Delivering our Need for Homes

*THIS REPRESENTATION IS ACCOMPANIED BY MULTIPLE ATTACHMENTS INCLUDING A SITE MAP AND VISION DOCUMENT*

These representations have been prepared on behalf of Crest Nicholson Eastern in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the "Site") for consideration in the Rochford District Council ("RDC") Issues and Options Local Plan ("the emerging Plan") consultation of March 2018.

Appendix 1 contains a Site Location Plan which shows the extent of the boundaries
of the site.

1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council's strategic housing need as part of the wider full Objectively Assessed Housing Need (OAHN) for the district. A proposed indicated layout is included within the Vision Document in Appendix 2 of these representations.

1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full OAHN. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council's settlement hierarchy.

1.4 Crest Nicholson is an award-winning national housebuilder with a proven track record of delivery, so if the site were allocated in the emerging Local Plan, the residential development of the site could be guaranteed.

1.5 The specific emerging Plan sections that these representations refer to are as follows:
● Vision
● Strategic Priority 1 - the homes and jobs needed in the area
 Strategic Priority 1.1
 Strategic Priority 1.3
 Strategic Priority 1.4
● Strategic Priority 3 - the provision of infrastructure
 Strategic Priority 3.1
● Strategic Priority 5 - protecting and enhancing our environment

 Strategic Priority 5.1

1.6 Full responses to the relevant issues and options within the emerging Plan are detailed in section 2 of this report and section 3 sets out the opportunity presented by the site for delivery of highly sustainable residential development on the northern edge of Rayleigh.

2.0 Our Response to the Issues and Options

The Vision

2.1 The vision section of the emerging Plan details the aims of the Council in relation to the three pillars of sustainability; our economy, our environment and our society. We support the Council's acknowledgement that this vision identifies that growth must be promoted within the district. This is fundamental to the three pillars of sustainable development. It therefore follows that sufficient housing sites must be delivered through the emerging Plan to support the employment, economic
and demographic growth anticipated throughout the Plan period in order to achieve the vision.

2.2 London Southend Airport forms a major part of the planned economic growth of South Essex. Rochford District Council's London Southend Airport and Environs Joint Area Action Plan (JAAP) was adopted in December 2014 in conjunction with Southend Borough Council and the area surrounding the airport is identified as a high scale employment growth area in the JAAP for both Rochford and Southend authorities. Land to accommodate 109,000 additional square metres of employment floorspace is allocated in the JAAP, comprising the new Saxon Business Park and
other smaller business parks and industrial estates, along with the potential to redevelop an area of underutilised brownfield industrial land at Aviation Way. In total, the land is capable of providing an additional 6,200 jobs in the area excluding direct airport related employment, but in order to fully realise the potential offered by this increase in employment land there must be commensurate housing provision through which a local workforce can be located.

2.3 We therefore consider that the planned employment growth must be matched by housing delivery in the most sustainable locations within the district. Rayleigh is one such location. It is strategically well located near to the trunk road network, main line railway to London and to the airport business park, the key employment area in the district. It therefore has optimal characteristics to contribute
significantly to this required housing delivery within the district.

Strategic Priority 1: The homes and jobs needed in the area

2.4 The emerging Plan sets out several strategic priorities for the Plan area in order to achieve the vision. The most relevant to these representations is strategic priority 1, relating to the delivery of homes and jobs in the district.

2.5 In the first instance we support the Council's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District. We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18). The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery. We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the National Planning Policy Framework (the "Framework"), which clearly requires local planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

2.6 We also consider that the emerging Plan should allocate sufficient housing sites to ensure that housing delivery matches the employment growth anticipated in the JAAP and wider Thames Gateway South Essex, a national priority area for growth and regeneration. The JAAP anticipates that the airport employment park alone could generate 6,200 new jobs by 2031 and the wider Thames Gateway South Essex is anticipated to deliver at least 52,000 new jobs1 over the same
period. Delivery of full OAHN in Rochford is therefore a crucial part of the wider strategic growth of South Essex.

2.7 RDC should therefore look to allocate land in the context of full OAHN for residential growth in the most sustainable locations to help attract and support the anticipated economic growth in and around the district and as part of the wider economic strategy for South Essex.

Strategic Priority 1.1: We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

2.8 Our comments relate specifically to objectively assessed housing need:

2.9 The options as set out are:
● A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
● B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
● C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

2.10 We consider that option A is the most suitable approach in relation to this issue, because it is the approach that is best supported by national planning policy and many local planning authorities local to Rochford are already taking this approach as part of their new Local Plans.

2.11 If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy
constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. Nearby local authorities of Basildon and Brentwood are both equally constrained by Green Belt but are both proposing to meet full OAHN. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

2.12 As a useful starting point, it is apparent from the Council's evidence base that the full OAHN could easily be accommodated on sites within the district; the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 identifies that there are 209 suitable and achievable sites within the district capable of accommodating 24,590 dwellings. This identified potential land capacity is well beyond that of the OAHN upper limit of 7,871 homes including the
shortfall in delivery prior to the emerging Plan period.

2.13 The potential land capacity above includes sites within the Green Belt and Special Landscape Areas and the majority of sites fall within these designations. These constraints should not prevent the allocation of the most suitable sites as part of a Local Plan review and in order to demonstrate that the Plan has been positively prepared, as part of the National Planning Policy Framework's
test of soundness under paragraph 182, we recommend that the Council undertakes further work in the form of a Green Belt review assessing individual sites for their contribution to the five purposes of including land within the Green Belt and their potential for release and development.

2.14 We therefore support option A.

Strategic Priority 1.3: How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?

2.15 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011). Rayleigh sits within the top tier of settlements as the most populated settlement in the district. Having regard to its sustainable location with easy access to public transport opportunities including mainline rail, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core Strategy was adopted.

2.16 Our comments on the Options are therefore as follows:

2.17 The realistic options as set out are:
● A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
● B. Increase density on allocated residential sites.
● C. Several small extensions to the existing residential area.
● D. A number of fewer larger extensions to the existing residential area.
● E. A new settlement.

2.18 We consider that option D is the most suitable method of meeting RDC's housing needs because it is the most deliverable over the Plan period.

