A. Reduce the threshold for the provision of affordable homes as part of a scheme (potentially in line with emerging national policy and guidance)

We should reduce the threshold for provision of affordable homes in line with national policy.
Note: This is in view of the relatively lower average wage in the District. The average cost of a new home is out of the reach of many. The district needs to force the housing association to fulfill its obligations to provide the necessary rented accommodation.

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.

It is very difficult to get RP's to commit to take on a couple of units in a scheme, particularly where they are part of a larger single accommodation block. It is highly likely that this will result in many more scheme coming forward will be subject to viability testing. Perhaps another solution is for a financial contribution to be made between 10 and 15 units, the level of this could be via a formula or viability based.

Please find below the Comments that Rawreth Parish Council wish to submit with regards to the Issue and Options Document (and draft Sustainability Appraisal)


Objectively Assessed Need (OAN) page 38
Section 6.30
A combination of both Option A & C. Seek to provide as much of the Districts housing need within out District given our environmental and other constraints, giving a percentage of new homes to residents to purchase on a first come first served basis for a limited period of time, bearing in mind we need to co-operate with neighbouring authorities.

Affordable Homes page 39
Section 6.31
A combination of A & C. Reduce the threshold for the provision of affordable homes in line with emerging residential policy.

Section 6.32
A combination of D & E. need to maximise the provision so wherever possible increase above the 35% but, this should be the minimum on all sites.

Homes for Older People and Adults with Disabilities
Section 6.33
Support integration within new developments to provide for various needs.

Section 6.36
Support option B.

Delivering our Need for Homes
Section 6.37
In order of preference support Options A, B, E, C, D. Density should be increased near to Town Centres and Transport hubs. Large extension to existing residential areas are becoming too remote from Town hubs, eg Hall Road, Ashingdon Road and Land to the North of London Road. Hence the possibility of a new settlement South West of Rayleigh, East of Hullbridge around Lower Road, north of Ashingdon but only if infrastructure is improved with national investment (we have responded separately on this point under Transport and Access)

Section 6.59
Support Options B & F. We need to preserve our existing stock of bungalows and restrict permitted development rights to enable the increasing elderly population to remain in independent living. To monitor the need for new bungalows in proposed mixed developments.

Gypsy, Travellers and Travelling Showpeople
Section 6.78
Support Option B combined with Option E. We support the Michelins Farm site provided it is in the District Council's control and strictly monitored with provisions for very limited natural expansion as the needs arise.

Paragraph 6.74 States that unauthorised sites are pursued through enforcement powers, there is no evidence to this in the case of the Cherry Hill Site on the A1245 which continues to increase in numbers.

Houseboats and Liveaboards
Section 6.86
Support Option c to safeguard the open apsects of the shoreline of the River Crouch and the River Roach.


Meeting Business Needs
Section 6.96
Support Option C. Paragraph 6.95 states that "the local road network also needs investment to improve accessibility", there needs to be connectivity with the national network to attract new business, as the imbalance between available employment and outflow to other areas needs urgently addressing.

Need for Jobs
Section 6.111.
Support a combination of Options A, C, E F with option B being worth of consideration . Paragraph 6.109. The increasing leisure use on some industrial sites makes these sites unattractive to further business use it also suggests that there was a surplus or business premises, possibly because of the inaccessibility of some sites due to congestion or poor roads, eg Brook Road, Eldon Way and Purdeys Way.





Tourism
Section 6.128
Support Option A. Paragraph 6.120 & 6.121 why does the "Crouch Coastal Community Team" not include the river up to the bridging point at Battllesbridge? Chelmsford City Council, Rawreth Parish Council and Rettendon Parish Council need to be involved.

Commercial Development
Section 7.20
Support Option A. Parking issues ie cost and accessibility restrict the enjoyment of facilities in the Town Centres, the draw of free parking at out of Town shopping centres, A127, Lakeside and Southend Airport divert resources away from small independent shops to large national chains. The Government promised that a levy on free parking was to be introduced this should help subsidise local centres, this needs addressing by National action.

Highways Infrastructure
Section 8.20
Object to Option C, Support Option B. Paragraph 8.4 note that 14,000 commute out of the District daily, 63% by car which puts pressure on the road network. The need to attract inward employment could reduce pressure on the system. The A127/A130 junction improvements are due to be operational 2022/23. The District is a peninsula therefore there is only one way out, westwards if the Government insists on expansion in Rochford, Southend and Castle Point then Central Government should invest in our future by alieving the congestion by a river crossing between Hulllbridge and Fambridge to link with the Burnham Road to bypass South Woodham Ferrers dual carriageway to the Turnpike/A130. The whole road should go through to the Tesco's roundabout on the A127, this could be linked to a new settlement as previously mentioned and relieve congestion around South Woodham Ferrers.

