Drafting Our Vision

We welcome the approach that there are 'many accessible and high quality open spaces and significant stretches of coastline providing attractive and accessible leisure opportunities...' However, we would like to see this expanded further to include ALL users within the Plan - walkers, cyclists, equestrians and the disabled - and we feel this should be reflected within the Vision and embedded throughout the Plan document. This could be reworded thus: '...many accessible and high quality open spaces and significant stretches of coastline providing attractive leisure opportunities accessible to as many users as possible...'

'Rochford District is a green and pleasant place' This may be true at the moment but will not continue to be true if building in every green space remains a priority. The 'green and pleasant place' will become a 'grey and dismal place' and once the green is gone, it is gone for ever so needs to be protected for current and future inhabitants of Rochford District.

5.10 Our Society
'focussing on delivering previously developed land first as a priority' and 'we have ensured that new homes are supported by a range of infrastructure necessary to mitigate potential impacts on communities'. This is not true of the 500 houses planned 2018 for Hullbridge i.e. land to be used was NOT previously developed and where is the range of infrastructure? Very concerned that other land on offer that is farm land would not be retaining the open, rural character of the area or protecting valued landscapes.

Strategic Objective 8: To support the continued use and sustainability of our village and neighbourhood centres which serve the local need of current and future residents.
The neighbourhood centre of our village, Hullbridge will not be supported if it becomes a town. At the moment, it meets the need of current residents but its character would be changed for ever if it were to become larger i.e. a town. Its current facilities/amenities would not be able to meet the need of a larger population and no significant infrastructure seems to be planned.

Strategic Objective 14: To work with Essex County Council and healthcare providers to ensure that our district's residents have access to good quality social and health and well-being services.
How do we ensure that this happens over the next 20 years? This is a big challenge e.g. I have had a gynae appointment postponed 3 times at Southend Hospital between Sept 2017 + end March 2018. This has meant that I am living with pain + stress daily. I had to wait 4 months for bereavement counselling, again, not good for my well-being.

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
Sellwood
Planning
Chartered Town Planners
Chartered Surveyors
Stoughton Cross House, Stoughton Cross, Wedmore, Somerset, BS28 4QP
Tel: 01934 712041 Fax: 01934 712118 Mobile: 07801 321162 Email: bob@sellwoodplanning.com
2
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.

Rochford Local Plan Regulation 18 Consultation
Representations on behalf of Rydon Homes
submitted by Sellwood Planning
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.

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

Dear Sir/Madam

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

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

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

Local Plan (Issues and Options Document)

Section 3: our characteristics

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

Section 4: our special challenges

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

Section 5: our vision and strategic objectives

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Detailed policy considerations

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

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

Sustainability Appraisal

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

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

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

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

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

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

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

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

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

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

No comment

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

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

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

Strategic Priority 1: Delivering homes and jobs

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

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

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

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

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

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

No comment

Sources of local plan evidence on the natural environment

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

i. General natural environmental evidence

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

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

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

ii. Landscape

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

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

iii. Biodiversity and geodiversity

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

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

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

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

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

iv. Access

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

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

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

v. Green infrastructure

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

vi. Soils

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

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

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

vii. Climate change

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

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

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

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

ix. Water Quality and Resources and Flood Risk Management

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

Dear Sir/Madam,

Re. Rochford District Council Local Plan Issues and Options

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

Comments on Issues and options

District Characteristics: The Environment

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

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

Vision

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

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

Strategic Objectives and Priorities

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

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

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

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

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

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

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

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

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

Telecommunications

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

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

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

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

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

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

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

General comments on historic environment policies:

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

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

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

Non-designated heritage assets:

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

Climate change and energy efficiency

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

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

Setting

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

Design

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Site Allocations

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

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

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

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

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

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

Assessing sites

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

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

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

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

Assessment criteria

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

Local Plan Evidence on the Historic Environment

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

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

Monitoring

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

Glossary

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

Mapping

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

Comments on Interim SA Report Oct 2017

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

Conclusion

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

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

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

*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.

