Introduction

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 I think this is a bit out of date.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.

*THIS REPRESENTATION INCLUDES SEVERAL ATTACHMENTS*

New Local Plan 2018. Issues and Options Documents

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

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

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

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

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

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

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

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

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

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

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

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

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

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


Section 1 (cont).

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

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

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


Section 1 (cont).

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

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

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

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

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

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

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

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


Section 3 (cont

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

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

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

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

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


Section 3 (cont.

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

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

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

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

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

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

Section 4

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

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

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

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

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

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

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

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

Section 5 (cont

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

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

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

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

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

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

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


Section 6 (cont

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

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

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

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

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

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

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

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

Section 6 (cont

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

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

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

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

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

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

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

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

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

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

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

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

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

Section 8 (cont


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

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

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

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

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

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

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

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

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

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

Page 156. Extensions etc. No comment

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

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

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

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

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

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

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

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

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

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

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