2.19 Delivering homes in a fewer number of larger urban extensions, directed to established and wellserviced settlements within the district, would ensure that new homes would be connected to existing employment opportunities, transport networks and essential facilities, without a scale of requisite infrastructure provision that would threaten delivery of other planning policy objectives, such as affordable housing. The scale of larger extensions provides greater certainty of their deliverability and would generate higher levels of S106 and/or CIL contributions for improvements to infrastructure and services. They also have the potential to deliver significant onsite community uses. For example, Land at Lubards Lodge Farm represents a unique opportunity to provide significant public open space, allotments and a much needed sports facility for Rayleigh Boys and Girls FC (please see the Vision Document at Appendix 2).

2.20 Our contention for discounting the alternative options are discussed below:
● Whilst the reference to the efficient use of brownfield land in option A is desirable in line with the national policy, densification and infilling has implications for amenity and design quality and the capacity of brownfield sites alone is insufficient to meet full OAHN. Furthermore, options A and B would drastically alter the character of existing settlements and residential land allocations to the extent that would be damaging to existing character. For these reasons, options A and B are considered unsuitable.

● Smaller scale extensions as referenced in option C would fail to deliver sufficient CIL or s106 receipts to enable the cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

For this reason, we consider option C unsuitable.

● The spatial characteristics of Rochford do not lend themselves well to a new settlement identified in option E. Rochford District is constrained by its relatively small geographical area exacerbated by the environmental constraints of the rural estuarine environments in the north and east. There are no obvious opportunities for a new settlement capable of delivering the required housing in a manner that would create sustainable communities. For this reason, option E is considered unsuitable.

2.21 This confirms our view that the only reasonable option is option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rayleigh, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements, CIL or delivery onsite to mitigate the impact of any scheme. We agree with and support this approach.

2.22 Our submission at Section 3 of this report demonstrates that, as a highly sustainable settlement at the top of the settlement hierarchy in the adopted Plan, with the largest population in the district (circa 40% of the District's population), we consider that Rayleigh is the most suitable settlement for accommodating significant housing growth to support the town and the wider district. Land at
Lubards Farm presents an excellent opportunity to deliver a larger scale extension to Rayleigh.

Strategic Priority 1.4: How do we plan for and deliver a good mix of homes in the future?

What types, sizes and tenures are needed?
2.23 The options as set out are:
● A Retain the current policy on types of house, which takes a flexible, market driven approach to types;
● B Include specific reference to the size and types of homes referred to in the South Essex SHMA;
● C Continue to require new homes to meet the National Technical Housing Standards - nationally described space standards;
● D Do not adopt specific policy on the mix of homes.

2.24 We consider that option B is the most suitable approach in relation to this issue, but a greater amount of flexibility should be built into policy wording. The policy should make reference to the housing mix requirement in the most up-to-date SHMA evidence without prescribing exact figures from the most up-to-date available at the time of the emerging Plan publication. Referring to the specific evidence base provides a degree of clarity for the developer whilst concurrently not being so specific as to be inflexible.

2.25 A further matter that does not appear to be considered in the options is that planning for a series of larger extensions to existing settlements means that strategic planning objectives such as housing mix and tenure may be planned for and delivered on a strategic scale. Need may be adequately met this way.

Strategic Priority 3.1: How can we prioritise and deliver improvements to the strategic and local highway network over the next 20 years?

2.26 We do not have any specific comments relating to options as set out under this strategic priority. However, in response to the issue of how to prioritise improvements to the highway network, these should be delivered proportionately and be spatially related to the delivery of homes and jobs. As we have contended, the most appropriate strategy of housing delivery would be larger urban extensions located in highly sustainable towns at the top of the settlement hierarchy, with Rayleigh representing the optimum location for significant growth. Highways improvements would similarly be best located in this area commensurate to housing growth.

Strategic Priority 5: Protecting and Enhancing Our Environment

Strategic Priority 5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

2.27 The options are:
● A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
● B. Amend the current Green Belt policy in the Core Strategy.
● C. Do not have a policy on the Green Belt.

2.28 We consider that option B is the most suitable approach

2.29 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be possible to balance these competing objectives by ensuring that a fully up-to-date evidence base
is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

2.30 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries (paragraph 84). Furthermore, it says that local planning authorities should consider the
consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).

2.31 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.

2.32 This is why we support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's OAHN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A
Green Belt Review would enable RDC to assess land parcels against the five Green Belt purposes.

2.33 Only once the Green Belt Review is complete, can RDC come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

2.34 Our submission demonstrates in the following section that Land at Lubards Lodge Farm, Rayleigh could be removed from the Green Belt as part of the Local Plan review in a manner that would enable a defensible re-drawn boundary in accordance with the five Green Belt purposes.

3.0 The Opportunity - Land at Lubards Lodge Farm, Rayleigh

3.1 Taking account of:
● Rochford District Council's full OAHN;
● The limited availability of brownfield land in the district;
● The spatial characteristics of the district lending themselves best to larger extensions to existing higher order settlements, including Rayleigh; and
● The need to locate new development in sustainable locations,
we consider that the Land at Lubards Lodge Farm, Rayleigh, presents an excellent opportunity for Rochford District Council to help meet its strategic housing needs as part of the new Local Plan. Our reasons for this are set out below.

Sustainable location

3.2 The town of Rayleigh is identified in both the adopted and emerging Plans at the top of the settlement hierarchy demonstrating the Council's view that is represents the most sustainable location for development. Paragraph 6.38 of the emerging Plan states that settlements at the top of the hierarchy are intrinsically sustainable by virtue of their more developed nature, extensive infrastructure connectivity and accessibility to services and the Council seeks to direct housing development to these locations.

3.3 Rayleigh benefits from excellent connectivity to the rest of South Essex and London through the strategic road network comprising the A127, A130 and the A13. It is linked to London Liverpool Street, Southend Victoria and London Southend Airport by train station located in the town centre.

A range of services and facilities are available within the town. The centre of Rayleigh comprises a range of retail units interspersed with food and drink establishments. Recreational buildings such as the Rayleigh Town Museum and The Mill Arts & Events Centre add to the offer in the town centre. To the south, the Brook Road Industrial Estate, as well as the units on the opposite side of
the Southend Arterial Road to the south, offer employment opportunities above and beyond those in the town centre. 18 schools and nurseries are present in Rayleigh as well as 6 GP surgeries and 6 supermarkets providing a comprehensive service offering within the settlement.

3.1 The following table provides a representation of the site's accessibility to key amenities and demonstrates its suitability for development.

