How do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

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.

6.8/6.9 OAN figures indicate that Rochford district needs 330-360 new homes per year BUT potential constraints such as environmental capacity, land availability, development viability, infrastructure capacity and other considerations set out in the NPPF will need to be taken into consideration when setting an appropriate and achievable housing target for our district.
Such constraints must be taken seriously if RDC genuinely aims to remain a green and pleasant place to live and to offer people a high standard of health and well-being. Is the housing target really appropriate for our district?

6.10 'our OAHN is a measure of our housing needs, but not equivalent to our future housing target, it is for the Local Plan to establish how many new homes can actually be delivered given the constraints of the district'
This means that we have a voice in determining how many new homes can be delivered in the area and RDC must listen to our voice. The constraints of the district are already mentioned in the South Essex SHMA + 'Environmental Capacity Study' stating that it's 'uncertain that the district has environmental capacity to accommodate this level of growth'.

6.12 The South Essex SHMA 2016 highlights that in 2014 the affordability ratio for our district was 9.7, the highest in South Essex, and substantially higher than England average of 6.9. Affordability is, therefore, a significant concern which needs to be addressed. The 2017 Addendum identifies that there is a need for around 296 affordable homes per year up to 2037 in our district ...
so that would mean the majority of new homes would need to be affordable. It is odd then, that new flats in our area, deemed affordable, are continually for sale or to let.

6.13 The Core Strategy requires affordable homes to be delivered as a proportion of the housing capacity of sites i.e. 35%.
How do we ensure that affordable homes meet the needs of our residents over the next 20 years?

The target of 240 homes per year between 2026 and 2031 from South Essex SHMA and comments from the Environmental Study 2015, states that it is uncertain that the district has the environmental capacity to accommodate this level of growth. The study, concludes that it is uncertain whether the cumulative impacts of even small-scale development of new homes would be acceptable.
It is important to remember this when planning applications for in-fill sites are put forward because they accumulate and add to the over crowded area, placing additional pressure on the district.

6.28 Any growth in the district has the potential to impact on the local environment. The Environmental Capacity Study 2015 considers a range of environmental factors including air quality, climate change, land, soils, minerals, water (resources, quality and flood risk), biodiversity, and the health and well-being of people.
How do we manage these issues effectively? Building significant numbers of new homes impacts negatively on the local environment. How can we maintain good levels of air quality and the health and well-being of people if there is less room to move and breathe?

RDC appears beholden to developers, look at the new homes along Hall Road Rochford and the homes on the old mushroom farm (pond chase) these are not 'affordable homes' or homes for local people these are large properties developed purely to maximise the profit for the home builder which only those moving out from London can afford. You provide lip service to affordable homes but in reality you allow the developers to change plans at the last moment (dropping amenities) to make the development profitable, which frankly shouldn't be a concern for local council. We need housing which is affordable to local people not 4/5 bedroom detached monstrosities.

At the moment there is a strong bias in planning decisions for over development of plots in order to meet national targets and possibly maximise council tax returns, however with an ageing population there is a stronger need for more bungalows. While lip service is paid to this need, there appears no tangible evidence that priority is being given to the development of bungalows in the district. Building bungalows is probably not as profitable for large developers as building larger multi-story housing but smaller developers may well be interested in doing so. However the predisposition within the planning department for larger development as this is more administratively convenient means that it is highly unlikely that there will be the number of bungalows built that are needed.

I would like to comment on the Issues and Options document as follows:

1) As Rayleigh is already at breaking point on the roads for most of the day, expanding it would be detrimental to the existing residents. Would it not be more beneficial to create a new town/village (or several), rather like the garden cities that have been hugely successful? This would enable you to create the roads/drainage/sewerage/open spaces that would compliment the housing that would be built and be able to sustain it. These could have their own character and be designed with people in mind. There could be areas for business, leisure, clubs, create cycle paths, space for allotments, and you could use renewable energy schemes throughout. This new area (s) would need to be somewhere where Rayleigh wasn't the only access to it. Building this type of scheme would reduce the increase in pollutants that would occur should any increase in building were to take place in Rayleigh. You must ensure that there is adequate greenbelt borders to stop urban sprawl. You also need to make available various entrance/exit routes to avoid bottlenecks and rat runs.

