Our Vision and Strategic Objectives

Forming the first stage of the Local Plan review, the Issues and Options Document identifies a series of strategic priorities and objectives to support the draft vision for the future of Rochford District. These are supported by key planning issues that have been identified for a number of themes, and potential options to deal with these issues.

Document Page, Policy and/or Paragraph Number

Comments

Our Vision and Strategic Objectives

5. Our Vision and Strategic Objectives 5.8

Maldon Council supports a number of key ideas and themes
that have come from paragraph 5.8. Improving the strategic
infrastructure network is a shared objective for both authorities;
the Southminster branch line holds a significant relationship with
the Southend train line, which must be safeguarded and
enhanced.

Delivering Homes and Jobs

Pg. 32. Para. 6.9 The revised OAN now expresses a range of between 331 and
361 homes per year. To effectively meet the revised OAN, all
possible options must be considered including a review of
Green Belt land. With the current pressures on housing need as
a national issue, there needs a balance between serving
strategic housing allocations and mitigating the consequences,
such as loss of greenfield land.

Pg. 39. Para. 6.31 Provided the national threshold for affordable housing is 10
units or 1000sqm, which has been widely adopted by most local
authorities, it would seem appropriate to use this threshold as
local policy given the pressures on affordable housing as a
national issue.

Pg. 56. Para. 6.86 Retention of or amendments to strengthen the existing policy
would be supported by the Council. Any amendments which
would be detrimental to the landscape, ecology and/or
biodiversity of the River Crouch would be objected to.

Pg. 58. Para. 6.91 With a revised OAN of 6620-7220 homes from 2017-2037, the
assessed need of up to 16 hectares of 'new' employment land between 2016-2036 would need to be appropriately situated to align with a vision that seeks increased provisions for sustainable transport and sustainable communities.

Delivering Infrastructure

Pg. 85. Para. 8.26 Although there are limitations on the level of influence local
planning authorities have on the level of provision with regard to public transport, the level of provision is based on the use of services. When identifying strategic housing allocations within the district, this must be taken into consideration. Protecting and Enhancing our Environment

Pg. 127. Para. 10.26 It should be emphasised that there will be a close working
relationship between all contributing authorities in the preparation and production of the Essex Coastal Recreational Avoidance and Mitigation Strategy and that there must be a Duty to Cooperate.

Pg. 127. Para. 10.27 Retaining or amending policy ENV1 to strengthen the current policy is supported.

Firstly may I thank the officers of the Council for their time at the public meeting held on 16 January 2018. I note with regret that more senior members of council planning staff were not available to justify or answer questions about the plans and hope that they will be more visible to residents in the future.

Before I raise specific issues about the plan, I feel I must point out that in drafting the document, the Council has started from an incorrect position from which it will now be very difficult to recover, namely that there is a need for 7,500 new dwellings in the area. As your council planning officer explained the figure of 7,500 is based on a standard model developed by the Government and takes into account no local factors. However, unfortunately this ludicrous figure of 7,500 has now set the bar of expectation with both opposition (the majority of residents) and pro-development (developers and land-owners) parties.

The Council should have started from a position that given the known opposition of existing residents to plans for major development, evidenced by the huge opposition to the Hall Road development (of 620 houses), combined with the factors weighing against further development, little additional development is considered appropriate in the local area and a figure of perhaps 250 homes offered as the most that could be absorbed. The starting position adopted by the Council is a major strategic error for which the Director of Planning must take full responsibility.

It is clear both from the factors outlined below and the opposition to the plan from existing council tax paying residents, that any further development of significant scale is unsustainable and the council should rethink this plan to arrive at a more acceptable and sustainable solution.

Major traffic congestion - The B1013 is the main road through Hawkwell and Hockley connecting the towns to Rochford and Rayleigh. This road is already heavily congested at peak periods such as "rush hour" and "school run" times. It also carries traffic to what is becoming a major airport and the major business park at the airport that is currently undergoing very significant expansion. Of particular concern is the junction of Spa Road, Woodlands Road and Southend Road (the mini-roundabout opposite The Spa public house), which is a major "pinch-point".

Impact on public safety - The two Fire Stations managed by Essex County Fire & Rescue Service at Hawkwell and Rochford, respectively, are manned on a "retained" basis. This means that fire crews are alerted to incidents by means of a radio-pager and aim to reach the fire station within 4-5 minutes. Additional traffic created by further residential and commercial development in the area will increase turn-out times thereby increasing the time it takes the Fire Service to attend incidents, placing those needing assistance at additional risk.