AMENITY DISTANCE FROM SITE
Bus stops 3 adjacent to site
Post office 1 within 50 metres

AMENITY DISTANCE FROM SITE
Pharmacy 1 within 50 metres
Shopping Asda within 400 metres
Rayleigh High Street within 1,800 metres
Schools 2 primary schools within 600 metres
2 secondary schools within 1,800 metres
Train station 1 within 1,600 metres
Leisure facilities The Rayleigh Club is adjacent to site
Rayleigh Leisure Centre is within 500 metres
Employment centres Lubards Farm is adjacent to site
Rawreth Lane Industrial Estate is within 1,000 metres
Library 1 within 1,900 metres
Banking 1 within 1,800 metres
Medical 1 within 200 metres

3.2 These demonstrate that the site is sustainably located. Many of these amenities are accessible by bicycle or on foot.

Deliverability

3.1 As the site is within single ownership and is unencumbered, we consider the site as a suitable candidate for allocation as a strategic residential development site because development would be deliverable. This correlates with the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 approved for inclusion and publication within the new Local Plan evidence base by the Planning Policy Sub-Committee on 17 November 2017. The site is assessed
in this document under the reference number CFS164 and the summary confirmed that the site is within Flood Zone 1 and not proximate to any environmental designations with the exception of the Green Belt; a policy designation.

3.2 Crest Nicholson is a national and multi-award-winning housebuilder with a proven track record of delivery of high quality residential schemes. This adds further weight to our demonstration that development on the site would be deliverable within early phases of the emerging Local Plan.

Benefitting from planned highways improvements

3.3 The site's location adjacent to the northern urban area of Rayleigh represents a logical extension to the town, well contained by Hullbridge Road to the east and Rawreth Lane to the south. Locating new development in this part of Rayleigh would mean it would benefit from planned improvements to the existing highway. Furthermore, its location near to the strategic highway network means that the impact of additional highway movements around the town centre would be minimised.

Figure 1: Extract from Drawing F221-202 General Arrangement 3Arm Roundabout from planning permission 16/00162/FUL

3.4 The consented and fully funded roundabout upgrade at the junction of Rawreth Lane and Hullbridge Road reference number 16/00162/FUL could, once delivered, allow for improved accessibility to the site with enhanced access to the wider strategic road network. The upgraded roundabout also offers the potential opportunity for a direct vehicle access from the roundabout itself.

Green Infrastructure

3.5 There is an opportunity to incorporate managed green infrastructure to the north of the site to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised. As the site is currently private
land it does not benefit from the same potential that its redevelopment would bring in this regard.

Green Belt

3.6 Below is a summary of a Green Belt Assessment undertaken by Eleanor Trenfield Landscape Architects Ltd of the site's contribution to the Green Belt. For further detail, please refer to the brochure appended to this report.
● Check the unrestricted sprawl of large built-up areas
An analysis of neighbouring land uses shows sporadic residential plotland development to the west and north of the site as well as commercial estate to the east and residential properties to the south-east which already contribute to the sprawl of Rayleigh north towards Hullbridge. The site therefore is more closely associated with the urban edge of Rayleigh than countryside and makes limited contribution to this purpose.
● Prevent neighbouring towns from merging
Existing sporadic development to the west and the north contribute to the erosion of this function on the site. The absence of a clearly defined urban edge of Rayleigh at this location is created by the plotland development and the site therefore does not act as a barrier preventing the spread of Rayleigh. Indeed, the plotland development already surrounds the site in most directions including towards neighbouring towns and so development on Lubards Farm would not deteriorate the function further.
● Assist in safeguarding the countryside from encroachment
Land between Rayleigh and Hullbridge has experienced piecemeal development resulting in minimal characteristics that would qualify it as 'countryside' land. Plotland developments already protrude significantly into the open land at this location, surrounding the site to the west and the north. In this sense, the countryside has already been significantly encroached and development on the site would not erode this function further.
● Preserve the setting and special character of historic towns
The land between Hullbridge and Rayleigh has no inter-visibility with the Conservation Area of Rayleigh. As such, development on the site is not considered to damage this purpose of including land within the Green Belt.

We consider it the most suitable Green Belt site adjacent to Rayleigh

3.7 In the context of the above, we have considered it appropriate to review the suitability of alternative Green Belt sites on the edge of Rayleigh. Given the scale of additional growth needed in Rochford, as identified by the OAHN, we have considered the credentials of alternative sites for strategic scale development.

3.8 Several sites around Rayleigh were submitted to the Council through the call for sites process for consideration within the new Local Plan and were presented at the Planning Policy Sub-Committee on 17 November 2017. The committee resolved to publish this document in the new Local Plan evidence base. These alternative sites are discussed briefly below along with our commentary regarding their comparatively weaker suitability credentials than that of Lubards Lodge Farm.
● Committed residential development exists to the west of Rayleigh under the reference number 15/00362/OUT on Land North of London Road, South of Rawreth Lane and West of Rawreth Industrial Estate. In our view, further development to the west of this location would lead to a significant increased sense of coalescence with Wickford and a sprawl of Rayleigh in this direction. See figure 2 below for reference.

Figure 2: Extract from the Council's Site Allocations Plan North of London Road, Rayleigh

To the north-east of Rayleigh, in the proximity of SHELAA site CFS105 Land north of Hambro Hill, is constrained by the topography and access. The area of CFS053 Land south of 38 and 39 Wellington Road, CFS098, CFS029 and CFS027 to the east of Rayleigh, falls within the Upper Roach Valley which is protected from development under CS Policy URV1. They would also require access through existing residential areas. We do not consider these sites of a scale capable of delivering strategic scale development and commensurate infrastructure requirements in accordance with the Council's priorities. Furthermore, their delivery would require land assembly and their delivery could not be guaranteed. See figure 3 below for reference.

To the south-east of Rayleigh, in the proximity of SHELAA site CFS127 Eastwood Nurseries off Bartletts, CFS044 south of Eastwood Road and CFS068 off Daws Heath Lane, there are small fragmented land parcels, likely to fall within different land ownerships. Development of this area is likely to be piecemeal and would in our view not be capable of delivering the high quality, integrated development achievable on the Lubards Lodge Farm site. In addition, site access from the narrow Daws Heath Road and from constrained access points off Eastwood Road are likely to be significant constraint in this location. See figure 4 below for reference.

To the south-west of Rayleigh, in the proximity of SHELAA site CFS121 Land north of A127, development is constrained by the exposed and open nature of the countryside experienced from this location. A substantial number of electricity pylons traverse the site between the substation adjacent to the south of the railway station and the National Grid main substation to the west of the A1245. A suitable point of vehicular access is also likely to be an issue for development in this area. See Figure 5 below for reference.

