South Essex Picture

This seems to say that the other districts cannot fulfil their housing need and the duty to co-operate puts the emphasis on Rochford to support them in achieving their targets. More housing is unsustainable in the Rochford district anyway, so I would hope that the planning department evidence that we cannot serve as a building site for other councils.

4.16 'we are served by a number of strategic roads, including A130, A127 and A13, with capacity limitations and a constrained local road network.' How do we ensure that any new homes are supported by appropriate, timely and necessary infrastructure in terms of transport but also in terms of utilities, telecoms, open spaces, education, health, flood risk etc?

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.

ROCHFORD DISTRICT COUNCIL DRAFT LOCAL PLAN
ISSUES AND OPTIONS AND DRAFT SUSTAINABILITY APPRAISAL
CONSULTATION

Thank you for the opportunity to comment on the District Council's Draft Local Plan
Issues and Options and Draft Sustainability Appraisal documents.
I confirm that careful consideration has been given to these documents, and that the
responses in this letter have been considered and agreed by leading Members of the
Council.

I should be grateful if you could take the following comments into account as the
Borough Council's response to this consultation.

General Observations

The Borough Council notes that work on some of the evidence base which will inform
and support Rochford District Council's emerging Local Plan is still underway, some
of which has been commissioned jointly with other local planning authorities, including the Borough Council. It is to be hoped that the District Council continues this work with relevant stakeholders, to ensure that emerging policies are robust and sound.

Duty to Co-operate

The Borough Council welcomes the full, active and on-going engagement of the
District Council in South Essex "duty to co-operate" matters. It therefore requests that the District Council maintains this approach, and in particular its commitment to the Continued preparation of a joint strategic plan for South Essex, as agreed by the Association of South Essex Local Authorities, in addition to any work it considers appropriate or necessary for a new Rochford Local Plan.

Housing Need

Consideration has been given to the approach that the District Council has taken in determining its Objectively Assessed Need (OAN) for housing. It is clear from the evidence that the need identified within the Issues and Options Report reflects more up-to-date national household projections, as required by the Planning Practice Guidance, taking into account matters such as economic growth and the need for affordable housing, and is informed by an up-to-date Strategic Housing Market Assessment. The approach taken in considering housing need is therefore considered to be robust and satisfactory.
Furthermore, in relation to meeting its OAN, the Borough Council welcomes the District Council's commitment to take into account environmental and other constraints such as Green Belt, and improvements in infrastructure, as well as its commitment to work with neighbouring local planning authorities to ensure that the housing need across the South Essex Housing Market Area is effectively met. Overall, it would appear that the strategic approach to growth set out in SP1.1 of the Rochford Issues and Options consultation document, has been well considered and is robust.

SP1.7: Meeting Business Needs

The Borough Council welcomes the aim of the District Council to provide higher level employment, realising the economic potential of London Southend Airport, and enhancing the skills of the district's population. It also supports the need for continued broadband improvements and a requirement for grow-on space for local businesses in the district, as well as a specific reference to tourism and rural diversification in the current employment growth policy, to deliver local, rural job opportunities and promote rural economic growth. The Borough Council also welcomes the promotion of employment growth in the district, through highway improvements and sustainable transport options, in order to improve accessibility to local jobs.

SP3.1: Highways Infrastructure

The Borough Council requests that the District Council considers its relationships with neighbouring authorities carefully when allocating growth locations, as part of the transport modelling to support the Local Plan, and also within the Local Plan itself. Collaborative engagement and continual working between local planning authorities, the highway authority, and transport providers would help ensure that strategic transport links are capable of accommodating any additional transport pressures.

Draft Sustainability Appraisal of the Rochford Local Plan

The content of the Draft Sustainability Appraisal of the Rochford Local Plan has been reviewed, and it can be confirmed that there are no comments to be made on this occasion.

Thank you for the opportunity to reply to your consultation, and I hope that you will be able to take these comments into account.

Thank you for inviting Basildon Borough Council to provide comments as part of Rochford District Council's consultation on its Regulation 18 New Local Plan Issues and Options Document and Draft Sustainability Appraisal (SA) of the Rochford Local Plan 2017. Please accept this letter as the response of Basildon Borough Council to the consultation.

Rochford District Council is in the first stages of consultation on the review of their current Local Development Plan, to ensure that the policies are robust, effective and up-to-date, in accordance with the Planning and Compulsory Purchase Act 2004.
Basildon Borough Council acknowledges that this is the first stage of consultation on the new Local Plan for Rochford, and that a number of issues and options are being considered. It is acknowledged that the Local Plan consultation document does not identify specific sites, and that more detailed planning policies will evolve as each consultation stage on the new Local Plan progresses. In view of this, Basildon Borough Council has considered the consultation documentation, its role as a neighbouring planning authority, and strategic and cross boundary matters which are covered by the Duty to Cooperate, and wishes to make a series of observations which Rochford should take into consideration when it prepares the draft version of its Local Plan.

SP1.1: Objectively Assessed Need (OAN)

Consideration has been given to the approach Rochford District Council has taken in determining its OAN for housing. It is clear from the evidence that the need identified within the Rochford District Issues and Options Report reflects more up-to-date national household projections, as required by the Planning Practice Guidance (PPG), taking into account matters such as economic growth and the need for affordable housing, and is informed by an up-to-date SHMA. A robust approach has been taken in considering the housing need within Rochford district, and no objection is being raised as to how the OAN figure has been calculated.
In relation to meeting its OAN, Rochford District Council is seeking to provide as much of the district's housing within the area, as far as possible, against the identified need, and given environmental and other constraints. Rochford District has also highlighted a commitment to work with neighbouring Local Planning Authorities (LPAs) to ensure that the housing need across the South Essex Housing Market Area is effectively met. In view of this, Basildon Council supports Rochford Council's intention to meeting its own needs, and to work effectively with neighbours to ensure that the need for housing in the South Essex Housing Market Area is collectively addressed. Basildon Borough Council will continue to support more effective joint working with Rochford as their new Local Plan emerges, in line with the Duty to Co-operate.
The aspiration to provide Rochford District residents with the opportunity to access a
percentage of new market homes on schemes as a priority is also noted. Basildon
Borough Council will recommend that any supporting policy requirement in relation to meeting the housing needs of residents should be backed with reasonable justification and evidence, in line with national policy and guidance.
Finally, attention is drawn to the emerging Basildon Borough Local Plan. Since the
Basildon Borough Draft Local Plan consultation in 2016, significant matters of principle in relation to the Basildon Local Plan have been considered and resolved. As a consequence, Basildon Council through several decision making processes, has taken the position that some changes should be made to either the Local Plan, or the process of preparing the Local Plan, in order to ensure it is sound. One of these changes arises from the fact that the suite of sites identified for inclusion in the Basildon Borough Local Plan does not meet the identified need for housing of between 19,440 and 19,720 homes. This gives rise to an unmet housing need, which when delivery issues are taken into account is around 4,000 homes for the plan period up to 2034. Following Basildon Borough Council's Infrastructure Growth and Development (IGD) Committee Meeting on the 16 January 2018, and in order to ensure that the Basildon Borough Local Plan is sound in regard to this matter, it has been recommended that assistance is formally sought from other LPAs in the Housing Market Area, to help Basildon Borough to meet its unmet housing need.
Basildon Borough Council therefore formally requests that Rochford District Council
considers whether they can assist in meeting some of Basildon Borough's unmet need in the Rochford District Local Plan.

SP1.5: Gypsy, Travellers and Travelling Showpeople

A need for 15 Gypsy and Traveller pitches up to 2018 was identified in the Rochford
District Core Strategy 2011. The Issues and Options Report however recognises the
recent changes made to legislation relating to Gypsies, Travellers and Travelling
Showpeople. Following the change in definition of Gypsies, Travellers and Travelling
Showpeople, a further Essex-wide Gypsy and Traveller and Travelling Showpeople
Accommodation Assessment (G&T and TS AA) was commissioned to understand the
implications for plan-making. A need for Gypsy and Traveller pitches was identified, but there was no need for Travelling Showpeople plots. The assessed need for Gypsy and Traveller pitches in Rochford District up to 2033 within the emerging G&T and TS AA 2017 for Rochford District could however still be met through the 15 pitch site allocated in the current Allocations Plan Policy GT1. This means that Rochford District can demonstrate a land supply up to 2033 (including a five year supply) for all Gypsy and Traveller households within the district, regardless of whether they meet the 2015 Planning Policy for Traveller Sites (PPTS) definition or not. Basildon Borough Council supports the approach Rochford District are taking in ensuring that their evidence base is up-to-date.

However, while the G&T and TS AA establishes a need for the plan period of 2013-2033, Rochford District's new Local Plan looks forward to 2037. It is therefore unclear how the Gypsy and Traveller needs for Rochford District will be met in the remainder of the plan period (2033-2037), and further evidence of this should be provided. Rochford District Council should carry out further work to re-assess the Gypsy, Traveller and Travelling Showpeople needs up to 2037, and should the need for pitches change in light of this, Rochford District Council should seek to update the Rochford Local Plan accordingly to continue to meet their full objectively assessed needs for Gypsy, Traveller and Travelling Showpeople.

There is also a concern that no acknowledgement has been made of the fact that there may be unmet needs arising from Greater Essex authorities for the provision of accommodation for Gypsies, Travellers & Travelling Showpeople within the Rochford Issues and Options Report, which is considered to be a shortcoming. Basildon Borough Council has agreed to work with Chelmsford City Council, Harlow District Council and Colchester Borough Council on behalf of the Essex Planning Officer's Association to develop a protocol for unmet Gypsy, Traveller and Travelling Showpeople need, should this situation arise in any local planning authority in Greater Essex. It is envisaged that this work will be carried out in 2018. Rochford District Council should therefore recognise and support the principle of this approach going forward, to ensure that there will be a technical approach in place to support any neighbouring authorities with any potential unmet Gypsy, Traveller and Travelling Showpeople need in the future. This is to ensure that a fair process is applied throughout Essex, and ensures compliance with the Duty to Cooperate.

SP3.1: Highways Infrastructure

The Rochford Issues and Options Report sets out different options for managing traffic in and around Rochford District. The report recognises that the A127 has known capacity and congestion issues. Consequently, Rochford Council has proposed to work with Essex County Council and Southend-on-Sea Borough Council, to develop a transport model for South Essex, which will cover the length of the A127. Basildon Borough Council supports this approach. Rochford Council's commitment within paragraph 8.18, to continue to work with neighbouring local authorities and the Highway Authority to promote strategic and more localised improvements to the highway network is also noted. This initiative is supported by Basildon Council. In particular, reference was made within paragraph 8.18, to the potential for a new link road from the A127 at Pound Lane/Cranfield Park Road to link to the A130 in Rochford District.

It should be noted that the proposed grade separated junction on the A127 at Pound
Lane, with the new link road to the A130 was identified within the Policy TS2 of the
Basildon Borough Draft Local Plan 2016 as part of the provision for new and improved transport infrastructure, essential to mitigate the impact of future housing and economic growth in Basildon Borough. It is expected that this junction will serve the development proposed at East Basildon and South Wickford, improve access to the A127 enterprise corridor, reduce pressure at the A132 Nevendon Interchange and Fairglen Interchange, as well as freeing up capacity for local traffic. This junction will therefore provide significant benefits for both the strategic and local road network. However, this proposal is substantially more expensive at around £130m, and raises issues around development viability.

The proposed improvement to highway infrastructure will therefore require support and funding from neighbouring authorities, to supplement developer contributions from the Department for Transport and South East Local Enterprise Partnership. As Rochford District communities could potentially benefit from the provision of the proposed grade separated junction on the A127 at Pound Lane, with the new link road to the A130, Basildon Borough Council formally requests that Rochford District Council should account for part funding of this junction within the new Local Plan for Rochford. As part of the transport modelling to support the Rochford Local Plan, and also within the Rochford Local Plan itself, Rochford District Council needs to also consider its relationships with neighbouring authorities when allocating growth locations. Basildon Borough is most likely to be affected if growth is concentrated to the west. It is therefore important that Rochford District Council ensures collaborative engagement and continual working between local planning authorities, with the highway authority, and with transport providers to ensure that strategic transport links are capable of accommodating the additional transport pressures that are likely to arise as a result of future population growth, particularly to the west of the Rochford District area.

SP3.2: Sustainable Travel

The main road linking Basildon Borough with Rochford District is the A127, which is well documented to experience capacity challenges, particularly in peak periods. Rochford District Council should ensure that new development have accessible services, and enables people to reduce the need to travel by private car, as much as possible, particularly as the district experiences high levels of car ownership and high levels of outcommuting. In addition, the South Essex Economic Development Needs Assessment (EDNA) 2017 identifies the A127 Enterprise Corridor as an important employment location in South Essex. The role of this corridor will be retained and grown, with the aim of attracting new investors to the corridor. Enhanced public transport connectivity between towns in Rochford District and this employment area in Basildon Borough should therefore be sought by Rochford District as part of the strategy for improving sustainable travel choices across the District and into South Essex.

SP4.3: Open Space and Outdoor Sports and Recreation

Basildon Council welcomes the opportunity to work with Rochford District Council and other neighbouring authorities in South Essex, to prepare more strategic level evidence of needs across the sub-region for open space, sports and recreation, in line with national policy, and to identify ways to improve connectivity between green spaces through the provision of green corridors.

Duty to Co-Operate

In order for the Rochford District Local Plan to be found procedurally sound, it will need to take account of a broader range of issues and opportunities affecting neighbouring areas and the wider region, considering and addressing strategic cross-boundary issues.
Attention is drawn to the joint-working that is underway in South Essex, which aims to deliver a more coordinated planning, regeneration and investment agenda to benefit the combined local communities. It is expected that the development of a Joint Strategic
Planning and Infrastructure Framework (SPIF) would set the strategic growth objectives for South Essex and provide the "effective mechanism" required to determine how unmet development needs from individual local authority areas would be met.
Building on this foundation, it is also relevant to mention the South Essex 2050 which is a unified long-term place vision for the South Essex area, with the addition of Brentwood Borough Council. This work, due to conclude in early 2018, is expected to determine how the work on the Joint SPIF and its inter-relationships to South Essex Local Plans will be prepared and managed in the future, and could accelerate the conditions needed to deliver the shared housing & job ambitions, enabled by significant improvements to transport & other infrastructure.
This shared support demonstrates that LPAs across the region have been engaging
constructively and actively, to maximise the effectiveness of Local Plan preparation in the context of strategic cross-boundary matters, and contribute to fulfilling the requirement for Local Planning Authorities to work together under the "Duty to Co-operate", as set out in the Localism Act 2011.
Basildon Borough Council is satisfied with the degree of engagement with regard to the Rochford District New Local Plan, and welcomes the opportunity to continue to work with Rochford District Council and other neighbouring authorities in the region on the content of the new Local Plan and its approach to strategic, cross-boundary matters such as housing growth, employment growth, and infrastructure provision through the Duty to Cooperate.

