Need for Care Homes

My opinions on The New Local Plan.
Whilst I am fully aware of the need for new homes, the number proposed vastly exceeds any infrastructure we currently have or are likely to get in the foreseeable future.
A) Roads. The A127, A129 and Rawreth Lane are already well above capacity at peak times of 4:30-6:00pm with traffic queueing for up to 30 minutes belching out polluting fumes. Tackling this issue with a congestion charge which has been mooted would be an unsatisfactory solution as there is no alternative. We cannot park then use an "underground" like London. The B1013 on which I live, moves either at snails pace at peak times or traffic exceeds the speed limit on blind bends, an accident risk which will be worse with the new developments on Folly Lane and Bullwood Hall.
The number of cars for 7500 houses will probably add at least 10000 extra cars to our already congested roads.
B) Doctors. The local surgeries are currently difficult to get appointments and doctors are leaving the NHS and can't be easily replaced. Who will care for the new residents?
C) Schools. The schools are mainly already oversubscribed. New schools will have to be built to educate new children.
D) Hospital and community care. Southend University Hospital is under threat of being downgraded and acute patients transferred to Basildon and Chelmsford. Apart from disagreeing with this for our current population, it will be even worse with more residents and times for transfer will increase due to the extra congestion on the roads.
Some of the proposed new sites affect places where the local care homes are. It is essential to plan not just for new homes but also new high quality care homes. It is not just the elderly that need care. Young and middle aged adults also need good quality care. For an exemplary style of care for disabled adults please see "Scotts Project Trust" https://www.scottsproject.org.uk in Kent which is no more expensive than other places.
It is essential that the council puts the horse before the cart, not the other way round and puts in infrastructure and new roads BEFORE any further new homes.
General Strategic Planning:
The green belt is essential and as little of it as possible should be used for new development. It is the lungs of our society and not only improves physical health but also mental health of residents. I believe firmly also that sunshine and access to nature promotes mental wellbeing which goes on to improve physical health and the follow on of less pressure on health resources. Thus I feel that the planners must consider light, shade and views when arranging new housing. It seems that the present developments are creating tiny gardens in the shade of neighbours. Wherever possible as many south facing gardens should be planned. It is not only good for the residents' health and plant growth, but solar panels can be added inconspicuously to roofs on the non-dominant aspect of the home.
Also, I don't think the Rochford area caters well to the "better off" older people. The assumption that a very small garden is desired and a small home is untrue. There are many in my position who would like a slightly smaller garden than they have, but a more accessible home that could cater for a wheel chair as time goes on. Therefore having new homes with space left for a domestic lift and fully flat floors would be desirable. This would be more flexible and not necessitate someone moving as they became less mobile.

There are several Care Homes listed in the CFS as possible areas for development, and no mention of where/how these will be replaced. This is not answering the need for Care Homes, but decreasing the capacity.

I strongly object to the planning proposal to flood this local authority district with a disproportionate and unacceptable volume of planning applications for residential accommodation
without any consideration to the effect this will have on the infrastructure needed to make these proposals sustainable. It is unacceptable that local district councils are permitted to give permissions to implement their housing policies and at the same time turn a blind eye and wash their hands on issues that can only be resolved at county council level so as to make these developments sustainable. It should be imperative that the two tiers of local authority organisations take a corporate approach and joint responsibility to ensure that the substantial increase in the number of houses to be developed will be sustainable in the environment as a whole.
B1013
1. Any competent planning officer with integrity and a feel for the concerns of the local community must already know that the B1013 road which runs between Rayleigh Weir and Rochford Town Centre is no longer fit for purpose. The need to reduce congestion and provide a free flow of traffic on this road demands that urgent proposals be put in place in the following areas so as to avoid the present slow moving, costly and time wasting movement of traffic causing unacceptable levels of atmospheric pollution in the environment;
The junction between Rayleigh High Street and Eastwood Road, the junction between Hockley Road and Websters Way, the junction between Hambro Hill and Hockley Road, the junction between Main Road Hockley and Buckingham Road, the junction between Southend Road, Spa Road and Main Road Hockley, the junction between Rectory Road and Hall Road and the junction between Hall Road and Bradley Way Rochford.
I understand that in future it is intended to build a substantial number of new houses on green field sites at Mount Bovers Lane, Ironwell Lane, Nursery Corner and Cherry Orchard Way. These developments have the potential of producing another approximately 3 500 vehicles, all of which which will need access to the B1013. In nineteen years time the demand for private motor cars serving these dwellings could easily rise to exceed an additional 7000. This is in addition to the demands already made from the recently built sites of 175 houses in Rectory Road and 600 houses in Hall Road.
I would be pleased to receive all the information that you may have concerning improvements to the B1013 to avoid any future grid lock occurring in this main access to several cccccccccc c local routes, so as to make the New Local Plan sustainable.
It is absurd and a planning folly of unmeasurable incompetence to inflict this number of additional vehicles on a road system which even now is unfit for purpose.
A possible solutions may be to provide two completely separate new access routes to the A127 and A130 to make these proposals sustainable and relieve congestion on the over-used B1013.
County Council Issues
2. In addition to providing an efficient and satisfactory transport network of highways to allow the free movement of traffic throughout the region, further measures will be needed to accommodate
the predicted increase in population by 2037. I would be obliged if you could inform me of the provision to be made for additional nursery, primary and secondary schools and college facilities in the wider area, to accommodate the predicted increase in children and young persons educational needs during the next 19 years.
3. As it is predicted that there will be an increase in the number of elderly people requiring care in the community, are additional measures being taken in the wider area for residential care homes to be provided to meet this need?
NHS Issues
4. With the predicted future increase in the population in 2037, the Mid&South Essex Hospital Trusts will need to assess the future requirements to provide a sufficient number of new hospitals and medical centres to meet the increase demand for these services.

