Drafting our Strategic Objectives

Strategic Objective 15: we note the aim to protect and enhance multi-functional green infrastructure and that this links in with health and wellbeing. We would like to see embedded within this Strategic Objective the aim to ensure such infrastructure is accessible to as many user groups as possible, including equestrians who are often overlooked when such infrastructure is planned. We would like to see this reworded thus: '...and to support the delivery of a fully-accessible multi-functional green infrastructure network...'

Strategic Objective 1: To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs, through prioritising the use of previously developed land first.
Have you prioritised the use of previously developed land? This does not appear to be the case to local residents who can see that land not previously developed is being used.

Strategic Objective 9: To ensure that all new homes and commercial premises are supported by appropriate, timely and necessary infrastructure to mitigate potential impact, including those relating to transport, utilities, telecommunications (including broadband), open spaces and greenways, flood risk, education, health and other community facilities.
How can we deliver such improvements over the next 20 years? Infrastructure is key and should be put in place prior to any new homes etc but why is it not being delivered?

Strategic Objective 10: To work with our neighbouring authorities in South Essex and beyond, and Essex County Council, as the highway authority for our district, to deliver meaningful improvements to the strategic and local highway network.

'Meaningful improvements' is the key phrase here - how can we improve sustainable travel for our local communities over the next 20 years?

Strategic Objective 11: To facilitate a change in the way residents travel through encouraging walking, cycling and the use of passenger and public transport - and interchanges between them - reducing out-commuting wherever possible...

In Hullbridge, only a small proportion of inhabitants work in the village, most of them 'out-commuting' to other parts of Essex or London. They walk and cycle within the village environs but it is not possible for them to cover large distances to work places. How are we going to encourage people to reduce their 'out-commuting' when public transport is expensive and sometimes unreliable?

Strategic Objective 13: To plan for effective flood risk and coastal change management across the district and working with Essex County Council as the Lead Local Flood Authority, Anglian Water, and the Environment Agency in the delivery of improved drainage infrastructure and sustainable drainage solutions.

How do we address water and flood risk management over the next 20 years? Apparently, Watery Lane has had some flood risk improvements but there is still evidence of flooding in the area. There are also flood risks to parts of the river Crouch in Hullbridge that need to be addressed.

Strategic Objective 15: To protect and enhance leisure, sport, recreation and community facilities and to support the delivery of a multi-functional green infrastructure network across our district and along the coastline, connecting to neighbouring areas in South Essex and beyond, to promote healthy and active lifestyles, and improve physical and mental health and well-being.
How do we continue to safeguard existing community facilities and support the delivery of new facilities that are actually wanted? For instance, RDC seems to think that more skateboard parks are vital in their planning but in reality this is not the case.

Strategic Objective 19: To protect, maintain and enhance our district's natural environment, geology and biodiversity, including our open spaces, recreational areas and our extensive coastline, as well as support wildlife, to create habitat networks and reduce fragmentation.
How do we do this when the RDC is planning reduction of open space and precious riverside, and wildlife habitats are getting smaller and smaller? What happens to the wildlife that is forced out of its natural habitat owing to increase in building?

Strategic Objective 20: To ensure that our district's Green Belt continues to serve its five purposes, in particular retaining the openness of the area, protecting valued landscapes.... retaining the physical separation between our towns and villages....

How do we do this when proposed building will destroy the openness of the area, take away valued landscapes and reduce the physical separation between towns/villages so that they merge into one another? We moved to a village as we wanted to live in a village, not a town and this choice is being taken away from us.