Dear Sir/Madam,

Rochford Local Plan Issues and Options consultation

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

Habitats Regulations Assessment (HRA)

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

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

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

Page 26, Drafting our Vision

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

Page 29, Strategic Priority 5

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

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

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

Page 125 - Biodiversity, Geology and Green Infrastructure

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

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

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

Page 127 - paragraph 10.27: options

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

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

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

Recreational Avoidance and Mitigation Strategy (RAMS)

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

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

Nature-friendly developments and Greenspace

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

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

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

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

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

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

*Further general advice provided in attachment*

*THIS REPRESENTATION IS ACCOMPANIED BY MULTIPLE ATTACHMENTS INCLUDING A SITE MAP AND VISION DOCUMENT*

These representations have been prepared on behalf of Crest Nicholson Eastern in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the "Site") for consideration in the Rochford District Council ("RDC") Issues and Options Local Plan ("the emerging Plan") consultation of March 2018.

Appendix 1 contains a Site Location Plan which shows the extent of the boundaries
of the site.

1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council's strategic housing need as part of the wider full Objectively Assessed Housing Need (OAHN) for the district. A proposed indicated layout is included within the Vision Document in Appendix 2 of these representations.

1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full OAHN. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council's settlement hierarchy.

1.4 Crest Nicholson is an award-winning national housebuilder with a proven track record of delivery, so if the site were allocated in the emerging Local Plan, the residential development of the site could be guaranteed.

1.5 The specific emerging Plan sections that these representations refer to are as follows:
● Vision
● Strategic Priority 1 - the homes and jobs needed in the area
 Strategic Priority 1.1
 Strategic Priority 1.3
 Strategic Priority 1.4
● Strategic Priority 3 - the provision of infrastructure
 Strategic Priority 3.1
● Strategic Priority 5 - protecting and enhancing our environment

 Strategic Priority 5.1

1.6 Full responses to the relevant issues and options within the emerging Plan are detailed in section 2 of this report and section 3 sets out the opportunity presented by the site for delivery of highly sustainable residential development on the northern edge of Rayleigh.

2.0 Our Response to the Issues and Options

The Vision

2.1 The vision section of the emerging Plan details the aims of the Council in relation to the three pillars of sustainability; our economy, our environment and our society. We support the Council's acknowledgement that this vision identifies that growth must be promoted within the district. This is fundamental to the three pillars of sustainable development. It therefore follows that sufficient housing sites must be delivered through the emerging Plan to support the employment, economic
and demographic growth anticipated throughout the Plan period in order to achieve the vision.

2.2 London Southend Airport forms a major part of the planned economic growth of South Essex. Rochford District Council's London Southend Airport and Environs Joint Area Action Plan (JAAP) was adopted in December 2014 in conjunction with Southend Borough Council and the area surrounding the airport is identified as a high scale employment growth area in the JAAP for both Rochford and Southend authorities. Land to accommodate 109,000 additional square metres of employment floorspace is allocated in the JAAP, comprising the new Saxon Business Park and
other smaller business parks and industrial estates, along with the potential to redevelop an area of underutilised brownfield industrial land at Aviation Way. In total, the land is capable of providing an additional 6,200 jobs in the area excluding direct airport related employment, but in order to fully realise the potential offered by this increase in employment land there must be commensurate housing provision through which a local workforce can be located.

2.3 We therefore consider that the planned employment growth must be matched by housing delivery in the most sustainable locations within the district. Rayleigh is one such location. It is strategically well located near to the trunk road network, main line railway to London and to the airport business park, the key employment area in the district. It therefore has optimal characteristics to contribute
significantly to this required housing delivery within the district.

Strategic Priority 1: The homes and jobs needed in the area

2.4 The emerging Plan sets out several strategic priorities for the Plan area in order to achieve the vision. The most relevant to these representations is strategic priority 1, relating to the delivery of homes and jobs in the district.

2.5 In the first instance we support the Council's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District. We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18). The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery. We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the National Planning Policy Framework (the "Framework"), which clearly requires local planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

2.6 We also consider that the emerging Plan should allocate sufficient housing sites to ensure that housing delivery matches the employment growth anticipated in the JAAP and wider Thames Gateway South Essex, a national priority area for growth and regeneration. The JAAP anticipates that the airport employment park alone could generate 6,200 new jobs by 2031 and the wider Thames Gateway South Essex is anticipated to deliver at least 52,000 new jobs1 over the same
period. Delivery of full OAHN in Rochford is therefore a crucial part of the wider strategic growth of South Essex.