Sustainable Travel
Section 8.37
Support Option A, C and E. Paragraph 8.32, Green Grid strategy was promised in the Core Strategy for the Land North of London Road Rawreth, however it seems to have disappeared in the Countryside plans. There is a need for joined up pedestrian/cycle ways to provide a meaningful and safe network. The subtrans national cycle route via Beeches Road/Watery Lane seems have disappeared, its unsafe because of the volume of traffic. Buses need to be convenient and cost effective alternatives to private vehicles.

Water and Flood Risk Management
Section 8.58
Support Options A & C which should be combined. Paragraph 8.45 Zone 2 and 3 areas of Rawreth are at risk from development upstream of the Brook system which drains Rayleigh, Thundersley, Bowers Gifford; Basildon and Wickford, all areas with development pressures. We need to co-operate with each authority to minimise risk in Rawreth and the River Crouch. Some areas of Rawreth are protected by sea defences which need upgrading to match the height of the North Bank. Because of the geology of the area in exceptionally wet years the impermeable clay can become saturated and ground water becomes an issue. The Rayleigh ridge is of mainly permeable Bagshot beds sitting on a clay base which gives rise to ground water. Flood risk from Highways improvements have to be properly modelled, for example the Fairglen interchange. Paragraph 8.49 the Water Cycle Study 2015 recommendation needs updating to take account of new future housing.

Health and Wellbeing
Section 9.11.
Support Option D with land allocation support.

Education
Section 9.29
Support Option A, B D and E Paragraph 9.26 stated that 800 new homes would generate a need for a new Primary School. Land to the North of London Road will generate 550 homes but this is not enough to generate a new school. St Nicholas School Rawreth was designed to be expanded to 210 pupils, it is currently half that, will expansion be an option?
Each new development should be treated individually to ensure adequate land is set aside for school sites if the demand can be shown. The Secondary School provision for age 16 to 19 years needs to be considered and addressed.

Open Space and Outdoor Sports Recreation
Section 9.42
Paragraph 9.39 "Depending on their size and scale these are considered appropriate in certain circumstances taking into account the impact on the Green Belt" So do the pitches in Old London Road Rawreth fit that criteria? In the SA Report it is stated that there were only about 30 pitches in Rochford District. There should be a re-appraisal and a comprehensive census of all sports facilities in Rochford. Why are most Council owned facilities underused and of poor quality? If private landowners can make a profit on pitches then the Council should review their facilities and invest in improvements to attract profitable use.

Green Belt
Section 10.16
Paragraph 10.6, Does this mean that the Green Belt can be expanded as well as reduced to facilitate development. Paragraph 10.7 there should be a sixth principle in food production and encouragement of locally produced sustainable food. Paragraph 10.15 the western boundary and strips of Green Belt are becoming too narrow as Basildon District, Shotgate expansion is built almost to the Rochford boundary. Is the land to the west of the western boundary of the land to the North of London Road still classified as Green Belt?

Air Quality
Section 10.72
Support Option B. We need to improve air quality by encouraging sustainable travel, also clean non polluting renewable energy. All new housing must incorporate PV panels or tiles on the roof.

Rural Exception Sites.
Section 11.19
Recognise the need for affordable housing in rural areas by small well designed sites in villages to retain the generations of families in their environment who can be supportive as a family unit, relieving pressure on social and health care services and reducing travel. Continue need for agricultural workers where new demand appears. Developments could be instigated by Parish Councils (see page 4&5 section on Community Led Planning)

Development of Previously Developed Land in the Green Belt
Section 11.49
In the guidance notes it was suggested that derelict agricultural/forestry areas should be excluded from the definition of Brownfield. Each site should be judged on its merits. In the case of Hambro Nurseries Rawreth where there are several hectares of un-used and underused greenhouses as well as areas of scrub and concrete, it should be looked at as on its own advantages it would be a development adjoining an existing residential area as was stated in the previous Core Strategy this Parish Council would support this area to consolidate and create a meaningful hub for the Village of Rawreth, the disadvantages put forward by the District Council were grossly exaggerated.


Contaminated Land
Section 11.81
Paragraph 11.80 it is stated that Rochford District Council don't have any formally declared contaminated land, what then is Michelins Farm?