Strategic Objective 22: To mitigate and adapt to the forecasted impacts of climate change, including the water environment, air quality, biodiversity and flooding, support more efficient use of energy and natural resources and facilitate an increase in the use of renewable and low carbon energy facilities.
How do we manage air quality issues, flooding etc in the future?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

6.33 Option: A

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

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

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

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

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

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

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

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

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

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

Tell Us More SP1.6: Houseboats Option B

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Tell Us More SP3.3: Communications infrastructure Option B

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

Tell Us More SP3.5: Renewable energy Option A

Tell Us More SP3.6: Planning Option A

Tell Me More SP4.1: Health Option D

Tell Me More SP4.2 Community facilities Option B

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

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

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

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

Tell Me More SP4.5: Young people Option A

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

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

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

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

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

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

Tell Us More SP5.5 Heritage and culture Option A

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

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

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

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

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

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

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

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

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

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

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

Tell Us More D.P1.5 Basements
Option A

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

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

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

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

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

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

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

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

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

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

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

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



Interim Sustainability Appraisal

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

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

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




Appendix

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

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

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

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

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

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

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

Chelmsford City Council (CCC) welcomes the opportunity to comment on Rochford District Council's Issues and Option Document 2017 to help influence the emerging document and monitor the key cross-boundary and strategic issues that affect CCC's administrative area.

The draft strategic objectives that Rochford District Council consider will help deliver its new Local Plan are set out at paragraph 5.11 of the Issues and Options Document. Strategic Objective 1 addresses housing delivery which is to be achieved by prioritising the use of previously developed land and working with neighbours in the South Essex. It is unclear if Rochford District Council intend to meet its local housing need in full or will be looking to other local authorities to meet some of its housing need.

Paragraph 47 of the NPPF requires local planning authorities to meet their full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the policies set out in the Framework. Rochford District Council should be satisfied that it can justify the shortfall in housing numbers and should seek to make provisions to meet deficiencies within their Local Plan over the plan period. Any deficiencies and mechanisms to address unmet need should accord with the Essex Planning Officers' Association Guidance 'Mechanism for the Consideration of Unmet Housing Need' which has been agreed by authorities across Essex.

Equally, Rochford District Council should seek to meet employment needs of the district in full over the next 20 years.

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.

Thank you for the opportunity to comment on the Rochford Local Plan Issues and Options consultation document. The following response is submitted on behalf of Anglian Water as sewerage undertaker for Rochford District.

I would be grateful if you could confirm that you have received this response.

Tell Us More: What do you think the new Local Plan should be trying to achieve, and why?

We are supportive of Draft Strategic Objective 13 which relates to Anglian Water's water recycling infrastructure but would ask that the Local Plan policies expands on this issue and emphasises the use of sustainable drainage systems (SuDS) as the preferred method of surface water management and that the timing of development is aligned with sufficient water recycling infrastructure. (Please see comments relating to Question SP3.4 and SP3.6).

Tell Us More 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?

Six potential options or a combination of the available options are identified as being a realistic strategy for the delivery of new homes. We would welcome further discussion with the Council about the distribution of additional housing and the implications for Anglian Water's existing infrastructure and the extent to which there is a need for new or improved infrastructure.

Tell Us More SP3.4: How do we address water and flood risk management over the next 20 years?

Reference is made to principal risks of flooding being from rivers, the sea and surface water within the district but not the risk of flooding from sewers. We would ask that the new Local Plan includes a specific policy on flood risk and water management which includes the following requirements:

* Applicants to demonstrate that capacity is available within the public sewerage network and receiving water recycling centre (formerly sewage treatment works) in Anglian Water's ownership or can be made available in time to serve the development.
* Sustainable Drainage Systems (SuDS) to be identified as the preferred method of surface water disposal and that it is considered as part of the design of new developments and re-developments. The policy should also ensure that applicants provide evidence as part of the planning application that they have followed the surface water hierarchy as outlined in the National Planning Practice Guidance. With surface water connections to the public sewerage networks being allowed only on an exceptional basis where alternatives are shown to be technically unfeasible.
* That suitable access is safeguarded for the maintenance of existing drainage infrastructure following development.

Reference is made to a recommendation on the Council's Environmental Capacity Study that the existing Water Cycle Study published in 2011 should be updated. In the event that the District Council is intending to commission an updated Water Cycle Study we would welcome further discussion with the District Council about the scope of any technical work. We are currently preparing a Water Recycling Long Term Plan currently being prepared which will set out Anglian Water's long term strategy for water recycling centres and sewerage catchments and is expected to be published in Summer 2018.

