planning Obligations and Standard Charges in accordance with the NPPF, the Planning Practice Guidance, the forthcoming changes in national policy on this matter, and the ECC Developers' Guide to Infrastructure Contributions and the recommended 'Infrastructure delivery and impact mitigation' policy set out in Appendix B to the Essex County Council Local and Neighbourhood Planners' Guide to School Organisation (2018). With reference to ECC comments in response to paragraph 6.48 and 8.74 above, the principle of "pooling" restrictions and applying standard charges to smaller sites is not sufficient to meet the substantial levels of investment required to enable the provision of the appropriate infrastructure.

ECC therefore recommends that RDC's existing planning t policy is amended to take into account the latest material considerations and that RDC uses the best practice policy for "Infrastructure delivery and impact mitigation policy' (referred to above) to deal with pooled contributions, and to list any on-site facilities (new schools or extra land to expand existing schools) within the individual housing allocation policies. It is necessary to separately designate land to be allocated for Education use as D1 use class. This is considered necessary to avoid residential hope value being attributed to school land as part of any development viability assessment.

ECC recommends that the use of the best practice policy approach, referred to above is applied to the provision of other specific infrastructure, as outlined in ECC Developers' Guide to Infrastructure Contributions (2016).

ECC would welcome the opportunity to work with RDC on an ongoing basis to develop an effective approach through the preparation of the Local Plan.

SUPPORTING HEALTH, COMMUNITY AND CULTURE (SECTION 9)

SP4.1 Health and Well-being;

ECC welcomes and strongly supports the approach taken by RDC regarding health within this section. ECC considers the approach to be very positive towards Public Health and the wider issues of health have been considered and the promotion of Public Health with reference to the NPPF. ECC would welcome the opportunity to work with RDC in the development of this policy in conjunction with their planning and Health and Wellbeing team; and can provide advice on a range of supporting evidence and good practice available to inform the preparation of the local plan. This includes:
 FEAT tool (http://www.feat-tool.org.uk/), which allows authorities identify the various types of food retailers within their districts, including A5, fast food retailers.
 RTPI dementia friendly practice guidance- http://www.rtpi.org.uk/knowledge/practice/dementia-and-town-planning/
 Sports England Active Design- https://www.sportengland.org/media/3426/spe003-active-design-published-october-2015-email-2.pdf
 Public Health England - Health profiles- https://fingertips.phe.org.uk/profile/health-profiles
Paragraph 9.11 Options to promote health and wellbeing:
A. Retain the existing policy in current local plan policy
B. Ensure that land is specifically for healthcare
C. No policy on healthcare needs
D. Build on the existing healthcare policy to address wider health and well-being issues

ECC Comments

ECC would expect RDC to develop a combination of options based on evidence and in accordance with the NPPF.

ECC as a lead advisor for Public Health will engage with RDC on an ongoing basis in the preparation of the Local Plan and Spatial Strategy, especially as the Local Plan progresses to consider specific sites and spatial strategy. ECC can also provide details of its policies, strategies, guidance and standards in respect of the delivery of specific infrastructure and the respective levels of growth required.

In respect of Option D, ECC is supportive of this approach to refresh and build upon the existing health and wellbeing policy and ECC Public Health would welcome the opportunity to work with RDC in the development of this policy in conjunction with their planning and Health and Wellbeing teams.

ECC considers this approach should include greater recognition of the role of the natural environment and Green Infrastructure within the communities' health and wellbeing, including opportunities in preventing and treating ill health, as well as promoting wellness, including greater access and use of green space

ECC does not support Option C, for the reasons stated within the justification, it is considered contrary to national policy, the emerging vision for the Local Plan, ECC's vision for Essex and the revised EDG.

SP4.2 Community Facilities;

Paragraph 9.15 Options for Community Facilities:
A. Retain the existing policy in current local plan policy
B. Strengthen provisions in the existing policy
C. No policy on community facilities

ECC would expect RDC to prepare a policy option based on evidence and in accordance with the NPPF.

ECC would anticipate the provision of a range of community infrastructure in support of Local Plans, would wish to engage with RDC on an ongoing basis in the preparation of the Local Plan and Spatial Strategy, especially as the Local Plan progresses to consider specific sites and spatial strategy. Further details are set out in Section 2B above and in response to Section 4 of the Issues and Options Report.
In terms of future provision, opportunities for the co-location of services and maximising the use of existing buildings will be encouraged, to respond to the increasingly integrated models of service provision and provision for multi-purpose facilities. There is increasing emphasis on the integration of other form of community infrastructure, such as libraries and community spaces.

New provision is therefore likely to be in the form of a co-located community hub/library. This will be dependent on the level of population growth and the demographic of that population, along with the service requirements of future library provision. It is therefore likely that new provision could be made at some of the larger growth locations, particularly if there is a need for other community facilities, e.g. health centres, community halls etc. However, at this stage it is not possible to identify specific needs or costs of provision. It is not possible to identify specific needs or costs at this stage. Co-location may be something that should be encouraged but this would be more of a policy focus, possibly through a masterplanning approach, for the new development.

Funding will need to come from developer contributions and will be delivered through the masterplanning of new development sites.

ECC does not support Option C for the reasons stated in the justification, it is considered contrary to national policy, the emerging vision and objectives of the draft local plan and would not enable the necessary infrastructure to be appropriately planned for and delivered to meet the needs of the local community (residents and businesses).

SP4.3 Education and Skills;

ECC note the scope of Strategic Priority 4.3 (this section) mainly concerns Educational facilities; however there is no acknowledgement of or reference to the provision and requirements for Special Education Needs, either within schools or the wider community. ECC recommends that this is addressed, to consider and demonstrate the needs of the residents and the contribution that it can make. ECC welcome the opportunity to work with RDC to explore this further and can provide additional information on ECC's policies, strategies and evidence in respect of the requirements for this service, to be taken into account in the preparation of the Local Plan.

Paragraph 9.17 ECC welcomes the references within this paragraph, however the reference to "Nursery Education" should be changed to "EYCC provision" and this change should be incorporated throughout the document. Equally the reference to the need to ensure that there is sufficient capacity within "schools" should be amended to specifically refer to "EYCC provision" in addition to schools

Paragraph 9.22 & 9.27 ECC advises that the Essex Employment and Skills Board (ESB), through its 2017-18 Evidence Base, has identified seven priority sectors for Greater Essex including: construction, logistics, advanced manufacturing and engineering, IT/digital, healthcare and finance and insurance. To address shortages in these areas the ESB works in partnership with skills training providers, employers and other partners to offer an Education and Industry, Science, Technology, Engineering and Maths programme, to all secondary schools. These taster day opportunities, open to the District's schools would complement the District's Career Taster Days and continue to promote apprenticeships and access to skills and training. ECC welcomes the opportunity to explore this further with RDC in the preparation of the Local Plan.

Paragraph 9.23 ECC would like to advise RDC that it is in the process of updating the referenced ECC Developers' Guide to Infrastructure Contributions (2016), to include planning obligations and standard charges for contributions to support the full range of post-16 provision, where need is sufficiently evidenced. This is as a result of students 16-18 being required to stay in some form of education or training. This would support workforces, support apprenticeships and work with local colleges to address identified skills gaps. This also reflects ECC's overarching Lifelong Learning Strategy 2014 - 2018 and supporting strategies

Paragraph 9.26 ECC requests that the references to the scale of residential development that would generate the need for a viable new school are updated, to reflect section 2.2 of the recently published Essex County Council Local and Neighbourhood Planners' Guide to School Organisation (the Planners Guide) i.e. circa 1,400 houses for a 2 form entry primary school and 4,500 houses for a 6 form entry secondary school.

ECC's School Organisation Team welcomes the opportunity to assist in the preparation of the Local Plan and the next stage will be for ECC to 'scenario test' the preferred option to identify the education infrastructure required to mitigate the cumulative impact of allocations and permitted development.

Paragraph 9.27 Please refer to ECC's comments in paragraph 9.22 above, ECC would welcome the opportunity to explore this further with RDC in the preparation of the Local Plan.

Paragraph 9.29 Options identified to plan for education and skills development in the future:

A. Retain the current policies on schools provision
B. Ensure that land is specifically allocated for schools
C. Do not have a policy on meeting education needs
D. Update the current employment growth policy on skills and continue to support skills development through a skills training academy
E. Promote apprenticeships through planning

ECC Comments

ECC does not consider these options to be mutually exclusive. ECC would expect RDC to develop a combination of the options based on evidence and in accordance with the NPPF.

In respect of this section and the range of Options, ECC recommends that they are expanded to explicitly incorporate the requirements and provision of Special Education Needs within schools and the wider community. ECC welcomes the opportunity to work with RDC on an ongoing basis to ensure this is addressed in the development of the Local Plan, in accordance with ECC's overarching Lifelong Learning Strategy 2014 - 2018 and supporting strategies, which include the provision of services from pre-birth to 24 for children with Special Educational Needs or Disabilities.
Further details are also available within
 Essex Early Years and Childcare Strategy 2015-2018;
 ECC Local and Neighborhood Planners' Guide to School Organisation; and the
 ECC Developers' Guide to Infrastructure Contributions (2016).
In respect of Options A and B, ECC does not consider there to be a need for separate education infrastructure policies as before. ECC recommends that RDC uses the best practice policy set out in Appendix B to the ECC Local and Neighborhood Planners' Guide to School Organisation, as set out in response to SP3.6 and paragraphs 8.73 and 8.75 above)regarding an appropriate and effective approach to pooled contributions, and to list any on-site facilities (new schools or extra land to expand existing schools) within the individual housing allocation policies.

It is necessary to separately designate land to be allocated for Education use as D1 use class. This is considered necessary to avoid residential hope value being attributed to school land as part of any development viability assessment.

In respect of Option C, ECC does not support this approach for the reasons stated in justification, it is considered contrary to the emerging vision and strategic objectives of the draft local plan, to national policy and would fail to comply with "Duty to Co-operate" in the preparation of a sound, legally compliant and deliverable local plan, as it would not enable the necessary educational infrastructure to be appropriately planned for and delivered to meet the needs of the local community (residents and businesses).