Evidence supporting this submission

Landscape

3.9 A Landscape and Visual Assessment (LVA) of the site has been undertaken and incorporated into the Vision Document in Appendix 2. The assessment identified a number of constraints and opportunities which have informed the proposed masterplan for the site but confirmed that development is entirely achievable in landscape terms.

3.10 The LVA recognised the existing neighbouring development and the mix of land uses at this location and concluded that residential development would not be uncharacteristic for the area. It recommends that the existing vegetation and hedgerow structures be retained as far as possible within the site, particularly bordering the 3 Public Right of Ways (PRoWs) on site. A significant opportunity exists to the north of the site, to provide a new open space connecting to the PRoW
network, providing amenity and green spaces for the proposed dwellings and enhancing biodiversity.

Ecology

3.11 An assessment of the Ecological Constraints and Opportunities has been undertaken and informed the proposed masterplan shown in the promotional brochure at Appendix 2.

3.12 The Assessment concluded that the site is largely of low ecological value but identified two European Designated sites within an 8km radius of the site. Of the two designations, the Crouch & Roach Estuary Special Protection Area (SPA) and Ramsar has the potential to be impacted indirectly due to increased recreational disturbance and a Habitat Regulations Assessment (HRA) is recommended to explore this further. This would be undertaken as the proposals progress.

3.13 The Assessment concludes that with an appropriately designed masterplan, development can be achieved on this site whilst also providing enhancements for biodiversity. An area of Suitable Accessible Natural Green Space (SANGS) is considered appropriate on the north of the site, to provide an alternative open space for future residents of the proposed new dwellings to minimise numbers travelling to the designated sites for recreational purposes.

3.14 Further phase 2 survey work is identified as necessary and these would be undertaken during the appropriate survey window as the proposals progress. Once all survey data is collected, appropriate mitigation measures would be incorporated into the proposals in line with recommendations.

Highways and Access

3.15 An appraisal of access opportunities has been undertaken on the site and has informed the masterplan shown in the promotional brochure in Appendix 2.

3.16 The appraisal identifies the potential for access to be obtained from a 4th arm on the consented roundabout at the junction of Hullbridge Road and Rawreth Lane under the planning permission 16/00162/FUL. Additional opportunities exist along Rawreth Lane, with potential for a 4th arm off the existing signalised junction with Downhall Park Way or a priority 'T' junction on Rawreth Lane.

3.17 Further work, in the form of a Transport Assessment, would be undertaken as the proposals progress. However, in light of the appraisal, residential development of the site as outlined in the promotional brochure is considered achievable.

Floods and Drainage

3.18 An initial floods and drainage assessment has been undertaken and informed the production of the masterplan shown in the promotional brochure at Appendix 2.

3.19 The site generally falls from the south-west to the north-east and located predominantly within Flood Zone 1, with small areas immediately adjacent to the watercourse flowing south to north on the eastern boundary. Some areas of the site are within areas of high, medium and low risk of surface water flooding with a depth of less than 300mm.

3.20 The Lead Local Flood Authority (LLFA) map places the site in a Critical Drainage Area and have produced a Surface Water Management Plan (SWMP) for the area. Whilst the site itself is not at risk of flooding, it is important that development does not increase the risk of flooding offsite within the wider catchment.

3.21 Unsuitable ground conditions exist for infiltration drainage techniques so a system of swales across the site would collect surface water and attenuate it before it passes to a detention basin. A Train of Sustainable Urban Drainage Systems (SuDS) would be incorporated into the scheme as well as 2 outfall points into the watercourse to drain the site. The features described above also offer habitats to support biodiversity and would enhance the environment by adding a water element to the scheme. The water detention centre, when not in use for water storage, would be designed to allow its use for other purposes.

3.22 Foul water would be collected in a tradition pipe network connecting to the existing Anglian Water sewers in Hullbridge Road. The pipe network would be offered to Anglian Water for adoption.

3.23 The drainage system on site has been developed in line with LLFA guidance and SuDS manual and is considered to appropriately address floods and drainage issues. Further refinement of the systems would be undertaken as the proposals progress.

4.0 Conclusion

4.1 These representations have been prepared on behalf of Crest Nicholson Eastern in respect of Land at Lubards Lodge Farm, Rayleigh for consideration in the Rochford Issues and Options Local Plan consultation of March 2018.

4.2 In order to achieve the vision and strategic priority 1 as detailed in the emerging Local Plan, development on the site is required. Significant employment growth is identified in the JAAP and in the wider South Essex sub-region. Housing delivery must match this growth.

4.3 Other neighbouring and nearby Green Belt local authorities are planning for their full OAHN within their Plan areas and there is no sound reason why Rochford should do otherwise.

4.4 In spatial strategy terms, a smaller number of large urban extensions would be the most sustainable approach for addressing this need, particularly in Rayleigh taking account of its sustainability and subsequent position at the top of the settlement hierarchy.

4.5 The Land at Lubards Lodge Farm is located in the Green Belt on the northern border of Rayleigh in a highly sustainable location, with access to the services and facilities within the town centre and the strategic road network and public transport links to London, wider south Essex and Southend airport. Within single ownership, the land is unencumbered and represents an excellent location for strategic scale residential development.

4.6 We would support the Council to undertake a Green Belt review of the district. This would confirm the Green Belt function of potential development sites including the Land at Lubards Lodge Farm and thereby justify strategic planning choices as part of the emerging Local Plan. We consider that Lubards Lodge Farm is the most suitable site for strategic scale residential development at Rayleigh. It also provides a unique opportunity to deliver significant community uses for the town's
existing and future residents.

4.7 A significant amount of preliminary assessments and appraisals have been undertaken to date and all conclude that development is entirely achievable on site. The Vision Document accompanying these representations at Appendix 2 provides further detail and shows the proposed initial masterplan for the site. Crest Nicholson specialises in the design and construction of high quality, community-led residential schemes and will continue to work with RDC and the local community to develop this vision for the site.

*THIS REPRESENTATION IS ACCOMPANIED BY MULTIPLE ATTACHMENTS INCLUDING A SITE MAP AND VISION DOCUMENT*

These representations have been prepared on behalf of Crest Nicholson Eastern in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the "Site") for consideration in the Rochford District Council ("RDC") Issues and Options Local Plan ("the emerging Plan") consultation of March 2018.

Appendix 1 contains a Site Location Plan which shows the extent of the boundaries
of the site.