We would welcome further discussions with the Council relating to any further technical work relating to water recycling infrastructure which is to be commissioned following the preparation of the Outline Water Cycle Study.

Tell Us More SP3.6: How do we deal with planning obligations and standard charges to support the delivery of new homes and jobs over the next 20 years?

The focus of this question is on the use of planning obligations and standard charges to provide infrastructure to support the delivery of development within the district. Anglian Water as a sewerage company seeks charges directly from developers under the provisions of the Water Industry Act 1991 as such we would not make use of planning obligations or standard charges under Planning Legislation for this purpose. Further information relating to the charges which will come into effect from 1st April 2018 is available to view at the following address:

http://www.anglianwater.co.uk/developers/charges/

However we would ask that any Local Plan policy relating to planning obligations/standard charges also emphasises the need for phasing and the use of planning conditions/obligations to ensure development is aligned with the provision of infrastructure for this purpose. Therefore we would ask that the following wording or similar be included in the Local Plan:

'Consideration must be given to the likely timing of infrastructure provision. As such, development may need to be phased either spatially or in time to ensure the provision of infrastructure in a timely manner. Conditions or a planning obligation may be used to secure this phasing.'

We would welcome further discussion with the District Council relating to the wording of the Local Plan policies relevant to Anglian Water prior to the next formal stage of the preparation of the Local Plan.

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

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

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

Until Rochford Council has fully assessed the policy constraints and capacity within the district it is unclear whether there is a potential unmet need. Furthermore Rochford Council will need to consider any implications of unmet need arising from other authorities in the housing market area.
Thurrock Council requests to be kept informed of any shortfall of housing provision arsing in Rochford during the preparation of the New Local Plan. Such matters will be increasingly be considered as part of the joint working arrangements and preparation of the South Essex joint strategic planning including the ongoing development of the evidence base and monitoring.
Thurrock Council also supports the approach of Rochford in Option 2 of SP1.1 of working with other Councils across South Essex to address the strategic cross-boundary matters such as housing need and distribution and unmet housing need. This key strategic issue will be considered as part of the joint strategic planning and as this will provide a strategic framework to inform the emerging Rochford Local Plan.
Rochford Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a spatial options study including a high level housing land and capacity assessment and further infrastructure studies.
The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Rochford District and the approach to be taken in the New Local Plan.
SP1.3:- How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district.
Thurrock Council supports the approach that Rochford Council has identified in the Issues and Options document with the six potential options representing realistic ways to deliver the additional homes required in the district. It is considered that a combination of a number of these options for delivering housing supply are likely to provide the source of housing capacity to meet OAHN for the plan period.
The 2017 Rochford Council SHELAA sets out that currently the Council land trajectory has identified there is sufficient suitable, available and achievable land to deliver a total of 3499 dwellings with most having planning permission but also including an additional 935 dwellings on land identified through existing allocations without permission or other sites assessed though the SHELAA, the call for sites and are predominantly on urban land.
As noted in the Issues and Options document there is currently insufficient appropriate sites to accommodate the projected OAHN for Rochford during the plan period and sourced from the urban area. In seeking to assess the potential options to accommodate the shortfall in housing supply the Council will need to carefully consider the balance between the levels of housing need and the environmental capacity and other policy constraints.

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

Strategic Priority 1:

The scale of the proposed development in Hullbridge is disproportionate. The village atmosphere will be lost. If housing is to be developed it should be in keeping with the existing housing stock. Given the ageing population, it would be a good idea to build a good selection of bungalow style accommodation. This should be of good quality and in a modern design. The dwellings should be totally energy efficient with solar panels, under floor heating, LED lighting, excellent insulation etc.