In respect of Option D, ECC recommends the current employment growth policy on skills and supporting skills development are amended and based upon the most up to date evidence and strategies, to determine the requirements for the future. For example ECC would wish to reserve the position on the proposal for construction of a specific academy; ECC recommends further investigation of the skills system is required to ensure it more closely reflects the needs (both now and emerging) of current and new employers. ECC would wish to engage and work with RDC on these matters including the need to address the social determinants of health.

In respect of Option E, ECC welcomes and is supportive of the approach to using development as a way of supporting local apprenticeships. ECC is in the process of updating the referenced ECC Developers' Guide to Infrastructure Contributions (2016), to include planning obligations and standard charges for contributions to support the full range of post-16 provision, where need is sufficiently evidenced.
This is as a result of students 16-18 being required to stay in some form of education or training. This would support workforces, support apprenticeships and work with local colleges to address identified skills gaps. ECC would wish to engaged and work with RDC in the development of these matters in the preparation of the Local Plan, to ensure it reflects the latest evidence and strategies, including for example (but not limited to) ECC's overarching Lifelong Learning Strategy 2014 - 2018.

SP4.4 Early Years and Childcare Provision;

Paragraph 9.30 Overall ECC is generally supportive of the approach to EYCC, as presented, however please be advised that the ECC Strategy "Essex Early Years and Childcare Strategy 2015-2016 will be reviewed late 2018. ECC would welcome the opportunity to work with RDC on an ongoing basis to ensure the draft Local Plan is prepared based upon the most up to date ECC strategies and objectives as well as the latest EYCC sufficiency data, which is reviewed annually. ECC wishes to be engaged with the next stages of the Local Plan and the consideration of site allocations and their assessments to ensure full consideration is given to the opportunities and impacts on EYCC infrastructure requirements and delivery matters arising from both individual and cumulative site allocations.

Paragraph 9.31 ECC recommend that the emphasis and role of the EYCC service as referred to is changed to correctly reflect the role and provision of EYCC services, which is for every child to achieve a good level of development and best start in life, and not for parents employment. The provision of EYCC facilities is a key service which supports parents wishing to re-enter employment, continue with their current employment or to pursue further or higher education. Please refer to the Essex Early Years and Childcare Strategy 2015-2018 for further clarification, which includes ECC's vision that "Children in Essex get the best start in life to enable them to reach their full potential". The access to high quality education is one of the fundamental influences on the long term life chances of children living in Essex. Furthermore this strategy forms part of ECC's broader Lifelong Learning Strategy 2014 - 2018, for children from pre-birth to 19 and pre-birth to 24 for children with Special Education Needs or Disabilities.

Paragraph 9.32 ECC welcomes and supports the reference to the EYCC sufficiency data (at August 2016) presented within table 11, however please be advised that this data is monitored and updated on an annual basis, and more recent information is now available. ECC would welcome the opportunity to work with RDC on an ongoing basis as the draft Local Plan is prepared, to ensure it based upon the most up to date and relevant ECC strategies and objectives including this EYCC sufficiency data (as referred to in paragraph 9.30 above).

Paragraph 9.33 ECC recommends that all references to nursery education is changed to "Early Years and Childcare Provision". ECC notes the reference to "Childrens Centres" within the paragraph and can advise that the provision of these service had been changed is and is now call "Essex Child and Family Well-being Service" as set out in paragraph 9.35. ECC recommends that all references to "Childrens Centres" throughout the draft Plan are now changed to "Essex Child and Family Well-being Service". Further information and evidence is available on ECC's website as follows: http://www.essex.gov.uk/Education-Schools/Early-Years-Childcare/Pages/Children%E2%80%99s-centres.aspx

Paragraph 9.34 & 9.35 ECC recommends that the references to "PB" are changed to "pre-Birth" to provide the clarification on the nature of the services being provided.

Paragraph 9.36 Options Identified for the provision of early years and childcare facilities:

A. Retain the current policies on schools, early years and childcare
B. Ensure that land is specifically allocated for schools, early years and childcare
C. Do not have a policy on early years and childcare facilities
ECC Comments
ECC would anticipate the strategy for early years and childcare facilities to be developed with a combination of the options, based on evidence and in accordance with the NPPF

In respect of this section and the range of Options, ECC recommends that they are expanded to explicitly incorporate the requirements and provision of Special Education Needs within EYCC and the wider community. ECC welcomes the opportunity to work with RDC on an ongoing basis to ensure this is addressed in the development of the Local Plan, in accordance with ECC's overarching Lifelong Learning Strategy 2014 - 2018 and supporting strategies, which include the provision of services from pre-birth to 24 for children with Special Educational Needs or Disabilities.

Further details are also available within:
 Essex Early Years and Childcare Strategy 2015-2018;
 ECC Local and Neighborhood Planners' Guide to School Organisation and the
 ECC Developers' Guide to Infrastructure Contributions (2016)
In respect of Option A, ECC is supportive of a broad approach in respect of Education and EYCC to ensuring there is sufficient provision. There is however a need to ensure that the policies are updated to reflect current and future need for the community. ECC recommends that the following are taken into account:
 ECC's Essex Early Years and Childcare Strategy 2015-2018;
 the implementation of the Government's Extended Funding Entitlement offer (30 hours) introduced in September 2017;
 ECC's emerging strategy for the "Essex Child and Family Service",
 the most up to date EYCC Sufficiency Data; and
 the Infrastructure delivery requirements set out in ECC Developers' Guide to Infrastructure Contributions (2016).

ECC would welcome the opportunity to continue to work with RDC, to ensure the most-up to date and relevant Strategies, guidance and evidence is used to inform the broad policy approach as well as the wider preparation of the draft Local Plan.

In respect of Option B, ECC is supportive of this approach to ensure specific land is allocated for the provision of schools and EYCC facilities. ECC would welcome the opportunity to continue to engage with RDC on this matter, and draw your attention to the requirements of the ECC Developers' Guide to Infrastructure Contributions (2016), the ECC Local and Neighborhood Planners' Guide to School Organisation, as well as ECC's comments above to paragraph 9.36 and the Options identified to plan for education and skills development in the future.

ECC does not support Option C, for the reasons stated in the justification, it is considered contrary, national planning policy and would fail to comply with the "Duty to Co-operate" in the preparation of a sound, legally compliant and deliverable Local Plan, the emerging vision and objectives, and it would not enable EYCC and educational infrastructure to be appropriately planned for and delivered to meet the needs of the local community (residents and businesses).

SP4.5 Open Space and Outdoor Sports and Recreation

Paragraph 9.37 ECC welcomes and supports the provision of Open Space, Outdoor Sports and Recreation (both formal and informal) and supports the preparation of up to date evidence with the joint South Essex Playing Pitch Strategy, in co-operation with Active Essex, as well as the need to commission a new Open Space Study incorporating Green space and infrastructure.

ECC recommends further consideration is given to the wider role of and value of green space to support healthy communities including general landscape value, green infrastructure, biodiversity, green corridors and country parks for the provision of managed informal passive and active recreational space for all residents.

Paragraph 9.42 Options identified for open space, outdoor sports and recreation:
A. Retain, and where necessary update, the existing overarching policy on open spaces
B. Retain, and where necessary update, our current policy on existing open space
C. Retain, and where necessary update, our current policy on new open space
D. Retain, and where necessary update, our current policies
ECC would expect RDC to develop a combination of the options, based on evidence and in accordance with the NPPF.

ECC would expect this to include the South Essex Playing Pitch Strategy and the Open Space and Green Infrastructure Study to be commissioned) and in accordance with the NPPF and guidance, including the emerging EDG (to be published February 2018) and Sport England's Active Design Principles, to create and promote healthy communities.

ECC recommend that further consideration is given to connectivity investment and improvements between green spaces through the provision of green corridors and enhancement of existing and new Green Infrastructure, which would provide a number of key benefits. This includes
 Climate change adaptation and mitigation
 Health, wellbeing and social cohesion
 Economic growth and investment
 Wildlife and habitats

This would support the creation of stronger communities and these benefits could be achieved through good planning and management to ensure green space is supplied and maintained. ECC would wish to engage with RDC on an ongoing basis in the preparation of the Local Plan, especially as the plan progresses to consider specific sites and spatial strategy.

In respect of Option C, ECC recommends that the "Challenge" on how to deliver infrastructure to support new homes should also seek to incorporate new open space Suitable Accessible Natural Greenspace (SANG) as part of new residential developments to avoid recreational impacts on European sites. Further details on this aspect are incorporated within the revisions to the emerging EDG. ECC also consider that this approach and option is cross referenced to the challenges set out in paragraph 4.17 and the approach to Greenways in paragraph 10.29 (Option H).

SP4.6 Indoor Sports and Leisure Centres

Paragraph 9.50 Options to address the provision of the indoor sports and leisure centres:
A. Retain the existing policy
B. Do not have a policy on indoor sports and leisure centres

ECC Comments

ECC would expect RDC to develop a policy approach based on evidence and in accordance with the NPPF.

ECC support Option A, subject to the need for any amendment arising from the new / emerging evidence base.

ECC does not support Option B, for the reasons stated within justification, it is considered contrary to the NPPF and the emerging vision and strategic objectives of the draft local plan.

SP4.7 Facilities for Young People;

Please refer to ECC's comments in response to SP4.3 - 4.5 above regarding community facilities; Education and Skills; Open Space and Outdoor Sports and Recreation; and Indoor Sports and Leisure Centres.

ECC would welcome the opportunity to work with RDC to ensure the latest ECC policies; guidance and evidence are taken into account to inform the principles, strategies and specific policies within the emerging Local Plan, please also refer to the Revised EDG.

SP4.8 Play Space Facilities;

Please refer to ECC's comments in response to SP4.3 - 4.5 above regarding community facilities; Education and Skills; Open Space and Outdoor Sports and Recreation; and indoor sports and leisure centres.