2) Any new houses built should have ample parking. New builds now days tend to build garages that are not big enough for a modern day car. You also seem to stick to the minimum of 2 parking spaces per dwelling, even when it is a 4-6 bedroom house. You then push parking onto the road network. This can be avoided if you implement rules into your documents.

3) Reduce the building of 4-6 bedroom houses. You only make an area exclusive when this is all you offer. The building companies favour this size house and only offer up 1-2 bedroom flats in their "affordable" range. What we need are 1, 2 & 3 bedroom houses for families (and your homeless department state that there are a shortage of 2 bedroom houses). The young CANNOT move out of the family home as the houses are NOT affordable for them, even with Government schemes. If they are lucky, they may be able to find somewhere miles away from their family and support networks. We need a mix of house sizes and this should be enforceable.

4) Many building companies create "boxes" that are fairly generic. We need to have houses that have character, otherwise we will be looking back and comparing what we are being given now like we do with the concrete monstrosities of the 1970's building estates.

5) The infrastructure of Rayleigh will be unable to cope with the amount of housing that you are obliged to provide. The road networks are almost at collapse, many with poor surfaces and pot holes (the criteria to repair them being amended all the time to the detriment of the road users). Who thought it was correct to cover a concrete road with tarmac? We now have roads that have both surfaces, the tarmac reducing all the time from the concrete (which does not adhere well together). Building in Rayleigh means that more traffic will pass through (or try to). Maybe you should be considering building a ring road around Rayleigh or another road that will link the A1245 to Hullbridge? More houses means more people, meaning that we will need more school places to be provided from nursery to 6th Form. How will this be achieved? What about GP's? We cannot get an appointment when we are ill now. More people on the Doctors list means longer waiting times. I suppose that eventually, people will in fact die from waiting to see their GP. That will reduce the population in Rayleigh!!! Cynical maybe. We need investment into GP's or Medical/Heath Centres, Schools, etc.

6)We need areas of provision for our residents who become homeless and we also need to provide smaller accommodation especially for our elderly residents who wish to downsize. There is a shortage of these type of properties. By having these available, the elderly can release their bigger houses into the market (reducing the need to build large houses) and move into these specially adapted dwellings. You would need a covenant on them to stop any of them being extended, and be purely for the "over 60's/70's etc.

7) Our car parks do not have the capacity now for residents at busy periods. how will they cope when there are thousands more houses?

8) The recycling centre in Castle Road cannot cope now so how will it be able to provide a service with even more households using it? It opens too late for people to use it on their way to work and it closes several times during the day in order to change over containers, thus causing long, road blocking queues (and pollution).

9) I noticed that our bordering Councils may not be able to meet their requirements and may request that some of their need be taken on by their neighbours. WE CANNOT take on the housing quotas for Southend and Castle Point. We have our own problems. We can also NOT be able to provide even more sites for travellers, we have several illegal sites now. We do not want another Crays Hill! If we compare the needs of these site residents, wanting to keep their expanding communities together, we must ask why they have not settled like the rest? My children cannot buy in Rayleigh. One has had to go to Basildon, the others are at home with no chance of affording to rent, never mind buy. We are all people. Why be treated differently? Could you provide my family somewhere they can live near me? No! But this is a requirement for other communities, which is discrimination.

In regard to Table 3, given the lack of delivery of housing in the district over the planning period, it is advanced that the authority should adopt the upper end of the range of objectively assessed need in compliance with Part 6 of the National Planning Policy Framework. On behalf of Southern & Regional Developments, Claremont Planning suggest that the adoption of a higher range will enable the Council to be more ambitious and set a higher target that may be more successful in delivering growth and addressing housing need; which has been inconsistently met over the past decade, as is illustrated in Figure 9 of this options document. This will also ensure that the LPA can meet any recognised cross-boundary need from the South Essex authorities, in line with the Duty to Cooperate obligations as set out in the National Planning Policy Framework.

The Issues and Options document notes that the latest evidence on objectively assessed need is for between 331 and 361 homes per annum, which is similar albeit slightly less than the draft standard formula of 361 homes per annum.

We notice that one of the options postulated for meeting that need is to work collaboratively with neighbouring districts, with the implication being that there is a feasible option by which some of Rochford District Council's needs might be met in neighbouring areas. The Council will be aware that its neighbouring authorities all share similar constraints to Rochford District itself, and none are in a position whereby they would willingly accommodate unmet need from within Rochford district, and in actual fact are more likely to be seeking the reverse. Working collaboratively therefore is not a solution to meeting locally arising housing need.