2.7 RDC should therefore look to allocate land in the context of full OAHN for residential growth in the most sustainable locations to help attract and support the anticipated economic growth in and around the district and as part of the wider economic strategy for South Essex.

Strategic Priority 1.1: We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

2.8 Our comments relate specifically to objectively assessed housing need:

2.9 The options as set out are:
● A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
● B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
● C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

2.10 We consider that option A is the most suitable approach in relation to this issue, because it is the approach that is best supported by national planning policy and many local planning authorities local to Rochford are already taking this approach as part of their new Local Plans.

2.11 If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy
constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. Nearby local authorities of Basildon and Brentwood are both equally constrained by Green Belt but are both proposing to meet full OAHN. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

2.12 As a useful starting point, it is apparent from the Council's evidence base that the full OAHN could easily be accommodated on sites within the district; the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 identifies that there are 209 suitable and achievable sites within the district capable of accommodating 24,590 dwellings. This identified potential land capacity is well beyond that of the OAHN upper limit of 7,871 homes including the
shortfall in delivery prior to the emerging Plan period.

2.13 The potential land capacity above includes sites within the Green Belt and Special Landscape Areas and the majority of sites fall within these designations. These constraints should not prevent the allocation of the most suitable sites as part of a Local Plan review and in order to demonstrate that the Plan has been positively prepared, as part of the National Planning Policy Framework's
test of soundness under paragraph 182, we recommend that the Council undertakes further work in the form of a Green Belt review assessing individual sites for their contribution to the five purposes of including land within the Green Belt and their potential for release and development.

2.14 We therefore support option A.

Strategic Priority 1.3: How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?

2.15 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011). Rayleigh sits within the top tier of settlements as the most populated settlement in the district. Having regard to its sustainable location with easy access to public transport opportunities including mainline rail, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core Strategy was adopted.

2.16 Our comments on the Options are therefore as follows:

2.17 The realistic options as set out are:
● A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
● B. Increase density on allocated residential sites.
● C. Several small extensions to the existing residential area.
● D. A number of fewer larger extensions to the existing residential area.
● E. A new settlement.

2.18 We consider that option D is the most suitable method of meeting RDC's housing needs because it is the most deliverable over the Plan period.

2.19 Delivering homes in a fewer number of larger urban extensions, directed to established and wellserviced settlements within the district, would ensure that new homes would be connected to existing employment opportunities, transport networks and essential facilities, without a scale of requisite infrastructure provision that would threaten delivery of other planning policy objectives, such as affordable housing. The scale of larger extensions provides greater certainty of their deliverability and would generate higher levels of S106 and/or CIL contributions for improvements to infrastructure and services. They also have the potential to deliver significant onsite community uses. For example, Land at Lubards Lodge Farm represents a unique opportunity to provide significant public open space, allotments and a much needed sports facility for Rayleigh Boys and Girls FC (please see the Vision Document at Appendix 2).

2.20 Our contention for discounting the alternative options are discussed below:
● Whilst the reference to the efficient use of brownfield land in option A is desirable in line with the national policy, densification and infilling has implications for amenity and design quality and the capacity of brownfield sites alone is insufficient to meet full OAHN. Furthermore, options A and B would drastically alter the character of existing settlements and residential land allocations to the extent that would be damaging to existing character. For these reasons, options A and B are considered unsuitable.

● Smaller scale extensions as referenced in option C would fail to deliver sufficient CIL or s106 receipts to enable the cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

For this reason, we consider option C unsuitable.

● The spatial characteristics of Rochford do not lend themselves well to a new settlement identified in option E. Rochford District is constrained by its relatively small geographical area exacerbated by the environmental constraints of the rural estuarine environments in the north and east. There are no obvious opportunities for a new settlement capable of delivering the required housing in a manner that would create sustainable communities. For this reason, option E is considered unsuitable.

2.21 This confirms our view that the only reasonable option is option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rayleigh, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements, CIL or delivery onsite to mitigate the impact of any scheme. We agree with and support this approach.

2.22 Our submission at Section 3 of this report demonstrates that, as a highly sustainable settlement at the top of the settlement hierarchy in the adopted Plan, with the largest population in the district (circa 40% of the District's population), we consider that Rayleigh is the most suitable settlement for accommodating significant housing growth to support the town and the wider district. Land at
Lubards Farm presents an excellent opportunity to deliver a larger scale extension to Rayleigh.