Strategic Priority 2:

The current leisure facilities are very limited and thought needs to be given as to how this can be improved? A Swimming pool and Gym would be ideal.
Open spaces need to be preserved to allow for sporting events to continue- football, rugby, netball. With the obesity crisis we need to encourage both young and old to be more active. Better walkways along the river. Bicycle tracks etc.

Strategic Priority 3:

The infrastructure needs to be upgraded BEFORE new houses are built. One minor collision on Lower Road can lead to huge traffic jams (look at Canvey Island to see how bad the road situation can be.) We need better roads, and we desperately need a better rail service into London. If the housing stock is aimed more at retired people this will alleviate some of the transport problems. At present during rush hour Rayleigh Station is the last place that you can get a seat on the train. People are standing at Wickford. Hundreds more houses in Hullbridge cannot be supported by the current rail network.

Strategic Priority 4:

It goes without saying that new doctors, clinics, schools will be needed. We cannot cope with the influx without this infrastructure being in place BEFORE development goes ahead.

Strategic Priority 5:

The green belt is vital to protect us all. Flooding is often observed down Watery Lane (the clue is in the name!) The huge open area already earmarked is going to have a detrimental effect to the wildlife in the area.

Please think about the existing residents of Hullbridge, many of whom have lived here for most of their life. Some small scale, sensible development would be welcome but not the vast swathes the council has agreed to.

In summary:

* The plans should be scaled back to a more manageable level
* More thought given to the types of housing. Eco friendly modern bungalows would be more desirable and less of a blot on the landscape.
* Infrastructure must be upgraded before any development goes ahead.

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

3. OUR CHARACTERISTICS

Our Economy

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

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

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

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

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

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

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

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

4 Our spatial challenges

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

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

5. OUR VISION AND STRATEGIC OBJECTIVES

5.11 Drafting our Strategic Objectives

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

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

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

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

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

6 Delivering Homes/Jobs

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

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

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

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

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

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

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

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

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

6.30 I agree Option C seems the most practical.

6.30 and 31 Problem seems insoluble.

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

7 Supporting Commercial Development

7.12 Retail/Leisure/Town Centres

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

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

8 Delivering Infrastructure

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

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

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

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

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

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

8.20 Options

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

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

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

What are the identified issues?

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

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

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

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

Water and Flood Risk Management

What are the realistic options?

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

Planning obligations and standard charges

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

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

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

9 Supporting Health, Community an Culture

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

9.11 What are the realistic options?

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

Community Facilities

What are the identified issues?

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

Options

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

Education and Skills

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

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

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

10 Protecting an Enhancing our Environment

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

10.16 Options

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

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

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

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

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

10.52 Options

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

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

11 Detailed Policy considerations

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

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

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





Light Pollution

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

1. INTRODUCTION

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

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

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

2. ECC Interest in the Issues and Options Consultation

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

3. DUTY TO CO-OPERATE

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

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

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

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

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

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

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

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

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

4A Summary

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

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

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

4B ECC Detailed Response to the Issues and Options Consultation

INTRODUCTION (SECTION 1)

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

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

TELL US YOUR VIEWS (SECTION 2)

Next Steps

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

OUR CHARACTERISTICS (SECTION 3)

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

Our Economy

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

Our Communities

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

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

National Picture

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

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

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

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

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

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

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

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

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

OUR VISION AND OBJECTIVES (SECTION 5)

Draft Vision

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

Strategic priorities

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

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

Strategic Objectives

SP1 The homes and jobs needed in the area

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

SP 2 Provision of retail, leisure and other commercial development

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

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

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

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

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

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

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

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

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

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

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

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

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

SP5 Climate Change and Environmental protection and mitigation

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

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

DELIVERING HOMES & JOBS (SECTION 6)