General Observations

It is noted that some of the evidence base, which will inform and support Rochford District Council's emerging Local Plan, is still underway. Some of this has been commissioned jointly with other LPAs, including Basildon Council. While it is not possible for Basildon Council to comment on the forthcoming evidence at this time, Basildon Borough Council will continue to work with Rochford District Council in the preparation of any joint evidence base work to ensure that it is comprehensive and appropriate for what the Local Plan will cover.

Rochford District Council should further identify options, strategic growth areas and
policies informed by up-to-date evidence and, through publication of a draft Local Plan, invite further representations from LPAs and other stakeholders.

Basildon Borough Council welcomes further engagement with Rochford District Council to ensure that the observations raised in this response are duly considered and to continue working together on strategic planning priorities through the Duty to Co-operate.

Draft Sustainability Appraisal of the Rochford Local Plan

Basildon Borough Council has reviewed the content of the Draft Sustainability Appraisal of the Rochford Local Plan, and can confirm that on this occasion, Basildon Borough Council has no comments to make, as it covers all the matters you would expect to see in such a document.

Thurrock Council has considered the Issues and Options document and the supporting Duty to Cooperate Topic Paper and has the following observations to make with regard to the Duty to Cooperate. Thurrock Council confirms it is satisfied with the level of consultation and engagement to date with regard to the emerging Rochford Local Plan.
The Rochford Issues and Options document clearly identifies in a number of its objectives and policy options the key strategic and cross boundary issues where it states the Council will work with the other South Essex local authorities and with individual organisations under the Duty to Cooperate. It is noted for example that homes and jobs, transport and other infrastructure are key issues identified for collaboration and joint working.
Rochford Council has also produced a Duty to Cooperate Topic Paper that sets out the legislative and policy context for the Duty to Cooperate and how Rochford has sought to meet its requirements. The topic paper highlights that there had been a need for more effective joint working between the South Essex local authorities and for arrangements that result in clear outcomes to address strategic cross boundary issues.
Thurrock Council welcomes and supports the continued involvement and participation of Rochford District Council in joint working and collaboration with the
other South Essex authorities including Thurrock. It is noted that Rochford Council has been and continues to be involved with the other South Essex authorities in the preparation of a range of technical evidence. Furthermore Rochford Council along with the other South Essex authorities and Essex County Council signed a Memorandum of Understanding in 2017 that includes a key set of principles and arrangements to improve the effectiveness of joint working including a commitment to prepare a Strategic Planning and Infrastructure Framework.
Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.
In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.
More recently the ASELA Councils have begun considering more detailed arrangements for joint strategic planning including an expression of interest in becoming a pilot for the Government's proposed Statement of Common Ground, the commissioning of further technical studies and the consideration of the exact nature and status of the joint spatial strategy including the possibility of producing a Joint Strategic Plan (JSP). Rochford District Council as a member of ASELA and in supporting the joint planning arrangements will also need to consider the level of resource and commitment that it can provide towards the new joint planning arrangements and its own emerging and future local plan(s) production.
A key issue for Rochford Council will be the need to consider how the emerging New Local Plan will align with the preparation of the joint strategic planning both in terms of the content and nature of the local plan(s) that the Council intends to prepare but also in the timing and production of such documents especially if the South Essex Councils agree to move forward with the option of a statutory joint strategic plan.
The importance placed by the Government on better joint working is set out in the draft revision to the NPPF published in March 2018 reflecting statements in the housing White Paper and previous consultation. The draft NPPF includes greater provision to produce joint plans and also proposes changes to the "effective" and "positively prepared" soundness tests for local plans to encourage agreements and joint working. The "effective" test also requires local authorities to evidence cross -boundary issues and joint working in a Statement of Common Ground.

Strategic Objective 1
Thurrock Council fully supports Rochford Council in seeking to deliver housing to meet its Objectively Assessed Housing Need. However it is considered the Objective should be rewritten as it could infer that housing will be primarily delivered through PDL and then working with South Essex Neighbours but not other potential sources.

Strategic Priority 1: The homes and jobs needed in the area.
Delivering Homes and Jobs
SP1.1: We have a real and identified need for affordable homes in the district and an aging population, so how do we sustainably meet our need for market and affordable homes and homes for older people and adults with disabilities over the next twenty years?
Thurrock Council supports an approach under Strategic Priority SP1.1 and Option1 for Rochford District Council to seek to fully accommodate the upper end of its Objectively Assessed Housing Heed (OAHN) within the district during the proposed plan period of 2017-37.
The Issues and Options document sets out that the recommended range of Objectively Assessed Housing Need for Rochford is between 331-361 dwellings per annum as evidenced from the 2017 Addendum to the South Essex Strategic Housing Market Assessment. The Council has identified that taking into account the shortfall of housing delivered in 2014-2017 from the OAN base date that this results in a projected housing need for the plan period 2017-2037 of between 7,181 and 7,881 dwellings.
The Government published in September 2017 draft potential options for a standardised methodology for assessing OAN. The draft paper recommends a target for Rochford District of 362 dwellings a year. This is only 1 dwelling a year more difference compared to the higher end of the current OAN range. It is accepted that the Government methodology is only draft and there are uncertainties as to when the final methodology will be published and whether the OAN figure for authorities will have altered significantly. Revised population and household projections are also due to be published by the Government and will need to be considered as part of the assessment of any revised OAN figures. Therefore at this stage there remains uncertainty on the future figure of OAN for Rochford. The Council will need to take into account the expected changes to the methodology, population and household projections along with other evidence for housing need as it moves to the next stages of plan preparation.
It is recognised that at this stage of the preparation of the Rochford Local Plan that the Council has not fully assessed the potential capacity of the district to accommodate the currently identified OAN. Thurrock notes that Rochford Council is continuing to develop the evidence base to support its local plan and is to undertake further work to review policy and environmental constraints, infrastructure restrictions and site deliverability in order to determine the level of housing that can be accommodated in the borough.
The Issues and Options document states that based upon current evidence including the 2017 Strategic Housing and Employment Land Availability Assessment (SHELAA) that the Council has identified insufficient sites for housing within the urban area to meet the OAHN identified for the plan period. Thurrock Supports the approach that the Council its taking to consider further the potential capacity of the borough to meet its own OAHN including the ongoing call for sites, a review of the Green Belt and landscape assessment, and further development of infrastructure requirements.

Until Rochford Council has fully assessed the policy constraints and capacity within the district it is unclear whether there is a potential unmet need. Furthermore Rochford Council will need to consider any implications of unmet need arising from other authorities in the housing market area.
Thurrock Council requests to be kept informed of any shortfall of housing provision arsing in Rochford during the preparation of the New Local Plan. Such matters will be increasingly be considered as part of the joint working arrangements and preparation of the South Essex joint strategic planning including the ongoing development of the evidence base and monitoring.
Thurrock Council also supports the approach of Rochford in Option 2 of SP1.1 of working with other Councils across South Essex to address the strategic cross-boundary matters such as housing need and distribution and unmet housing need. This key strategic issue will be considered as part of the joint strategic planning and as this will provide a strategic framework to inform the emerging Rochford Local Plan.
Rochford Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a spatial options study including a high level housing land and capacity assessment and further infrastructure studies.
The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Rochford District and the approach to be taken in the New Local Plan.
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.
Thurrock Council supports the approach that Rochford Council has identified in the Issues and Options document with the six potential options representing realistic ways to deliver the additional homes required in the district. It is considered that a combination of a number of these options for delivering housing supply are likely to provide the source of housing capacity to meet OAHN for the plan period.
The 2017 Rochford Council SHELAA sets out that currently the Council land trajectory has identified there is sufficient suitable, available and achievable land to deliver a total of 3499 dwellings with most having planning permission but also including an additional 935 dwellings on land identified through existing allocations without permission or other sites assessed though the SHELAA, the call for sites and are predominantly on urban land.
As noted in the Issues and Options document there is currently insufficient appropriate sites to accommodate the projected OAHN for Rochford during the plan period and sourced from the urban area. In seeking to assess the potential options to accommodate the shortfall in housing supply the Council will need to carefully consider the balance between the levels of housing need and the environmental capacity and other policy constraints.

It is identified in the Rochford SHELAA that through the ongoing call for sites process the Council have identified significant additional potential capacity but the suitability of these sites to come forward for housing will be subject to the further assessment of environmental capacity and review of other policy constraints such as the Green Belt that are being undertaken as part of the local plan process.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAHN including discussion with adjoining authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in to accommodate part of their housing need.
SP1.5: How do we sustainably meet our need for Gypsy and Traveller pitches over the next 20 years?
The Issues and Options document sets out the needs for Gypsies and Travellers arising in Rochford to 2033 as identified from the recently published Gypsy and Travellers Accommodation Assessment (GTAA) of 2018. The Council states it has potential pitch provision through an allocation to meet most of the identified needs of Gypsy and Travellers up to 2033 regardless of whether the Gypsy and Travellers meet the current planning definition. The Issues and Options documents sets out a range of alternative options to meet this need, including giving careful consideration to provision for the needs of those households that no longer meet the planning definition of Gypsy and Travellers.
Thurrock supports the overall approach of Rochford Council to accommodate its own Gypsy and Travellers need. However it is noted that the assessment of need based on the most recent GTAA only covers the period to 2033. It is considered the Rochford Council will need to further review the GTAA to ensure it has identified the Gypsy and Traveller need to cover the whole plan period. Clarification is sought that the Council will accommodate this need within the borough. At this stage it is unclear what in terms of potential unmet Gypsy and Traveller need there is across Essex and in particular South Essex. Rochford Council along with the other authorities in South Essex will need to consider this matter as part of the Duty to Cooperate process.
SP5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and wider South Essex area?
Thurrock Council supports Option B for taking the Green Belt policy forward in the New Rochford Local Plan that includes the potential amendment of existing policy.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAN including discussion with other authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this
need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in order to accommodate part of their Housing and other development needs.

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.

NEW LOCAL PLAN - Rochford District Council 2018 - Issues and Options

3. OUR CHARACTERISTICS

Our Economy

3.3 "South Essex.. a national priority for growth and regeneration". I object. We have employment sources eg London Southend Airport (but people commute in from elsewhere for jobs and rent locally, thus using up jobs and housing. We have local businesses, industrial parks, shops. Many commute to London. But S. Essex is overcrowded and there is some unemployment. Though we are served by Greater Anglia and C2C rail lines to London, other areas, Kent, Sussex etc, are served by main line termini, so we don't need more population here.

3.13-3.16 As you well illustrate, circa two thirds of Rochford district is agricultural, flood risk, so difficult of access and of limited population, the bulk of which is in much smaller west. Consequences are clear.

Schools are overcrowded and measures are being sought, with difficulty, to extend them. Examples:- developers of new 600 estate in Hall Road promised a new primary school. Then, then with excuse that 2 developers involved, only 300 each, they opted out of S106 agreement, so no school.

Hospitals are at risk, surgeries are overcrowded - and it isn't just the old problem.

Traffic, on most accesses, including B1013, now of rush hour size all day, characterised by mile long traffic jams. Road works may contribute, including A127 at Kent Elms, but all noticeably worse since autumn 2016 due to Hall Road, Clements Hall, Christmas Tree Farm and other large developments in the west. Wholesale demolition of residences for redevelopment, including historic ones in eg Hockley that would have been listed elsewhere.

3.18 Note historic Rochford and Rayleigh, plus Conservation areas, of high historic value. "400 listed buildings.. a number of heritage assets not listed nationally, but of local historic importance". But in Hockley, a considerable number of historic buildings have been demolished that elsewhere would have been listed. Reference is made to Local List - one iconic, historic building on the hill entering Hockley was on Local List. So Rochford council abolished its Local List "Government now frowns on Local Lists", until after demolition, when list was renewed. Building was replaced by flats. Hockley has always been the poor relation in this respect. Meanwhile much public money was being spent on preservation is Rayleigh and Rochford, council saying money mustn't be wasted on preservation of iconic building in Hockley.

3.20 "higher proportion of older residents". For a while, but recently an increasing number of younger people in Hockley, so don't target older people for eviction.

3.22 "long term worsening in affordability" and 893 households on Housing Waiting List. One major cause - Government policy of mass selling off of Council housing cheaply during 1980s, councils not allowed to use resultant sums to build more council homes or care for what remained. Council houses had 2 purposes:- one, for families need to save up with cheap rent till they could buy own home; two, for families who could never afford to buy.

4 Our spatial challenges

4.4 I object. Under the National Planning Policy Framework Local Planning Authorities are to work out how many houses they need and plan positively how to meet need in full or if they need help from neighbours - presumably Duty to Cooperate - this is unrealistic.

4.13, 15, 18 I object. If Castle Point, Southend, London are unable to meet all their need for new homes, as you demonstrated in paras 4.13, 15, 16, Rochford will be unable to fulfil their surplus needs under Duty to Cooperate.

5. OUR VISION AND STRATEGIC OBJECTIVES

5.11 Drafting our Strategic Objectives

Strategic Objective 2 this doesn't work... Affordability - developers of schemes above a certain size are required to set 35% as affordable. Information is at least one developer sold off the Waiting List percentage to another borough for its Waiting List. What about Rochford's Waiting List of over 900?

Strategic objective 10 Doesn't work. ".. to work with other authorities and Essex County Council to deliver meaningful improvements to highway network". The ECC 2016 fund for this showed a £4.4 billion gap not matched by Government investment.

Strategic Objective 14 "To work with ECC and health care providers to ensure residents have.. quality social and health services. Doesn't work. Local health arrangements are struggling and too many people are pouring down from London and elsewhere to live here. Hospital under threat and Government heavy charges for care at home.

Strategic Objective 17 Doesn't work. On 4.2.18 Government announced change to plan law to permit extending buildings by 1-3 storeys - how can you cope with that?

Strategic Objective 18 I object. "to support.. delivery of.. primary, secondary etc education facilities".. see my earlier comment re a developer promising S106 agreement for a primary school, then when plan consent given, he opted out as 2 developers involved - 300 homes each. What can you do about that except getting law changed?