Strategic Priority 1.4: How do we plan for and deliver a good mix of homes in the future?

What types, sizes and tenures are needed?
2.23 The options as set out are:
● A Retain the current policy on types of house, which takes a flexible, market driven approach to types;
● B Include specific reference to the size and types of homes referred to in the South Essex SHMA;
● C Continue to require new homes to meet the National Technical Housing Standards - nationally described space standards;
● D Do not adopt specific policy on the mix of homes.

2.24 We consider that option B is the most suitable approach in relation to this issue, but a greater amount of flexibility should be built into policy wording. The policy should make reference to the housing mix requirement in the most up-to-date SHMA evidence without prescribing exact figures from the most up-to-date available at the time of the emerging Plan publication. Referring to the specific evidence base provides a degree of clarity for the developer whilst concurrently not being so specific as to be inflexible.

2.25 A further matter that does not appear to be considered in the options is that planning for a series of larger extensions to existing settlements means that strategic planning objectives such as housing mix and tenure may be planned for and delivered on a strategic scale. Need may be adequately met this way.

Strategic Priority 3.1: How can we prioritise and deliver improvements to the strategic and local highway network over the next 20 years?

2.26 We do not have any specific comments relating to options as set out under this strategic priority. However, in response to the issue of how to prioritise improvements to the highway network, these should be delivered proportionately and be spatially related to the delivery of homes and jobs. As we have contended, the most appropriate strategy of housing delivery would be larger urban extensions located in highly sustainable towns at the top of the settlement hierarchy, with Rayleigh representing the optimum location for significant growth. Highways improvements would similarly be best located in this area commensurate to housing growth.

Strategic Priority 5: Protecting and Enhancing Our Environment

Strategic Priority 5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

2.27 The options are:
● A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
● B. Amend the current Green Belt policy in the Core Strategy.
● C. Do not have a policy on the Green Belt.

2.28 We consider that option B is the most suitable approach

2.29 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be possible to balance these competing objectives by ensuring that a fully up-to-date evidence base
is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

2.30 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries (paragraph 84). Furthermore, it says that local planning authorities should consider the
consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).

2.31 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.

2.32 This is why we support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's OAHN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A
Green Belt Review would enable RDC to assess land parcels against the five Green Belt purposes.

2.33 Only once the Green Belt Review is complete, can RDC come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

2.34 Our submission demonstrates in the following section that Land at Lubards Lodge Farm, Rayleigh could be removed from the Green Belt as part of the Local Plan review in a manner that would enable a defensible re-drawn boundary in accordance with the five Green Belt purposes.

3.0 The Opportunity - Land at Lubards Lodge Farm, Rayleigh

3.1 Taking account of:
● Rochford District Council's full OAHN;
● The limited availability of brownfield land in the district;
● The spatial characteristics of the district lending themselves best to larger extensions to existing higher order settlements, including Rayleigh; and
● The need to locate new development in sustainable locations,
we consider that the Land at Lubards Lodge Farm, Rayleigh, presents an excellent opportunity for Rochford District Council to help meet its strategic housing needs as part of the new Local Plan. Our reasons for this are set out below.

Sustainable location

3.2 The town of Rayleigh is identified in both the adopted and emerging Plans at the top of the settlement hierarchy demonstrating the Council's view that is represents the most sustainable location for development. Paragraph 6.38 of the emerging Plan states that settlements at the top of the hierarchy are intrinsically sustainable by virtue of their more developed nature, extensive infrastructure connectivity and accessibility to services and the Council seeks to direct housing development to these locations.

3.3 Rayleigh benefits from excellent connectivity to the rest of South Essex and London through the strategic road network comprising the A127, A130 and the A13. It is linked to London Liverpool Street, Southend Victoria and London Southend Airport by train station located in the town centre.

A range of services and facilities are available within the town. The centre of Rayleigh comprises a range of retail units interspersed with food and drink establishments. Recreational buildings such as the Rayleigh Town Museum and The Mill Arts & Events Centre add to the offer in the town centre. To the south, the Brook Road Industrial Estate, as well as the units on the opposite side of
the Southend Arterial Road to the south, offer employment opportunities above and beyond those in the town centre. 18 schools and nurseries are present in Rayleigh as well as 6 GP surgeries and 6 supermarkets providing a comprehensive service offering within the settlement.