Objectively Assessed Need (OAN) - Option A Support

Affordable Homes - Options A and E Support

Homes for Older People and Adults with Disabilities - Option A Support

Need for Care Homes - Option A Support

Delivering our Need for Homes - Options C and E Support

Good Mix of Homes - Option A Support

Bungalows - Option E Support

Density of Schemes - Option G Support

Gypsy, Travellers and Travelling Showpeople - Option A Support

Houseboats and Liveaboards - Option D Support

Meeting Business Needs - Option E Support

Need for Jobs - Option F Support

London Southend Airport - Option D Support

Supporting Tourism and Rural Diversification - Option B Support

Retail, Leisure and Town Centres - Option A Support

Villages and Local Neighbourhood Centres - Option A Support

Highways Infrastructure - Options A and C Support

Sustainable Travel - Option A Support

Communications Infrastructure - Option B Support

Water and Flood Risk Management - Option B Support

Renewable Energy Generation - Option B Support

Planning Obligations and Standard Charges - Option A Support

Health and Well-being - Option D Support

Community Facilities - Option B Support

Education and Skills - Options D and E Support

Early Years and Childcare Provision - Option A Support

Open Space and Outdoor Sports and Recreation - Option D Support

Indoor Sports and Leisure Centres - Option A Support

Facilities for Young People - Option A Support

Play Space Facilities - Option A Support

Green Belt - Option A Support

Biodiversity, Geology and Green Infrastructure - Options A, G and H Support

Wallasea Island and the RSPB's Wild Coast Project - Option A Support

Landscape Character - Option C Support

Protecting and Enhancing Heritage and Culture - Option A Support

Good Design and Building Efficiency - Options A and F Support

Air Quality - Options A, B and C Support

Mix of Affordable Homes - Option F Support

Self-Build and Custom-Build Homes - Option A Support

Rural Exception Sites - Option G Support

Annexes, Outbuildings and Independent Homes - Option B Support

Basements - Option A Support

Replacement, Rebuild or Extension of Existing Green Belt Homes - Option B Support

Agricultural, Forestry and Other Occupation Homes - Option A Support

Development of Previously Developed Land in the Green Belt - Option A Support

Extension of Domestic Gardens in the Green Belt - Option A Support

Parking Standards and Traffic Management - Option A Support

Homes Businesses - Options A Support

Alterations to Existing Business Premises - Option B Support

Advertising and Signage - Option A Support

Light Pollution - Option B Support

Contaminated Land - Option A Support

Delivering Infrastructure

Underlying Thoughts

There are recognised congestion and capacity issues in the District with key areas of concern found in and around the town centres of Rayleigh, Rochford and Hockley. The traffic congestion, from Rayleigh Town Centre southbound to the A127, produces levels of NOx that have regularly exceeded EU limits since at least 2006. A designated Air Quality Management Plan is in place to reflect.
Whilst well supported by the A127, A13, A130, the West of the District suffers from bottle necks due to the number of vehicles accessing them. With the River Crouch (N), North Sea (W), and Thames Estuary (S) surrounding the District, its geography contributes to a greater west bound traffic flow.
The A127 is the primary East - West road (linking Rochford District with Southend, Castle Point, and Basildon) and improving this route could increase employment opportunities in the East and at Southend Airport. Recently, £27million was secured by Essex County Council (from the Local Growth Fund) to improve Fairglen Interchange (A127, A130, A1245). Basildon Borough Council's local plan also highlights a potential new link road for A127 - A130 via Pound Lane.
Roads such as the A129, B1013 and Rawreth Lane suffer knock on effects of the main pinch points to become bottle necks of their own. The use of non-strategic highway routes to give access to the North of Essex (e.g. Watery Lane) also contributes to congestion.
Residents have identified 16 pinch points on the local road network including: Rawreth Lane, London Road, Rayleigh Town Centre (Crown Hill, Websters Way, Eastwood Road), and Carpenters Arms Roundabout.
Improving the road network should be a priority before additional large scale housing projects are implemented to avoid making congestion and air quality worse. Unfortunately, the narrow roads found in town centres, along with fast, winding, rural roads present significant challenges to increasing the capacity of current roads and creating new cycle routes along them. Ignoring the problem however will not make it disappear.
The limited transport capacity in our town centres could have a detrimental impact on businesses. To support business and economic growth, surface access to hubs outside of the centres, such as Southend Airport, should be improved.
As well as struggling infrastructure, the District has high levels of car ownership. As a supplement to infrastructure improvements, we should encourage a change in how the infrastructure is used.
Whilst fragmented, the District does contain cycle routes: Ashingdon Road, Hall Road, Cherry Orchard (all Rochford), and Hullbridge Road (between Hullbridge and Rayleigh) and we should look to increase this network.
There are very few electrical vehicle charging points in the District, however the provision of electrical upstands and outlets for recharging vehicles would typically not require planning permission meaning we have an opportunity to increase charging point numbers.

Core Strategy Policy ENV8 requires development plans of >4 homes to secure 10% of their energy from decentralised and renewable or low carbon sources. Accepting applications for, large scale, solar panel schemes will help ensure we not only reach this target but significantly increase it (such applications have been received in the past, including at Southend Airport).
Equality of infrastructure is a challenge in the rural East where residents suffer from poor Broadband and we should look to modernise policy to include fibre optic capabilities across the District.
Whilst unclear how funds would be allocated out of it, the Council is working to deliver a Community Infrastructure Levy (CIL) on future development schemes. This is a good idea in theory, but we must ensure this doesn't become an excuse for not providing infrastructure as part of housing schemes.