6 Delivering Homes/Jobs

6.2 I object. "Delivering.. of new homes.. market, affordable etc". "Any new homes.. supported by suitable infrastructure.. so does not impose unnecessary burden on capacity of existing infrastructure". As I commented under earlier headings, local population has been added to by others coming down from London and elsewhere. Local settlements were agricultural villages and 2 market towns, so local main roads were narrow, winding country lanes, now tarmacked over for motorised traffic, which cannot be changed to motorways, particularly as they are now fully developed either side and beyond.

Also as I said earlier, in 2016 Essex County Council has a £4.4 billion fund gap for highways infrastructure.

6.9 6.10 This sums it up - realisation that environment capacity and availability, viability, infrastructure etc limits what is possible re housing need.

The only possible solution - a new garden settlement to take more population, obviously in Green Belt some of which is flood plain. A by-road would be needed which would also help with traffic density elsewhere. This would need to be carefully planned.

6.19 Affordability a significant issue in Rochford. Re market houses - London people are selling up for good prices and can buy in Rochford district for lower price, though still expensive apparently and local people cannot afford. Re the 921 people on Rochford Waiting List, information is that another council bought out the required percentage of social homes in one development. I think such cases should be taken into account in the Duty to Cooperate.

There are local families who want gardens for their children - even homes they could afford are snapped up by developers. Estates are built with houses packed together, for profit naturally - builders need a living - so no gardens.

6.20 I agree what you say re private rent and Waiting List. As before - 1980s Government had council houses sold off - rest assigned to housing associations. Until law changes re council housing - nil you can do.

6.25 Re Duty to Cooperate, it is already clear you cannot contribute to other districts, without driving locals out of their homes.

6.29 It is clear to you also you cannot deliver the target given by S. Essex HMA, so you cannot aid other councils under Duty to Cooperate.

6.30 I agree Option C seems the most practical.

6.30 and 31 Problem seems insoluble.

6.33 Homes for Older People and Adults with Disabilities Don't forget many older people are able to manage in own homes. Some are suggesting they be removed to make room for younger people. In fact, if removed, only the bulldozer would move in to provide expensive executive dwellings for rich people moving down from London and elsewhere.

7 Supporting Commercial Development

7.12 Retail/Leisure/Town Centres

Re Cinema - "Scope for small independent niche cinema" - you had the Regal cinema in Rayleigh, very successful, but demolished to accommodate the Mill Hall.

"Catering.. priority need for Class A3 restaurant/café in Hockley - I object - there are no less than 7 in the centre already. Hockley well provided for retail, except that since supermarket arrived, basic needs - grocers, butchers, greengrocers with which Hockley was well furnished and are needed, have all gone.

8 Delivering Infrastructure

8.4 "high level of car ownership" - naturally, nowadays. Hence that militates against largescale developments.

8.6 Object. CIL and S.106 agreements won't solve anything. Firstly, they are only for developers to mitigate immediate vicinity traffic problems in relation to their application. In Rochford and elsewhere traffic problem is widespread. Secondly, it is notorious that developers enter S.106 agreements to get plan consent, then they find excuses to opt out of them.

8.8 This is the nub. Your propose eg 7,500 new homes, needing vast changes to traffic facilities, costing huge sums. As previously, Essex County Council noted in 2016 a £4.4 billion fund gap in their infrastructure needs, not matched by Government investment.

8.13 "lack of resilience on local highway network" eg "large volumes of traffic queuing at key junctions" - this is just what you get with huge new development estates - each home having 2+ cars.

8.14 The B1013 via Rayleigh, Hockley, Hawkwell, Rochford "large volumes of traffic queuing at key junctions" is just what you had in morning/evening rush hours. Now, since autumn 2016, you have it all day, often 7 days/week, precisely due to vast new development estates in the vicinity. A new settlement is needed, probably in Green Belt.

8.19 " it's important to acknowledge.. there are limited funds available.. to deliver improvements to the local highway network" - exactly as noted before regarding ECC highways funds - this militates against large development whatever Government is reputed to demand.

8.20 Options

B CIL, like S.106 agreements, as before, is doubtful and individual cases of improvement would not solve B1013 problem. It's now almost as busy with commercial traffic as A127.

Only answer is new motorway through S E Essex, also serving new settlement.
8.22 Sustainable Travel

Idea of increasing public transport is great. Only problem is bus services are privatised. Due to many of those working age in some areas having cars, the bulk of bus passengers there are free passers and Arriva naturally doesn't want them - they claim full sum is not paid to them via Government. Once said "we are not running a service, but a business". This is why some services are drastically cut. I can't think of a solution.

What are the identified issues?

8.33 You note cycle paths are badly needed. Problems of safety occur in Hockley for lack of them. Problem is there is no transit area available for them in Hockley.

You propose amendments to bus routes in Rochford, presumably via Bradley Way - fair enough. There is a rumour of re-routing No8 through Hall Road and Cherry Orchard Way, presumably to serve new 600 estate and new business park. If true, hard luck for those in Rectory Road, Hawkwell. Also, unlike rest of Rectory Road, new stops either side serving new Christmas Tree Farm estate are hardly ever used. Won't the same apply to Hall Road estate whose occupants will undoubtedly be car owners, likewise users of the business park?

Free bus service for Hullbridge secondary school children a good idea.

8.37 What are the realistic options? Option C seems the most practical.

Water and Flood Risk Management

What are the realistic options?

8.58 Option A Retain existing flood risk policy for coastal flooding - forbid development with exception of brownfield - most likely but still doubtful - even if previously developed, still at flood risk.

Planning obligations and standard charges

8.67 Problem with S.106 agreements (payments or mitigating additional works by developers) as before, they enter agreements to get plan consent, then find plausible excuses to opt out.

8.69 Planning conditions - also opted out if they want something else.

8.70 As before one developer promised a primary school, then claimed 2 builders involved, each with half the houses, so escaped obligation. A developer reputedly sold his percentage of social housing to another council for their Waiting List. I hope you can succeed with Community Infrastructure Levy.

9 Supporting Health, Community an Culture

9.7 to 9.10 What are the identified issues
With inevitable Government cuts to NHS provision for the hospital and surgeries and ever greater numbers pouring down into S E Essex from London and elsewhere, problem is insoluble.

9.11 What are the realistic options?

I cannot think of a solution. Money and land needed not available.

Community Facilities

What are the identified issues?

9.14 "facilities.. under threat.. to be developed for other uses" not only shops, pubs etc, also public libraries - eg Hockley one admitted by a County Councillor an a Leader of RDC councillors to be so.

Options

Option B definitely a good idea ".. to resist conversion of community facilities to residential". In fact "prevent" would be better word than "resist".

Education and Skills

I am informed some London 11+ passers are bussed to our nearby grammar schools - Southend and Westcliff, thus reducing places for local children.

Re local villages - some primary schools have closed due to reduced population, but middle class parents so resident drive their children to preparatory schools in Southend, while those of other social classes are left out.

9.28 Option E I support Promoting apprenticeships through cooperation with businesses in offering same and further education a good idea.

10 Protecting an Enhancing our Environment

10.15 I agree with the Environmental Capacity Study 2015 that "it is uncertain whether the district could accommodate additional growth, and unlikely t9o be able to accommodate needs from other areas".

10.16 Options

Option B is sinister - "an assessment of the Green Belt as a whole would need to be taken into consideration". I admit I said a new settlement would possibly be unavoidable, but wholesale change is not on. There would be a solid wall of development from London to the coast.

10.26 Habitats I agree Natural England's need to develop an Essex-wide strategy to identify how potential impacts of .. disturbance resulting from delivering new homes in the country may be mitigated against. The fact is a number of home gardens in somewhat developed areas have habitats of protected creatures which are potentially threatened by developers, not just SPAs, SACs and Ramsars.

10.40 I disagree - Environmental Capacity Study 2015 re grades of agricultural land, Study recommends distinction between 3a and 3b to identify possibilities for smallscale housing development - ? is that how 600 were built in Hall road outside Rochford, mostly sold to Londoners for £650,000?

10.48 How to overcome the Local List - typical - 1 Southend Road Hockley - iconic building, up for development and on Local List - so Rochford council abolished their Local List - "government now frowns on Local Lists", until I =t was demolished. Then Local List was restored as government now approved Lists. (Other councils denied knowledge of such order and had no intention of abolishing theirs.

10.50 conservation Areas - such designation does not prevent adverse changes apparently - so why bother?

10.52 Options

Option A - Action Plans for Rochford and Rayleigh in particular, due to their historic significance are heavily focussed on protecting the character o town centres, unlike Hockley where many historic and iconic buildings have ben demolished. Incidentally circa half of Rayleigh centre was demolished in 1960s, now obviously replaced with typical 1960s buildings. See my comment at 10.48 re one iconic building in Hockley, where in fact many such buildings, which would have been protected elsewhere have gone.

10.54 "good design" to prevent further erosion of area's character - where Hockley is concerned - don't make me laugh at the consequences.

11 Detailed Policy considerations

11.2 35% affordable, of which 80% should be social, to provide homes for those on Rochford Waiting List - fine, but how come we are informed of a case this percentage was bought out by another council for their waiting list?

11.4 "If definition changes we would still need to ensure we seek to meet needs of our residents as far as we can" throws some doubt on your powers in 11.2 in face of above and government and the House Builders Federation.

11.5 This seems to confirm my doubts about the Waiting List in view of government policy and above federation.





Light Pollution

11.73-11.76
11.74 "Identification of environmental zones to dictate the permitted lighting threshold that can be reached" is nonsense. It doesn't matter whether urban, countryside, whatever, if a neighbour light can be seen from one's home, but does not penetrate one's home same, that is permissible. But if the light does penetrate one's home, that is not permissible.

Dear Sir/Madam

Rochford District Council Issues and Options Document and Draft Sustainability Appraisal (Screening) Public Consultation

Thank you for your consultation on the above dated 6th February 2018 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Local Plan (Issues and Options Document)

Section 3: our characteristics

 Under key Environment Characteristics: (page 12) the first bullet point states "our district has significant areas of ecological value, particularly the Crouch and Roach estuaries and Foulness Island". We advise that this sentence includes the international and national designated importance of the estuaries.

Section 4: our special challenges

 Section 4.10 highlights cooperation between Essex authorities in strategic and cross-boundary matters. We advise that the natural environment is included as a cross-boundary matter in light of the strategic approach required to address recreational disturbance impacts on coastal protected sites. Rochford District Council has signed a Memorandum of Understanding to work with neighbouring authorities though the Essex Recreation Avoidance Mitigation Strategy (RAMS) project and we recommend that this is recognised in the list of cross-boundary matters which will be addressed through the Duty to Cooperate.

Section 5: our vision and strategic objectives

 The draft vision for 2037 (page 25) is written as "Rochford District is a green and pleasant place with a focus on business and high quality homes supported by accessible and responsive services and facilities, creating healthy and sustainable communities". We suggest the following amendment: Rochford District is an environmentally rich and pleasant place with a focus on business and high quality homes supported by accessible and responsive services and facilities, creating healthy and sustainable communities.

Our Environment (page 26): as in line with the NPPF and the commitment of the 25 Year Environmental Plan to "embed an environmental net gain principle for development, including housing and infrastructure" we recommend a commitment to delivering net gain for the natural environment, in order to compensate for residual impacts of development on environmental assets. In addition this could be included and expanded in Strategic Objective 19.

Section 6: delivering homes and jobs

Strategic Priority 1.6: Houseboats and Liveaboards (page 54): further information on current houseboat and liveaboard numbers and location in Rochford and the wider Essex area would be useful as baseline data to understand potential impacts of increased numbers to designated sites. Impacts should include both disturbance to species and habitats and pollution from waste effluent.

We support the following options:
o B) Amend existing policy to strengthen criteria.
o D) Amend the definition in the Development Management Plan with the aim of agreeing a clear definition at county level and one that reflects potential impacts on protected sites
o C) Allocate specific areas of coastline where such uses may be acceptable
 Policy should align with best practice proposed by the Essex RAMS project to ensure recreation disturbance is adequately managed within a strategic framework that is Habitats Regulations Assessment compliant (HRA).

 Natural England welcomes the opportunity to work with the Local Planning Authority to address the issue, with regard to potential ecological impacts, and help formulate a policy that does not pose an adverse impact on any designated sites.

 Strategic Policy 1.9: London Southend Airport (page 65): any potential impacts to air quality resulting from an increase in flights, duration and/or adjustment in aircraft or flight paths (including the operational implications of stacking) and road infrastructure should be considered and HRA compliant. It is likely any proposed expansion would require a Habitats Regulations Assessment and this needs to be addressed at a strategic level as part of the Local Plan. Delivery of any mitigation recommendations identified through the HRA and SA will need to be secured through robust Plan policies.

 Natural England's preferred option is A, "retain and update the Core Strategy policy supporting London Southend Airport's growth". This option will update existing policy and ensure reflection of any environmental impacts particularly on any Sites of Special Scientific Interests (SSSI's) and Natura 2000 sites.

 Strategic Policy 1.10: supporting tourism and rural diversification. This policy should consider any potential impacts to the natural environment including recreational disturbance.

 This section should also recognise that the England Coast Path may provide economic opportunities for tourism and the rural environment.

Strategic Policy 3: the provision of infrastructure for transport, telecommunications, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat)

 Strategic Policy 3.4: water and flood risk management. Natural England supports the proposal to update the Water Cycle Study and we advise that the results of this study should be used to inform the HRA. We acknowledge that that the Environmental Capacity Study found that water supply and capacity for water treatment was sufficient until 2032. The revised Local Plan extends this time period until 2036 and consideration should be given to ascertain if additional capacity is required to meet the needs of development up to 2036. Evidence should be provided to demonstrate that any measures needed to address capacity shortfalls can be implemented ahead of / in line with development. This is needed to demonstrate that Local Plan development is sustainable and will not have an adverse effect on the environment including nationally and internationally designated sites. Delivery of mitigation measures should be secured through robust Plan policies.

 In Para 8.46 this section states "As noted within the Environmental Capacity Study 2015 the Essex and South Suffolk Shoreline Management Plan policy is to hold the line with maintaining or upgrading defences along the coast." This implies that 'hold the line' is the SMP preferred policy along the whole of the Rochford shoreline. We advise this section is revised to reflect the SMP fully and include coastline areas under managed realignment.

The plan should refer to the relevant Shoreline Management Plan and take forward applicable actions. Local Authorities should use Shoreline Management plans as a key evidence base for shaping policy in coastal areas.

Sea level rise and coastal change are inevitable and bring both challenges and opportunities for people and nature. Sustainable coastal management needs to embrace long-term change and achieve positive outcomes for both.