We also note that the Issues and Options consultation notes in several places that the objectively assessed housing need figure should not be seen as a housing requirement, but as an objective that needs to be balanced against other relevant criteria, and in this respect, the Issues and Options report makes reference to the findings of the 2015 Environmental Capacity Study. The suggestion is made that this piece of work provides evidence that there are substantive environmental constraints that would prevent even 1,440 homes over and above the adopted Core Strategy, let alone the 7,000+ homes that the SHMA is suggesting would be required up to 2037.

There are three problems with the Council's reliance on the 2015 Capacity Study, which are:

1. It does not provide any conclusive evidence - what the report actually says is that, using the limited information available, it is "uncertain" that environmental capacity exists and that its conclusions are "subject to review". It states " ... Ultimately the precise location and scale of development will determine the significance of impacts". Put simply, this high level and limited piece of work as it stands does not support or provide sufficient evidence to sustain delivering anything less than the full objectively assessed need for housing;

2. Even were the 2015 Capacity Study determinative of an identifiable environmental limit, the starting point for the Council would not be to reduce the amount of new homes to be built, but to investigate how, through new development, measures could be put in place to mitigate the effects of development to resolve that conflict. This is recognised in the report itself, which states "... Mitigation will also play an important role in helping to reduce the impacts of development and increase the potential for certain areas to accommodate further growth.";

3. Even if it could be demonstrated that a particular environmental limit were breached and could not be mitigated, the Council would be required to show how its unmet need could be addressed elsewhere. The recent failure of Castle Point's Local Plan under the auspices of the Duty to Co-operate should act as a salutary reminder of the difficulty faced by Local Planning Authorities seeking to provide less than their full housing need without being able to demonstrate that measures are in place for that need to be met elsewhere.

The Issues and Options report notes that affordable housing need in the local area exceeds what is likely to be deliverable, but that is even more of a reason for seeking to achieve the full OAHN requirement, to maximise affordable housing delivery and meet the widest range of need, rather than seeking to artificially reduce provision.

I would first like to say I don't to believe in consultations as they do not represents public opinion due to the lack of response from residents. This is mainly caused by making the online method too complicated with too many questions. The drop in presentation that were provided by RDC were pathetic with just two maps showing the areas put up for development. Is this the best RDC can do?

I would like to object to building any more homes on green belt land that joins existing villages an towns in Rochford District. The current building programme that runs until 2025 is already causing serious traffic jams on the existing roads with the resulting air pollution, even though building work has only just started. It has been stated that drivers in our area spend 30 hours per year in rush hour jams, the highest in our region. The second highest being Chelmsford at 23 hours per year.

I believe the existing infrastructure has taken on too much already and not just roads but services like electrics, gas, water, sewers and the health system, including the hospital, GP surgeries and dentists. RDC have indicated that they will include additional infrastructure this time but they have a very poor record on this so far, as the current increase in housing has produced practically none at all. I realise the reason for this is that additional housing comes from RDC and the infrastructure from Essex County Council (ECC) who provide the funds but so far this has not happened, as there aren't any.

We do need additional homes for our children to buy but unfortunately most are unaffordable and many end up being used to relocate people from London councils to relatively cheaper homes in our area. We also need retirement home developments in our area that would free up existing larger homes.

We live on a peninsular surrounded on three side by water, if we really have to have an additional 7,500 new houses in our district, I believe a new Garden Village could be located near South Fambridge and served by a new road from the north connecting to the B1012 would be the best solution. This road could cross the River Crouch near Fambridge linking to North Fambridge railway station.

If RDC allow more homes to be built adjacent to the existing B1013 and all the other already clogged up roads in our area, it will make the lives of our residents a misery and I believe they will not put up with it any more.

I object to the new local plan as follows:-

1. Loosing green belt which is a buffer to Hockley sprawl, and .
2. The problem with infrastructure has been ongoing for more years than I care to remember the situation in Hockley just gets worse with the Spa pinch point, low funding?
3. No spare capacity for Health and care facilities including Adult social acre let alone for 7500 extra houses.
4. The number of affordable homes home for rent needs to increase from 35% and include quads in this category .
5. The type of houses need to be moderated, so it is not mainly high end and expensive.
6. Fewer but larger sites
7. Please make the next stage of public consultation easier for all to use, the present site is too cumbersome.