ECC General Comments

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

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

SP1.1 Need for Market, Affordable and Specialist Homes

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

ECC Comments

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

Affordable Homes

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

ECC Comments

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

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

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

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

ECC Comments

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

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

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

Homes for Older People and Adults with Disabilities

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

ECC Comments

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

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

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

SP1.2 Care Homes

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

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

ECC Comments

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

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

SP1.3. Delivering our Need for Homes

ECC General Comment

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

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

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

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

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

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

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

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

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

ECC Comments

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

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

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

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

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

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

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

SP1.4 Good Mix of Homes

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

ECC Comments

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

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

SP1.5 Gypsy, Travellers and Travelling Showpeople

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

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

SP1.6 Houseboats and Liveaboards

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

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

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

ECC Comments

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

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

SP1.7 Meeting Business Needs;

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

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

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

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

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

ECC Comments

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

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

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

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

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

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

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

SP1.8 Need for Jobs;

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

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

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

ECC Comments

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

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

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

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

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

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

ECC Comments

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

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

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

SP1.10 Supporting Tourism and Rural Diversification

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

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

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

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

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

Paragraph 6.128 Options for tourism and rural diversification:

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

ECC Comments

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

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

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

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

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

SP2.1 Retail, Leisure and Town Centres

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

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

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

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

SP3.1Highways Infrastructure

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

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

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

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

Paragraph 8.20 Options for the Local Highway Network:

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

ECC Comments

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

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

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

Strategic Highways Network Transport

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

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

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

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

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

SP3.2 Sustainable Travel

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

ECC Comments

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

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

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

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

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

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

SP3.3 Communications Infrastructure,

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

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

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

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

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

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

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

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

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

SP3.4 Water and Flood Management,

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

ECC Comments

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

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

SP3.5 Renewable Energy Generation

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

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

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

ECC Comments

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

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

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

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

SP3.6 Planning Obligations and Standard Charges;

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

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

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

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

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

ECC Comments

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

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

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

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

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

SUPPORTING HEALTH, COMMUNITY AND CULTURE (SECTION 9)

SP4.1 Health and Well-being;

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

ECC Comments

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

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

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

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

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

SP4.2 Community Facilities;

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

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

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

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

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

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

SP4.3 Education and Skills;

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

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

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

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

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

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

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

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

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

ECC Comments

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

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

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

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

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

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

SP4.4 Early Years and Childcare Provision;

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

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

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

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

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

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

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

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

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

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

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

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

SP4.5 Open Space and Outdoor Sports and Recreation

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

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

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

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

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

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

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

SP4.6 Indoor Sports and Leisure Centres

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

ECC Comments

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

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

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

SP4.7 Facilities for Young People;

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

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

SP4.8 Play Space Facilities;

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

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

PROTECTING AND ENHANCING OUR ENVIRONMENT (SECTION 10)

Paragraph 10.1 Overall ECC welcomes the Strategic Priority SP5

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

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

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

SP5.1 Green Belt

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

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

Paragraph 10.16 Options in relation to the Green Belt:

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

ECC Comments

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

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

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

SP5.2 Biodiversity, Geology and Green Infrastructure

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

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

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

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

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

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

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

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

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

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

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

ECC Comments

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

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

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

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

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

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

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

SP5.3 Wallasea Island and the RSPB Wild Coast Project

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

ECC Comments

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

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

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

SP5.4 Landscape Character;

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

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

ECC Comments

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

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

SP5.5 Protecting and Enhancing Heritage and Culture

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

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

SP5.6 Good Design and Building Efficiency

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

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

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

ECC Comments

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

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

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

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

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

ECC Comments

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

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

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

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

SP5.7 Air Quality

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

Paragraph 10.72. Options in relation to Air Quality:

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

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

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

DETAILED POLICY CONSIDERATIONS (SECTION 11)

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

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

D.P1.1 Mix of Affordable Housing

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

ECC Comments

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

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

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

ECC Comments

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

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

DP1.10 Parking standards and Traffic Management

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

ECC Comments

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

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

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

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

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

D.P1.11 Home Businesses

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

ECC Comments

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

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

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

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

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

DRAFT SUSTAINABILITY APPRAISAL

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

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

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

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 INCLUDES AN ATTACHMENT*

We submit these representations to the Regulation 18 consultation on the Rochford Local Plan in support of the site, land south of Eastwood, Rayleigh (as shown on the site location plan).
Representations to the Regulation 18 consultation on the Rochford Local Plan
The consultation is centred around nine questions. We set out our initial comments in respect of these themes, which should be considered by the Council in its plan making, below.