It is high time that councillors and planning officers at district council level looked beyond the increased revenue incentive received from the New Build Bonus grants issued by the central government and focus their attention on the long term effect that these proposals will have on the environment now being provided by local district councils for future generations to come.

I am emailing regarding the above to share my concerns regarding the level of proposed new housing over the coming years particularly with regard to the enviroment in the Hullbridge area where I reside.

1. There will need to be consideration for additional schools to accommodate the anticipated increased pupil numbers. Is this in the plans.

2. Has any thoughts been given to the increased traffic numbers which will inevitably be seen. At present, Lower Road, in particular, is very busy as are other roads in the area. Appropriate speed limits will have to be put in place, especially on Lower Road. Access will also be a severe problem at busy times.

3. There will need to additional Doctors, has the local practice been appraised of the situation as it is not always easy to get an appropriate appointment at the moment.

4. Are additional bus routes planned where necessary & are the local bus companies likely to provide new routes or extra services.

5. Will there be an allowance for Sheltered Housing in any of the proposed sites particularly in view of the aging population. A number of bungalows on each site could be appropriate.

6. Some of the proposed sites do not have mains drainage at present. As this will obviously need to be provided on new developments, will existing homes in those areas have the opportunity to have this provided.

7. We reside in Lower Road opposite La Vallee Farm which is one of the proposed sites. I am surprised that land designated as farmland will be considered for housing development.

8. Perhaps, in view of Brexit, we might consider that we should maintain our farmland to provide for our population in view of the potential increase in costs of imports which may occur.

9. With regard to La Vallee Farm & adjacent sites, you may be aware that the road in that area is presently prone to flooding with water coming down from the higher ground above the farm. Hopefully, this will be a further consideration to take on board.

10. As mentioned earlier, the speed limit of 40mph in this area will be excessive if a residential development is allowed. Certainly, appropriate access to Lower Road is paramount as traffic levels on this road are likely to substantially increase.

I hope that the above points will be considered on any of the proposed sites with stringent reviews undertaken before plans are approved.

The infrastructure must be able to cope with the additional population in what is generally a very rural area.

I am emailing regarding the above & wish to comment on the proposals. I have particular concerns on the effect on the local infrastructure & in turn its effect on the environment.

It was extremely disappointing to note that mature trees & the hedgerow on Lower Road in respect of the development to Malyons Lane have all been taken away. My concern is how much else will be destroyed due to these new plans.

I have other concerns in this matter as to how it affects the Hullbridge area as follows:

1. What will be the effect on local schools due to the obvious major increase in pupil numbers. Presumably new schools are proposed.

2. There will be an increased need for additional doctors, has any approach been made to the existing practice in Hullbridge to gain their views.

3. At present Lower Road is already very busy & these proposals will inevitably increase the amount of traffic using it. Currently a high proportion of traffic uses Watery Lane which is already inappropriate for the amount using it.

4. Will there be any extra thought given to the older population such as Sheltered Accommodation and perhaps including bungalows on any development.

5. Public transport facilities will have to be improved. Have the bus companies been approached to extend their current routes and provide new routes to any development where there is currently no service.

6. I live close to La Vallee Farm which is one of the proposed sites. I have a number of concerns with this site in particular as mentioned in the following points.

7. At present, this is designated as farmland and I would have thought that we should be preserving such land to provide food for a growing population. Who knows what effect Brexit will have on supply of food. There must be more appropriate land other than using productive farmland.

8. Also, the road outside La Vallee is prone to flooding with the water flowing down from higher ground above the farm. This, again, does not seem appropriate.