ECC would welcome the opportunity to work with RDC to ensure the latest ECC policies; guidance and evidence are taken into account to inform the principles, strategies and specific policies within the emerging Local Plan, please also refer to the Revised EDG.

PROTECTING AND ENHANCING OUR ENVIRONMENT (SECTION 10)

Paragraph 10.1 Overall ECC welcomes the Strategic Priority SP5

ECC supports the inclusion and strategic priority 5 (and SO19) regarding conservation and enhancement of the natural environment, broadly in accordance with NPPF (paragraph 156). ECC recommends that the objectives should be further amended, to include policies which seek to minimise the impacts to biodiversity in accordance with NPPF paragraph 117, which sets out the need for planning policies to:
 plan for biodiversity at a landscape-scale across local authority boundaries;
 identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation;
 promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan;
 aim to prevent harm to geological conservation interests;

ECC recommends that this is developed under the Duty to Co-operate with neighbouring authorities to both identify the wildlife corridors and to implement them through planning policies.

ECC consider the following Acts, Strategies and Guidance to be relevant and recommends that these are taken into account and used as appropriate:
 NERC Act 2006 concerning biodiversity duties for public bodies;
 England Biodiversity Strategy 2020; Net Gain initiative;  DEFRA's biodiversity metric calculator; and
 Essex Biodiversity Validation Checklist.

SP5.1 Green Belt

Paragraphs 10.5 ECC notes and supports RDC's desire to protect the Green Belt,
10.15 whilst also seeking to meet the emerging vision and strategic objectives for the District, including the preparation of evidence incorporating a review of the Green Belt boundary for plan making purposes in accordance with the NPPF.
ECC supports this approach and welcomes the opportunity to work closely with RDC on this matter, in accordance with ECC's Full Council motion in December 2014 and 2017, to support the Essex District, Borough and City Councils which when developing their Local Plans, seek to protect Green belt sites from inappropriate development and to ensure that housing development cannot occur where there is insufficient infrastructural provision. ECC will not support Local (Development) Plans unless adequate resources are identified from developers, local councils and/or Government grants to ensure that sufficient infrastructure, including roads, schools, medical facilities, parking, sewerage and drainage, is provided in a timely manner and in a way that balances the needs to promote economic growth and provide housing for residents whilst protecting their quality of life.

In 2017 ECC called on the Secretary of State for Communities and Local Government to issue urgent statutory guidance, which removes the opportunity for this exploitation and protects valued greenfield sites from predatory development.'

Paragraph 10.16 Options in relation to the Green Belt:

A. Retain the existing policy on broad Green Belt principles in the Core Strategy
B. Amend the current Green Belt policy in the Core Strategy
C. Do not have a policy on the Green Belt

ECC Comments

ECC would expect RDC to develop a policy option based on evidence and in accordance with the NPPF. In respect of both Options A and B, ECC recommend a Review of the Green Belt boundary as part of the evidence base to inform the preparation of the Local Plan and its emerging spatial strategy, in accordance with NPPF (paragraphs 83-85), to set the framework for Green Belt and settlement policy.

ECC would welcome the opportunity to work with RDC to ensure the latest ECC policies; guidance and evidence are taken into account to inform the principles, strategies and specific policies within the emerging Local Plan.

ECC does not support Option C, for the reasons stated within the justification and would expect RDC to take any decision based on robust evidence and in accordance with the NPPF.

SP5.2 Biodiversity, Geology and Green Infrastructure

Paragraph 10.17 ECC welcomes the overall approach to protect and enhance the natural environment by RDC, including a review of the evidence base to ensure decisions are based upon the most up to date biodiversity and geodiversity information.

ECC recommends the inclusion and reference to the Outer Thames Estuary SPA within the list of European sites.

Paragraph 10.19 ECC note that Green Infrastructure (GI) is only referred to in its wider District context (see ECC comments to paragraph 6.4). However, due to the rural nature of the District, ECC considers localised GI design principles should be incorporated as part of a proposed housing development, specifically large developments such as Garden Communities and Urban Extensions. This would be in accordance with the NPPF and the Core Planning Principles and in particular paragraph 114 for conserving and enhancing the natural environment, by setting out the strategic approach within the Local Plans.

ECC recommends the principles in NPPF paragraph 114 are incorporated within Strategic Priority SP5.2 to protect, manage and enhance important habitats, nature conservation areas, geo-diversity and greenways.

Paragraph 10.20 ECC recommends Local Geodiversity/Geological Sites (LoGS) are added to the list of local sites. These are in addition to Local Wildlife sites (LoWS) and would be in accordance with NPPF paragraph 117.

Paragraph 10.21 As outlined above in response to Strategic Objective 12, ECC welcomes the reference to 'encouraging adherence to the waste hierarchy' and making 'best use of mineral deposits' but considers that these statements could be afforded slightly more clarity. Supporting the waste hierarchy and ensuring a sustainable use of minerals requires that existing facilities and infrastructure are safeguarded to ensure that they are able to continue to make their planned contribution to the mineral and waste strategies operating in the County. Whilst already covered by MLP Policy S8 and WLP Policy 2, it is considered beneficial for this to be incorporated into the Rochford LP objectives (see suggested change to Strategic Objective 12 above).

ECC welcomes and supports the reference to the requirement to safeguard mineral development recognised in paragraph 10.21 and consider the proposed modification to Strategic Objective12 to be in accordance with this recognition. However, it is noted that there is no similar recognition for waste facilities, which the proposed modification to Strategic Objective 12 would then cover.

Paragraph 10.22 ECC supports the approach outlined in this paragraph and polices DM25-DM27 which are considered to be in accordance with NPPF paragraph 118 to deliver biodiversity and the requirements of the NERC Act

Paragraph 10.26 ECC welcome and support the development of an Essex-wide strategy in respect of Recreational Disturbance Avoidance Mitigation Strategy, however note that this would mitigate for recreational disturbance impacts, in-combination with other plans and projects.

Paragraph 10.27 Options in relation to Biodiversity and Geodiversity in the district:
A. Retain or amend our current broad policy on sites of nature conservation importance
B. Do not have a policy on sites of nature conservation importance

Paragraph 10.28 Options identified to support and protect local habitats which have important ecological value:
C. Retain our current policy on trees and woodlands
D. Retain our current policy on other important landscape features
E. Retain our current policy on species and habitat protection
F. Update our current policy on Local Wildlife Sites
G. Condense and merge our current policies on nature conservation
Paragraph10.29 Options identified in relation to greenways in the district:
H. Retain our current policy on greenways
I. Do not have a policy on greenways

ECC Comments

Options A- I: ECC does not consider the options to be mutually exclusive. ECC would expect RDC to develop a combination of the options based on evidence and in accordance with the NPPF and guidance, whilst also having regard to the evidence presented in sections SP4.5 and 4.6 and ECC comments (see above).

ECC would wish to engage with RDC on an ongoing basis in the preparation of the Local Plan, especially as the plan progresses to consider specific sites and spatial strategy.

In respect of Option A, ECC welcomes and supports the proposal to commission a joint South Essex Open Space and Green Strategy, which shall subsequently inform this Local Plan. ECC also welcomes the importance assigned to nature conservation sites, the identification and enhancement of local wildlife/green corridors and networks to build biodiversity resilience to climate change allowing species dispersal within the urban landscape. These corridors will also provide a provision of greenways for walking and cycling; improve accessibility to green spaces and should have regard to the cycle network in the Rochford Cycling Action Plan.

ECC consider there to be the additional benefits including the health and wellbeing agenda, as well as improving the attractiveness of a place and potential to attract visitors and investment to the area.

In respect of Options C-G (local habitats) - Whilst ECC does not disagree with these options, consideration should be given to the preparation of one policy, incorporating all the policies referred to (within options C-G and ENV1). This would enable a holistic approach to be taken to our natural environment, with the elements considered as a "whole", within Option G.

In respect of Option G, if developed, ECC recommends that the policy is expanded to include "greenways" (please refer to ECC's comments in sections SP4.5 and 4.6 above in relation to open space and outdoor recreation and green infrastructure).
ECC supports Option H (Greenways), in principle, if it is not incorporated within Option G, as suggested above. ECC consider there to be a need to ensure "greenways" are captured, in accordance to NPPF, and having regard to the wider benefits as outlined above in respect of biodiversity; resilience to climate change, protecting the health of the green space, green infrastructure, open space, outdoor recreation, sustainable travel options and to promoting healthy communities.

ECC does not support Options B and I, for the reasons stated within their justifications, they are considered contrary to national policy and the emerging Local Plans strategy and vision.

SP5.3 Wallasea Island and the RSPB Wild Coast Project

Paragraph 10.34 Options identified for Wallasea Island and the RSPB's Wild Coast Project:
A. Retain the current policy which supports the Wallasea Island Wild Coast Project
B. Continue to support further development at Essex Marina as per current policy
C. Do not support further development at Essex Marina

ECC Comments

ECC would expect RDC to develop a policy approach for based on evidence and in accordance with the NPPF.

In respect of Option A, ECC would anticipate the strategy for Wallasea Island and the RSPB's Wild Coast project, to be developed with a combination of the options, based on evidence and in accordance with the NPPF including consideration for a project level HRA and appropriate mitigation for recreational disturbance.
ECC would recommend the need for a holistic approach within the context of the wider emerging spatial strategy, as well as the other emerging strategies in respect of open space, green space, nature conservation, rural diversification, tourism green infrastructure and sustainable travel. A balanced approach is considered necessary to both support the Wallasea project and improvements to accessibility, whilst ensure this would be sustainable with minimal ecological impact to ensure its survival and viability as a visitor destination.

In respect of Options B & C in relation to the Essex Marina, ECC would expect a policy approach to be developed based on evidence and in accordance with the NPPF.

SP5.4 Landscape Character;

Paragraph 10.35 ECC notes and welcomes inclusion of this section and the importance and use of Landscape Character Assessments as part of the baseline criteria for any development proposal. The principle of this approach is supported and should ensure the existing landscape elements are retained and that any new elements should enhance the overall landscape character.