Local Plans should therefore provide for coastal adaptation and work with coastal processes. Plans within coastal areas should recognise the need to respond to changes over long timescales and adopt an integrated approach across administrative and land/sea boundaries. A successful integrated approach should set levels of sustainable levels of economic and social activity whilst protecting the environment.

We would also advise that Local Plans should help facilitate the relocation of valued environmental assets away from areas of risk.

Strategic Priority 4: The provision of health, security, community and cultural infrastructure and other local facilities

Strategic Policy 4.3: open space and outdoor sports recreation. We advise that open space policy corresponds with Natural England's Accessible Natural Green Space Standards (ANGST), which describes the amount, quality and level of visitor services we recommend for all areas. This will help to ensure the delivery of sufficient levels of high quality informal open space to meet the needs of new residents and to buffer and enhance the resilience of the natural environment, particularly more sensitive designated sites.
Strategic Policy 5: protecting and enhancing our environment

Strategic Policy 5.2: biodiversity, geology, and green infrastructure (10.27). We recommend the strengthening of existing policy ENV1 and a commitment to net gain in line with the requirements and aspirations of the NPPF and 25 Year Environmental Plan.

Protection of local habitats of important ecological value (10.28).We agree that option F should be updated to reflect the findings of the latest Local Wildlife Sites assessment. If options C-F are merged to form a singular strategic nature conservation policy, it should include the same level of protection and enhancement as existing policy.

Section 10.43 identifies broad soil sensitivity and its importance to wildlife across the district. The Local Plan should give appropriate weight to the roles performed by the area's soils. These should be valued as a finite multi-functional resource which underpins our wellbeing and prosperity. Decisions about development should take full account of the impact on soils, their intrinsic character and the sustainability of the many ecosystem services they deliver.

The plan should safeguard the long term capability of best and most versatile agricultural land (Grades 1, 2 and 3a in the Agricultural Land Classification) as a resource for the future in line with National Planning Policy Framework paragraph 112 to safeguard 'best and most versatile' agricultural land. The plan should recognise that development (soil sealing) has an irreversible adverse (cumulative) impact on the finite national and local stock of Best and Most Versatile (BMV) land. Avoiding loss of BMV land is the priority as mitigation is rarely possible. Retaining higher quality land enhances future options for sustainable food production and helps secure other important ecosystem services.

 Strategic Policy 5.3: Wallasea Island and the RSPB's Wild Coast Project. Natural England supports option A which retains existing policy and supports Wallasea Island Wild.

 Strategic Policy 5.4: landscape character. Natural England expects the Plan to include strategic policies to protect and enhance valued landscapes, as well as criteria based policies to guide development, as set out in the National Planning Policy Framework (NPPF).

 We support the review of the Upper Roach Valley and coastal protection belt as part of the Local Landscape Character Assessment and new evidence should be used to strengthen and adapt existing policy.

Detailed policy considerations

 D.P1.13: light pollution (page 163): light pollution can give negative impacts on local amenity, intrinsically dark landscapes and on nature conservation, particularly invertebrate and bats. We advise that policies should address impacts on the natural environment in accordance with government guidance on light pollution1. Light pollution policy should ensure the protection of existing dark skies and that new developments increased local light pollution in sensitive areas.

 The Campaign to Protect Rural England have produced maps on light pollution which may be a useful evidence resource for local policy.

Sustainability Appraisal

Natural England is broadly satisfied that the Sustainability Appraisal has been prepared in accordance with the requirements of the SEA Directive, as transposed through the Environmental Assessment of Plans and Programmes Regulations 2004. We have provided advice on the Issues and Options Document and Draft Sustainability Appraisal below.

1. Do you think the Local Plan might have a 'likely significant effect' on Natura 2000 sites? If so, in which broad locations and what might be the likely effects?
Depending on the quantum and location of development, the local plan may have a likely significant effect on:
 Crouch and Roach Estuaries SPA and Ramsar,
 Foulness SPA and Ramsar
 Essex Estuaries SAC
 three SSSIs Hockley Woods, Foulness and the Crouch and Roach Estuaries

However, details of new housing location allocations is not provided in the sustainability appraisal or issues and options document. The local plan will need to have its own Habitats Regulations Assessment (HRA) in due course. The findings and recommendations of the HRA should inform the SA. Mitigation recommendations should be referenced, and implementation secured, through robust Plan policies.

Sufficient evidence should be provided through the HRA to demonstrate any significant effects including increased recreational pressure and changes in air quality associated with new development, with suitable and proportionate mitigation included. The district is sensitive to changes in air quality and evidence through air quality modelling may need to be provided. A likely increase in visitor pressure at key locations may also need to be delivered and measures to address adverse effects should follow the mitigation hierarchy, i.e. measures to avoid impacts should be prioritised. Where adverse impacts cannot be avoided, detailed measures to mitigate these will need to be provided.

Natural England welcomes the commitment to develop an Essex wide strategy to identify potential impacts of recreational disturbance resulting from the delivery of new homes and mitigation delivery through the Essex Coastal Recreational Avoidance and Mitigation Strategy.

We fully support the ambition to work with neighbouring local authorities to identify local wildlife corridors and networks across boundaries

2. Have all the policies, plans, and programmes that are relevant to the production of the Plan been considered? Or are there other documents that should be added to those outlined in the 'Schedule of Plans, Policies & Programmes relevant to the Plan'?

Natural England has not reviewed the plans listed. However, we advise that the following types of plans relating to the natural environment should be considered where applicable to your plan area;

Green infrastructure strategies
 Biodiversity plans
 Rights of Way Improvement Plans
 Shoreline management plans
 Coastal access plans
 River basin management plans
 Relevant landscape plans and strategies

3. Is the data collected in the 'Schedule of Baseline Information relevant to the Plan', to the best of your knowledge, factually correct?

No comment

4. Is the data collected in the 'Schedule of Baseline Information relevant to the Plan' is relevant and suitable for the Plan? Do you know of, or have, any additional data that you think should be added to the list already collected?

We advise that local habitat policy is reviewed and aligned with up to date baseline data to ensure maximum positive effect on biodiversity, health and wellbeing
Please see attached Annex A for our advice on additional sources of local plan evidence on the natural environment.

5. Do you agree that the issues identified as 'Key sustainability issues' are the main sustainability issues relevant to the Plan? Are there any other sustainability issues that you believe should be added?

Strategic Priority 1: Delivering homes and jobs

3.2.1.4 Tourism and rural diversification - option B: if the council seeks to expand the current approach to tourism and include other forms of rural diversification, consideration should be given to increased recreational disturbance and assessed as part of the HRA process. Any mitigation should be proportionate to insure sustainable growth in this area.

6. Will the indicators and data identified in the 'Schedule of Baseline Information relevant to the Plan' provide an effective framework for monitoring the performance of the Plan against the SA Objectives in the 'Draft Sustainability Objectives and SEA Topic'?

As set out in Planning Practice Guidance, you should be monitoring the significant environmental effects of implementing the current local plan. This should include indicators for monitoring the effects of the plan on biodiversity (NPPF para 117).
The natural environment metrics in the baseline information are largely driven by factors other than the plan's performance. They are thus likely to be of little value in monitoring the performance of the Plan. It is important that any monitoring indicators relate to the effects of the plan itself, not wider changes. Bespoke indicators should be chosen relating to the outcomes of development management decisions.

Whilst it is not Natural England's role to prescribe what indicators should be adopted, the following indicators may be appropriate.

Biodiversity:
 Number of planning approvals that generated any adverse impacts on sites of acknowledged biodiversity importance.
 Percentage of major developments generating overall biodiversity enhancement.
 Hectares of biodiversity habitat delivered through strategic site allocations.
Green infrastructure: Percentage of the city's population having access to a natural greenspace within 400 metres of their home.
 Length of greenways constructed.
 Delivery of objectives and targets in the Green Grid Strategy
 Hectares of accessible open space per 1000 population.

7. Are there other/additional methodologies that could be used to identify the significant effects of the Local Plan?

No comment

Sources of local plan evidence on the natural environment

The following sources of evidence may be useful in ensuring local plans are evidence based, in line with paragraph 165 of the National Planning Policy Framework (NPPF) and assist in meeting Strategic Environmental Assessment (SEA) requirements. A range of additional locally specific evidence is also likely to be needed to underpin plan preparation.

i. General natural environmental evidence

National Character Areas (NCAs) divide England into 159 distinct natural areas. NCA profiles contain descriptions of the area and statements of environmental opportunity, which may be useful to inform proposals in your plan. Natural England has also published downloadable natural capital maps. There is a suite of ten maps, of different aspects of natural capital, which contributes to our understanding of where our natural capital is.

The Magic website will provide you with much of the nationally held natural environment data for your plan area in downloadable GIS format.
Local environmental record centres may hold a range of additional information on the natural environment, principally ecological. The following local organizations may also hold environmental information where applicable: Local Nature Partnerships, Wildlife Trusts, Areas of Outstanding Natural Beauty Partnerships and Nature Improvement Areas.

Evidence relating to the significant environmental effects of the current local plan should be available (in line with SEA legislation), as should suitable biodiversity evidence for any plan adopted after the NPPF came into effect (27 March 2012), usually through the current plan's Annual Monitoring Report.

ii. Landscape

The Magic website provides data on the extent of protected landscapes (National Parks and Areas of Outstanding Natural Beauty). National Park/Area of Outstanding Natural Beauty Management Plans may also be a source of useful evidence. These are usually found on these organisations websites.

Most areas have local landscape character assessments. These are tools to help understand the character and local distinctiveness of the landscape and identify the features that give it a sense of place. It can help to inform, plan and manage change in the area. Data on tranquillity is held by CPRE. They also hold mapping data on light pollution.

iii. Biodiversity and geodiversity

The most relevant layers on Magic for you to consider are Ancient Woodland, Local Nature Reserves, Priority Habitat Inventory, Sites of Special Scientific Interest (including their impact risk zones), Special Areas of Conservation, Special Protection Areas, and Ramsar Sites (including, where relevant, marine designations).
You may also wish to draw on more detailed information on specific Sites of Special Scientific Interest and the Conservation Objectives and Site Improvement Plans for Special Areas of Conservation and Special Protection Areas.

Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Larger areas of priority habitat will usually be mapped either as Sites of Special Scientific Interest on the Magic website or as Local Wildlife Sites or Local Geological Sites. Local wildlife site data is usually held by local planning authorities themselves as is local geological site data. Local Environmental Record Centres and local wildlife and geoconservation groups are also a source of information on Local Sites.

Natural England maintains the Open Mosaic Habitat on Previously Developed Land Inventory (a priority habitat dataset currently not integrated into the Priority Habitat Inventory on Magic) and is available on request from Natural England via email; NaturalEnglandGIDataManagers@naturalengland.org.uk.
Local Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area. Local Geodiversity Action Plans (LGAPS) identify agreed local action for geodiversity, a list of active LGAPs can be found at UK Geodiversity Action Plan (http://www.ukgap.org.uk/getting-involved/lgaps.aspx).
Some areas have identified Biodiversity Opportunity Areas or similar for spatially targeting biodiversity restoration work.

Protected species are those species protected under domestic or European law. Local environmental record centres are likely to hold much of the available data on such species.

APIS holds data on air pollution in particular in relation to protected nature conservation sites.

iv. Access

The Magic website holds the following access related data: National Trails, Public Rights of Way (on the Ordnance Survey base map), Open Access Land (the Countryside and Rights of Way Act 2000 layer), together with national and local nature reserves, country parks and the England Coast Path.

Locally held data will include the definitive Public Rights of Way, and may include Rights of Way Improvement Plans where they exist, and any locally mapped open space audits or assessments.

Natural England's work on Accessible Natural Greenspace Standards (ANGSt) may be of use in assessing current level of accessible natural greenspace and planning improved provision.

v. Green infrastructure

Green infrastructure strategies may comprise or contain useful evidence sources where they exist.

vi. Soils

A provisional Agricultural Land Classification (ALC) map is on Magic, and the GIS layer 'Likelihood of Best and Most Versatile Land' is available on request from Natural England via email;

Some areas already have detailed ALC maps. The coverage of existing detailed MAFF post 1988 ALC surveys is shown on Magic. The MAFF post 1988 ALC survey reports and maps themselves are available from Natural England or from Gov.UK. Our publication Agricultural Land Classification: protecting the best and most versatile agricultural land may also be of help.

General mapped information on soil types and Agricultural Land Classification is available (under 'landscape') on the Magic website and also from the LandIS website, which contains more information about obtaining soil data.

vii. Climate change

The Climate Change Adaptation Manual provides evidence to support nature conservation in a changing climate. The National Biodiversity Climate Change Vulnerability Assessment Model provides a spatially explicit assessment of the relative vulnerability of priority habitats. The data files can be accessed here: National Biodiversity Climate Change Vulnerability Assessment data. The LWEC Climate Change Impacts Report Cards present the latest evidence on how climate change is affecting different aspects of our environment, economy and society.

viii. Coastal and Marine issues
The following may be of help:
 Catchment flood management plans (considers all types of inland flooding, from rivers, groundwater, surface water and tidal flooding).
 Shoreline management plans (considers flooding from the sea).
 Any estuary or harbour management plans that are held locally.
 River basin management plans (covers entire river systems, including river, lake, groundwater, estuarine and coastal water bodies).
 Coastal Erosion Maps.

 The Marine Management Organisation has a marine planning evidence base which supplies a range of information on marine planning.

 There may be specific Heritage Coast information held locally, such as a management plan.

ix. Water Quality and Resources and Flood Risk Management

The Planning Practice Guidance provides guidance on information sources for the water environment.

Response by the House Builders Federation to the Rochford Local Plan Regulation 18 consultation

Thank you for consulting the Home Builders Federation (HBF) on the Development Management Plan. The HBF is the principal representative body of the housebuilding industry in England and Wales and our representations reflect the views of discussions with our membership of national and multinational corporations through to regional developers and small local housebuilders. Our members account for over 80% of all new housing built in England and Wales in any one year.