Air polution - At certain times of the day, the air pollution caused by current major traffic congestion in some parts of Hockley and Hawkwell is already likely to be in breach of the standards set by the European Commission (Directives 2008/50/EC and 2004/107/EC). However, as the Council has been reluctant to carry out appropriate air quality monitoring it has been left to a group of independent councillors to undertake a 12 month study the results of which are due shortly. Clearly, the additional traffic resulting from further housing and commercial development will add to the toxic level of pollution in the atmosphere adding to the misery of those suffering with respiratory medical conditions and to the detriment of the health of residents. However, it is not only the excessive vehicle traffic that causes high levels of pollution. It must be appreciated that having a significant airport within the immediate vicinity is a major cause of both air and noise pollution.

Green Belt Development - Major developments suggested on major areas of green belt land between Gusted Hall Lane and Mount Bovers Lane would cause significant damage to the environment and have a dramatically negative impact on the landscape of the area. Not only would it destroy an important wildlife area but also productive arable farming land would be lost forever. Greenbelt land should be protected with any development limited to Brownfield and "in-fill" development to ensure the essential character of Hawkwell is maintained.

Developments absent from the plan and errors in mapping - There appears to be developments that have been approved that are absent from the plan. For example, the approval of circa. 70 homes on the site of the former Bullwood Hall prison are not even mentioned and their impact is not considered. The area marked on the map for prospective development in Hillside Avenue, Hawkwell is a small rear garden with no access and unsuitable for development. These are important omissions and errors that need to be corrected.

Independence of AECOM - Within the document, the Council refers to the draft scoping report prepared by "independent consultants" AECOM. A look at AECOM's annual report for 2017 shows very clearly, large multi-national and highly aggressive organisation focussed primarily on its own commercial objectives. For such an organisation to be successful it will be dependent on strong relationships with developers and construction companies, who stand to benefit from large building projects. The Council may wish to consider this when preparing tenders for further work and ensuring that any relationships AECOM may have with parties who stand to benefit from large developments are fully transparent and to seek assurances that no conflict of interest is present.

Information Asymmetry - The council tax payers expect the council planning team to be the "experts" in the area of planning policy and we expect them to produce credible proposals to safeguard the integrity and existing nature of the local area for residents. Instead what has been produced is a long, meandering and sometimes complex document containing vast quantities of largely irrelevant data and very little by way of evidence, with the apparent purpose of deterring engagement from residents. Even simple traffic surveys and existing air quality data are absent from the document, presumably because the facts would not support the case for over development that the Council is clearly promoting. Residents expect the council to be protecting their interests in discussions such as these as residents do not have access to the amount of information and resources that parties such as developers and large construction companies have at their disposal.

Conclusion - In conclusion, there are sadly very few, if any, positive proposals in the plan for existing residents and I am left wondering what we are in fact paying our council tax for?

The New Local Plan document does not, as it claims, "set out a shared vision for the future of our district" as it does not take any account of the strong views of most existing residents who are opposed to this so called "vision".

The Council planning team has missed a significant opportunity to put forward proposals to improve the district for the residents of Hawkwell and surrounding areas and instead is bending over backwards to support major developers who are only concerned about profit and greedy landowners who see an opportunity to make a "killing" from their assets, to the detriment of the majority of residents.

I call for far greater transparency in the communications that have clearly been ongoing between prospective site owners and Council officials to ensure that the public have a full picture of how this initial set of sites has been derived.

Given that a plan already exists up until 2025, it is far too early to consider further development as the alleged "evidence" on which the proposals are based will change e.g. the increased level of traffic from developments under construction but not yet completed. The proposals put forward are clearly not sustainable and do not strike the right balance between environmental, economic and social factors and are not in the best interests of current residents of the area.

Introduction

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

Spatial Challenges

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

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

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

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

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

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

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

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

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

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

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

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

Vision and Strategic Objectives

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

Delivering Homes and Jobs

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

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

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

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

London Southend Airport

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

Supporting Commercial Development

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

Delivering Infrastructure
Highway Infrastructure

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

Sustainable Travel

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

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

Protecting and Enhancing the Environment
Green Belt

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

Biodiversity, Geology and Green Infrastructure

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

Landscape Character

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

Detailed Policy Considerations
Mix of Affordable Homes

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

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

Rochford Local Plan Regulation 18 Consultation

Thank you for the opportunity to comment on the Regulation 18 version of the Rochford Local Plan. These representations are submitted on behalf of Rydon Homes which has an interest in land south of Wellington Road, Rayleigh (site CFS053 in the 2017 SHELAA).

Attached to this representation is a schedule which sets out Rydon's views on the options presented in the document. Hopefully, this will assist your analysis. However, such a point by point response can also obscure the Respondent's overall views on the plan and its main issues. In view of this, this letter brings together the various themes of the Rydon response.

The main points are :
1. The Vision and Strategic Objectives should make it clearer that the plan should seek to meet local housing needs in full. Many other Local Authorities with high levels of Green Belt (eg St Albans) have concluded that their housing needs have to be met and have commissioned a Green Belt Review to identify which land parcels serve the least Green Belt purposes.