1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council's strategic housing need as part of the wider full Objectively Assessed Housing Need (OAHN) for the district. A proposed indicated layout is included within the Vision Document in Appendix 2 of these representations.

1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full OAHN. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council's settlement hierarchy.

1.4 Crest Nicholson is an award-winning national housebuilder with a proven track record of delivery, so if the site were allocated in the emerging Local Plan, the residential development of the site could be guaranteed.

1.5 The specific emerging Plan sections that these representations refer to are as follows:
● Vision
● Strategic Priority 1 - the homes and jobs needed in the area
 Strategic Priority 1.1
 Strategic Priority 1.3
 Strategic Priority 1.4
● Strategic Priority 3 - the provision of infrastructure
 Strategic Priority 3.1
● Strategic Priority 5 - protecting and enhancing our environment

 Strategic Priority 5.1

1.6 Full responses to the relevant issues and options within the emerging Plan are detailed in section 2 of this report and section 3 sets out the opportunity presented by the site for delivery of highly sustainable residential development on the northern edge of Rayleigh.

2.0 Our Response to the Issues and Options

The Vision

2.1 The vision section of the emerging Plan details the aims of the Council in relation to the three pillars of sustainability; our economy, our environment and our society. We support the Council's acknowledgement that this vision identifies that growth must be promoted within the district. This is fundamental to the three pillars of sustainable development. It therefore follows that sufficient housing sites must be delivered through the emerging Plan to support the employment, economic
and demographic growth anticipated throughout the Plan period in order to achieve the vision.

2.2 London Southend Airport forms a major part of the planned economic growth of South Essex. Rochford District Council's London Southend Airport and Environs Joint Area Action Plan (JAAP) was adopted in December 2014 in conjunction with Southend Borough Council and the area surrounding the airport is identified as a high scale employment growth area in the JAAP for both Rochford and Southend authorities. Land to accommodate 109,000 additional square metres of employment floorspace is allocated in the JAAP, comprising the new Saxon Business Park and
other smaller business parks and industrial estates, along with the potential to redevelop an area of underutilised brownfield industrial land at Aviation Way. In total, the land is capable of providing an additional 6,200 jobs in the area excluding direct airport related employment, but in order to fully realise the potential offered by this increase in employment land there must be commensurate housing provision through which a local workforce can be located.

2.3 We therefore consider that the planned employment growth must be matched by housing delivery in the most sustainable locations within the district. Rayleigh is one such location. It is strategically well located near to the trunk road network, main line railway to London and to the airport business park, the key employment area in the district. It therefore has optimal characteristics to contribute
significantly to this required housing delivery within the district.

Strategic Priority 1: The homes and jobs needed in the area

2.4 The emerging Plan sets out several strategic priorities for the Plan area in order to achieve the vision. The most relevant to these representations is strategic priority 1, relating to the delivery of homes and jobs in the district.

2.5 In the first instance we support the Council's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District. We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18). The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery. We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the National Planning Policy Framework (the "Framework"), which clearly requires local planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

2.6 We also consider that the emerging Plan should allocate sufficient housing sites to ensure that housing delivery matches the employment growth anticipated in the JAAP and wider Thames Gateway South Essex, a national priority area for growth and regeneration. The JAAP anticipates that the airport employment park alone could generate 6,200 new jobs by 2031 and the wider Thames Gateway South Essex is anticipated to deliver at least 52,000 new jobs1 over the same
period. Delivery of full OAHN in Rochford is therefore a crucial part of the wider strategic growth of South Essex.

2.7 RDC should therefore look to allocate land in the context of full OAHN for residential growth in the most sustainable locations to help attract and support the anticipated economic growth in and around the district and as part of the wider economic strategy for South Essex.

Strategic Priority 1.1: We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

2.8 Our comments relate specifically to objectively assessed housing need:

2.9 The options as set out are:
● A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
● B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
● C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

2.10 We consider that option A is the most suitable approach in relation to this issue, because it is the approach that is best supported by national planning policy and many local planning authorities local to Rochford are already taking this approach as part of their new Local Plans.

2.11 If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy
constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. Nearby local authorities of Basildon and Brentwood are both equally constrained by Green Belt but are both proposing to meet full OAHN. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

2.12 As a useful starting point, it is apparent from the Council's evidence base that the full OAHN could easily be accommodated on sites within the district; the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 identifies that there are 209 suitable and achievable sites within the district capable of accommodating 24,590 dwellings. This identified potential land capacity is well beyond that of the OAHN upper limit of 7,871 homes including the
shortfall in delivery prior to the emerging Plan period.

2.13 The potential land capacity above includes sites within the Green Belt and Special Landscape Areas and the majority of sites fall within these designations. These constraints should not prevent the allocation of the most suitable sites as part of a Local Plan review and in order to demonstrate that the Plan has been positively prepared, as part of the National Planning Policy Framework's
test of soundness under paragraph 182, we recommend that the Council undertakes further work in the form of a Green Belt review assessing individual sites for their contribution to the five purposes of including land within the Green Belt and their potential for release and development.

2.14 We therefore support option A.

Strategic Priority 1.3: How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?

2.15 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011). Rayleigh sits within the top tier of settlements as the most populated settlement in the district. Having regard to its sustainable location with easy access to public transport opportunities including mainline rail, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core Strategy was adopted.

2.16 Our comments on the Options are therefore as follows:

2.17 The realistic options as set out are:
● A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
● B. Increase density on allocated residential sites.
● C. Several small extensions to the existing residential area.
● D. A number of fewer larger extensions to the existing residential area.
● E. A new settlement.

2.18 We consider that option D is the most suitable method of meeting RDC's housing needs because it is the most deliverable over the Plan period.

2.19 Delivering homes in a fewer number of larger urban extensions, directed to established and wellserviced settlements within the district, would ensure that new homes would be connected to existing employment opportunities, transport networks and essential facilities, without a scale of requisite infrastructure provision that would threaten delivery of other planning policy objectives, such as affordable housing. The scale of larger extensions provides greater certainty of their deliverability and would generate higher levels of S106 and/or CIL contributions for improvements to infrastructure and services. They also have the potential to deliver significant onsite community uses. For example, Land at Lubards Lodge Farm represents a unique opportunity to provide significant public open space, allotments and a much needed sports facility for Rayleigh Boys and Girls FC (please see the Vision Document at Appendix 2).