9. This area does not have mains drainage at present so this will inevitably have to be installed.

10. The present speed limit in this area is 40mph which must be decreased if further access onto Lower Road is required.

As stated, I am extremely concerned as to the effect on the local environment & trust that sufficient & exhaustive investigations will be undertaken before any sites are given planning permission

I write today to add my voice to your current building plans.
We need more housing for our current residents "YES" but of the right type and in the right place!
As the 500 house development is still under construction in Rochford, you cannot be sure that only locals will purchase, and only residents will purchase or rent their properties, it is safe to say that migration will occur adding to the liability of the council for decades to come!
Putting even more strain on services that are barely coping now. Some schools may have capacity now, but look 10 years into the future
and the sums will be different.

Details assessment of the current development "must" be undertaken before any further development can commence, Schools, roads, Health services, transport etc.
It is a published fact the in Essex we have more cars per mile of road than any other county in England, and a good proportion of Essex is fields, the concentration of development is affecting businesses in lost working hours, deliveries are difficult and slow, costing lost revenue.
In the short term small developments, of 50 properties or less would ease infrastructure problems.
Building retirement bungalows within every village, town or settlement would free up family homes and retired couple would not have to leave their community, where they have friends and support.
Please remember that for every action their is an opposite reaction, the consequences are huge for the future of our district.

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.

My comments are as follows:

Page 38 , item 6.30
OPTIONS we must provide our own District housing quota. RDC has a significant green belt area, our neighbouring authorities are largely built up. If we opted to pool future development Rochford would inevitably lose open land other areas cannot provide.

Page 42, Table 5, also pages 44 and 45.
I strongly object to Rochford District Council's 'Settlement Heirarchy'. In my opinion this system is obsolete and inappropriate going forward. Past waves of development in the same areas have led to reduced living standards for residents in the more urban parts of the District. Negligible infrastructural improvements have been provided to offset this development.
If the level of development envisaged in SHMA addendum 2017 were agreed for the District as a whole (Page 33, Table 3), then I consider the development should be either:
A) Evenly distributed through all the parishes in the District creating about 25 homes per parish per annum.
or
B) The creation of a Locally Led Garden Village or Town as per government's recent policy guidance. Ideally this would be close to a pre-existing major artery A Road, such as the A1159. It should be noted that this area benefits from retail and leisure facilities, it also has easy access into Southend, which is asper page 10 Figure 2, is the destination for the largest number of residents leaving Rochford District every day for work (more than the number that go to inner and outer London combined).
The Rochford District area ( Fossetts Farm), close to the A1159 is I believe green belt. However the District will inevitably be obliged to release green belt land and we should not assume the boundaries of existing urban areas are the only green belt to be re-categorised. We must put the lives and wellbeing of our resident above our noble principles of preserving remote parts of the green belt.

Page 78 Highway Infrastructure 8.3
Although, as stated, Rayleigh is close to a number of 'A' roads, those same highways create significant problems for Rayleigh and the western part of Rochford District.
The major multi lane A roads are all at the edge of the Rochford District or beyond its boundary. However most other A roads and main B roads within Rochford District are over 150 years old in modernised/upgraded form. Indeed most of the main roads in the western part of the District can be found on the 1875 County Series O.S. Map. It is truly astonishing that so much development has been added over the following 140 years with the same, if improved, roads. In essence we have a vastly expanded population funnelled down pre 20th century roads. This explains the traffic problems on roads in Rayleigh. Effectively no wholly new transport infrastructure has been added in 150 years to the western end of the District. This results in delays and difficult traffic movements throughout the week.
However one positive point we should not lose under any circumstances is the current traffic system in the centre of Rayleigh at least preserves the town centre. Were it returned to the former one way system, with it's race track effect, the District's most successful town centre would be greatly harmed and cease being a pleasant place to shop.
Traffic from all the adjoining communities Hockley, Hullbridge and Hawkwell flow through Rayleigh on the afore mentioned 200 hundred plus year old roads.
Another problem adversely effecting the traffic in Rayleigh and the western part of the District, is that congestion and frequent problems on the A127, which funnels many vehicles through the town in a west /east or reverse direction.
I submit that these road factors, which create delay and pollution in the western District, preclude further significant development in Rayleigh or Rawreth (above and beyond that already agreed).

Air Pollution
Tackling air pollution from road traffic should be at the heart of our new local plan. We are fortunate to have a good railway system running through the District. On a small scale cycling is rising in popularity and good for both the environment and also for the health and well being of residents, however cycling is poorly catered for in Rochford District. Adding cycle lanes in the overcrowded and somewhat dangerous main roads in our urban areas may be rather too challenging. However if RDC does opt for the 'Locally Led Garden Village or Town' option we should ensure safe cycle lanes are included in any scheme.

Historic Buildings , Conservation Areas and Local Lists
I am concerned that Local Lists have been somewhat down graded by Rochford District Council over recent decades. Whilst not giving the almost guaranteed protection of national Listing they do confer significant protection especially in Conservation Areas.
Conservation Areas / the Historic Core of Towns and villages are an efficient way of protecting historic and attractive areas of the District. I recommend that as part of the Local Plan process Conservation Area boundaries should be reviewed, with a view to extension, subject to local Public Consultation (not just County Council advice).