I OBJECT to COL38 in Appendix C

1. In 2000 this Play space was given to Ashingdon Parish Council on a Peppercorn rent for 100yrs.
2. We now find it is called a Former Play Space.
3. It was registered with HM Land Registry Title No. EX739404 on 5th February 10.12.2004 as Malvern Road Play Space.
4. In Mr Martin Elliot's report on 1st December 2014 ( this was over a proposed Bridleway)
He stated :-The route across the play area is deemed a public right of way due to its use by pedestrians over a period of time, in his report (point 39) he records that there was significant concern expressed by the objectors (RDC and local residents) to the need to protect the public open space from development

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

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

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

General Observations

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

Duty to Co-operate

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

Housing Need

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

SP1.7: Meeting Business Needs

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

SP3.1: Highways Infrastructure

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

Draft Sustainability Appraisal of the Rochford Local Plan

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

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

This letter provides Gladman Developments Ltd (Gladman) representations in response to the Issues and Options consultation for the New Rochford Local Plan. Gladman specialise in the promotion of strategic land for residential development with associated community infrastructure and welcome the opportunity to comment at this early stage of the plan preparation. We look forward to assisting the Council and hope our comments are helpful and considered constructively to aid the development of a sound plan.
Gladman has considerable experience in the development industry in a number of sectors including residential and employment development. From that experience, we understand the need for the planning system to provide local communities with the homes and jobs that they need to ensure that they have access to a decent home and employment opportunities.
Gladman also has a wealth of experience in contributing to the Development Plan preparation process, having made representations on numerous local planning documents throughout the UK and having participated in many local plan public examinations. It is on the basis of that experience that the comments are made in this representation.
The National Planning Policy Framework sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order to prepare a sound plan it is fundamental that it is:
* Positively Prepared - The Plan should be prepared on a strategy which seeks to meet objectively assessed development and infrastructure requirements including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
* Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on a proportionate evidence base;
* Effective - the plan should be deliverable over its period and based on effective joint working on crossboundary strategic priorities; and
* Consistent with National Policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
The White Paper and Revised NPPF
The Government White Paper ('Fixing our Broken Housing Market') issued in February 2017 is a very clear statement from Government on the importance of the delivery of housing to the wider economy. The Government are in no doubt
that the housing market in Britain is broken which, according to the Prime Minister, is one of the greatest barriers to progress in the country today. Average house costs are almost eight times average earnings which is an all-time record and soaring prices and rising rents caused by a shortage of the right homes in the right places has slammed the door of the housing market in the face of a whole generation. The reason for this crisis is that the Country is simply not building enough homes and has not done so for far too long. The consensus is that we need from 225,000 to 275,000 or more homes per year to keep up with population growth and to start to tackle years of under-supply.
Everyone involved in politics and the housing industry therefore has a moral duty to tackle this issue head on. The White Paper states quite unequivocally that 'the housing shortage isn't a looming crisis, a distant threat that will become a problem if we fail to act. We are already living in it.' Tackling the housing shortage is not easy. It will inevitably require some tough decisions. But the alternative, according to the White Paper, is a divided nation, with an unbridgeable and ever-widening gap between the property haves and have-nots. The challenge of increasing supply cannot be met by government alone. It is vital to have local leadership and commitment from a wide range of stakeholders, including local authorities, private developers, housing associations, lenders and local communities. The starting point is building more homes. This will slow the rise in housing costs so that more ordinary working families can afford to buy a home and it will also bring the cost of renting down. We need more land for homes where people want to live. All areas therefore need a plan to deal with the housing pressures they face.
Currently, over 40 per cent of local planning authorities do not have a plan that meets the projected growth in households in their area. All local authorities should therefore develop an up-to-date plan with their communities that meets their housing requirement based upon an honest assessment of the need for new homes.
Local planning authorities have a responsibility to do all that they can to meet their housing requirements, even though not every area may be able to do so in full. The identified housing requirement should be accommodated in the Local Plan, unless there are policies elsewhere in the National Planning Policy Framework that provide strong reasons for restricting development, or the adverse impacts of meeting this requirement would significantly and demonstrably outweigh the benefits. Where an authority has demonstrated that it is unable to meet all of its housing requirement, it must be able to work constructively with neighbouring authorities to ensure the remainder is met.