2.20 Our contention for discounting the alternative options are discussed below:
● Whilst the reference to the efficient use of brownfield land in option A is desirable in line with the national policy, densification and infilling has implications for amenity and design quality and the capacity of brownfield sites alone is insufficient to meet full OAHN. Furthermore, options A and B would drastically alter the character of existing settlements and residential land allocations to the extent that would be damaging to existing character. For these reasons, options A and B are considered unsuitable.

● Smaller scale extensions as referenced in option C would fail to deliver sufficient CIL or s106 receipts to enable the cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

For this reason, we consider option C unsuitable.

● The spatial characteristics of Rochford do not lend themselves well to a new settlement identified in option E. Rochford District is constrained by its relatively small geographical area exacerbated by the environmental constraints of the rural estuarine environments in the north and east. There are no obvious opportunities for a new settlement capable of delivering the required housing in a manner that would create sustainable communities. For this reason, option E is considered unsuitable.

2.21 This confirms our view that the only reasonable option is option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rayleigh, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements, CIL or delivery onsite to mitigate the impact of any scheme. We agree with and support this approach.

2.22 Our submission at Section 3 of this report demonstrates that, as a highly sustainable settlement at the top of the settlement hierarchy in the adopted Plan, with the largest population in the district (circa 40% of the District's population), we consider that Rayleigh is the most suitable settlement for accommodating significant housing growth to support the town and the wider district. Land at
Lubards Farm presents an excellent opportunity to deliver a larger scale extension to Rayleigh.

Strategic Priority 1.4: How do we plan for and deliver a good mix of homes in the future?

What types, sizes and tenures are needed?
2.23 The options as set out are:
● A Retain the current policy on types of house, which takes a flexible, market driven approach to types;
● B Include specific reference to the size and types of homes referred to in the South Essex SHMA;
● C Continue to require new homes to meet the National Technical Housing Standards - nationally described space standards;
● D Do not adopt specific policy on the mix of homes.

2.24 We consider that option B is the most suitable approach in relation to this issue, but a greater amount of flexibility should be built into policy wording. The policy should make reference to the housing mix requirement in the most up-to-date SHMA evidence without prescribing exact figures from the most up-to-date available at the time of the emerging Plan publication. Referring to the specific evidence base provides a degree of clarity for the developer whilst concurrently not being so specific as to be inflexible.

2.25 A further matter that does not appear to be considered in the options is that planning for a series of larger extensions to existing settlements means that strategic planning objectives such as housing mix and tenure may be planned for and delivered on a strategic scale. Need may be adequately met this way.

Strategic Priority 3.1: How can we prioritise and deliver improvements to the strategic and local highway network over the next 20 years?

2.26 We do not have any specific comments relating to options as set out under this strategic priority. However, in response to the issue of how to prioritise improvements to the highway network, these should be delivered proportionately and be spatially related to the delivery of homes and jobs. As we have contended, the most appropriate strategy of housing delivery would be larger urban extensions located in highly sustainable towns at the top of the settlement hierarchy, with Rayleigh representing the optimum location for significant growth. Highways improvements would similarly be best located in this area commensurate to housing growth.

Strategic Priority 5: Protecting and Enhancing Our Environment

Strategic Priority 5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

2.27 The options are:
● A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
● B. Amend the current Green Belt policy in the Core Strategy.
● C. Do not have a policy on the Green Belt.

2.28 We consider that option B is the most suitable approach

2.29 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be possible to balance these competing objectives by ensuring that a fully up-to-date evidence base
is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

2.30 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries (paragraph 84). Furthermore, it says that local planning authorities should consider the
consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).

2.31 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.

2.32 This is why we support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's OAHN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A
Green Belt Review would enable RDC to assess land parcels against the five Green Belt purposes.

2.33 Only once the Green Belt Review is complete, can RDC come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

2.34 Our submission demonstrates in the following section that Land at Lubards Lodge Farm, Rayleigh could be removed from the Green Belt as part of the Local Plan review in a manner that would enable a defensible re-drawn boundary in accordance with the five Green Belt purposes.

3.0 The Opportunity - Land at Lubards Lodge Farm, Rayleigh

3.1 Taking account of:
● Rochford District Council's full OAHN;
● The limited availability of brownfield land in the district;
● The spatial characteristics of the district lending themselves best to larger extensions to existing higher order settlements, including Rayleigh; and
● The need to locate new development in sustainable locations,
we consider that the Land at Lubards Lodge Farm, Rayleigh, presents an excellent opportunity for Rochford District Council to help meet its strategic housing needs as part of the new Local Plan. Our reasons for this are set out below.

Sustainable location

3.2 The town of Rayleigh is identified in both the adopted and emerging Plans at the top of the settlement hierarchy demonstrating the Council's view that is represents the most sustainable location for development. Paragraph 6.38 of the emerging Plan states that settlements at the top of the hierarchy are intrinsically sustainable by virtue of their more developed nature, extensive infrastructure connectivity and accessibility to services and the Council seeks to direct housing development to these locations.

3.3 Rayleigh benefits from excellent connectivity to the rest of South Essex and London through the strategic road network comprising the A127, A130 and the A13. It is linked to London Liverpool Street, Southend Victoria and London Southend Airport by train station located in the town centre.

A range of services and facilities are available within the town. The centre of Rayleigh comprises a range of retail units interspersed with food and drink establishments. Recreational buildings such as the Rayleigh Town Museum and The Mill Arts & Events Centre add to the offer in the town centre. To the south, the Brook Road Industrial Estate, as well as the units on the opposite side of
the Southend Arterial Road to the south, offer employment opportunities above and beyond those in the town centre. 18 schools and nurseries are present in Rayleigh as well as 6 GP surgeries and 6 supermarkets providing a comprehensive service offering within the settlement.

3.1 The following table provides a representation of the site's accessibility to key amenities and demonstrates its suitability for development.

AMENITY DISTANCE FROM SITE
Bus stops 3 adjacent to site
Post office 1 within 50 metres

AMENITY DISTANCE FROM SITE
Pharmacy 1 within 50 metres
Shopping Asda within 400 metres
Rayleigh High Street within 1,800 metres
Schools 2 primary schools within 600 metres
2 secondary schools within 1,800 metres
Train station 1 within 1,600 metres
Leisure facilities The Rayleigh Club is adjacent to site
Rayleigh Leisure Centre is within 500 metres
Employment centres Lubards Farm is adjacent to site
Rawreth Lane Industrial Estate is within 1,000 metres
Library 1 within 1,900 metres
Banking 1 within 1,800 metres
Medical 1 within 200 metres

3.2 These demonstrate that the site is sustainably located. Many of these amenities are accessible by bicycle or on foot.