Paragraph 10.44 Options identified for Landscape Character:
A. Retain the current policies on the Upper Roach Valley
B. Retain the current policies on the Coastal Protection Belt
C. Develop a broad policy on landscape character
D. Ensure consistency throughout Development Management Plan policies in relation to supporting development in appropriate landscape character areas and special landscapes.
E. Do not have a policy on landscape character

ECC Comments

ECC would anticipate a combination of the options A-D to be developed based upon evidence and in accordance with NPPF.

ECC does not support Option E for the reasons stated within the "justification", it is considered contrary to NPPF (paragraph156).

SP5.5 Protecting and Enhancing Heritage and Culture

Paragraph 10.45 ECC notes and welcomes the reference to the EDG, within this section and throughout the Issues and Options Report; however as this EDG is being revised and now includes sections such as Green infrastructure, Garden Communities and SUDS, which could form other key adoptable guidelines for future development.

ECC recommend that the new revised EDG is taken into account in the ongoing preparation of the draft Local Plan and ECC would welcome the opportunity to work with RDC on this matter.

SP5.6 Good Design and Building Efficiency

Paragraph 10.54 ECC recommend that this section is updated to reflect the updates and changes within the revised EDG 2018, which now specifically addresses health and wellbeing requirements. ECC can confirm that Sports England has been engaged with the revisions to the EDG, to include the Sport England - Active Design Principles 2015; which is supported by Public Health England and is consistent with the overall approach to health and wellbeing.

Paragraph 10.57 ECC recommend that a reference should be included to require the sustainable use of minerals in the construction of approved developments. This would be consistent with Strategic Objective 12 which aims to make best use of mineral resources, in accordance with the NPPF.

Paragraph 10.62 Options identified in relation to ensuring design principles are appropriate:
A. Retain the existing policies on design.
Ensure design policies make specific reference to Secured by Design, and the need to strike an appropriate balance between urban design and security.
C. Retain current guidance within our Supplementary Planning Documents.
D. Develop specific design principles for individual towns and villages building on the current guidance within our Supplementary Planning Documents.

ECC Comments

ECC would anticipate a combination of the options A-D to be developed based upon evidence and in accordance with NPPF.

ECC recommends the following Guidance and Evidence is also taken into account to inform the emerging Local Plan:
 The Revised EDG (to be published in February 2018)
 Sport England - Active Design Principles 2015 (which provide updates which specifically include health and well-being requirements and the creation of inclusive and active places. ECC can confirm that Sports England has been engaged with the revisions to the EDG, to include the; which is supported by Public Health England and is consistent with the overall approach to health and wellbeing.

In respect of Option A, ECC considered this option would need to be amended to take into account changes in national policy and guidance, including the removal of the Code for Sustainable Homes.

In respect of Option B, ECC consider the guidance within the Revised EDG to be applicable and relevant.

Paragraph 10.63 Options for building efficiency standards for new homes, and new commercial and industrial buildings.
E. Remove reference to the Code for Sustainable Homes and replace with a simpler policy on water efficiency.
F. Continue to drive up energy efficiency standards for new homes through replacing the Code for Sustainable Homes with one that focuses on energy, thermal and water efficiency in particular.
G. Do not have a policy on energy efficiency standards for new homes.
H. Retain existing policy on BREEAM.
I. Amend the existing policy on BREEAM to apply to only certain types of buildings.
J. Include a specific policy on the efficiency of conversions, extensions and alterations to existing homes.
K. Do not have a policy on energy efficiency standards for conversions, extensions and alterations to existing homes.

ECC Comments

ECC would anticipate a combination of the options E-F and H-J to be developed based upon evidence and in accordance with NPPF (paragraph 156).

In respect of Option E, whilst the removal of reference to the "Code for Sustainable Homes" would be appropriate, there would be a need to ensure an appropriate approach to water efficiency is developed, in accordance with the NPPF to address the broad principles being developed within the emerging vision, strategic objectives and spatial strategy (as outlined in Option C) and to incorporate the standard for energy efficiency within Option F to promote sustainable development, and resilience to climate change, in accordance with the NPPF.

In respect of Option J, this is supported by ECC and is considered to be consistent with best practice, for example the approach contained in Uttlesford District Council's Supplementary Planning Document on home extensions to reduce carbon dioxide emissions from existing building.

ECC does not support Options G & K, for the reasons stated within the respective justifications, they are it is considered contrary to the NPPF (paragraph 156) and the emerging vision and strategic objectives of the draft Local Plan.

SP5.7 Air Quality

Paragraph 10.64 ECC recommends that the scope and content of this section is expanded to include the latest national policy advice including the "National Air Quality Plan (2017)" published by DEFRA in July 2017, and the designation of the A127 to the east of Rayleigh Weir as an area having possible air quality issues.
Paragraph 10.69 ECC recommends inclusion and reference to the adoption of the AQMP for Rayleigh should be updated to say it was adopted in 2017 as this document has been issued after the date of adoption

Paragraph 10.72. Options in relation to Air Quality:

A. Retain the existing policies on air quality
B. Continue to promote clean air initiatives, such as sustainable ways to travel and renewable energy projects
C. Support, where appropriate, the actions put forward in the Rayleigh Town Centre Air Quality Action Plan
D. Do not have a policy on air quality
ECC Comments
ECC would anticipate a RDC to develop a combination of options, based on evidence and in accordance with the NPPF and DEFRA's National Air Quality Plan (2017), which specifically designates the A127 to the east of Rayleigh Weir as having possible air quality issues.

ECC recommends that consideration is also given to the use and role of wider sustainable development principles including green infrastructure, green spaces and green design principles to provide an opportunity to enhance the environment and support wider health.

ECC does not support Option D, for the reasons stated in the justification, it is considered contrary to NPPF (Paragraph 156), the National Air Quality Plan (Defra 2017) legislation, and the emerging vision and strategic objectives of the draft local plan.

DETAILED POLICY CONSIDERATIONS (SECTION 11)

ECC notes the majority of the issues identified within this section concern detailed matters, below the overarching strategic polices and principles addressed in the preceding sections of the ECC response to the Issues and Options consultation.
The principle of the approach is noted, however, ECC would anticipate all the themes and options to be developed, based on evidence and in accordance with the NPPF, taking into account the outcomes of the wider emerging spatial strategies and principles being developed within this Issues and Options consultation, as part of the preparation of the Local Plan.

In addition to the above, ECC can provide the following detailed comments on specific themes:

D.P1.1 Mix of Affordable Housing

Paragraph 11.5 Options to address the split between affordable housing products:
F. Retain the current affordable homes split (80% social and 20% intermediate) where a scheme meets the prescribed threshold
G. Amend the split taking into account any changes in national planning policy and guidance (if the definition of affordable homes is widened to include other products)
H. Do not have a prescribed split in a policy

ECC Comments

ECC would anticipate a RDC to develop a combination of options, based on evidence and in accordance with the NPPF

Please refer to ECC's comments in response to SP1.1 (see Paragraphs 6.30, 6.31 and 6.32) above which equally apply to this option; and in particular ECC's recommendations for consideration to be given to the provision of key worker homes through the affordable housing schemes, to support the needs of healthcare providers (see paragraph 6.31)

DP1.8 Options for development of Brownfield (Previously Developed) Land in the Green Belt in the future
A. Retain the current policy on previously developed land
B. Do not have a policy on previously developed land

ECC Comments

ECC would anticipate the approach to the development of Brownfield Land in the Green Belt, to be developed based on evidence and in accordance with the NPPF, as stated in ECC's response to SP5.1 and paragraph 10.16 regarding the policy approach to Green Belt, the need for a Review of the Green Belt Boundary.

ECC does not support Option B for the reasons stated within the justification, and it is considered contrary to the NPPF (paragraphs 79-92).

DP1.10 Parking standards and Traffic Management

Paragraph 11.57 Options identified for Parking and Traffic Management:
A. Retain our broad policy on parking standards and remove our Development Management Plan
B. Retain our current approach to traffic management
C. Do not have policies on parking and traffic management.

ECC Comments

ECC would expect RDC to develop a combination of options A and B, based on evidence and in accordance with the NPPF.

Please also refer to ECC's response to highway infrastructure (Section 8) regarding the Local and Strategic Highway Network and Sustainable Travel. There is a need for greater emphasis to be placed on an integrated package of transport solutions, which is applicable to Parking Standards and Traffic Management. Please also refer to ECC's earlier comments in Sections 6-8, regarding the development of sustainable communities, and in particular active design principles, promotion of healthy communities and the revised EDG to be applicable. This is necessary to ensure a holistic approach and consistency across the emerging vision and strategic objectives within the draft Local Plan.

In respect of Option B, this is partially supported by ECC, given the need to ensure that the policy is strengthened to provide an appropriate level of off street parking and to fully mitigate the impact of development (as set out in the traffic management plan), however there may be the potential to combine these options into one policy.

ECC would welcome the opportunity to explore this further with RDC as part of the preparation of the Local Plan.

ECC does not support Option C, for the reasons stated in the justification; it is considered contrary to NPPF (paragraph 156 & 157), the Essex LTP, EPOA's Parking Standards Design and Good Practice Guide; and the revised EDG.

D.P1.11 Home Businesses

Paragraph 11.61 Options to deal with home businesses:
A. Retain the current policy
B. Take a more restrictive approach to home businesses
C. Take a more flexible approach to home Businesses
D. Do not have a policy on home businesses

ECC Comments

ECC would expect RDC to develop a combination of the options A-C, based on evidence and in accordance with the NPPF.

In respect of Option C, ECC would support a more flexible approach to home businesses, taking into account the balances within this section and the inter-relationship and links to ECC's earlier comments regarding the ambition for communication infrastructure (improvements to broadband coverage and speed) as well as the need for "grow on space", to accommodate businesses as they become more successful and need more space from which to operate.