3.1 The following table provides a representation of the site's accessibility to key amenities and demonstrates its suitability for development.

AMENITY DISTANCE FROM SITE
Bus stops 3 adjacent to site
Post office 1 within 50 metres

AMENITY DISTANCE FROM SITE
Pharmacy 1 within 50 metres
Shopping Asda within 400 metres
Rayleigh High Street within 1,800 metres
Schools 2 primary schools within 600 metres
2 secondary schools within 1,800 metres
Train station 1 within 1,600 metres
Leisure facilities The Rayleigh Club is adjacent to site
Rayleigh Leisure Centre is within 500 metres
Employment centres Lubards Farm is adjacent to site
Rawreth Lane Industrial Estate is within 1,000 metres
Library 1 within 1,900 metres
Banking 1 within 1,800 metres
Medical 1 within 200 metres

3.2 These demonstrate that the site is sustainably located. Many of these amenities are accessible by bicycle or on foot.

Deliverability

3.1 As the site is within single ownership and is unencumbered, we consider the site as a suitable candidate for allocation as a strategic residential development site because development would be deliverable. This correlates with the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 approved for inclusion and publication within the new Local Plan evidence base by the Planning Policy Sub-Committee on 17 November 2017. The site is assessed
in this document under the reference number CFS164 and the summary confirmed that the site is within Flood Zone 1 and not proximate to any environmental designations with the exception of the Green Belt; a policy designation.

3.2 Crest Nicholson is a national and multi-award-winning housebuilder with a proven track record of delivery of high quality residential schemes. This adds further weight to our demonstration that development on the site would be deliverable within early phases of the emerging Local Plan.

Benefitting from planned highways improvements

3.3 The site's location adjacent to the northern urban area of Rayleigh represents a logical extension to the town, well contained by Hullbridge Road to the east and Rawreth Lane to the south. Locating new development in this part of Rayleigh would mean it would benefit from planned improvements to the existing highway. Furthermore, its location near to the strategic highway network means that the impact of additional highway movements around the town centre would be minimised.

Figure 1: Extract from Drawing F221-202 General Arrangement 3Arm Roundabout from planning permission 16/00162/FUL

3.4 The consented and fully funded roundabout upgrade at the junction of Rawreth Lane and Hullbridge Road reference number 16/00162/FUL could, once delivered, allow for improved accessibility to the site with enhanced access to the wider strategic road network. The upgraded roundabout also offers the potential opportunity for a direct vehicle access from the roundabout itself.

Green Infrastructure

3.5 There is an opportunity to incorporate managed green infrastructure to the north of the site to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised. As the site is currently private
land it does not benefit from the same potential that its redevelopment would bring in this regard.

Green Belt

3.6 Below is a summary of a Green Belt Assessment undertaken by Eleanor Trenfield Landscape Architects Ltd of the site's contribution to the Green Belt. For further detail, please refer to the brochure appended to this report.
● Check the unrestricted sprawl of large built-up areas
An analysis of neighbouring land uses shows sporadic residential plotland development to the west and north of the site as well as commercial estate to the east and residential properties to the south-east which already contribute to the sprawl of Rayleigh north towards Hullbridge. The site therefore is more closely associated with the urban edge of Rayleigh than countryside and makes limited contribution to this purpose.
● Prevent neighbouring towns from merging
Existing sporadic development to the west and the north contribute to the erosion of this function on the site. The absence of a clearly defined urban edge of Rayleigh at this location is created by the plotland development and the site therefore does not act as a barrier preventing the spread of Rayleigh. Indeed, the plotland development already surrounds the site in most directions including towards neighbouring towns and so development on Lubards Farm would not deteriorate the function further.
● Assist in safeguarding the countryside from encroachment
Land between Rayleigh and Hullbridge has experienced piecemeal development resulting in minimal characteristics that would qualify it as 'countryside' land. Plotland developments already protrude significantly into the open land at this location, surrounding the site to the west and the north. In this sense, the countryside has already been significantly encroached and development on the site would not erode this function further.
● Preserve the setting and special character of historic towns
The land between Hullbridge and Rayleigh has no inter-visibility with the Conservation Area of Rayleigh. As such, development on the site is not considered to damage this purpose of including land within the Green Belt.