Deliverability

3.1 As the site is within single ownership and is unencumbered, we consider the site as a suitable candidate for allocation as a strategic residential development site because development would be deliverable. This correlates with the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 approved for inclusion and publication within the new Local Plan evidence base by the Planning Policy Sub-Committee on 17 November 2017. The site is assessed
in this document under the reference number CFS164 and the summary confirmed that the site is within Flood Zone 1 and not proximate to any environmental designations with the exception of the Green Belt; a policy designation.

3.2 Crest Nicholson is a national and multi-award-winning housebuilder with a proven track record of delivery of high quality residential schemes. This adds further weight to our demonstration that development on the site would be deliverable within early phases of the emerging Local Plan.

Benefitting from planned highways improvements

3.3 The site's location adjacent to the northern urban area of Rayleigh represents a logical extension to the town, well contained by Hullbridge Road to the east and Rawreth Lane to the south. Locating new development in this part of Rayleigh would mean it would benefit from planned improvements to the existing highway. Furthermore, its location near to the strategic highway network means that the impact of additional highway movements around the town centre would be minimised.

Figure 1: Extract from Drawing F221-202 General Arrangement 3Arm Roundabout from planning permission 16/00162/FUL

3.4 The consented and fully funded roundabout upgrade at the junction of Rawreth Lane and Hullbridge Road reference number 16/00162/FUL could, once delivered, allow for improved accessibility to the site with enhanced access to the wider strategic road network. The upgraded roundabout also offers the potential opportunity for a direct vehicle access from the roundabout itself.

Green Infrastructure

3.5 There is an opportunity to incorporate managed green infrastructure to the north of the site to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised. As the site is currently private
land it does not benefit from the same potential that its redevelopment would bring in this regard.

Green Belt

3.6 Below is a summary of a Green Belt Assessment undertaken by Eleanor Trenfield Landscape Architects Ltd of the site's contribution to the Green Belt. For further detail, please refer to the brochure appended to this report.
● Check the unrestricted sprawl of large built-up areas
An analysis of neighbouring land uses shows sporadic residential plotland development to the west and north of the site as well as commercial estate to the east and residential properties to the south-east which already contribute to the sprawl of Rayleigh north towards Hullbridge. The site therefore is more closely associated with the urban edge of Rayleigh than countryside and makes limited contribution to this purpose.
● Prevent neighbouring towns from merging
Existing sporadic development to the west and the north contribute to the erosion of this function on the site. The absence of a clearly defined urban edge of Rayleigh at this location is created by the plotland development and the site therefore does not act as a barrier preventing the spread of Rayleigh. Indeed, the plotland development already surrounds the site in most directions including towards neighbouring towns and so development on Lubards Farm would not deteriorate the function further.
● Assist in safeguarding the countryside from encroachment
Land between Rayleigh and Hullbridge has experienced piecemeal development resulting in minimal characteristics that would qualify it as 'countryside' land. Plotland developments already protrude significantly into the open land at this location, surrounding the site to the west and the north. In this sense, the countryside has already been significantly encroached and development on the site would not erode this function further.
● Preserve the setting and special character of historic towns
The land between Hullbridge and Rayleigh has no inter-visibility with the Conservation Area of Rayleigh. As such, development on the site is not considered to damage this purpose of including land within the Green Belt.

We consider it the most suitable Green Belt site adjacent to Rayleigh

3.7 In the context of the above, we have considered it appropriate to review the suitability of alternative Green Belt sites on the edge of Rayleigh. Given the scale of additional growth needed in Rochford, as identified by the OAHN, we have considered the credentials of alternative sites for strategic scale development.

3.8 Several sites around Rayleigh were submitted to the Council through the call for sites process for consideration within the new Local Plan and were presented at the Planning Policy Sub-Committee on 17 November 2017. The committee resolved to publish this document in the new Local Plan evidence base. These alternative sites are discussed briefly below along with our commentary regarding their comparatively weaker suitability credentials than that of Lubards Lodge Farm.
● Committed residential development exists to the west of Rayleigh under the reference number 15/00362/OUT on Land North of London Road, South of Rawreth Lane and West of Rawreth Industrial Estate. In our view, further development to the west of this location would lead to a significant increased sense of coalescence with Wickford and a sprawl of Rayleigh in this direction. See figure 2 below for reference.

Figure 2: Extract from the Council's Site Allocations Plan North of London Road, Rayleigh

To the north-east of Rayleigh, in the proximity of SHELAA site CFS105 Land north of Hambro Hill, is constrained by the topography and access. The area of CFS053 Land south of 38 and 39 Wellington Road, CFS098, CFS029 and CFS027 to the east of Rayleigh, falls within the Upper Roach Valley which is protected from development under CS Policy URV1. They would also require access through existing residential areas. We do not consider these sites of a scale capable of delivering strategic scale development and commensurate infrastructure requirements in accordance with the Council's priorities. Furthermore, their delivery would require land assembly and their delivery could not be guaranteed. See figure 3 below for reference.

To the south-east of Rayleigh, in the proximity of SHELAA site CFS127 Eastwood Nurseries off Bartletts, CFS044 south of Eastwood Road and CFS068 off Daws Heath Lane, there are small fragmented land parcels, likely to fall within different land ownerships. Development of this area is likely to be piecemeal and would in our view not be capable of delivering the high quality, integrated development achievable on the Lubards Lodge Farm site. In addition, site access from the narrow Daws Heath Road and from constrained access points off Eastwood Road are likely to be significant constraint in this location. See figure 4 below for reference.

To the south-west of Rayleigh, in the proximity of SHELAA site CFS121 Land north of A127, development is constrained by the exposed and open nature of the countryside experienced from this location. A substantial number of electricity pylons traverse the site between the substation adjacent to the south of the railway station and the National Grid main substation to the west of the A1245. A suitable point of vehicular access is also likely to be an issue for development in this area. See Figure 5 below for reference.

Evidence supporting this submission

Landscape

3.9 A Landscape and Visual Assessment (LVA) of the site has been undertaken and incorporated into the Vision Document in Appendix 2. The assessment identified a number of constraints and opportunities which have informed the proposed masterplan for the site but confirmed that development is entirely achievable in landscape terms.