Further details on this are set out in ECC's response to meeting business needs (SP1.7 and paragraph 6.87); the options to support employment and economic growth (paragraphs 6.94 & 6.96); and Communication Infrastructure and the options to improve broadband coverage and speed including ultrafast broadband (SP3.3 and paragraphs 8.43 & 8.44).

ECC's considers there to be a need for a holistic approach and consistency across the emerging vision and strategic objectives within the draft Local Plan.

ECC does not support Option C for the reasons stated within the justification, it is considered contrary to the emerging vision and strategic objectives within the draft Local Plan.

DRAFT SUSTAINABILITY APPRAISAL

ECC consider the SA to be a good example of an initial Regulation 18 'Issues and Options' appraisal, exploring the sustainability considerations of a wide range of strategic options and assessing them to the same level of detail.
Whilst not a criticism of the SA, it is considered that the options explored surrounding OAN possibilities within the Plan could be expanded upon within the SA. The Plan, at Table 2 (South Essex Housing Market Area - OAN for new homes (Source: South Essex SHMA Addendum 2017)) indicates a range of between 331 and 361 homes per year. Although the upper and lower figures displayed are perhaps not distinctively different to warrant separate assessment within the SA under the Regulations, RDC may want the SA to consider assessing indicative higher and lower figures in future iterations. If felt necessary, this could also be expanded to assess reasonable spatial strategy options / permutations under different scenarios regarding levels of growth (i.e. at which level of growth would certain spatial strategy options be considered reasonable). Further, it may also be considered necessary to assess the figure included for the District in the recent DCLG consultation which set a standardised methodology for calculating housing needs. This is in consideration of the Plan being at an early stage of preparation and uncertainty as to what might be the District's OAN later on in the plan-making process.

ECC notes the reference throughout the SA and the Issues and Options Report, to 'a combination of options' and considers that whilst this may be a logical option in most cases, care needs to be taken as to what form a 'combined' policy would contain and aspire to.

ECC recommends that the "Climate Change" section should include a reference on whether the proposal will support the findings/priorities of the South Essex Surface Water Management Plan (2012 and emerging 2018 revision).

*THIS REPRESENTATION INCLUDES MAPS AND TABLES WHICH ARE CONTAINED WITHIN THE ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Great Wakering', Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Great Wakering from the Green Belt alongside the provision of a strategic
site-specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) and offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 considers the site, surroundings and suitability;
* Section 3 considers the strategic policy context;
* Section 4 outlines the District's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 summarises the relevant procedural considerations;
* Section 7 responds to specific questions raised by the consultation; and
* Section 8 sets out the case for exceptional circumstances and concludes the
report.

2. SITE, SURROUNDINGS AND SUITABILITY

2.1 The Site extends to approx. 127 acres / 51 hectares, located on the southern
edge of Great Wakering, as shown in Appendix 1.

2.2 The site is located in the south-east of the District, directly to the south of Great
Wakering. Southend Victoria Railway Station is located approximately 6.2km to
the west of the site; Southend Airport is located approximately 7.5km to the
north-west and the Essex coastline is located approximately 1.1km to the southeast
of the site as shown in Figure 1 below.

Figure 1: Land at Great Wakering in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.


Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, with intermittent trees and
hedgerows on all sides, with built form associated with Great Wakering, including
residential properties adjacent to the north, east and western boundaries. The
Great Wakering Primary School adjoins the north-western corner of the site and
an existing farm and associated buildings is located to the south and partially
dissects the site.

2.6 The site is bound by Poynters Lane to the south and Shoebury Road to the east,
with the built extent of North Shoebury situated approximately 600m to the west
and Shoeburyness approx. 425m to the south.

Site Deliverability
2.7 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

2.8 Table 1 below provides a summary of the site's suitability to accommodate
development, indicating the local planning policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Residential and community land uses to the
north, east and west;
Agricultural (arable) land to the south.
Flood Zone Primarily located in Flood Zone 1 (lowest probability) with a small area of the site within Flood Zone 2 & 3 in the south-east corner. Given the size of the overall site, it is envisaged that any future scheme can be designed around this and provide suitable flood risk mitigation.
Public Rights of Way Yes
A single PROW runs through the centre of the site in a north-south direction.
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape
Character Area No
Contamination No
Conservation Area No
The Great Wakering Conservation Area is located 100m to the north of the site beyond intervening existing residential properties
Listed Buildings No
The Great Wakering Conservation Area (approx. 100m to the north) contains a number of Listed Buildings
Area of Archaeological Importance /
Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No
The Foulness Coast SSSI is located approx. 400m to the south-east at the closest point
SSSI Impact Risk Zone Yes
Associated with the Foulness Coast SSSI
National / Local Nature Reserve No
RAMSAR Site No
The Foulness Coast RAMSAR is located approx. 400m to the south-east at the closest point
Special Area of Conservation No
The Essex Estuaries SAC is located approx. 1km to the south-east at the closest point
Special Protection Area No
The Foulness Coast SPA is located approx. 400m to the south-east at the closest point
Site of Nature Conservation Importance No
Ancient Woodland No
Sustainability The site is located directly adjacent to Great Wakering which is identified as a Second Tier Settlement within the adopted Core Strategy
(2011), which benefits from a reasonable range of social and community infrastructure (services and facilities) and access to public transport. Accordingly, Great Wakering is considered to be a reasonably sustainable location suitable to
accommodate additional growth to meet identified housing needs and ensure the future vitality and viability of the town and associated community services.

2.9 As demonstrated in Table 1 above, the site is therefore identified as suitable for
development with no insurmountable physical, technical or environmental
constraints to development.

Site Availability

2.10 The site is under single freehold ownership and comprises open arable
agricultural land on the southern edge of Great Wakering.

2.11 There are no legal constraints to the availability of the land for development.

2.12 The landowner is willing to make the site available for development and Taylor
Wimpey (a national housebuilder) is actively promoting the site through the
emerging Local Plan.

2.13 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available for development within the emerging
Plan period.

Site Viability

2.14 The site comprises open arable agricultural land (i.e. Greenfield Land) and whilst appropriate mitigation will be required to address potential flood risk and
ecological considerations, it is not anticipated that there will be any abnormal
costs associated with the development of this site as may be expected on
previously developed (brownfield) land.

2.15 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Development Vision

2.16 Taking into account the characteristics of the site, it is envisaged that a suitable
and deliverable development can be accommodated at the site without reducing the 'gap' in built-form between Great Wakering and North Shoebury/Shoeburyness to the south and west and allowing for suitable flood mitigation and ecological measures to the south-east.

2.17 The promotion of this site assumes that 60% of the site (approx. 30.6ha) will be developable at an average density of 35 dwellings per hectare, equating to a total
potential yield of circa 1,100 new homes.

Conclusions - Implications for the New Local Plan
* The site is suitable for residential development with no insurmountable
environmental, technical or social infrastructure constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in years 2020-2036)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing
3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt
3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.
3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional circumstances', through the preparation of the Local Plan. At such time, LPAs should consider Green Belt boundaries having regard to their intended
permanence in the long term, so that they should be capable of enduring beyond
the Plan period (paragraph 83). The implication of this criteria being that where
significant development pressure exists and exceptional circumstances are
warranted to develop in the Green Belt, it is considered appropriate for LPAs to
seek to remove such sites from the Green Belt through the Local Plan-making
process in order that they can deliver sustainable development to meet their
identified development needs.

3.10 The Government's consultation on a Revised NPPF (March 2018) seeks to define what constitutes 'exceptional circumstances' at paragraphs 135 and 136 as
follows:

135. Once established, Green Belt boundaries should
only be altered in exceptional circumstances, through
the preparation or updating of plans. Strategic plans
should establish the need for any changes to Green Belt
boundaries, having regard to their intended permanence
in the long term, so they can endure beyond the plan
period. Where a need for changes to Green Belt
boundaries has been demonstrated through a strategic
plan, detailed amendments to those boundaries may be
made through local policies, including neighbourhood
plans.

136. Before concluding that exceptional circumstances
exist to justify changes to the Green Belt boundaries, the
strategic plan-making authority should have examined
fully all other reasonable options for meeting its
identified need for development. This will be assessed
through the examination of the plan, which will take into
account the preceding paragraph, and whether the
strategy:
a) makes as much use as possible of suitable brownfield
sites and underutilised land;
b) optimises the density of development, including
whether policies promote a significant uplift in minimum
density standards in town and city centres, and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring
authorities about whether they could accommodate
some of the identified need for development, as
demonstrated through the statement of common ground.

3.11 It is anticipated that the above definitions will be incorporated within a revised
NPPF to be published in Summer 2018.

3.12 The NPPF (2012) continues that when drawing up or reviewing Green Belt
boundaries, LPAs should take account of the need to promote sustainable
patterns of development (paragraph 84). Sustainable patterns of development
are not defined in policy. However, this is considered to relate to taking into
account a range of additional factors beyond the contribution towards Green Belt
purposes. These factors might include local development needs, public transport
availability and local highways capacity and accessibility to local services and
social infrastructure. With regard to sustainability, it is necessary to recognise
the wider and updated context of how sustainable development is defined in the
NPPF as set out in paragraph 7 whereby it should contribute towards social,
economic and environmental objectives.

3.13 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.14 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.15 In summary, the NPPF and anticipated revisions to the NPPF, supports the longstanding principles of Green Belt protection, whilst acknowledging that the
objectives of the planning system continue to evolve, reflecting current land use
pressures and social needs. The Government's priority is to deliver growth and
sustainable development through harmonising, wherever and whenever possible,
the social, economic and environmental processes that deliver sustainable places.
Policy also reinforces the plan-led system which gives planning authorities the
power to undertake Green Belt reviews to help inform the emerging spatial
strategies necessary in order to meet development needs. The role and function
of the Green Belt therefore needs to be considered within this overarching context
to assist in the delivery of sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 The following seeks to highlight the significant development needs within the
District and the associated need to bring forward suitable and sustainable Green
Belt sites in order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
(upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy.