We consider it the most suitable Green Belt site adjacent to Rayleigh

3.7 In the context of the above, we have considered it appropriate to review the suitability of alternative Green Belt sites on the edge of Rayleigh. Given the scale of additional growth needed in Rochford, as identified by the OAHN, we have considered the credentials of alternative sites for strategic scale development.

3.8 Several sites around Rayleigh were submitted to the Council through the call for sites process for consideration within the new Local Plan and were presented at the Planning Policy Sub-Committee on 17 November 2017. The committee resolved to publish this document in the new Local Plan evidence base. These alternative sites are discussed briefly below along with our commentary regarding their comparatively weaker suitability credentials than that of Lubards Lodge Farm.
● Committed residential development exists to the west of Rayleigh under the reference number 15/00362/OUT on Land North of London Road, South of Rawreth Lane and West of Rawreth Industrial Estate. In our view, further development to the west of this location would lead to a significant increased sense of coalescence with Wickford and a sprawl of Rayleigh in this direction. See figure 2 below for reference.

Figure 2: Extract from the Council's Site Allocations Plan North of London Road, Rayleigh

To the north-east of Rayleigh, in the proximity of SHELAA site CFS105 Land north of Hambro Hill, is constrained by the topography and access. The area of CFS053 Land south of 38 and 39 Wellington Road, CFS098, CFS029 and CFS027 to the east of Rayleigh, falls within the Upper Roach Valley which is protected from development under CS Policy URV1. They would also require access through existing residential areas. We do not consider these sites of a scale capable of delivering strategic scale development and commensurate infrastructure requirements in accordance with the Council's priorities. Furthermore, their delivery would require land assembly and their delivery could not be guaranteed. See figure 3 below for reference.

To the south-east of Rayleigh, in the proximity of SHELAA site CFS127 Eastwood Nurseries off Bartletts, CFS044 south of Eastwood Road and CFS068 off Daws Heath Lane, there are small fragmented land parcels, likely to fall within different land ownerships. Development of this area is likely to be piecemeal and would in our view not be capable of delivering the high quality, integrated development achievable on the Lubards Lodge Farm site. In addition, site access from the narrow Daws Heath Road and from constrained access points off Eastwood Road are likely to be significant constraint in this location. See figure 4 below for reference.

To the south-west of Rayleigh, in the proximity of SHELAA site CFS121 Land north of A127, development is constrained by the exposed and open nature of the countryside experienced from this location. A substantial number of electricity pylons traverse the site between the substation adjacent to the south of the railway station and the National Grid main substation to the west of the A1245. A suitable point of vehicular access is also likely to be an issue for development in this area. See Figure 5 below for reference.

Evidence supporting this submission

Landscape

3.9 A Landscape and Visual Assessment (LVA) of the site has been undertaken and incorporated into the Vision Document in Appendix 2. The assessment identified a number of constraints and opportunities which have informed the proposed masterplan for the site but confirmed that development is entirely achievable in landscape terms.

3.10 The LVA recognised the existing neighbouring development and the mix of land uses at this location and concluded that residential development would not be uncharacteristic for the area. It recommends that the existing vegetation and hedgerow structures be retained as far as possible within the site, particularly bordering the 3 Public Right of Ways (PRoWs) on site. A significant opportunity exists to the north of the site, to provide a new open space connecting to the PRoW
network, providing amenity and green spaces for the proposed dwellings and enhancing biodiversity.

Ecology

3.11 An assessment of the Ecological Constraints and Opportunities has been undertaken and informed the proposed masterplan shown in the promotional brochure at Appendix 2.

3.12 The Assessment concluded that the site is largely of low ecological value but identified two European Designated sites within an 8km radius of the site. Of the two designations, the Crouch & Roach Estuary Special Protection Area (SPA) and Ramsar has the potential to be impacted indirectly due to increased recreational disturbance and a Habitat Regulations Assessment (HRA) is recommended to explore this further. This would be undertaken as the proposals progress.

3.13 The Assessment concludes that with an appropriately designed masterplan, development can be achieved on this site whilst also providing enhancements for biodiversity. An area of Suitable Accessible Natural Green Space (SANGS) is considered appropriate on the north of the site, to provide an alternative open space for future residents of the proposed new dwellings to minimise numbers travelling to the designated sites for recreational purposes.