Plans should be reviewed regularly and are likely to require updating in whole or in part at least every five years. An authority will also need to update their plan if their existing housing target can no longer be justified against their objectively assessed housing requirement. Policies in Local Plans should also allow a good mix of sites to come forward for development, so that there is choice for consumers, places can grow in ways that are sustainable, and there are opportunities for a diverse construction sector including opportunities for SME housebuilders to deliver much needed housing.
In terms of rural areas, the Government expects local planning authorities to identify opportunities for villages to thrive, especially where this would support services and help meet the need to provide homes for local people who currently
find it hard to live where they grew up. It is clear that improving the availability and affordability of homes in rural areas is vital for sustaining rural communities, alongside action to support jobs and services. There are opportunities to go further to support a good mix of sites and meet rural housing needs, especially where scope exists to expand settlements in a way which is sustainable and helps provide homes for local people. This is especially important in those rural areas where a high demand for homes makes the cost of housing a particular challenge for local people.
Finally, the Government have made it clear through the White Paper that local planning authorities are expected to have clear policies for addressing the housing requirements of groups with particular needs, such as older and disabled
people.
The White Paper is the cornerstone of future Government policy on fixing the broken housing market. It provides the direction of travel the Government is intending to take and is a clear statement of intent that this Government is serious
about the provision of the right number of houses in the right places. The Local Plan therefore needs to consider these policy intentions now in order to ensure that it fulfils the Government's agenda and provides the homes that its local communities need.
Following the election, Sajid Javid re-iterated the Government's intentions for boosting housing growth stating that he wants areas that have benefitted from soaring property prices to play their role in solving the housing crisis. Mr Javid
pointed out that where property prices were particularly unaffordable, local leaders would need to take a long, hard and honest look to see if they are planning for the right number of homes. Consultation on the new proposed standardised methodology for calculating housing need took place in late 2017. This has now been followed by consultation on a revised NPPF, which opened on the 5th March. The Council should therefore be very mindful of the changes this will entail to the plan preparation process to ensure the requirements of the new NPPF will be met when the final version is published and implemented later this year. Many of the changes consulted on in the Housing White Paper will be brought forward in the revised NPPF and this will assist the Council in determining its preferred options and also housing requirement as the plan preparation progresses.
Duty to Cooperate
The Duty to Cooperate is a legal requirement established through Section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. It requires local authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues throughout the process of Plan Preparation. If a Council fails to satisfactorily discharge its Duty to Cooperate, this cannot be rectified through modifications and an Inspector must recommend non-adoption of the Plan.
Whilst Gladman recognise that the Duty to Cooperate is a process of ongoing engagement and collaboration, as set out in the PPG it is clear that the Duty is intended to produce effective policies on cross boundary strategic matters. In
this regard, the Council must be able to demonstrate that it has engaged and worked with its neighbouring authorities, alongside the existing joint work arrangements, to satisfactorily address cross boundary strategic issues, and the
requirement to meet any unmet housing needs. This is not simply an issue of consultation but a question to ensure that the Housing Market Area's (HMA's) housing needs are met in full. Failure to satisfactorily discharge the duty to cooperate cannot be rectified by modifications and a Planning Inspector
must recommend non-adoption of the plan. An issue familiar within the Housing Market Area following Castle Point's withdrawal of its Local Plan after a failure to satisfactorily discharge the Duty to Cooperate. The revised NPPF will require
a statement of common ground between authorities within the HMA which would require the updating of the current memorandum of understanding between the authorities. This document currently lacks any certainty that housing needs will be met within the HMA and this will require clarification moving forward.
Sustainability Appraisal
In accordance with Section 19 of the Planning and Compulsory Purchase Act 2004, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA),and also incorporate the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA regulations).
The SA/SEA is a systematic process that should be undertaken at each stage of the Plans preparation, assessing the effects of the emerging proposals on sustainable development when judged against all reasonable alternatives. The Council should ensure that the future results of the SA clearly justify its policy choices. In meeting the development needs of the area, it should be clear from the results of this assessment why some policy options have progressed and others have been rejected. This must be undertaken through a comparative and equal assessment of each reasonable alternative, in the same level of detail for both chosen and rejected alternatives. The Council's decision making and scoring should be robust, justified and transparent.
Objectively Assessed Need
Gladman are concerned that the realistic options that have been identified for establishing the Objectively Assessed Needs and housing requirement for the plan are not actually realistic options and instead Options A and B are fundamental requirements for the plan making process whilst there is no sound basis for following option C.