Accommodation for independent older age group residents in or close to town centres
In recognition of increasing older age group numbers within our District, we should a guidance note to allow town centre older age group units for independent mobile residents. These may come with shared garden / recreational areas. With the changing nature of our town centres and the erosion of some retail and public facilities such as Police Stations, the Council should encourage the conversion of historic buildings and the redevelopment of the more modern inappropriate and unappealing town centre buildings for elderly person accommodation. This is not to suggest that all modern buildings are bad and all old buildings good, however popular support for historic buildings in Conservation and adjacent areas should be given weight when considering planning applicatons. All development within Conservation Areas should meet the highest standard of architecture as in any historic towns in the country, furthermore elderly person units should be required to provide good sound proofing especially in town centre locations.

Page 39 6.31 Affordable housing
Developers do not want to include affordable housing within their schemes as it adversely affects their profit margins. A significant number of new residents have been coming from the London area where they are able to sell houses for extremely high values compared with the local housing stock, this has caused additional house inflation and has led to a greater demand for large housing units out of the reach of many local young people hoping to get a first foothold on the housing ladder. The new Local Plan should recognise and address this problem. Simple requirement for affordable housing within schemes may not be successful going forward. It would be good for RDC local policies to explore the possibility and practicality of requiring large scale developers to sell small parcels of land at reduced price to Housing Associations either for rental property or part rent part purchase schemes.

Page 41 6.36 Care Homes
Care Home finances are under severe financial pressures, which lead to problems for the NHS. Policy option B would be the best response in current circumstances of rising demand and limited supply.

Comments: New Development Plan 2017-2037
We are writing to register our OBJECTION to the planned extra 7,500 homes proposed in the Second New Development Plan. We feel this is far too many. The full effect of the extra 2,600 homes to be built under the First Development Plan has not been felt yet.

We are concerned that:

1. There is no match FUNDING for a supporting Infrastructure. We live in a peninsular, if you enter our area you need to return the same way. The roads are already clogged, especially at rush hour. Travelling through Hockley between 4.00 and 6.30 p.m. is impossible, with huge tailbacks through the village. Pollution should be monitored.

2. There are no guarantees that UTILITIES can match extra demands.

3. There is no spare capacity within the HEALTH & CARE SERVICES. A personal friend of mine recently tried twice in a week to get a Doctors appointment at Greensward Surgery, only to be told they were not even accepting child emergencies that day.

4. There is no let up in the sacrifice of the GREEN BELT & AIR QUALITY. Greenbelt is there to protect the countryside from urban sprall. Some of the proposed sites would virtually join Hockley to Rayleigh.

5. No long-term LEGACY left for future generations. What quality of life will future generations have if we don't plan appropriately.

Resolutions:
1. Infrastructure to be considered first before extra housing planned.

2. Build Quality Bungalows/complexes for elderly people. Many elderly people are still living in their family home with unused space and high running costs as they have nothing else suitable to move into. Much needed family housing could then be released.

3. Housing for LOCAL people. Many people migrate from London to take advantage of the lower prices in comparison. There should be a percentage of new build properties set aside for purchasing by LOCAL people ONLY.

4. More help for the young in the area. Special schemes negotiated to enable local people's children to be able to stay in their own area.

5. Is it possible to negotiate with other Districts in Essex who have the infrastructure to be able to expand, and offer some of our allocated housing numbers from Government?

6. We would also like to see more suitable complex's/flats to enable people with disabilities to live independently.

TARGET NUMBERS NEED TO BE CUT TO AT LEAST NATURAL GROWTH LEVELS.

*THIS REPRESENTATION INCLUDES SEVERAL ATTACHMENTS*

New Local Plan 2018. Issues and Options Documents

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

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

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

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

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

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

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

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

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

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

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

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

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

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


Section 1 (cont).

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

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

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


Section 1 (cont).

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

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

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

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

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

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

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

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


Section 3 (cont

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

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

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

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

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


Section 3 (cont.

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

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

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

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

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

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

Section 4

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

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

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

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

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

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

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

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

Section 5 (cont

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

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

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

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

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

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

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


Section 6 (cont

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

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

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

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

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

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

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

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

Section 6 (cont

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

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

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

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

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

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

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

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

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

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

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

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

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

Section 8 (cont


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

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

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

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

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

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

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

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

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

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

Page 156. Extensions etc. No comment

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

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

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

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

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

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

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

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

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

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

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

"Drafting our Strategic Objectives"

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

Section 6

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

"Need for Care Homes"

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

Section 8

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

Section 9

Above 9.11 use heading 'Recruitment and Retention of Health

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

Section 9 (cont'd)

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

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

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

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