2. The Green Belt Review should be progressed in parallel with an assessment of which sites would best promote a more sustainable pattern of development and minimise the use of the car.

3. The plan recognises that Rayleigh is the largest settlement in Rochford District and has the greatest range of facilities and services, plus public transport. As a
consequence, new housing allocations within and on the edge of Rayleigh have the
greatest chance of minimising the need to use the car in favour of walking, cycling
and public transport. Whilst it is accepted that the centre of Rayleigh is currently an
Air Quality Management Area, your 2015 Environmental Capacity Study (para 8.2)
recognises that a package of mitigation measures is available.

4. Whilst it is a matter of concern that your Environmental Capacity Study only focusses on the environmental facet of sustainable development and largely ignores the social and economic aspects, it is noted that it concludes (para 8.27) that the greatest capacity for further development lies within and on the edge of the urban areas in the north and west of the District. When this conclusion is combined with the sustainable credentials of Rayleigh, it is clear that the evidence base provides the justification for smaller housing allocations on the periphery of Rayleigh.

5. The Rydon land south of Wellington Road, Rayleigh (CFS053 - see attached plan) is a strong candidate for allocation since
* It is within walking distance of Rayleigh Town Centre
* It has an existing access on to Wellington Road
* It is close to schools, open space and community facilities
* It is not constrained by environmental or heritage issues
* It is outside the boundary of the Upper Roach Valley (see Figure 07 of the
Environmental Capacity Study)
* The site could be released from the Green Belt with only limited impacts on
the purposes of the Green Belt
* An indicative master plan is attached (No. 2575-A-1004 A) which shows how
the site can be planned to provide up to 80 homes. This master plan forms
part of the 'Site Appraisal and Promotion Document' provided to you on the
18th May 2017. If you would like this resubmitted, please let me know.
Should you feel that a meeting would be useful to discuss this site, perhaps you could suggest some dates.

1. Vision (para. 5.9) : The Vision should include the objective of fully meeting housing needs within the Rochford District.

2. Vision (para 5.10) : The 'Our Society' Vision should contain the objective of fully
meeting housing needs with Rochford District.

3. Strategic Objective (para 5.11) : The objective should make it clear that 'sufficient homes' equates to Objectively Assessed Housing Needs, or such housing figure that emerges from the 'Right Homes' consultation by DCLG. It is unclear what 'prioritising the use of previously developed land first' means. Given the scale of housing needs, it is likely that both previously developed land and Green Belt releases will be needed throughout the plan period.

4. Strategic Priority 1 (para 5.11) : There should be an objective to locate new housing where it can best deliver the most sustainable pattern of development.

5. Strategic Priority 1 (p38) : The plan should pursue Option A to seek to provide as
much housing as possible within Rochford District.

6. Affordable Housing Threshold (para. 6.31) : Option A should be selected to
maximise the delivery of affordable homes from a wider range of sites.

7. Affordable Housing Percentage (para 6.31) : In order to ensure delivery and viability the percentage of affordable housing should be retained at 35%.

8. Settlement Hierarchy (p42, Table 5) : The settlement hierarchy is supported as logical and evidence based.

9. (para 6.45) : Since housing need is likely to require the release of Green Belt land, the Council should commission a Green Belt Review to assess which sites contribute least to Green Belt purposes.

10. (para. 6.46) : Greater weight should be given to locations for new housing which
offer the opportunity to use non car based modes of travel.

11. (para. 6.48) : The most appropriate option is one which combines A, B and C.
Options D and E (larger new allocations or a new settlement) conflict with the
conclusion of the Environmental Capacity Study that the preferred options would
entail smaller allocations within and on the edge of the urban areas in the north and
west of the District.

12. Housing Mix (p46, Table 6) : The table should be disaggregated to provide separate mixes for market and affordable housing. Option A on page 48 is the most
appropriate option.

13. Local Highways (p83) : Given the acknowledged current problems of air quality in
Rayleigh Town Centre, priority should be given to Option C to investigate the
upgrading of Rawreth Lane or Watering Lane to take traffic away from the centre of
Rayleigh.

14. Planning Obligations (p99) : The existing Policy should be retained (Option A).

15. (para. 10.15) : The conclusions of the Environmental Capacity Study that the greatest potential for development lies within and on the edge of settlements to the north and west of the District are supported. Given the size of Rayleigh and its range of services, facilities and public transport, it should be the logical first choice for sustainable housing allocations. Since recent development in the town has been to the west, this Local Plan should seek to 'rebalance' the spatial form of Rayleigh by the allocation of land to the east, such as the land south of Wellington Road.

16. Green Belt (para. 10.16) : It is considered that a Green Belt Review (Option B) will have to form an essential part of the evidence base for the new Local Plan. This
should be commissioned as soon as possible.

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.