Duty to Co-operate

The Duty to Co-operate (S110 of the Localism Act 2011 which introduced S33A into the 2004 Act) requires the Council to co-operate with other prescribed bodies to maximise the effectiveness of plan making by constructive, active and on-going engagement. The high level principles associated with the Duty are set out in the National Planning Policy Framework (NPPF) (paras 156, 178 - 181) and in twenty three separate paragraphs of the National Planning Practice Guidance (NPPG). In determining if the Duty has been satisfactorily discharged it is important to consider the outcomes arising from the process of co-operation and the influence of these outcomes on the Local Plan. One of the required outcomes is the delivery of full objectively assessed housing needs (OAHN) for market and affordable housing in the housing market area (HMA) as set out in the NPPF (para 47) including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182).
The Council considers itself to be in an HMA with Basildon, Castle Point and Southend-on-Sea. We would not disagree with this HMA but it must be recognised that there will be linkages with other neighbouring HMAs that could lead to it being reasonable for housing needs from outside the HMA to be met within Rochford. However, it would appear that there are particularly challenges facing the South Essex HMA. The recent decision by Castle Point Borough Council to unilaterally reduce the amount of homes they will seek to deliver is one such challenge. This would suggest that there is a need for strong co-operation between the authorities in deciding how the housing needs of the HMA will be met. We therefore welcome the efforts that are being made to improve co-operation across the South Essex HMA. There is clearly the appetite for joint working that can deliver shared outcomes when necessary, as was the case for the Joint Area Action Plan for London Southend Airport. A similar degree of positive and effective co-operation must be given to the issue of meeting housing needs and we welcome any positive steps that are taken in this direction. One such step has been the preparation of a Memorandum of Understanding (MOU). However, whilst this is a reasonable start it we would suggest that the Council seeks to secure greater certainty that housing needs will be met within the HMA. The MOU should establish tangible outputs or agreement as to how development needs will be met and where which is a key requirement of co-operation as set out in paragraph 179 of the NPPF which states:

"Joint working should enable local planning authorities to work together to meet development requirements which cannot be wholly met within their own areas - for instance because of a lack of physical capacity or because to do so would cause significant harm to the principles and policies of this Framework"

It is important to remember that paragraph 181 of the NPPF states that co-operation should result in "... a final position where plans are in place to provide the land and infrastructure necessary to support current and projected future levels of development". The Council should look to ensure that this is the goal of any co-operation and if achieved can be considered to have fulfilled both the legal and policy elements of the duty to co-operate.

The need for market and affordable homes

Objectively assessed needs

The approach set out in the Council's Strategic Housing Market Assessment update would appear to be a sound basis for assessing housing needs. The outcome of this study is an objectively assessed housing need (OAN) for Rochford of between 331 and 361 dwellings per annum (dpa). The higher figure is a 41% uplift on the 2014 based household projections. The higher estimate of OAN establishes a level of housing needs that is similar to the Government's expectations for Rochford if the standard methodology where to be applied, as such we would urge the Council to prepare a plan to meet the higher OAN. In seeking to meet this level of need the Council have identified three options on page 38 of the consultation document:

A. meet our own needs as far as possible given environmental and other constraints
B. Work with other neighbouring LPAs to ensure the needs of the HMA are met
C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be made available to residents of Rochford first.

The first two options set out are not options but fundamental requirements of the plan making process as established in paragraphs 14 and 47 of the NPPF. The key question for the Council is how will it meet its own OAN as well as ensure the needs of the HMA are met in full. To achieve this the Council will have to co-operate with its partners in the HMA to establish an effective strategic approach to housing delivery. Given that the HMA has already seen one authority, Castle Point BC, attempt to reduce its housing requirement without consulting with other authorities in the HMA it is imperative that more robust systems for co-operation are established as soon as possible.
Whilst the Council are right to consider the constraints on development within the District it should not seek to restrict its housing requirement solely on the basis of environmental capacity, as is alluded to in paragraph 6.29. Paragraph 7 of the NPPF sets out that there are three dimensions to sustainable development and the Council will also need to consider the social and economic advantages that arise from meeting housing needs. In particular the Council will need to consider whether they are able to mitigate against any negative environmental impacts or indeed whether the social and economic benefits outweigh any negative environmental impacts. As such the Environmental Capacity Study 2015 prepared by the Council may inform the consideration of development options as part of the Sustainability Appraisal but it should not be used as the basis to establish the District's housing requirement.

What will be essential is for the Council to undertake an assessment of the planning constraints to development as established in footnote 9 to paragraph 14 of the NPPF. In particular we consider it essential that the Council undertakes a review of its Green Belt to understand the degree to which land under this designation continues to support the purposes as set out in paragraph 80 of the NPPF and to consider whether there are any exceptional circumstances that would support amendments to the current boundary. When considering exceptional circumstances we recommend that the Council refers to the case of Calverton Parish Council v Nottingham City Council, Broxtowe and Gedling Borough Council [2015] EWHC 1078. This case highlighted the importance of considering housing needs and supply against the strength of the Green Belt when assessing whether exceptional circumstances are present. So whilst the Government have stated that housing need on its own are not likely to constitute exceptional circumstances, they would be sufficient where land is not performing strongly against the purposes of Green Belt. We would also add that the worsening affordability of housing in the District would also contribute to the argument that there are exceptional circumstances to amend Green Belt boundaries in Rochford. If the Council has not already begun the process of reviewing the Green Belt we would recommend that work is taken forward with some urgency.

With regard to option c, the Council cannot seek to apply a "Rochford First" approach to the sale of market homes. Such an approach is fundamentally opposed to the operation of the free market. Just as residents of Rochford are permitted to buy homes in any other part of the Country, so people from elsewhere should be permitted to purchase homes in Rochford. Whilst the HBF have worked with the Mayor of London and our members to establish a voluntary scheme to promote homes in London for the first 3 months on which they are marketed solely to those living and working in the Capital we must stress that this is a voluntary scheme and not one that has been established though the plan making process. We do not consider it appropriate to have a planning policy that would restrict sales in this manner, in fact we would consider it beyond the scope of the planning system to prevent a developer from selling homes to any willing buyer. We would therefore strongly suggest the Council does not take forward option C on page 38.

Affordable homes

The Council must set their affordable housing policy at a level that does not affect the viability of development within their area or push it to the margins of viability. This means that despite the Council's statement in paragraph 6.32 that delivering a lower proportion of affordable housing is not a reasonable option it may need to consider such an approach. In fact PPG encourages this in paragraph 10-007 which states:
"Emerging policy requirements may need to be adjusted to ensure that the plan is able to deliver sustainable development."

Until the necessary evidence is available it is not possible to determine the correct approach to regarding the level of affordable housing that should be provided. The level of affordable housing that development can reasonably support will vary in relation to the infrastructure required, the nature of the development strategy being taken forward and other policies in the plan, such as the optional technical standards discussed below, will all reduce the potential contribution development can make toward supporting affordable housing and must be tested before the Council considers its options.

If the Council wishes to improve the provision of affordable housing it also has the option of increasing the allocation of land for residential development. PPG sets out in paragraph 2a-029 that an:

"... increase in the total housing figures included in the local plan should be considered where it could help deliver the required number of affordable homes"
We would therefore encourage the Council to consider the option of increasing the overall supply of land to a level that not only meets the need for affordable housing but also establishes a reasonable level of affordable housing contribution. However, any policy must not require contributions from developments of fewer than 10 units and less than 1000 sqm. Any policy, such as option C on page 39 of the consultation document would, that seeks to do so would not be consistent with the written ministerial statement of the 2 March 2015 and paragraph 23b-031 of PPG.

Homes for older people and Adults with disabilities

Any policy on optional accessibility standards will need to be full justified, as required by paragraph 56-007 in PPG, on the basis of need, viability and the accessibility and adaptability of the existing housing stock. In particular the Council needs to consider the impact on viability of delivering both the lower and higher accessibility standards set out in part M4 of the Building Regulations. Whilst on their own the costs may not appear significant the cumulative impact of these costs alongside those for affordable housing, infrastructure, open space, energy efficiency etc. that the Council have suggested will be required is significant. It should also be noted that paragraph 56-009 of PPG states that: "Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling." The Council should therefore not apply the higher level Part M4(3) to market homes.

Delivering Housing needs

Meeting housing needs

All the options set out at paragraph 6.48 should be considered and it is likely that a mix of these options will be required in order to meet the development needs of the District, and potentially offer opportunities to meet housing needs from elsewhere in the HMA if necessary. It is also important as part of the development of the local plan to ensure that the Council provides a mix of development opportunities. The Government set out in the Housing White Paper the importance it places on ensuring there are opportunities for small and medium sized house builders as well as large volume house builders. As such it will be important to allocate a range of different sites and not rely on strategic allocations to deliver the vast majority of the Council's housing needs. The allocation of small site not only provides opportunities for SME developers it also improves rates of delivery as smaller sites can be developed more quickly enabling the Council to maintain a five year land supply prior to strategic sites coming on line.

Bungalows

We do not consider it appropriate to set a target for the development of bungalows. Bungalows will have a much larger footprint than two and three story homes of the same floor area and as such have a significant impact on viability due to the reduction in the number of units that can be delivered on a site. The Council must also remember that there is a need to maximise development on each site and the delivery of bungalows will significantly reduce the capacity of each site. This will require the Council to release more land or set higher density targets than the 30 dwellings per hectare, as identified as an option on page 50, if it is to meet housing needs.

Housing Mix

We would agree that the current policy in the Core Strategy provides no real guidance to applicants as to what a policy compliant scheme would look like. The NPPF in paragraph 17 and 154 is clear that the local plan, and the policies it contains, should support effective and efficient decision making with policies that provide a clear indication as to how a decision maker should react. We would therefore support option B which would provide clear guidance with the flexibility to vary the mix on the basis of viability.

The continued application of the nationally described space standard will need to be fully justified as required by paragraph 56-020 of the NPPF on the basis of need and viability. Should the Council consider it to have sufficient evidence we would recommend that any policy is sufficiently flexible to vary these standards to support higher densities in appropriate locations. Well-designed homes can easily meet the needs of many individuals and families whilst being below the nationally described space standards and the Council should ensure it has the ability to support such developments.

Design and building efficiency

Paragraph 10.63 sets out seven options with regard efficiency standard in buildings. The HBF does not generally object to local plans encouraging developers to include renewable energy as part of a scheme, and to minimising resource use in general, however it is important that this is not interpreted as a mandatory requirement. This would be contrary to the Government's intentions, as set out in ministerial statement of March 20151, the Treasury's 2015 report 'Fixing the Foundations2' and the Housing Standards Review, which specifically identified energy requirements for new housing development to be a matter solely for Building Regulations with no optional standards. As such we would support option G not to have a policy on energy efficiency standards. Any other approach would be inconsistent with the Government's approach to building standards which it limits to those optional technical standards set out in PPG.

Self-build and custom housebuilding

In considering its options for the delivery of self and custom build housing the Council needs to consider the approaches set out in PPG. Whilst this suggests developing policies in local plans for self-build and custom housebuilding it also outlines that the need for Council to consider:

 Using their own land

 Engaging with land owners to encourage them to consider self-build and custom housebuilding and facilitating access where a land owner is interested

 Working with custom build developers to maximise opportunity

Further guidance is also provided in para 57-14 of PPG which sets out the need for Council's to consider how they can support the delivery of self-build plots through their housing strategy, land disposal and regeneration functions. This would suggest that the Council needs to set policies that support and encourage land owners and developers to bring forward plots the emphasis should be on the local authority using their own land and as part of their overall housing strategy finding the necessary plots. We therefore consider option A to be inconsistent with national policy as it seeks to impose a proportion of self-build plots on land owners and developers rather than facilitating, encouraging and incentivising the delivery of serviced plots for self-build and custom housebuilding. We would recommend that the option D is the most appropriate with regard to approach taken in the local plan.
Should the Council choose to have a policy it will be important to consider what should happen to self-build plots should they not be sold. Where it is agreed that self-build plots will be provided on sites as part of any S106 agreement the policy must set out that any unsold will revert to the developer after 6 months of it being offered on the open market to be delivered as part of the overall scheme. We would also recommend that if development of a purchased plot has not commenced within three years of purchase that the buyer be refunded and the plot reverts to the developer. It is important that plots should not be left empty to detriment of its neighbours or the development as a whole.

Parking standards

Whilst Government policy supports the use of minimum parking standards for residential development there is also a drive for higher density residential development around transport hubs. In order to achieve higher densities and ensure schemes remain viable it may be necessary to reduce parking requirements in sustainable locations below stated minimums. We would therefore recommend that any policy state that where appropriate development will be permitted below minimum standards. This would ensure the policy is sufficiently flexible to support sustainable and viable development, all of which are key elements the NPPF, specifically paragraphs 7, 14, 39 and 173.

We hope these comments are of assistance in taking the plan forward to the next stage of plan preparation and examination. Should you require any further clarification on the issues raised in this representation please contact me.

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).

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 HAS AN ACCOMPANYING ATTACHMENT*

ROCHFORD NEW LOCAL PLAN ISSUES AND OPTIONS
TITHE PARK, POYNTERS LANE, SHOEBURYNESS

We write on behalf of our client, Stolkin and Clements (Southend) LLP, who owns the Tithe Park site. Our client wishes to promote this site for a mixed use residential led development including community uses and public open space.

Tithe Park is a large site of 35 hectares, which lies immediately to the north of the existing urban edge of the Borough of Southend-on-Sea, and is bounded to the north by Poynters Lane. The site is available, deliverable, and suitable for residential led development. It is owned solely by our clients and can be brought forward for development. To our knowledge there are no major obstacles to development of the site, which is currently in an agricultural use.

The enclosed masterplan envisages in the region of 490 dwellings which would significantly contribute towards housing targets.

We believe that the site could benefit both Rochford and Southend, particularly with the NPPF's emphasis on positively preparing plans. It provides an opportunity to address strategic cross boundary issues which is a key theme in the Issues and Options consultation document.

The Issues and Options consultation document highlights the 'duty to cooperate'. Paragraph 4.15 explains that Southend may be unable to meet all of its new need for new homes and jobs within its own boundaries. The document also highlights the large number of people travelling between Rochford and Southend for work (figures 2 and 3) and explains that Rochford District sits within a local Housing Market Area with Southend and Castle Point Boroughs (Figure 8).

Our client supports Option B for addressing 'Objectively Assessed Need' which promotes working with neighbouring Local Planning Authorities to ensure that housing need across the South Essex Housing Market Area is effectively met (Paragraph 6.30). This will ensure that the plan is sound.

As set out in Paragraph 6.29, site specific studies can be undertaken to identify sites adjacent to existing urban areas, such as Tithe Park.

With regard to the options for delivering the number of homes required it is likely that a combined approach as set out in Paragraph 6.48 will be appropriate. Whilst it may be possible to increase the density of some existing sites, identifying extensions to existing urban areas is likely to be necessary. Larger sites, such as Tithe Park, can provide infrastructure and services to mitigate the impact of any scheme and benefit the local area.