4.8 RDC should carefully consider the significant social implications associated with
not meeting objectively assessed / identified needs, which in particular is likely to
exacerbate an increasing affordability problem for all sections of the community.
Not meeting objectively assessed needs is likely to increase pressure on RDC to
find affordable homes for young people and families and accommodation for an
ageing population whilst also making it harder for local businesses to find and
retain employees.

Supply

4.9 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.10 The NPPF requires (paragraphs 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.11 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.12 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.13 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.14 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.15 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.16 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.17 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible; however, it has indicated that it may not be able to meet all of its needs within its own boundary.

4.18 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas within the Borough. The Council's proposed New Local Plan (2016) sought
to meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.19 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Councils and accordingly any flexibility in housing supply in Chelmsford is likely to
be taken up by these authorities in the first instance.

4.20 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southend, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.21 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.22 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.23 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities' unmet housing needs and are facing their own significant challenges
in meeting identified needs.

4.24 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Great Wakering.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 The following therefore provides an assessment of the site's contribution towards
the purposes of the Green Belt in order that the potential 'harm' of its loss can be
appropriately considered.

Green Belt Purpose 1: To check the unrestricted sprawl of large built-up
areas

5.7 The original purpose of the Metropolitan Green Belt was to restrict the outward
expansion of Greater London. In this instance, Southend-on-Sea is also
considered to be a 'large built-up area' of interest.

5.8 The site is located beyond the relevant built-up areas and intervening
development (particularly on the site's western boundary) exists between the
areas of North Shoebury and Shoeburyness.

5.9 Accordingly, the site cannot be considered to contribute to a wider Green Belt
network that provides a strategic barrier against the outward sprawl of large
built-up areas.

5.10 It is therefore concluded that the site provides limited or no contribution to the
first Green Belt purpose.

Green Belt Purpose 2: To prevent neighbouring towns from merging

5.11 The site is located on the southern edge of Great Wakering and is bound by
intervening development on its western edge and by Poynters Lane to the south.

5.12 It is envisaged that a suitable development could be designed at this location to
ensure that the existing 'gap' between Great Wakering and North Shoebury and
Shoeburyness to the south and west is not reduced, with Poynters Lane ensuring
a long-term defensible boundary further to the south.

5.13 It is therefore concluded that the site is not capable of acting as a gap or break
between two or more definable settlements and therefore is not considered
capable of making any contribution to the Green Belt objection of preventing
neighbouring towns from merging.

Green Belt Purpose 3: To assist in safeguarding the countryside from
encroachment

5.14 The site is recognised to be a countryside location on the edge of Great Wakering and accordingly any development at this site will, by necessity, result in
encroachment on the countryside. However, it is important to consider a range of
factors including land and environmental designations, land uses and urbanising
features which may detract from the quality and function of the countryside at
this location.

5.15 The site is not subject to any statutory or local landscape or ecological
designations which might otherwise contribute towards the quality of the
countryside at this location. Accordingly, the 'quality' of the landscape is
considered to be of limited value.

5.16 Moreover, in terms of land uses, the site comprises an arable agricultural field
which is enclosed by the existing built extent of Great Wakering to the north, east
and west and Poynters Lane to the south. Accordingly, there is a strong
urbanising influence on this site detracting from the quality and function of the
countryside at this location.

5.17 As such, the site is enclosed on all sides by existing built form or significant urban infrastructure and is not considered to represent a contiguous element within the wider countryside due to its effective isolation by existing physical barriers and
urbanising features. Furthermore, the site's quality in terms of landscape and
ecological designations further detract from the 'value' of the countryside at this
location.

5.18 Accordingly, it is considered that the site is only capable of having a 'partial'
contribution to the third purpose of the Green Belt.

Green Belt Purpose 4: To preserve the setting and special character of
historic towns

5.19 This purpose of the Green Belt is to perform a 'girdle' role, as a green ring around historic settlements and/or to provide the landscape context to historic features that preserves historic setting by keeping land open.

5.20 The Great Wakering Conservation Area is bordered in all directions by existing
development that has grown around it as the settlement has expanded and as
such the setting of the Conservation Area and the heritage assets contained
therein is now predominantly within the wider setting of the settlement rather
than the surrounding countryside.

5.21 Accordingly, the site is not considered to play a strong role in complementing the setting or special character of the Conservation Area due to the presence of the
existing intervening development. It is therefore concluded that the site does not
contribute towards the preservation of the historic setting and special character of
Great Wakering.

5.22 Consequently, the site is not capable of contributing to the fourth purpose of the Green Belt.

Green Belt Purpose 5: To assist in urban regeneration, by encouraging
the recycling of derelict and other urban land

5.23 The objective of this purpose is to constrain the supply of development land in
order to encourage the recycling of previously developed sites which would not
otherwise be developed, and therefore assist in urban regeneration. This
objective can only be realised if there is a supply of derelict and other urban land
that is capable of being recycled and which is deliverable.

5.24 This purpose of the Green Belt is particularly difficult to quantify but ultimately
relies on a supply of suitable brownfield land to meet objectively assessed
housing needs. As set out in Section 4, this is not the case. Furthermore, it is
considered reasonable to assume that some of this brownfield land will likely be
subject to delivery constraints and therefore in practice is unlikely to come
forward in the short-term (whether or not this site is removed from the Green
Belt).

5.25 Accordingly, in the context of an insufficient supply of deliverable brownfield land to meet housing needs and the resulting requirement to identify suitable
alternative sites to accommodate growth, it is confirmed that in practice the
significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.26 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against these Green Belt purposes (as
summarised in Table 2 below), it is shown to only provide a limited contribution
to these stated purposes.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5) To assist in urban regeneration, by encouraging the
recycling of derelict and other urban land
Limited or no contribution

5.27 Accordingly, the value of this site to the Green Belt is therefore
considered to be limited and by virtue, any harm arising from its removal
from the Green Belt is also limited.

5.28 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. PROCEDURAL CONSIDERATIONS

6.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Great Wakering) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

6.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite its supposed permanence, the Green Belt can
be reviewed by Local Authorities through their Local Plan reviews (paragraph 83),
which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

6.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

6.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

6.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the
necessary certainty that the Local Authority can deliver the development required
to meet its needs and spatial objectives. Moreover, the exceptional circumstances
required to release the Green Belt in the first instance will likely not exist unless
the benefits associated with any development clearly outweigh the potential
harm. The inference being that the Green Belt will not usually be released unless
for development purposes. It is therefore considered that the removal of land
from the Green Belt and the subsequent allocation for an alternative land use are
intrinsically linked.

6.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

6.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

6.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

6.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period, which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

7. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

7.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

7.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

7.3 The consultation document suggests three options for meeting identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

7.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

7.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

7.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

7.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question 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?

7.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement.

7.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

7.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs, it is therefore
clear that no single 'approach' as identified by the consultation will be sufficient to
provide all the homes RDC needs in the next Local Plan period. As such, RDC will
need to consider a combination of delivery strategies to meet their identified
housing needs, including larger extensions to the residential areas.

7.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the
sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

7.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

7.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Great Wakering, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the District as a whole.

7.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

8. SUMMARY AND CONCLUSIONS

8.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Great Wakering, in response to the current Local Plan Issues & Options
consultation by RDC.

8.2 The purpose of these representations has been primarily to respond to questions
raised within the consultation in respect of the amount of growth required and the
distribution of development over the next Plan period, and seeks to set out the
case for a revision to the Green Belt boundary to remove Land at Great Wakering
from the Green Belt alongside the provision of a strategic site-specific policy that
allocates the site for residential development in the emerging Local Plan.

8.3 The site at Great Wakering is deliverable (suitable, available and viable) and
offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

8.4 These representations demonstrate that the promotion of Land at Great Wakering is not exclusive to any one particular 'spatial approach' as set out in the
consultation document and instead highlights the site's suitability to contribute
towards the District's housing needs in all circumstances (in line with the
sustainable development principles of the NPPF), and accordingly sets out the
following case for exceptional circumstances to justify a revision to the Green Belt
boundary:

i) The Strategic Policy Framework:
* Local Plans should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need.
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives.
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being.
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate that 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the
site is demonstrated to be suitable for release from the Green Belt
and capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

8.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Great Wakering to deliver approximately 1,100 muchneeded
and high-quality new homes consistent with the policies of the NPPF.

8.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

8.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure that a positive policy position for the
site is taken forward to deliver real benefits for the local community and the
District as a whole.

*THIS REPRESENTATION INCLUDES MAPS AND FIGURES, PROVIDED IN ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Hawkwell', to the south of Hockley in Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Hawkwell from the Green Belt alongside the provision of a strategic site specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) in the short-term and offers the opportunity to accommodate a highquality
development of approximately 400 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 describes the site and its surrounding context;
* Section 3 considers the strategic policy context;
* Section 4 outlines the Borough's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 considers the site's deliverability;
* Section 7 summarises the relevant procedural considerations;
* Section 8 responds to specific questions raised by the consultation;
* Section 9 summarises and concludes the report.

2. SITE AND SURROUNDINGS

2.1 The Site extends to approx. 22.7 hectares, with a potential developable area of
approx. 10.5 hectares, located on the southern edge of Hockley, to the west of
Main Road (B1013) and north of Gustedhall Lane, Hawkwell as shown in
Appendix 1.

2.2 The site is located in the south-west of the District, approximately 1.5km south of Hockley train station, approximately 7km north-west of Southend-on-Sea central
station, approximately 4.2km to the east of Rayleigh train station and
approximately 3km west of Rochford train station as shown in Figure 1 below.
Figure 1: Land at Hawkwell in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.

Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, bordered by existing trees and
hedgerows on all sides, with built form associated with Hawkwell village, including
residential properties, community uses (Belchamps Scout Activity Centre) and
commercial units located to the north and east and agricultural land to the south
and west.

2.6 The site is situated within the 'Upper Roach Valley' Landscape Character Area,
with Hockley Woods Site of Special Scientific Interest (SSSI), Local Nature
Reserve and Ancient Woodland located approximately 270m to the north-west
and Gustedhall Wood and Potash Wood (Ancient Woodlands) located
approximately 150m to the south and south-west and south-east respectively.