By prioritising local highways and junctions, such as Rawreth Lane, we have an opportunity to modernise them and their junctions with other important roads. We should do this alongside supporting efforts by Essex County Council to improve the strategic highway network such as the A127 & A130.
Congestion on the districts roads has led to levels of NOx pollution higher than EU guidelines in some areas of the district. Alongside rising to the huge challenges of improving the network we could reduce the environmental impact of congestion by encouraging electric vehicles. Introducing policy concerning charging points for electric vehicles would be a good start.
We should support the current policy on public transport and strengthen it to ensure that public transport access is a key consideration for development schemes. This will encourage the modal shift in travel that the council advocates.
Telecommunication infrastructure policy should be amended to include specific reference to improving broadband and mobile coverage, especially fibre-optics, as this will aid desired business growth and place us better to utilise future technological advances.
Currently, schemes can be developed in flood zones if the site is designated as brownfield. Building in flood zones should be avoided, regardless of whether buildings have existed there before. We are better served by allowing flood zones to occasionally flood in order to avoid or mitigate damages to properties around them. We should revise the Core Strategy to remove the brownfield exception.

Delivering Homes
Background

Underlying Thoughts
Reduce House Building until pressures on Infrastructure are reduced
Using a target figure of 240 homes per year, the Environmental Capacity Study 2015 concludes that it is uncertain if our district can accommodate the number of homes targeted. The Council's Core Strategy sets a higher target of 250 homes, until 2025, however has only hit this once. For these reasons, it is time we changed approach, whilst underlying infrastructure problems are addressed.
Whilst Castle Point, Southend & London have constraints that may mean they cannot meet their housing and employment needs, the Environmental Capacity Study 2015 also concludes that it is unlikely that our district can accommodate additional housing needs from other areas.
This isn't to say we should ignore housing building responsibilities, rather move to an approach that truly recognises the mutual dependency between economic, environmental, and social factors. New homes should be accessible through a variety of transport modes and shouldn't increase the burden on the already stretched road network. Filling empty homes should be a priority.
With this in mind, the council should amend current policy that any housing scheme delivered can only mitigate its own impact as opposed to existing deficiencies. Ignoring the challenges of the existing deficiencies will not help solve them; simply exacerbate them. The idea that "development should only be prevented or refused on transport grounds where the... impacts are severe" should also be reviewed.

We should seek to provide as much of the district's housing needs within our own area, as far as possible, given the environmental and other constraints such as infrastructure. Until we can remove these constraints, the mitigating action is to spread additional homes across the district by making small extensions to existing residential areas.
Increasing density within town centres such as Rayleigh should be avoided. Whilst these areas have more infrastructure, it is under too much pressure at this stage. The current density policy (30 homes / hectare) should be maintained.
A non-committal, viability study into the creation of a new garden village should be considered if it can be achieved in parallel to the opening of new access points, such as crossing the river Crouch, to relieve pressure on current road infrastructure.
In response to the increasing housing waiting list and acknowledged issues around affordability the threshold for the provision of 'affordable homes' should be reduced to developments of 13 or more homes and the proportion of them increased to between 40% & 50%.
The current approach to applications for specialist and care homes is to review them on an ad hoc basis using available evidence for need and should be kept moving forward.
The current, flexible and market driven, approach to the types of new homes being built should be retained with the exception of bungalow building where we should introduce a small proportion of them on larger housing schemes.
Reservations about the allocation of Michelins Farm as a Gypsy and Traveller site exist and resident's questions of concern require answers. Whilst the allocation is rightly being questioned, the current criteria based approach to these developments should be retained.
The definition of a 'Houseboat' currently contained in the Development Management Plan should be amended as the current definition is being abused by those who travel up and down the river Crouch for the sole purpose of claiming that the 'primary use' of their boat is travel (as opposed to accommodation).

Delivering Jobs

Supporting sustainable travel and prompting highways improvements will have a positive impact on business growth and employment opportunities. With this in mind, we should look to improve surface access to business estates such as Southend Airport in order to increase the economic opportunities of them, by strengthening current policy on access improvements.
The District's current policies around driving retail opportunities to the identified town centres are working and fit for purpose when supplemented by village and neighbourhood top-up centres. For this reason, protecting those local and neighbourhood shops should continue.
There is an opportunity to diversify business opportunities in the rural parts of the District by introducing policy surrounding the sustainable use of greenbelt land for weddings / events (that might include short term camping), as long as protection criteria were introduced and adhered to.