Strategic Priorities for the Local Plan

In the first instance, the district is required to plan to meet its objectively assessed needs. The objective of the plan, and the resultant spatial strategy should be to meet the needs of the district within the district. This is the approach the NPPF sets out that Councils should undertake in their plan making. Paragraph 14 of the NPPF outlies that at the heart of the NPPF is a presumption in favour of sustainable development, which for plan-making means that authorities should 'positive seek opportunities to meet the development needs of their area' and that 'Local Plans should meet objectively assessed needs' in most instances. Paragraphs 150-157 set out the core principles for plan-making. The paragraphs emphasise that Local Plans should be prepared with the objective of contributing to the achievement of sustainable development, and opportunities to achieve economic social and environmental dimensions of sustainable development should be taken.
We are supportive of the Housebuilders Federation (HBF) representations to the Local Plan, which set out that the district needs to properly establish their full objectively assessed housing needs, and that better working must occur across the HMA and with the South Essex HMA authorities in order to satisfy their duty to cooperate (as required by the NPPF).

Green Belt

It is important that evidence base documents, including a Green Belt review, should inform, not dictate the shape and nature of the Local Plan. The development of Local Plan strategies, to be appraised through the Sustainability Appraisal should be the product of analysis of the compressive evidence base by planning officers and their colleagues. From the strategy set out, we are not clear whether this is recognised and planned for. We are keen to reiterate that the Local Plan should allocate sites, which can promote sustainable patterns of travel, create safe inclusive communities and economic prosperity, through sustainable development.

Building More Homes

Whilst environmental constraints should be a consideration in planning to meet housing needs, they should not preclude trying to meet the district's full needs. The Council should seek to positively meet its needs within the district, and look at where needs can best be met, in the event the full needs cannot be met. The HBF representations support this approach.

*THIS REPRESENTATION INCLUDES SEVERAL ATTACHMENTS*

New Local Plan 2018. Issues and Options Documents

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

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

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

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

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

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

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

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

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

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

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

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

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

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


Section 1 (cont).

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

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

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


Section 1 (cont).

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

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

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

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

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

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

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

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


Section 3 (cont

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

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

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

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

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


Section 3 (cont.

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

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

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

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

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

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

Section 4

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

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

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

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

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

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

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

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

Section 5 (cont

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

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

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

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

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

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

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


Section 6 (cont

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

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

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

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

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

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

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

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

Section 6 (cont

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

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

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

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

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

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

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

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

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

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

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

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

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

Section 8 (cont


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

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

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

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

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

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

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

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

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

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

Page 156. Extensions etc. No comment

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

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

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

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

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

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

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

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

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

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

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

"Drafting our Strategic Objectives"

Strategic Objective 14: change healthcare providers to healthcare commissioners and providers include this as an additional Strategic Objective: Ensure new developments consider the Health and Wellbeing principles of the Essex design guide

Section 6

Section 6 - 6.2 - replace "affordable homes" with 'affordable homes including key worker housing'

"Need for Care Homes"

Add: Planning for care homes should be in conjunction with the health economy and take account of the additional health needs of the residents

Section 8

8.42 - regarding broadband - reference importance of fast, reliable broadband for health services to enable health care delivery in the community

Section 9

Above 9.11 use heading 'Recruitment and Retention of Health

Option B. (in table) - replace text in first column with 'Ensure that land is specifically allocated to healthcare where required'

Section 9 (cont'd)

Option C. (in table) - please not we will not support this option

9.15 - Can these be utilised as meeting space for home based businesses and mobile working?

9.5 - after "50 homes or more" insert 'in one or more phases of development

Include in text in 9.5 - 'care homes and independent living schemes should also propose suitable mitigation measure'