2.7 Table 1 below provides a summary of local policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Employment, residential and community land
uses to the north and east; Agricultural (arable) land to the south and west.
Flood Zone Flood Zone 1 (lowest probability)
Public Rights of Way Yes - PROW's run along the sites northern and western boundaries
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape Character Area Yes
Contamination No
Conservation Area No
Listed Buildings No (NB: Mount Bovers Grade II Listed Farmhouse is located on the site's north-western boundary and Sweynes Grade II Listed Farmhouse is located on the site's north-eastern boundary)
Area of Archaeological Importance / Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No (Hockley Wood SSSI located approx. 270m to the north-west
SSSI Impact Risk Zone Yes (associated with Hockley Wood SSSI
National / Local Nature Reserve No (Hockley Wood LNR located approx. 270m to
the north-west)
RAMSAR Site No
Special Area of Conservation No
Special Protection Area No
Site of Nature Conservation Importance No
Ancient Woodland No (NB: Hockley Wood, Gustedhall Wood and Potash Wood all located within close proximity)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing

3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

1 DCLG Housing White Paper (2017) 'Fixing our Broken Housing Market'

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt

3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.

3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional
circumstances', through the preparation of the Local Plan. At such time, LPAs
should consider Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the Plan period (paragraph 83). The implication of this criteria being that where significant development pressure exists and exceptional circumstances are warranted to develop in the Green Belt, it is considered appropriate for LPAs to seek to remove such sites from the Green Belt through the Local Plan-making process in order that they can deliver sustainable development to meet their identified development needs.

3.10 The Government's Housing White Paper (February 2017) acknowledges at
paragraphs 1.38 & 1.39 that the NPPF does not define what constitutes
exceptional circumstances and therefore proposes to amend and add to national
policy through a revised NNPF (anticipated to be published in Summer 2018) to
make clear that:
"Authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements, including:
* Making effective use of suitable brownfield sites and the opportunities offered by estate regeneration;
* The potential offered by land which is currently underused, including surplus public sector land where appropriate;
* Optimising the proposed density of development;
and
* Exploring whether other authorities can help to meet some of the identified development requirement"

3.11 The NPPF continues that when drawing up or reviewing Green Belt boundaries,
LPAs should take account of the need to promote sustainable patterns of
development (paragraph 84). Sustainable patterns of development are not
defined in policy. However, this is considered to relate to taking into account a
range of additional factors beyond the contribution towards Green Belt purposes.
These factors might include local development needs, public transport availability
and local highways capacity and accessibility to local services and social
infrastructure. With regard to sustainability, it is necessary to recognise the
wider and updated context of how sustainable development is defined in the NPPF
as set out in paragraph 7 whereby it should contribute towards social, economic
and environmental objectives.

3.12 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.13 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.14 In summary therefore, the NPPF supports the long-standing principles of Green
Belt protection, whilst acknowledging that the objectives of the planning system
continue to evolve, reflecting current land use pressures and social needs. The
Government's priority is to deliver growth and sustainable development through
harmonising, wherever and whenever possible, the social, economic and
environmental processes that deliver sustainable places. Policy also reinforces the
plan-led system which gives planning authorities the power to undertake Green
Belt reviews to help inform the emerging spatial strategies necessary in order to
meet development needs. The role and function of the Green Belt therefore needs
to be considered within this overarching context to assist in the delivery of
sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 In reference to the proposed 'case for development' outlined above, the following seeks to highlight the significant development needs within the District and the associated need to bring forward suitable and sustainable Green Belt sites in
order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
*upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per
annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy. RDC should carefully consider the significant social
implications associated with not meeting objectively assessed / identified needs,
which in particular is likely to exacerbate an increasing affordability problem for
all sections of the community. Not meeting objectively assessed needs is likely to
increase pressure on RDC to find affordable homes for young people and families
and accommodation for an ageing population whilst also making it harder for local
businesses to find and retain employees.

Supply

4.8 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.9 The NPPF requires (paragraph's 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.10 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.11 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.12 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.13 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.14 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.15 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.16 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible, however
it has indicated that it may not be able to meet all of its needs within its own
boundary.

4.17 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas with the Borough. The Council's proposed New Local Plan (2016) sought to
meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.18 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Council's and accordingly any flexibility in housing supply in Chelmsford is likely
to be taken up by these authorities in the first instance.

4.19 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southen, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.20 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.21 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities,
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.22 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities unmet housing needs and are facing their own significant challenges in
meeting identified needs.

4.23 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Hawkwell.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 Accordingly, Pegasus Group has undertaken an independent review of site's
contribution towards the purposes of the Green Belt as defined by the NPPF. The
full Appraisal is enclosed at Appendix 3 and summarised in Table 4 below.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5.7 The fifth purpose of the Green Belt ('to assist in urban regeneration, by
encouraging the recycling of derelict and other urban land') is to constrain the
supply of development land in order to encourage the recycling of previously
developed sites which would not otherwise be developed, and therefore assist in
urban regeneration. This objective is difficult to quantify but can only be realised
if there is a supply of derelict and other urban land that is capable of being
recycled and which is deliverable.

5.8 As highlighted in Section 4, the Council's evidence base highlights that there is an inherent shortfall of available and (unconstrained) land to meet identified housing
needs. Accordingly, in the context of an insufficient supply of deliverable
brownfield land to meet housing needs and the resulting requirement to identify
suitable alternative sites to accommodate growth, it is considered that in practice
the significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.9 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to
keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against the Green Belt purposes it is shown to
only provide a limited contribution to these stated purposes. Accordingly, the
value of this site to the Green Belt is therefore considered to be limited
and by virtue, any harm arising from its removal from the Green Belt is
also limited.

5.10 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

5.11 Moreover, the analysis enclosed at Appendix 3 provides a robust 'Green Belt &
Landscape Strategy' for the site to ensure appropriate mitigation is inherently
designed into any future development to protect and preserve the sites interface
with the settlement and wider Green Belt and Upper Roach Valley setting as
explained further in Section 6 below.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. SITE DELIVERABILITY AND DEVELOPMENT VISION

6.1 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

6.2 The following therefore provides a 'high-level' review of the deliverability of Land
at Hawkwell.

Site Suitability

Access and Highways

6.3 These representations are supported by an assessment of local highways and
access constraints and opportunities enclosed at Appendix 4.

6.4 The accompanying evidence provides a review of RDC's latest Local Plan evidence base, an overview of sustainability matters and identifies a potential access
arrangement.

6.5 The accompanying report concludes that:
* The site is within a good range of a number of local services and facilities,
including Hockley Railway Station for long distance journeys;
* Local travel characteristics indicates that existing residents in the vicinity of
the site have the highest public transport and lowest private car use for
commuting patterns in the district - a pattern considered likely to reflect that
of any future residents at the site;
* That suitable and safe access can be designed to enable vehicular and
pedestrian/cyclist access in accordance with local guidance; and
* The development of the site for approximately 400 dwellings would equate to
just circa three additional vehicles per minute on the highway network.
* The site could provide a suitable package of off-site highways improvements
commensurate with the impact of the scheme to further enhance the
accessibility of the site and promote opportunities for sustainable travel.

6.6 Accordingly, there are no insurmountable highways and access constraints at the
site, which is considered to present a significant opportunity to contribute towards
RDC's sustainable transport objectives.

Landscape and Townscape

6.7 The site is located within the Green Belt and the Upper Roach Valley Landscape
character area which seeks to protect a 'green lung' and landscapes of value
(noting it also aims to promote recreation).

6.8 The accompanying 'Landscape and Visual Analysis' (Appendix 3) considers the
constraints and opportunities at the site and proposes a robust landscape
strategy to demonstrate that the site can accommodate a sensitively designed
residential scheme with only limited landscape and visual effects at a localised
level and that such impacts can successfully be avoided or reduced through
appropriate mitigation.

6.9 Such an approach addresses the interface between the settlement edge and the
wider countryside and how this can influence prospective amendments to the
Green Belt boundary. The use of the existing landscape components to guide the
landscape strategy ensures a robust and enduring boundary to the Green Belt in
line with national policy and maintains the integrity of the wider Upper Roach
Valley.

6.10 Accordingly, the proposals would represent a limited landscape impact adjacent
to the existing urban fringe and presents a positive contribution in terms of
improved green infrastructure and recreational opportunities.

Flood Risk

6.11 The site is located within Flood Zone 1 (lowest risk) as defined by the
Environment Agency and is therefore sequentially preferable and considered
suitable in principle for residential development in flood risk terms.
6.12 Any future planning application at this site would need to be supported by a site specific flood risk assessment and surface water drainage strategy, incorporating
Sustainable Urban Drainage Systems (SUDS).

Ecology

6.13 The site is not subject to any statutory or local environmental / ecological
designations.

6.14 Hockley Woods Site of Special Scientific Interest (SSSI), Local Nature Reserve
and Ancient Woodland located approximately 270m to the north-west and
Gustedhall Wood and Potash Wood (Ancient Woodlands) located approximately
150m to the south and south-west and south-east respectively. Moreover, the
current agricultural land use of the site is considered to be of low ecological
value.

6.15 Accordingly, there are no ecological constraints at this site restricting future
delivery and development of the site will provide an opportunity to introduce
enhanced wildlife habitats and ecological corridors through the site to link the
Hockley Woods with surrounding Ancient Woodlands to improve the function of
the site as part of a wider Green Infrastructure Network.

Heritage
6.16 The site is not designated as a Conservation Area or Archaeological Site, nor does it contain any Listed Buildings or Scheduled Monuments.

6.17 Accordingly, the site is not constrained by any heritage assets and the site is not considered to be particularly sensitive to change from a heritage perspective.