Our client would be willing to incorporate community facilities and they are not specifically tied to their masterplan. Furthermore, the development would be able to provide a good mix of homes including a range of sizes and affordable housing. There is also the potential for a care home or sheltered housing should the Council determine that there is a need for this.

Tithe Park could also provide employment floor space for small businesses as part of a mixed use development. As set out at paragraph 6.92 of the consultation document, 87% of Rochford businesses have less than 10 people, these micro businesses require start-up space and grow on space. Our clients support this and would be willing to include some employment within the development. We would welcome the opportunity to discuss the site and the potential mix of uses with you.

In our view, there are strategic advantages to pursing Tithe Park and we would welcome the opportunity to meet with you to discuss the proposals. If you would like any further information, then please do not hesitate to give me a call.

Dear Sir/Madam,

Rochford Local Plan Issues and Options consultation

Thank you for providing the RSPB with the opportunity to comment on this consultation. We are very grateful for the short extension in time enabling us to provide the following response.

Habitats Regulations Assessment (HRA)

We recognise that a number of HRAs relating to previous development plans and strategies have been provided as part of the evidence base. Whilst informative, these are not up to date. However, we note and welcome your commitment to presenting a draft HRA at the next stage of the plan process (per paragraph 1.12) and we look forward to commenting on this document. If you require any assistance in its formation, we would be happy to assist.

Page 19, paragraph 4.7: Challenge - how do we work with our neighbours to meet the requirements of the Duty to Co-operate?

The RSPB welcomes that Rochford has committed to working on the Recreational Avoidance and Mitigation Strategy (RAMS) lead by Essex Place Services and Natural England along with all other District Authorities in the county. The effective funding, delivery and future monitoring of this strategy must ensure that recreational impacts from proposed new housing across the district will be managed to ensure that adverse effects on the network of European designated sites are avoided.
Reviewing the 2005 Green Grid Strategy will also serve to meet the Council's Duty to Co-operate.

Page 26, Drafting our Vision

We welcome the inclusion of the Wallasea Wild Coast project in the "Our Environment" section of the draft Vision. In order to be consistent with national planning policy to conserve and enhance biodiversity, we recommend that "where possible" is deleted from lines 6/7 of this section. To have an over-arching vision which aims to have enhanced the built, historic and natural environment provides the Council with a positive momentum. We consider that saying "where possible" may lead to stasis and is not in the spirit of what a vision should be.

Page 29, Strategic Priority 5

The RSPB broadly supports the four strategic objectives set out under this Priority. However, we recommend that mention of "recreational areas" within a strategic objective based around the natural environment would be more appropriately placed in Strategic Priority 4.

In so doing, we are not being dismissive of recreational areas as providing some ecological resource, but given that they are designed to attract people, such a high-level of expected disturbance would be likely to have a detrimental impact on any important species or habitats present.

Page 55, paragraph 6.83 - houseboats
We support the Council's approach to protect the network of designated sites that may be potentially affected by the inappropriate positioning of houseboats.

Page 125 - Biodiversity, Geology and Green Infrastructure

SP5.2 - How should we protect, manage and enhance our important habitats, nature conservation areas, geology and greenways?

We welcome the strong policy position that the Council sets out to protect and enhance sites and habitats.
Policy DM27 in the Development Management Plan (DMP) also recognises "species" and we ask that this is captured as part of this consultation as well. Question SP5.2 would read more appropriately if it was amended to read:
"..our important habitats and species, nature conservation areas.".
A firm principle of nature conservation is to first understand the distribution of any important species through effective, co-ordinated monitoring. Having species recognised from the outset will set the framework to achieving that aim.

By extension, the Council's Environmental Capacity Study (paragraph 6.31) recognises a number of priority species which occur within the district, e.g. Turtle Dove, Little Tern, Corn Bunting, Lapwing (see page 5 for more detail). The RSPB and other conservation organisations would be able to assist the Council in effectively mapping their distribution as part of the first step towards their protection and enhancement.

Page 127 - paragraph 10.27: options

The RSPB supports option A, which sets out to: "Retain or amend our current broad policy on sites of nature conservation importance".

The Council would be fully justified in adopting a policy that recognises the need "..to identify and seek to enhance local wildlife corridors and network s..".
An integrated landscape approach to improve ecological networks is fundamental in conserving our wildlife.

However, this approach will not be sufficient to achieve the recovery of all species, and in some cases, it will need to be complemented by specific tailored actions. As highlighted in Professor John Lawton's 2010 report Making Space for Nature, many habitats such as hedgerows, meadows, heathlands, woodlands, sand dunes, wetlands and flower rich field margins do not fall within protected sites. We welcome the Council's recognition of the need for such an approach (paragraph 10.25) and that the Green Grid Strategy (2005) is in need of reviewing. This review should look to encompass the entire council boundary and would lend itself to linking in to Wallasea and the aspirations set out in answer to question SP5.3 on page 4 below.

Recreational Avoidance and Mitigation Strategy (RAMS)

We recommend that it is specified in the pre-submission Local Plan that the frameworks and masterplans for any developments include clear and evidenced strategies to avoid increasing recreational pressure on internationally designated wildlife sites, in line with duties on the Council to conserve biodiversity which would accord with the RAMS.
We are pleased to see Councils' commitment to this county-wide strategic mitigation plan currently under development for recreational impacts of new housing developments on internationally-designated sites. Where a development is likely to give rise to a significant effect on an internationally designated site and it is possible to mitigate this effect, developers should be required to contribute to the RAMS, to ensure that mitigation is strategic rather than piecemeal, and give confidence that mitigation measures can be delivered. We recommend that these requirements are specified within an appropriate policy in the Local Plan.

In order to understand whether measures to protect sensitive sites are being effective, there needs to have been a baseline of monitoring conducted to understand the extent and type of pressure these sites face.
Information from this monitoring can then be used to inform the RAMS, which from experience elsewhere in the UK, we know will require paid wardens/rangers to be employed to raise awareness of the importance of coastal sites and promote positive behaviours amongst local communities and visitors alike.
The RSPB would welcome working with the Council and other parties, e.g. Essex Wildlife Trust, in helping to maximise the over-arching benefits to biodiversity, residents and visitors alike of such a strategy.

Nature-friendly developments and Greenspace

Alongside the RAMS, we consider that the key means to avoid increasing pressure on designated sites will be through provision of high quality green space close to people's homes and at a scale that is appropriate to the level of planned growth. This should be wildlife rich green space, again in line with the Council's biodiversity duties. Furthermore, access to such spaces will have wider societal benefits by contributing to the health and wellbeing of residents, e.g. dog-walking, jogging or wildlife-watching.
All developments should be nature friendly, with homes for nature integrated with homes for people during the design phase. With the planned scale of development there will be many opportunities to bring nature closer to people at the local scale. An example of how to develop nature-friendly homes is the Kingsbrook Barratt Homes development at Aylesbury, Oxfordshire where RSPB has worked in partnership with Barratt Homes PLC to design housing that benefits people and nature (https://protecteu.mimecast.com/s/2767BHYRg0LUZ).
Further details on our experience working with Barratt Homes PLC and Aylesbury Vale District Council to set a positive example of nature-friendly and wildlife rich development, which we would like to see as the new common standard is provided in Annex 1.
Offering the opportunity for increased connection to nature within the development, through accessible and wildlife-rich green space and wildlife friendly gardens benefits both the natural environment and maximises the health and well-being benefits for residents. The benefits of nature on people's mental health are widely reported within scientific literature (Healthy lives, healthy people: our strategy for public health in England' - Dept Health White Paper, November 2010; paragraph 3.36); however, recently it has become apparent that the quality of the natural environment may be more important than the quantity of it. People are twice as likely to report low psychological distress when living close to quality green space compared with those living near low quality green space.

Therefore, it is important not only to plan for easy access to green spaces in our living environment but also to improve the quality of these green spaces - incorporating greater levels of biodiversity in our green spaces could be one way to achieve this. Natural England have established methods to calculate how much green space will be required in relation to the level of recreational need, known as the Accessible Natural Greenspace Standard (https://protecteu.mimecast.com/s/6RgRBU7edE0IV). We recommend these methods provide the basis of calculating necessary greenspace for new developments.
The RSPB would be grateful for the opportunity to provide further advice on these matters during preparation of the pre-submission version of the Local Plan.
One of the main pressures identified on designated sites is dogs' off-lead. New developments should therefore be managed with dog-walkers in mind and have accessible green space within easy walking distance. The average dog-walk is 2.7km and a dog-owner will only walk around 4-500m to begin exercising their dog, otherwise they are likely to drive to a site to do so. This in itself, adds unnecessary traffic to roads and will increase air pollution and heighten the risk of sensitive sites being disturbed.
Hampshire County Council have produced a guidance document called Planning for dog ownership in new developments: reducing conflict - adding value. Access and greenspace design guidance for planners and developers (March 2013)2 which provides greater detail.

Page 128 - paragraph 10.28: options
The RSPB supports option G, but critically this must retain the principles outlined in Development Management Plan policies DM25-27 together with a commitment to conserving and enhancing habitats and species and working to deliver this on a landscape-scale. The Local Wildlife Sites review should form the basis for robust protection of LoWS as an integral component of such a policy.

Page 128 - paragraph 10.29: options
We support Option A to retain the current policy on Greenways. This has particular relevance to Wallasea. The Green Grid Strategy (Figure 11) identifies a Greenway linking Rochford to Wallasea.

Page 129 - Wallasea Island and the RSPB's Wild Coast Project
SP5.3 - How do we continue to support the RSPB's development of Wallasea Island as an important nature conservation project and visitor destination in the future?

The RSPB broadly supports option A. For the last two years, we have been working closely with the Council on the functioning of the site as a whole and on the provision of improved visitor facilities in particular. We want to continue to work closely with Council to deliver a site that delivers tourism benefits and income generation both on site and in the wider community. We are confident that together we can deliver these benefits in a sustainable and cost effective fashion. Other key issues that we are keen to explore/instigate if possible are sustainable transport links to Wallasea from Rochford and Southend - including via cycle routes, sustainable links across the river to/from Burnham-on-Crouch and joint promotion of the site. It is important that the stated intention of the Core Strategy policy URV2 that any development around the marina "will be supported, provided any adverse ecological impacts are avoided or mitigated for" is retained. This would accord with the mitigation hierarchy endorsed by the Royal Town Planning Institute (RTPI) and the Chartered Institute of Ecology and Environmental Management (CIEEM).

*Further general advice provided in attachment*

Representations on behalf of Manor Oak Homes
*THIS REPRESENTATION INCLUDES SEVERAL ATTACHMENTS*

Rochford District Council - New Local Plan: Issues and Options Document 2017
We refer to the above document and are pleased to enclose representations prepared on behalf of our clients, Manor Oak Homes. As a housebuilder with an active interest in land in Great Wheatley, Rayleigh, Manor Oak Homes is extremely grateful for the opportunity to comment on the emerging plan.

Manor Oak Homes response to the document is set out in this letter supported by the following enclosures:
1. Vision Statement prepared by R G + P Architects
2. Initial Masterplan - Drawing No. 40843 033
3. Initial Masterplan Option 2 - Drawing No. 40843 034
4. Initial Landscape and Visual Appraisal prepared by Aspect Landscape Planning Ltd
5. Highways, Access, Flood Risk and Drainage Note prepared by JPP

Duty to Co-operate

The recognition at paragraph 4.1 of the agenda at the national level for growth to address the historic under delivery of new homes is welcomed, as is the recognition of the need to ensure that Rochford as an authority delivers the right homes in the right places at paragraph 4.4.

Given the challenges facing the south Essex Housing Market Area (HMA) there is a need for strong co-operation between the authorities, at both officer and political level, if these objectives and the needs of the HMA are to be met. The decision of the Council's within the South Essex HMA to prepare a Memorandum of Understanding (MOU) is in this regard welcomed. However, while it represents a positive start and the different stages at which each authority is in the process is noted, the document does not currently provide sufficient comfort or certainty that the needs of the area can be met, and in particular, that a final position where plans are in place to provide the land and infrastructure necessary to support it is achievable and that each authority will fulfil its responsibilities (paragraphs 179 and 181).

SP1.1 The Need for Market and Affordable Homes

The South West Essex Strategic Housing Market Assessment (SHMA) Addendum 2017 projects the need for homes up to 2037 in the district to be between 331 and 361 per annum or 6,620 - 7,220 in total (7,181 - 7,871 including shortfall since 2014). The use of the SHMA Update as the basis for assessing housing needs and identifying the Objectively Assessed Need (OAN) of the district does is Manor Oak Homes' view represent a sound approach. It is interesting to note that the higher figure in the range is almost identical to the level of need generated (362 homes per annum) if the standard methodology proposed by the Government's September 2017 'Right Homes in the Right Places' consultation document is applied. Given this endorsement and the clear need to boost supply, particularly if any dent in affordable needs is to be made, Manor Oak Homes would encourage the Council to adopt the higher OAN figure in the preparation of its plan.
With reference to paragraph 6.9, although it is true that the OAN is not a housing target for the district and that account can be taken of potential constraints in reaching the final requirement upon which a plan is prepared, paragraph 47 of the NPPF does makes it clear that the starting objective is to meet full OAN. It is noted that Rochford is the subject of a number of potential constraints, not least Green Belt, but this should not necessarily prevent the OAN from being met and is an issue that many other similarly constrained authorities are positively responding to.
The consultation document at paragraphs 6.28-6.29 presents this matter in a somewhat negative manner suggesting an underlying reticence on behalf of the Council to consider the matter objectively and to properly balance all matters in order that full need can be met. Indeed, much is made of the conclusion reached by the Council's Environmental Capacity Study 2015, which cast doubt on the environmental capacity of the district to accommodate the level of growth envisaged. However, this was a strategic level document and does not represent the findings of more site-specific assessments of impact, which are likely to identify capacity through infill and extensions to urban areas. Further, it was not informed by any Green Belt Review - for an authority that is so affected as Rochford is by Green Belt, and which will ultimately need to release Green Belt land if increased levels of growth are to be accommodated, we find it somewhat surprising that the Council has embarked on the preparation of a new local plan in the absence of a Green Belt Review. It must in any event be kept in mind that the environmental dimension is only one of the three strands of sustainable development and it may well be that the economic and social benefits arising from development, for example the ability to help meet the worsening affordability gap identified in the consultation document, outweigh harm to the environmental strand. We would urge the Council to keep an open mind in this regard.
At paragraph 6.30, the consultation document sets out three options for ensuring the needs of the district are met, as far as possible. We find these options somewhat perplexing. Options A and B (seeking to provide as much of the district's need within the area, as far as possible, given environmental and other constraints and working with neighbours to ensure housing need across the HMA is effectively met) are not options but are rather fundamental requirements of the NPPF. The Council therefore has no option but to prepare a plan that meets these. Option C would limit choice and would do nothing to enable the physical provision of sufficient homes to meet identified need.