Until the formal publication of the Government's standardised approach to assessing housing needs is published and implemented Gladman would suggest using the approach as established in the South Essex SHMA. This is currently considered to be a sound basis for assessing housing needs, with the upper range of the Objectively Assessed Need (OAN) for Rochford being a very similar figure to the standard methodology as currently proposed. Gladman suggest that this upper figure is aimed for now to reduce delay later in the plan preparation process. Whilst the Council are right to consider constraints on development within the Borough, environmental capacity should not be the sole reason for reducing its housing requirement. This is only one dimension of sustainable development and the Council should consider the social and economic benefits of housing delivery and whether these would outweigh the negative environmental impacts. Further, mitigation of these environmental impacts should be a consideration before deriving at the decision that the environmental capacity would not enable the delivery of full
objectively assessed housing needs. Should it be established that the Council cannot meet its own housing requirements this will require collaboration with
authorities in the HMA to ensure that these needs do not go unmet.
Affordable Housing
Gladman would suggest the use of a viability assessment to establish the level of affordable housing that will be sought in the Borough in the plan period. This should be at a level that does not affect the viability of development or push it to the margins. Until a viability assessment has been undertaken it is not possible to determine the correct approach to the level of affordable housing that should be provided. The level of affordable housing that development can reasonably support will vary in relation to the infrastructure required, the nature of the development strategy being taken forward and other policies in the plan, such as the optional technical standards.
Specialist Accommodation, Homes for Older People and Adults with Disabilities
The provision of specialist housing to meet the needs of older people is of increasing importance and the Council need to ensure that this is reflected through a positive policy approach within the Local Plan. The Councils need a robust understanding of the scale of this type of need across the Borough.
Specialist housing with care for older people is a type of housing which provides choice to adults with varying care needs and enables them to live as independently as possible in their own self-contained homes, where people are able to access high quality, flexible support and care services on site to suit their individual needs (including dementia care). Such schemes differ from traditional sheltered/retirement accommodation schemes and should provide internally
accessible communal facilities including residents' lounge, library, dining room, guest suit, quiet lounge, IT suit, assisted bathroom, internal buggy store and changing facilities, reception and care managers office and staff facilities.
Given the existing evidence in relation to ageing populations, and the national strategy in relation to housing for older people, Gladman recommend that the new Local Plan should include a specific policy in relation to the provision of specialist accommodation for older people. The following text provides an example of the type of policy which could be included in the new Local Plan:
"The provision of purpose built and/or specialist accommodation with care for older people in sustainable locations will be supported in Principle Settlements. Schemes should also be considered in other sustainable settlements where there is a proven need. Apartments should be restricted for occupation by only those with care needs, include minimum compulsory care packages, should also include age restrictions and an extensive range of communal facilities.
Schemes are expected to be promoted in partnership with an onsite 24/7 care provider to safeguard the delivery of care and support to residents.
Such schemes fall wholly within the auspices of C2 use, meet an otherwise unmet need for specialist accommodation for older people, deliver care and communal facilities and will not therefore be required to contribute towards affordable housing."
Delivering New Homes
Gladman suggest that a mix of options will be needed to ensure the delivery of the spatial strategy and housing requirement. To maximise housing supply the widest range of sites, by size and market location, are required so that house builders of all types and sizes have access to suitable land in order to offer the widest possible range of products.
The key to increased housing supply is that number of sales outlets. A wider variety of sites in the widest possible range of locations ensures all types of house builder have access to suitable land which in turn increase housing delivery.
Good Mix of Homes
Gladman do not consider it appropriate to set a target for the development of bungalows. Bungalows will have a much larger footprint than two and three-story homes of the same floor area and as such have a significant impact on viability
due to the reduction in the number of units that can be delivered on a site. The Council must also remember that there is a need to maximise development on each site and the delivery of bungalows will significantly reduce the capacity of each site. This will require the Council to release more land or set higher density targets than the 30 dwellings per hectare, as identified as an option on page 50, if it is to meet housing needs.
Green Belt
Gladman urge the Council to undertake a full review of the Green Belt within the Borough to identify areas that are no longer meeting the five purposes of Green Belt as set out in the Framework. Once established these areas should be considered for release from the Green Belt to help meet the OAN for the Borough. Without having undertaken this work the Council will not be able to justify not meeting its own needs, especially if other authorities indicate they will not be
able to help Rochford meet any unmet needs.
Conclusions
We hope you find these comments helpful and if you require clarification on any of the issues raised in this letter please contact me. If you could add me to your mailing list for the new Local Plan and any supporting documents I would be most grateful.

