B. Include a specific policy on the provision of care homes, and identify appropriate locations in conjunction with Essex County Council

On behalf of Southern & Regional Developments, Claremont Planning support the approach which Option B would provide. In the context of Rochford, as well as nationally, an increasingly ageing population requires the provision and delivery of more facilities such as Care Homes. Whilst writing it into policy, Option B will also ensure that delivery of these homes will be made in suitable and accessible locations which contribute towards the creation of more mixed communities, in compliance with Part 8 of the NPPF.

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


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

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

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

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

Section 6.36
Support option B.

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

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

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

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

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


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

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





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

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

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

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

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

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

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

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

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

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

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

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


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

Rochford Parish Council welcomes the opportunity to comment on this Document and whilst fully supporting the Strategic Priorities and Objectives of the Vision wonder whether the vision is, in its own right, rather long.

The council would support the following options which the document identifies.

6.30 C
6.31 B
6.32 D
6.33 B
6.36 B
6.48 E
6.58 C
6.59 F
6.60 H
6.78 B
6.86 B
6.96 B & C
6.111 A & F
6.117 A & D
6.128 A & B
7.20 C
7.27 A & B
8.20 B (Councillors have concerns that option C would be unable to accommodate significant increases in traffic flow without a major infrastructure investment.
8.21 A
8.37 B & C
8.44 B
8.58 C
8.66 B
8.75 A
9.11 D
9.15 B
9.29 A, B, D & E
9.36 B
9.42 A, B, C & D
9.50 A
9.61 A
10.16 B
10.27 A
10.28 G
10.29 H
10.34 B
10.44 C & D
10.52 A
10.62 C
10.63 J
10.72 B
11.5 G
11.12 B
11.19 B
11.27 A
11.36 A
11.40 B
11.44 A
11.49 A
11.53 B
11.57 A & B
11.61 C
11.65 B
11.72 A (Councillors would like to see this strengthened especially in relation to advertising on residential property.
11.76 B
11.81 A

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.