At present Manor Oak Homes consider that the consultation document does not give the impression of the Council seeking to positively plan for meeting the needs of the district.

SP1.3 Delivering our Need for Homes

The table at paragraph 6.48 sets out six options for delivering the new homes needed in the district, including increasing densities, extensions to existing residential areas and a new settlement. The scale of the growth required, together with the need to ensure a rolling programme of delivery, is such that the plan will need to make provision for a mix of development sites. Indeed, the lead in times involved in the release and delivery of larger sites is such that the Council will need to ensure that it identifies and allocates a variety of differently sized sites, especially medium sized sites of 100-150 dwellings capable of delivering quickly and making a meaningful contribution to boosting the supply of market and affordable homes. The reality is therefore that the plan will need to employ a number, if not all, of these options if the need is to be accommodated in a sustainable manner and the plan is to be effective.

The OAN range of 331-361 homes represents an increase on the annual requirement of the current adopted Core Strategy of 32 - 44% and a total increase of 4,865 - 5,553 homes beyond the requirement set by the Core Strategy 2025. As we have stated above, Manor Oak Homes believes that it is the higher of the range that the district should be aiming to meet.

The Core Strategy and Allocations Document pursued a strategy that prioritised the reuse of previously developed land, but in the interests of promoting sustainable development by directing growth to the higher tier settlements, it was necessary to release Green Belt at strategic locations. While there may be some opportunity to accommodate additional housing within the urban areas by increasing densities, the reality as the Core Strategy showed is that the release of a significant amount of land adjoining settlements will be required, which will bring with it the need for Green Belt release, if sustainable patterns of development are to be achieved. In this context, and as stated above, Manor Oak Homes urge the Council to undertake a Green Belt Review at the earliest opportunity and to consider seriously the benefits offers by Green Belt sites, particularly those located around the higher tier settlements, being promoted through the development plan process. One such opportunity is our client's land to the north of Great Wheatley Road, Rayleigh, the merits of which are discussed further below.

Land North of Great Wheatley Road, Great Wheatley, Rayleigh

Lying adjacent to the existing built up area of Great Wheatley, Rayleigh, Manor Oak Homes' land to the north of Great Wheatley Road represents an appropriate location for new housing that should be considered positively for release through the new local plan. The site has been promoted through the Council's 'Call for Sites' exercise and has been given a reference number CFS176. The site comprises Green Belt land, but in view of its contained nature being surrounded on three sides (north, east and south) by existing housing and located adjacent to the existing settlement, it is considered that it represents a natural and infill/ extension sustainably located within convenient reach of existing local facilities and services, including Rayleigh train station.

The location of the site, which extends to 10.97 hectares, is indicated on page 14 of the Vision Statement contained at Enclosure 1). It comprises two medium sized arable fields, a pocket of woodland to the south east and a small tract of pastoral land which extends towards Great Wheatley Road to the south. Existing residential development abuts the site to the north, east and south. Great Wheatley Farm is located directly to the south west of the site, and a large scale substation is located to the north. A railway line which broadly runs east to west is located approximately 200m to the north of the site which further reduces the perceived tranquillity of the site. A network of major road corridors is located within the site's localised context to the west, comprising the A127 Southend Arterial Road, the A1245, and the A130.
A detailed description of the site and surrounding area, including site constraints, can be found in both the accompanying Vision Statement (Enclosure 1) and the Initial Landscape and Visual Impact Assessment (Enclosure 4). In addition, illustrative masterplans, which can be found at Enclosures 2 and 3 show two possible options for developing the site for up to 150 homes. An explanation of these schemes can be found within the Vision Statement. A Highways, Access, Flooding and Drainage Note prepared by JPP Consulting is contained at Enclosure 5, which explains that a development of up to 150 dwellings served primarily from an access from Poyntens (Drawing No. TA10A) would be unlikely to have a significant adverse impact on the surrounding highway network. Further, being in an area at a low risk of fluvial and surface water flooding, it would be unlikely to increase flood Risk and could be drained in line with current guidance.
The location of the site in the Green Belt is recognised, and in this regard, the accompanying Initial Landscape and Visual Impact Assessment (LVIA) prepared by Aspect Landscape Planning Ltd provides an assessment of the landscape sensitivity of the site, the contribution the site makes to the five purposes of the Green Belt and the appropriateness of the proposed illustrative masterplans.
In reviewing effects upon the landscape character, the LVIA explains that the site is visually well contained and whilst some localised harm of the site itself is acknowledged as a result of developing a current green field site, the harm would be restricted to the site and its immediate context only and reduces substantially within the wider landscape setting. It is considered that the immediate and localised setting has capacity to accommodate sensitively designed and well considered residential development and that a new defensible Green Belt boundary can be provided. Development for residential uses on the site would be compatible with the localised context and would link with the existing built up edge of Rayleigh to the north, east and south, which already forms a notable urbanising feature within the site's setting to the west, and any proposed development would be seen within this context. Indeed, it would not introduce any new components that would appear out of character within the context of these views and would not appear dominant or overbearing within the context of the adjoining streetscene, nor would it breach the current limits to Rayleigh formed by the major road corridors within the site's localised context. These act as suitable defensible Green Belt boundaries. It is considered that the development of the site for residential uses would comply with the aims and objectives of the NPPF, and would not significantly affect the characteristics of the surrounding Green Belt designation.

Any Green Belt Review undertaken by the Council would have regard to the five purposes the Green Belt serves, these being to check the unrestricted sprawl of large built-up areas, prevent neighbouring towns from merging, assist in safeguarding the countryside from encroachment, preserve the setting and special character of historic towns, and assist in urban regeneration. We have therefore undertaken an assessment of the extent to which the site contributes to these purposes and a summary of the conclusion is set out below:

Urban Sprawl

The development would extend the built-up area of Rayleigh beyond its existing boundaries. The residential site lies to the south west of the settlement boundary as defined on the adopted Rochford Allocations Plan Policies Map. To the north the site is bounded by a large sub-station, railway line and extensive residential development beyond. The southern and eastern boundaries of the site are fully enclosed by properties on Great Wheatley Road, Highmead, Spring Gardens, Poyntens and Burrowsway with the built up are of Rayleigh beyond. By reason of its location in close proximity to the settlement boundary and enclosure by existing built form, particularly to the north and south which extends well beyond the western extent of the site, the proposed development would appear as a natural extension and would not constitute urban sprawl of the kind that Green Belt policy is intended to prevent.

Sprawl of the kind Green Belt Policy is intended to prevent describes unplanned, ad hoc incursions into the countryside. By comparison the proposed development would represent a sustainable planned development that would positively respond to an identified economic and social need, site and infrastructure constraints, including the landscape, and seeks to integrate with existing development. By virtue of layout, form and significant structural planting as shown on the accompanying illustrative masterplans, it would create a new defensible boundary to the built up area.

Merging of Neighbouring Towns

The area of Green Belt in which the residential site falls separates Rayleigh from Thundersley, north and south Benfleet and Basildon to the south and west and Wickford to the north west. These settlements are sufficiently well separated from Rayleigh not to merge if the proposed housing development were approved. In any event the residential site contributes little to the separation by reason of its small size and if it were developed the impression would be little different from that which exists now.

Encroachment into the Countryside

Being located outside the existing built up area, the residential site lies within the countryside, and in this regard, its development as proposed would result in an encroachment in this area. The development would result in what is now undeveloped land within the countryside becoming urbanised but its impact would be moderated by reason of its close relationship to the existing built up area to the north, south and east.

As the LVIA explains, the site is not of particularly high landscape value, is influenced by its urban fringe setting and is well contained by adjoining residential development. It is considered that the extent of mature vegetation within the site's localised and wider setting would ensure that any impact upon the wider countryside as a result of development would be localised. It is considered that whilst proposed development of the site would develop some green field agricultural land on the edge of Great Wheatley, it would not represent a significant encroachment into the countryside, being contained by the existing urbanising features that are already characterised by the urban edge, and the opportunities that are provided to form a new logical Green Belt boundary along the west of the site through reinforced and new planting.

Setting of Historic Towns

So far as the residential site is not located on the main arterial route into Rayleigh and would be well screened, the proposed development would have no detrimental impact on the setting or historic character of the town.

Urban Regeneration

The residential site comprises greenfield Green Belt land, and as a result, the proposed residential development would not result in the recycling of derelict or other urban land. It is worthy of note however that due to the insufficiency of previously developed urban land in the District, the release of greenfield Green Belt land is anticipated in order to meet future housing needs. As a sustainably located greenfield site it offers the opportunity to meet housing needs and provide a comprehensive scheme with wider social and economic benefits.

Summary

Land to the north of Great Wheatley Road is capable of accommodating a level of development that could contribute positively in the long term to the shaping of the urban edge of Rayleigh by creating an enduring Green Belt edge. The illustrative masterplans show how the site could be developed in a manner consistent with the provisions of the NPPF, in particular paragraphs 85 and 80, ensuring boundaries are redefined utilising physical and permanent features such as the woodland and tree belts with landscape buffers to define the new Green Belt edge. A suitable and substantial undeveloped 'gap' could be maintained between the redefined Green Belt edge and existing settlements, and the development of the site would therefore not result in coalescence. This would also ensure that the setting and separate characters of the settlements would be preserved. It is therefore considered that the removal of the site from Green Belt would not significantly affect the characteristics of the surrounding Green Belt designation or compromise the purposes for including land within it.

I trust the comments made above are in order and due regard will be had to them. Should you have any queries or require any clarification of the points made, please do not hesitate to contact myself, or my colleague, Geoff Armstrong.

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | LAND EAST AND WEST OF SUTTON ROAD

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, on Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.
Please note that details relating to the Land East and West of Sutton Road also formed part of Rochford District Council's 'Call for Sites consultation 2016'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land east and west of Sutton Road
The land east and west of Sutton Road is identified within the submitted plan (Appendix A1), but for clarity the site is divided into two sections by Sutton Road. The land to the west of Sutton Road is 56.3ha in size while the Land east of Sutton Road is 36.8ha. The site is located approximately 1km to the south east of Rochford Town Centre and Rochford mainline Railway Station. The site is bound by residential development to the east, employment and commercial facilities to the north (Purdeys Industrial Estate) and Temple Farm Industrial Estate to the south, Fossets Park to the South West. Reads of Sutton Road Nursery is located to the west of Sutton Road. The site is also bordered by an existing road network, including Shopland Road/Sutton Road to the north and Southend Road to the east. The site currently comprises agricultural land. The public safety Zone associated with Local Southend Airport lies outside the boundary of the site. The site can be accessed via Sutton Road and Fossetts Way.
New Hall Grade II listed building is located on the western side of Sutton Road and any new development on this site will have to be sympathetic to this heritage asset.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. Development of the site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing
Public Safety Zone to Southend Airport and the existing road network.
Promotion of this site for residential use will provide additional sustainable and infrastructure benefits to Rochford and the wider South Essex district. These benefits will include.

 Enable east/west connections without impacting on A1159;
 Provide access to the outer town retail uses and sport stadium potential to reduce impact on
A2259;
 Reconfiguration of Rochford/Southend Road at harp house roundabout;
 Provide better access to the airport to reduce highways impact on Warners Bridge Chase
residents and rebuilding Warners Bridge;
 Improvement to be made to Anne Boleyn roundabout on junction of Rochford Road and Sutton
Road, easing congestion within the district by providing a loop road;
 Provide landscape buffer to Shoplands Equestrian Centre heritage asset providing a through link
to Shopland and potential eastward connections; and
 Development of the site will also provide a landscape setting for Brookes and ecological site.
It is envisaged that the site is suitable for approximately 1,400 dwellings a primary school and a local centre. Alternatively the site could be suitable for industrial use, offices or a mixed use development. Development of the land east and west of Sutton Road will promote growth within Rochford and the neighbouring authorities. It will be of a scale to justify strategic infrastructure investment, in what should
be a key growth corridor for Rochford and Southend. Furthermore it will help support local employment and encourage economic growth. New development will ensure the long term vitality and viability of existing services and business in the local area, and encourage new businesses to locate to this location.
Further benefits of the development of the land east and west of Sutton Road are explained in more detail throughout these representations.

b. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and
the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - the plan should be prepared based on a strategy which seeks to meet
objectively assessed development and infrastructure requirements, including unmet requirements
from neighbouring authorities where it is reasonable to do so and where it is consistent with
achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the
reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on
cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.

Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];
 Be based upon and reflect the presumption in favour of sustainable development, with clear
policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area
[17];
 Seek to secure high quality design and good standard of amenity for all existing and future
occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]
In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with
respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable
development; and
 The Duty to Co-operate.

c. Emerging Local Plan Issues and Options Document
The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.
As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.
As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-
Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Land east and west of Sutton Road, presents an opportunity for both RDC and SBC to contribute positively to the South Essex housing and wider infrastructure investment need.
The key 'Core Purpose and Aims' of ASELA, pertinent to land east and west of Sutton Road are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.

d. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.

The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.

On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the subregional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's required housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAHN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However projected completion rates indicate that a 20% buffer plus shortfall is unlikely to not be met, although the shortfall is considered by RDC to be relatively minor at an
estimated 166 dwellings over the five years.

When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore,
when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.

Supporting Economic Growth and Employment

The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate
controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.

Protecting the Green Belt

The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.
The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development,
'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.

RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.

Delivering Infrastructure

In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focusses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London
Southend Airport.

e. Ensuring the Delivery of Sustainable Development

Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land to the east and west of Sutton Road is currently located within the Green Belt, promotion of the site for residential development provides significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location in relation to London Southend Airport.

Land East and West of Sutton Road

The land east and west of Sutton Road, is in a sustainable location, in close proximity to existing services and facilities as well as employment opportunities. It is suitable for residential development and would help to improve associated roads and infrastructure, easing congestion and providing better access to Rochford, Southend, and London Southend Airport. It is also suggested that new landscaped parks and open spaces which will provide a landscape buffer to Shoplands equestrian centre and heritage assets as well as providing a potential new link to Shoplands and eastward connections.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for land east and west of Sutton Road has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix A3).

Social

Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.

As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required
housing need. Development of this site could help to deliver approximately 1,400 homes towards RDC required housing need target.

Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need.
Development of this site would also bring improvements to the local infrastructure helping to provide better access to the town centre and London Southend Airport. These improvements will also help to ease congestion around the district and the wider area.