3.14 Further phase 2 survey work is identified as necessary and these would be undertaken during the appropriate survey window as the proposals progress. Once all survey data is collected, appropriate mitigation measures would be incorporated into the proposals in line with recommendations.

Highways and Access

3.15 An appraisal of access opportunities has been undertaken on the site and has informed the masterplan shown in the promotional brochure in Appendix 2.

3.16 The appraisal identifies the potential for access to be obtained from a 4th arm on the consented roundabout at the junction of Hullbridge Road and Rawreth Lane under the planning permission 16/00162/FUL. Additional opportunities exist along Rawreth Lane, with potential for a 4th arm off the existing signalised junction with Downhall Park Way or a priority 'T' junction on Rawreth Lane.

3.17 Further work, in the form of a Transport Assessment, would be undertaken as the proposals progress. However, in light of the appraisal, residential development of the site as outlined in the promotional brochure is considered achievable.

Floods and Drainage

3.18 An initial floods and drainage assessment has been undertaken and informed the production of the masterplan shown in the promotional brochure at Appendix 2.

3.19 The site generally falls from the south-west to the north-east and located predominantly within Flood Zone 1, with small areas immediately adjacent to the watercourse flowing south to north on the eastern boundary. Some areas of the site are within areas of high, medium and low risk of surface water flooding with a depth of less than 300mm.

3.20 The Lead Local Flood Authority (LLFA) map places the site in a Critical Drainage Area and have produced a Surface Water Management Plan (SWMP) for the area. Whilst the site itself is not at risk of flooding, it is important that development does not increase the risk of flooding offsite within the wider catchment.

3.21 Unsuitable ground conditions exist for infiltration drainage techniques so a system of swales across the site would collect surface water and attenuate it before it passes to a detention basin. A Train of Sustainable Urban Drainage Systems (SuDS) would be incorporated into the scheme as well as 2 outfall points into the watercourse to drain the site. The features described above also offer habitats to support biodiversity and would enhance the environment by adding a water element to the scheme. The water detention centre, when not in use for water storage, would be designed to allow its use for other purposes.

3.22 Foul water would be collected in a tradition pipe network connecting to the existing Anglian Water sewers in Hullbridge Road. The pipe network would be offered to Anglian Water for adoption.

3.23 The drainage system on site has been developed in line with LLFA guidance and SuDS manual and is considered to appropriately address floods and drainage issues. Further refinement of the systems would be undertaken as the proposals progress.

4.0 Conclusion

4.1 These representations have been prepared on behalf of Crest Nicholson Eastern in respect of Land at Lubards Lodge Farm, Rayleigh for consideration in the Rochford Issues and Options Local Plan consultation of March 2018.

4.2 In order to achieve the vision and strategic priority 1 as detailed in the emerging Local Plan, development on the site is required. Significant employment growth is identified in the JAAP and in the wider South Essex sub-region. Housing delivery must match this growth.

4.3 Other neighbouring and nearby Green Belt local authorities are planning for their full OAHN within their Plan areas and there is no sound reason why Rochford should do otherwise.

4.4 In spatial strategy terms, a smaller number of large urban extensions would be the most sustainable approach for addressing this need, particularly in Rayleigh taking account of its sustainability and subsequent position at the top of the settlement hierarchy.

4.5 The Land at Lubards Lodge Farm is located in the Green Belt on the northern border of Rayleigh in a highly sustainable location, with access to the services and facilities within the town centre and the strategic road network and public transport links to London, wider south Essex and Southend airport. Within single ownership, the land is unencumbered and represents an excellent location for strategic scale residential development.

4.6 We would support the Council to undertake a Green Belt review of the district. This would confirm the Green Belt function of potential development sites including the Land at Lubards Lodge Farm and thereby justify strategic planning choices as part of the emerging Local Plan. We consider that Lubards Lodge Farm is the most suitable site for strategic scale residential development at Rayleigh. It also provides a unique opportunity to deliver significant community uses for the town's
existing and future residents.

4.7 A significant amount of preliminary assessments and appraisals have been undertaken to date and all conclude that development is entirely achievable on site. The Vision Document accompanying these representations at Appendix 2 provides further detail and shows the proposed initial masterplan for the site. Crest Nicholson specialises in the design and construction of high quality, community-led residential schemes and will continue to work with RDC and the local community to develop this vision for the site.