Social Infrastructure

6.18 Hawkwell is identified as a 'first-tier' settlement within the adopted RDC Core
Strategy (2011), being grouped with Rochford, Ashingdon and Hockley and is
therefore considered to be one of the District's most sustainable settlements
benefiting from a range of local facilities and services, including:
* Bus Stops (Mount Bovers Lane) on site's north-eastern corner with regular
services to Hockley and Rayleigh;
* GP surgery and pharmacy (approx. 600m north-east);
* Dentists (approx. 750m north and 1.1km north-west);
* Westerings Primary Academy (approx. 400m north);
* Greensward Academy (approx. 1.7km north);
* Belchamps Scout Activity Centre (approx. 100m north);
* Clements Hall Leisure Centre (approx. 500m north-east)
* Hockley Train Station (approx. 1.5km north);

6.19 Hawkwell also benefits from its close proximity to Hockley which supports a good range of local retail and employment opportunities

6.20 Accordingly, Hawkwell is recognised to be one of the District's most sustainable
settlements that can comfortably cater for the day-to-day needs of the local
community and provide access to a range of other services including community,
recreational, education and health facilities and is therefore capable of
accommodating an additional sustainable level of development to ensure the
future vitality and viability of the town and associated community services.

6.21 It is noted in Section 9 of the Issues & Options document that there is a need /
requirement for an early years and childcare provision in Hawkwell. The site at
Hawkwell therefore provides an opportunity to address this through the provision
of a purpose-built facility.

Overall Site Suitability

6.22 The above assessment highlights the opportunity presented by the site to
contribute towards the District's housing needs at a sustainable location and
demonstrates that's there are no insurmountable physical, environmental or
technical constraints precluding the development of land at Hawkwell as
illustrated by the enclosed Constraints & Opportunities Plan at Appendix 5.

Development Vision

6.23 The site therefore presents a key opportunity to deliver the District's spatial and sustainable objectives over the next Plan period and the following 'development
vision' for the site has evolved following further detailed investigation into the
site's constraints and opportunities as set out above.

6.24 Accordingly, the Illustrative Development Framework enclosed at Appendix 6
incorporates the following key design principles in response to the detailed
investigations as set out within this report.

i) Development Vision:
* The Concept Design sets out our vision for the future of the site
(Land at Hawkwell) to deliver approx. 400 new homes and
associated public open space and green infrastructure
enhancements.
* There is also an opportunity to provide a purpose-built facility
for early years childcare should it be required, to meet any
identified need.

ii) Housing Principles:
* Opportunities to deliver a mix of dwelling types, tenures and
sizes on the site, including for first-time buyers, family,
affordable homes and older persons housing;
* The site therefore seeks to provide much needed new homes for
all sections of the community.

iii) Townscape Principles:
* Potential developable area of 12.1 hectares;
* Development density of approx. 35 dwellings per hectare to
optimise the capacity of Green Belt land whilst being
sympathetic to the site's surroundings, consistent with national
policy.

iv) Landscape Principles:
* Development Envelope:
o Restricted spatial extent of the development envelope
(to the eastern part of the wider site) to ensure that built form does not encroach on the higher parts of the site to the west, thus protecting the wider extent of the Upper Roach Valley and maintaining consistency with the existing prominent settlement edge;
o Maintain openness in the western part of the wider site area to provide a substantial and robust buffer to the wider Green Belt context;
o Reintroduction of some former landscape patterns;
o Restricted to the northern and southern edges to provide a stand-off to nearby visual receptors;
o Restricted to the eastern edge to provide a stand-off to the existing boundary vegetation;
o Development envelope to be divided by a proposed central 'greenway';
o Incorporation of a 'density strategy' to ensure the more sensitive areas on the western and southern edges of the site incorporate lower density and higher density directed to the least sensitive parts of the site;
* Existing Vegetation Strategy:
o Retain and enhance existing vegetation across the site wherever possible;
o Enhancement of existing vegetation, including appropriate management, replacement planting and new planting to reinforce boundaries and improve species
diversity;
* Green Infrastructure and open space:
o Inclusion of green corridors throughout the site, focused on providing suitable buffers to adjacent landscape components and visual receptors;
o Inclusion of pockets of green infrastructure and open space on the eastern edges of the site, forming the lower parts of the site these can complement the approach to SUDS and provide multi-functional landscape spaces;
o Provision of new public access routes through a network of open spaces across the site, but also as an integral part of the residential layout;
o Provision of new recreational access in the form of informal parkland' areas in the western part of the site;
o Incorporating a substantial 'greenway' through the core of the site, providing a green link (visual and physical) between Main Road and the wider countryside to the
west and having reference to historic field patterns - this area will also be an opportunity to create a high quality and multi-functional open space;
o A particular focus on green infrastructure creation on the western part of the site so as to deliver a robust physical green edge to the settlement that supports an enduring boundary to the Upper Roach Valley and to the Green Belt - this can include substantial woodland planting that will provide closer physical connectivity between areas of ancient woodland; and
o A strategy for landscape planting that will complement
and enhance the existing green infrastructure network,
including substantial hedgerows, tree belts and
woodlands to provide green infrastructure connectivity.
* Environmental Considerations:
o Where appropriate, utilising existing landscape features
to inform and guide the drainage strategy, including use
of existing drainage ditches and the lower parts of the
site to develop sustainable drainage patterns that can, in
turn, complement strategic landscape proposals;
o Approaches to existing vegetation and proposed green
infrastructure/open space include potential compatibility
with ecological and biodiversity objectives through
retaining and enhancing habitats as appropriate.
* Green Belt Considerations:
o Use of existing and proposed landscape elements and features to define a robust and enduring boundary to the Green Belt

v) Ecology Principles:
* Potential for significant ecological improvements (for species
and habitats) through new tree planting and creation of green
corridors through the site.

vi) Access and Movement Principles:
* Vehicular access to be provided via Main Road;
* Opportunity to link the development with existing Public Rights
of Way around the site.

6.25 The enclosed Development Framework Plan therefore represents a deliverable,
sympathetic and sustainable vision for the site, however it is envisaged that this
concept will evolve further through further site investigations and stakeholder
engagement and consultation.

Site Availability

6.26 The site is under single ownership and comprises an arable agricultural field on
the western edge of Hawkwell.

6.27 There are no legal constraints to the availability of the land for development and the landowner is willing to make the site available for development and is actively promoting the site through the emerging Local Plan.

6.28 The site is under option by Taylor Wimpey, one of the country's largest
housebuilders and accordingly the site is considered to be available for residential
development and the potential to provide a purpose-built facility for early years
childcare (if required).

6.29 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available, deliverable and suitable for
development in the early part of the new Local Plan period.

Site Viability

6.30 The site comprises a 'greenfield' agricultural site and accordingly it is not
anticipated that there will be any abnormal costs associated with the
development of this site as may be expected on previously developed
(brownfield) land.

6.31 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Conclusions - Implications for the New Local Plan

* The site is suitable for residential development with no insurmountable
environmental or technical constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
* The Development Framework represents a deliverable (suitable, available
and viable) and sustainable vision for the site that is 'landscape-led' and
responds sympathetically to its environment to demonstrate how the site
could be developed to deliver approx. 400 new homes, new Public Open
Space and Green Infrastructure; and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in the early part of the plan period
(subject to the removal of the Green Belt designation).

7. PROCEDURAL CONSIDERATIONS

7.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Hawkwell) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

7.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite their supposed permanence, the Green Belt
can be reviewed by Local Authorities through their Local Plan reviews (paragraph
83), which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

7.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

7.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

7.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the necessary certainty that the Local Authority can deliver the development required to meet its needs and spatial objectives. Moreover, the exceptional circumstances required to release the Green Belt in the first instance will likely not exist unless the benefits associated with any development clearly outweigh the potential harm. The inference being that the Green Belt will not usually be released unless for development purposes. It is therefore considered that the removal of land from the Green Belt and the subsequent allocation for an alternative land use are intrinsically linked.

7.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

7.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

7.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

7.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period , which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

8. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

8.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

8.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

8.3 The consultation document suggests three options for meet identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

8.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

8.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

8.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

8.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

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

8.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement

8.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

8.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs (as set out in
Section 4 above), it is therefore clear that no single 'approach' as identified by
the consultation will be sufficient to provide all the homes RDC needs in the next
Local Plan period. As such, RDC will need to consider a combination of delivery
strategies to meet their identified housing needs, including larger extensions to
the residential areas.

8.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

8.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

8.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Hawkwell, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the
District as a whole.

8.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Hawkwell is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

9. SUMMARY AND CONCLUSIONS

9.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Hawkwell, in response to the current Local Plan Issues & Options
consultation by RDC.

9.2 The purpose of these representations has been primarily to respond to questioned raised within the consultation in respect of the amount of growth required and the distribution of development over the next Plan period, and seeks to set out the case for a revision to the Green Belt boundary to remove Land at Hawkwell, from the Green Belt alongside the provision of a strategic site-specific policy that allocates the site for residential development in the emerging Local Plan.

9.3 The site at Hawkwell is deliverable (suitable, available and viable) in the shortterm and offers the opportunity to accommodate a high-quality development of
approximately 400 new homes.

9.4 These representations demonstrate that the promotion of Land at Hawkwell is not exclusive to any one particular 'spatial approach' as set out in the consultation
document and instead highlights the site's suitability to contribute towards the
District's housing needs in all circumstances (in line with the sustainable
development principles of the NPPF), and accordingly sets out the following case
for exceptional circumstances to justify a revision to the Green Belt boundary:

i) The Strategic Policy Framework:
* Local Plan's should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need;
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives;
and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Access and highways;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable; and
o Development Vision:
* Following detailed investigation into the site's
environmental and technical constraints and
opportunities, a deliverable and sustainable concept
has been developed that is 'landscape-led',
integrates sympathetically with its surroundings and
optimises the development potential of the site to
contribute towards RDC's significant housing needs.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate for 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Hawkwell is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and
capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

9.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Hawkwell to deliver approximately 400 much-needed and
high-quality new homes consistent with the policies of the NPPF.

9.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

9.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure a positive policy position for the site
is taken forward to deliver real benefits for the local community and the District
as a whole.