Economic

Land east and west of Sutton Road is located adjacent to the south east of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport and Temple Farm Industrial Estate. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its
suitability for residential development.

The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location which is within walking distance from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local
service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK
average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating a significant number jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53
jobs are created in the wider economy.
It is envisaged that development of this site could also provide new jobs as the proposal will look to include the erection of a new primary school and one local centre.

Environmental

At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site. Development of the site would also provide a landscape buffer to Shoplands equestrian centre heritage
asset, providing a through link to Shoplands and potential eastward connections. Within the site, development would provide a landscape setting for Brookes ecological sites.
Development of the site will also be sympathetic to New Hall Grade II listed building located on the western side of Sutton Road by securing a high quality design which will reflect the area.
Furthermore, the site is within walking distance from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land east and west of Sutton Road meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the
NPPF:

Table 1
Land East and West of Sutton Road
1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the north and Temple Farm Industrial estate to the south as well as the existing road network.
- The development of this site would provide a logical 'rounding off' of the existing urban area.
2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the North West of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, London Southend Airport, Fossetts Park and Temple Farm Industrial Estate.
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006.
4. to preserve the setting and special character of historic towns
- Land east and west of Sutton Road is not in or adjacent to any Conservation Areas. A high quality designed development which is sympathetic and aims to protect New Hall Grade II Listed Building.
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land
- There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.

Sustainable Development Scorecard Analysis

Taking the above information into account, the scorecard analysis of the proposed site east and west of Sutton Road has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 84% and a Parity score of 88%.
The Scorecard analysis shows that the proposed site scores very well for the elements of the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and reduce transport emissions as a result of the proximity to sustainable transport options.
The scheme also scores well on both the economic and social aspects, due to the site's proximity to London Southend Airport, Temple Farm and Purdeys Industrial estate and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a prominent location in which to accommodate additional growth due to the presence of two train stations (Rochford and London Southend Airport) with frequent, sustainable connections to central London and Southend-on-Sea.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.

f. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land east and west of Sutton Road will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area. It
is envisaged that development on the site could provide approximately 1,400 towards RDC's required housing need.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable,
achievable and deliverable sites, such as this one, are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

For the reasons given in Table 1, the land east and west of Sutton Road should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing Public Safety Zone to London Southend Airport and the existing road network.
Through development of the site there is also potential to make several infrastructure improvements to the local road network which will have wider benefits for the South Essex Districts.

*THIS REPRESENTATION HAS AN ATTACHMENT*

ROCHFORD DISTRICT LOCAL PLAN - ISSUES AND OPTIONS CONSULTATION (13 DEC 2017 - 7 MARCH 2018) - Persimmon Homes Representations

1.Introduction

Persimmon Homes welcomes the opportunity to comment on the Issues & Options version of the Rochford Local Plan.

Persimmon Homes are one of the UK's leading builders of new homes with a track record of delivery in the eastern region. They are particularly active in Essex therefore a developer with significant experience of both market and planning issues in the area, as well as being a 'user' of the development plan.

2Scope of representations

Persimmon Homes are promoting residential development at the following sustainable site that would assist Rochford meet its housing needs;

-Land between Western Road and Weir Farm Road, Rayleigh (Site ID CSF087) - this 4.18 ha site was advanced as part of the 2015 call-for-sites. Submitted alongside this letter of representation is a 'Site Deliverability Statement: Development at Land south of Kingswood Crescent, Persimmon Homes, February 2018'.

3Representations

Duty to Co-operate
One of the required outcomes of the Duty to Co-operate is the delivery of full objectively assessed housing needs (OAHN) for market and affordable housing in the housing market area (HMA) as set out in the NPPF (para 47) including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182).

The Council defines its Housing Market Areas as including Basildon, Castle Point and Southend-on-Sea.

Local Authorities comprises Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council have formed the Association of South Essex Local Authorities (ASELA). We note that as of the end of 2017 ASELA have prepared a Memorandum of Understanding (MOU). Part of the aims of ASELA is to 'Open up spaces for housing, business and leisure development by developing a spatial strategy'.

It is evident from the experience at Castle Point that certain authorities have expressed a desire not to meet their full OAHN. It remains to be seen the establishment of this body will provide effective governance and a mechanism by which to ensure genuine co-operation to meet full OAHN. Many adjoining authorities within the northern part of Essex have not had to factor in meeting housing growth from ASELA Authorities and are significantly more advanced with their development plans than the majority of South Essex Authorities.

The need for market and affordable homes

Para 5.11 (p27) Strategic Priority 1

We are concerned that the Council's 'Strategic Priority 1: The homes and jobs needed in the area' is too narrow in its scope and does not accord with the NPPF

'To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs through prioritising the use of previously developed land first and working with our neighbours in South Essex'.

This implies that there is two routes to meeting housing and jobs; (1) opportunities on brownfield sites and (2) meeting unmet need via the Duty to Co-operate. The plans strategic policies should seek to deliver 'the homes and jobs needed in the area' in accordance with para 156 of the NPPF. The Council do not have the evidence to establish that it cannot meet its own development requirements. This strategic policy is unduly narrow and restrictive, does not accord with the NPPF and is not supported by evidence.

The issues and options document does not identify that the Council will undertake a Green Belt review. In terms of accommodating sustainable development that allows future generations to meet their needs, an assessment should be made of the wider sustainability issues of meeting its full OAHN housing requirements together with an assessment against the Green Belt purposes. This may lead to the identification of land released from the Green Belt to provide a portfolio of sites and is an arguable 'exceptional circumstance' for reviewing the boundary. The NPPF seeks to align Green Belt boundary review with sustainable patterns of development (paragraph 84).
There is a risk that constraining growth to previously developed land would not enable the Council to address its other strategic objectives, including supporting future housing need and addressing affordability issues (Objective 2) and supporting economic growth (Objectives 3 and 4). Unduly limiting growth would also not support Strategic Priorities 2 and 3 as this would limit growth in the economy and the opportunity to lever investment in infrastructure.

Strategic Priority 1 does not accord with the Governments policy to significantly boost housing supply. The draft amendments to the NPPF also sets out an expectation for objectively assessed needs to be accommodated unless there are strong reasons not to, including any unmet needs from neighbouring areas.

Objectively assessed needs

Council's SHMA identified objectively assessed housing need (OAN) for Rochford of between 331 and 361 dwellings per annum (dpa). 361 dpa is a 41% uplift on the 2014 based household projections. This level of housing is similar to the Government's standard methodology target.

The consultation identifies three options (p38):

A.meet our own needs as far as possible given environmental and other constraints

B.Work with other neighbouring LPAs to ensure the needs of the HMA are met

C.Consider a policy requirement to deliver a percentage of new market homes on schemes to be made available to residents of Rochford first.

These are not mutually exclusive options. The first two are requirements of the NPPF.

As detailed above, we are concerned that the Council's Strategic Priority has been too narrowly framed and is not NPPF compliant. In addition, the Council should commit to a Green Belt review to help it assess the extent it can meet full OAHN and comply with para 14 of the NPPF.

In relation to Option 'c', we consider that there is no national planning policy support to limit a percentage of market homes to qualifying residents of Rochford. Furthermore, such a policy would be anti-competitive and discriminatory. It is relevant to note that no surrounding authorities, including those within the HMA, have policy that seeks to restrict occupation of market homes. Such a policy should impede social mobility, including the need to provide houses to support economic growth.

The Council should plan to meet full OAHN which will ensure that the needs of Rochford are met in full, including for those who aspire or need to live in the borough in the future. We strongly suggest that the Council does not advance option 'C' as to do so would risk the soundness of the plan.

Affordable Homes (p39 - 6.32)

In line with the NPPF, the development plan needs to be deliverable. Levels of affordable housing need to be informed by an assessment of housing need and what developments can viably support. Para 173 of the NPPF is clear that 'the scale of development identified in the
plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened'.

The Council should look to establish the level of affordable housing based on a thorough understanding of development viability. As there is a high level of need, the Council should assess the potential to deliver a higher housing figure as this would increase the total supply.

Homes for older people and Adults with disabilities

Any policy on optional accessibility standards will need to be fully justified, as required by paragraph 56-007 in PPG, on the basis of need, viability and the accessibility and adaptability of the existing housing stock.

Council needs to consider the impact on viability of the scale of obligations and policy burdens sought, including delivering both the lower and higher accessibility standards set out in part M4 of the Building Regulations.

Part M4(3) should not be application to market homes. PPG states: "Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling."

(Paragraph 56-009).

Delivering our Need for Homes (p46)

We note the existing settlement hierarchy.

It is too early in the process to discount any of the options set out at para 6.48. It is considered that the Council should not unduly constrain itself and needs to fully investigate the options based on robust evidence. We consider that the Council should undertake a review of its Green Belt and assess the extent to which this could assist in meeting the full OAHN.

In terms of option 'E' 'A new settlement', the Council will need to consider the extent to which this could be delivered within the plan period, the associated complexities and the critical mass needed to ensure it would be sustainable.

Good Mix of Homes (p46-48)

We support Option A which retains a flexible approach to the type of market homes delivered. It is considered that a target a mix for affordable homes is appropriate, subject to flexibility to ensure that it can reflect the specific circumstances of the site.

Option C - The current adopted plan contains minimum habitable floorspace standards within Table 3. Whilst the 'National Technical Housing Standards - nationally described space standards' have superseded these by default, it is relevant to note that the Council Standards were derived from HCA and are in the most part are not as high as the NPSS. Therefore the previous plan assessed a less onerous standard.
Paragraphs 174 and 177 of the NPPF make it clear that via the Local Plan process LPAs should assess the cumulative impact of policy burden, including housing standards, to ensure that it does not put implementation of the plan at serious risk.

The new Ministerial Statement stated the following: "The optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the National Planning Policy Framework and Planning Guidance."

Accompanying this, Paragraph 001 Reference ID:56-001-20150327 of the NPPG made it clear that LPAs will need to gather evidence to determine whether there is a need for additional standards in their area and justify setting appropriate policies in their Local Plans. Paragraph 002 Reference ID 56-002-20160519 of the NPPG confirms that LPAs should consider the impact of using these standards as part of their Local Plan viability assessment.

The new NPPG section provided substantial guidance in terms of the implementation of the new regime including specific advice on the individual standards which are discussed below.

NPPG sets out clear criteria which Councils must satisfy in order to adopt optional NDSSs over and above the requirements of Building Regulations.

Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:

*need - evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.

*Viability - the impact of adopting the space standard should be considered as part of a plan's viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.

*timing - there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.

The guidance effectively sets out three stages which must be overcome to ensure the NDSSs are only applied where needed and impacts are fully considered.

In the recently Housing White Paper the Government have confirmed their view that the fundamentals of the Building Regulations system remain sound and that important steps were taken in the last Parliament.

In relation to Space Standards, paragraph 1.55 states that "the use of minimum space standards for new development is seen as an important tool in delivering quality family homes. However the Government is concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. For example, despite being highly desirable, many traditional mews houses could not be built under today's standards.
We also want to make sure the standards do not rule out new approaches to meeting demand, building on the high quality compact living model of developers such as Pocket Homes. The Government will review the Nationally Described Space Standard to ensure greater local housing choice, while ensuring we avoid a race to the bottom in the size of homes on offer."

The above confirms the Government's intentions to review NDSSs. This does not have any immediate impact upon Colchester's emerging plan. However, it does demonstrate the Government's unease with a one size fits all approach and its desire to ensure greater local housing choice. Unfortunately, introduction of the NDSSs would narrow the choice available at the expense of affordability and viability.

Option E - We do not consider it appropriate to include a requirement for bungalows. This would reduce the density of development. In addition, modern homes are often capable of adaptable to assist accessibility.

In terms of density (p50), we support the Council's use of minimum density to ensure efficient use of land. The Council will need to ensure it is clear as to where higher minimum densities would be appropriate and assess where these should apply. If higher densities are applied in certain locations, policies should be framed to ensure that there is a recognition that new development may be of a scale and density which is distinct from the prevailing character of the area.

Renewable Energy Generation (p98)

The cost of any additional measures will need to be factored into an assessment of viability.

Planning Obligations and Standard Charges (p99)

The Council should ensure that reliance upon s106 with the associated pooling restrictions do not impede growth. The options do not consider the role of CIL.

Early Years and Childcare Provision (P109)

It is considered that whilst expanding existing education facilities may play a role, the scale of development may warrant identifying sites for education purposes. It is considered that this option should not be ruled out.

Open Space and Outdoor Sports and Recreation (p115)

The Council should not only review its policy, but look at the opportunities that development brings to secure new open space and Green Infrastructure.

As detailed in the attached promotional document, the development of part of land between Western Road and Weir Farm Road, Rayleigh (CSF087) provides the opportunity to formalise footpath routes and improve access to Green Infrastructure in this locality.
Green Belt (p121)

As detailed above, the Council needs to consider its options to meet its full OAHN, including the implications for the Green Belt in doing so. The Council need to undertake a review of its Green Belt to understand the degree to which land under this designation continues to support the purposes as set out in paragraph 80 of the NPPF and to consider whether there are any exceptional circumstances that would support amendments to the current boundary.

It is considered unhelpful to frame the options in relation to the current Core Strategy which addresses a different plan period and does not seek to meet the current OAHN.

Good Design and Building Efficiency (p135)

Paragraph 10.63 sets out seven options with regard efficiency standard in buildings.

We support option G not to have a policy on energy efficiency standards. Any other approach would be inconsistent with the Government's approach to building standards which it limits to those optional technical standards set out in the PPG.

Mix of Affordable Homes

It is evident that the Council needs to deliver more housing, including affordable housing. We consider that the Council's policy needs to be reviewed in light of evidence of need, viability and changes to national guidance. The government introduced 'affordable rent' in 2011 and this needs to be reflected in policy.

Self Build and Custom Homes

Emphasis should be on the local authority using their own land and as part of their overall housing strategy finding the necessary plots. Option A is inconsistent with national policy as it seeks to impose a proportion of self-build plots on developers. We recommend that the option B is the most appropriate.

Development of Previously Developed Land in the Green Belt (p156)

As part of the Green Belt review the Council should look at opportunities to develop previously developed sites in the Green Belt. In undertaking this exercise, the Council should look at the opportunities this presents to build sustainable extensions to settlements and the benefit that may arise in terms of providing affordable housing within settlements that may not otherwise arise. Sites of former glasshouses and redundant agricultural buildings close to or within settlements offer opportunities for housing.

I would be grateful if you could acknowledge receipt of these representations.

*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.