Issues and Options Document

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

6.33 Option: A

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

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

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

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

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

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

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

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

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

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

Tell Us More SP1.6: Houseboats Option B

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Tell Us More SP3.3: Communications infrastructure Option B

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

Tell Us More SP3.5: Renewable energy Option A

Tell Us More SP3.6: Planning Option A

Tell Me More SP4.1: Health Option D

Tell Me More SP4.2 Community facilities Option B

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

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

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

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

Tell Me More SP4.5: Young people Option A

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

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

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

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

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

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

Tell Us More SP5.5 Heritage and culture Option A

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

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

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

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

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

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

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

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

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

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

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

Tell Us More D.P1.5 Basements
Option A

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

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

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

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

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

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

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

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

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

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

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

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



Interim Sustainability Appraisal

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

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

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




Appendix

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

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

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

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

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

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

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

Maldon District Council Comments on the Rochford District Council New Local Plan: Issues and Options Document 2017
Forming the first stage of the Local Plan review, the Issues and Options Document identifies a series of strategic priorities and objectives to support the draft vision for the future of Rochford District. These are supported by key planning issues that have been identified for a number of themes, and potential options to deal with these issues.
Document Page, Policy and/or Paragraph Number Comments
Our Vision and Strategic Objectives
5. Our Vision and Strategic Objectives 5.8 Maldon Council supports a number of key ideas and themes that have come from paragraph 5.8. Improving the strategic infrastructure network is a shared objective for both authorities; the Southminster branch line holds a significant relationship with the Southend train line, which must be safeguarded and enhanced.
Delivering Homes and Jobs
Pg. 32. Para. 6.9 The revised OAN now expresses a range of between 331 and 361 homes per year. To effectively meet the revised OAN, all possible options must be considered including a review of Green Belt land. With the current pressures on housing need as a national issue, there needs a balance between serving strategic housing allocations and mitigating the consequences, such as loss of greenfield land.
Pg. 39. Para. 6.31 Provided the national threshold for affordable housing is 10 units or 1000sqm, which has been widely adopted by most local authorities, it would seem appropriate to use this threshold as local policy given the pressures on affordable housing as a national issue.
Pg. 56. Para. 6.86 Retention of or amendments to strengthen the existing policy would be supported by the Council. Any amendments which would be detrimental to the landscape, ecology and/or biodiversity of the River Crouch would be objected to.
Pg. 58. Para. 6.91 With a revised OAN of 6620-7220 homes from 2017-2037, the assessed need of up to 16 hectares of 'new' employment land between 2016-2036 would need to be appropriately situated to align with a vision that seeks increased provisions for sustainable transport and sustainable communities.
Delivering Infrastructure
Pg. 85. Para. 8.26 Although there are limitations on the level of influence local planning authorities have on the level of provision with regard to public transport, the level of provision is based on the use of services. When identifying strategic housing allocations within the district, this must be taken into consideration.
Protecting and Enhancing our Environment
Pg. 127. Para. 10.26 It should be emphasised that there will be a close working relationship between all contributing authorities in the preparation and production of the Essex Coastal Recreational Avoidance and Mitigation Strategy and that there must be a Duty to Cooperate.
Pg. 127. Para. 10.27 Retaining or amending policy ENV1 to strengthen the current policy is supported.



Additional Comments
Reference to Wallasea Island in the Burnham-on-Crouch Neighbourhood Plan Referenced within the 'made' Burnham-on-Crouch Neighbourhood Development Plan, the town will encourage the RSPB to invest appropriately in facilities that will encourage visitors to travel sustainably between Burnham-on-Crouch and Wallasea. The Council supports the aspirations of the Burnham-on-Crouch Neighbourhood Plan in this regard and wishes these aspirations to be acknowledged by Rochford District Council.
Speed Limits on the River Crouch With reference to the River Crouch, the Council seeks the acknowledgment of Rochford District Council with regard to the issues related to the omitted speed restrictions and a commitment to overcome these challenges. The sensitive shorelines of the River Crouch have been noted to be a high priority for conservation within Maldon District Council and therefore would like to form an open and productive dialogue with Rochford District Council to mitigate the relevant issues.