3.10 The LVA recognised the existing neighbouring development and the mix of land uses at this location and concluded that residential development would not be uncharacteristic for the area. It recommends that the existing vegetation and hedgerow structures be retained as far as possible within the site, particularly bordering the 3 Public Right of Ways (PRoWs) on site. A significant opportunity exists to the north of the site, to provide a new open space connecting to the PRoW
network, providing amenity and green spaces for the proposed dwellings and enhancing biodiversity.

Ecology

3.11 An assessment of the Ecological Constraints and Opportunities has been undertaken and informed the proposed masterplan shown in the promotional brochure at Appendix 2.

3.12 The Assessment concluded that the site is largely of low ecological value but identified two European Designated sites within an 8km radius of the site. Of the two designations, the Crouch & Roach Estuary Special Protection Area (SPA) and Ramsar has the potential to be impacted indirectly due to increased recreational disturbance and a Habitat Regulations Assessment (HRA) is recommended to explore this further. This would be undertaken as the proposals progress.

3.13 The Assessment concludes that with an appropriately designed masterplan, development can be achieved on this site whilst also providing enhancements for biodiversity. An area of Suitable Accessible Natural Green Space (SANGS) is considered appropriate on the north of the site, to provide an alternative open space for future residents of the proposed new dwellings to minimise numbers travelling to the designated sites for recreational purposes.

3.14 Further phase 2 survey work is identified as necessary and these would be undertaken during the appropriate survey window as the proposals progress. Once all survey data is collected, appropriate mitigation measures would be incorporated into the proposals in line with recommendations.

Highways and Access

3.15 An appraisal of access opportunities has been undertaken on the site and has informed the masterplan shown in the promotional brochure in Appendix 2.

3.16 The appraisal identifies the potential for access to be obtained from a 4th arm on the consented roundabout at the junction of Hullbridge Road and Rawreth Lane under the planning permission 16/00162/FUL. Additional opportunities exist along Rawreth Lane, with potential for a 4th arm off the existing signalised junction with Downhall Park Way or a priority 'T' junction on Rawreth Lane.

3.17 Further work, in the form of a Transport Assessment, would be undertaken as the proposals progress. However, in light of the appraisal, residential development of the site as outlined in the promotional brochure is considered achievable.

Floods and Drainage

3.18 An initial floods and drainage assessment has been undertaken and informed the production of the masterplan shown in the promotional brochure at Appendix 2.

3.19 The site generally falls from the south-west to the north-east and located predominantly within Flood Zone 1, with small areas immediately adjacent to the watercourse flowing south to north on the eastern boundary. Some areas of the site are within areas of high, medium and low risk of surface water flooding with a depth of less than 300mm.

3.20 The Lead Local Flood Authority (LLFA) map places the site in a Critical Drainage Area and have produced a Surface Water Management Plan (SWMP) for the area. Whilst the site itself is not at risk of flooding, it is important that development does not increase the risk of flooding offsite within the wider catchment.

3.21 Unsuitable ground conditions exist for infiltration drainage techniques so a system of swales across the site would collect surface water and attenuate it before it passes to a detention basin. A Train of Sustainable Urban Drainage Systems (SuDS) would be incorporated into the scheme as well as 2 outfall points into the watercourse to drain the site. The features described above also offer habitats to support biodiversity and would enhance the environment by adding a water element to the scheme. The water detention centre, when not in use for water storage, would be designed to allow its use for other purposes.

3.22 Foul water would be collected in a tradition pipe network connecting to the existing Anglian Water sewers in Hullbridge Road. The pipe network would be offered to Anglian Water for adoption.

3.23 The drainage system on site has been developed in line with LLFA guidance and SuDS manual and is considered to appropriately address floods and drainage issues. Further refinement of the systems would be undertaken as the proposals progress.

4.0 Conclusion

4.1 These representations have been prepared on behalf of Crest Nicholson Eastern in respect of Land at Lubards Lodge Farm, Rayleigh for consideration in the Rochford Issues and Options Local Plan consultation of March 2018.

4.2 In order to achieve the vision and strategic priority 1 as detailed in the emerging Local Plan, development on the site is required. Significant employment growth is identified in the JAAP and in the wider South Essex sub-region. Housing delivery must match this growth.

4.3 Other neighbouring and nearby Green Belt local authorities are planning for their full OAHN within their Plan areas and there is no sound reason why Rochford should do otherwise.

4.4 In spatial strategy terms, a smaller number of large urban extensions would be the most sustainable approach for addressing this need, particularly in Rayleigh taking account of its sustainability and subsequent position at the top of the settlement hierarchy.

4.5 The Land at Lubards Lodge Farm is located in the Green Belt on the northern border of Rayleigh in a highly sustainable location, with access to the services and facilities within the town centre and the strategic road network and public transport links to London, wider south Essex and Southend airport. Within single ownership, the land is unencumbered and represents an excellent location for strategic scale residential development.

4.6 We would support the Council to undertake a Green Belt review of the district. This would confirm the Green Belt function of potential development sites including the Land at Lubards Lodge Farm and thereby justify strategic planning choices as part of the emerging Local Plan. We consider that Lubards Lodge Farm is the most suitable site for strategic scale residential development at Rayleigh. It also provides a unique opportunity to deliver significant community uses for the town's
existing and future residents.

4.7 A significant amount of preliminary assessments and appraisals have been undertaken to date and all conclude that development is entirely achievable on site. The Vision Document accompanying these representations at Appendix 2 provides further detail and shows the proposed initial masterplan for the site. Crest Nicholson specialises in the design and construction of high quality, community-led residential schemes and will continue to work with RDC and the local community to develop this vision for the site.

ROCHFORD DISTRICT COUNCIL STRATEGIC HOUSING & EMPLOYMENT LAND AVAILABILITY ASSESSMENT 2017 - APP. B, MAP Q

REPRESENTATION IN RESPECT OF:-FUTURE HOUSING DEVELOPMENT - GT. WAKERING

1. Gt. Wakering is once again in the spotlight for new housing developments. The Star Lane Brickworks site is more or less complete. There are 2 more sites in the pipeline. The next will be land south of the High Street adjacent to the Star Lane Development. SER9b. After this SER9a - Land west of the Little Wakering Road.

2. Any new housing development will put additional pressures on the local amenities & infrastructure.

3. All developments in Gt. Wakering will make demands on its schools/medical facilities/transport/roads.

4. All statements on the latest documentation state that Amenities are either Excellent or Good

5. Already the parents of the rising 5's are being refused the local school of their choice. There are no obvious choices for alternatives in the catchment area. Local research on the Star Lane site has revealed that parents have in the main chosen to keep their children at their previous schools. It has to be said that many of these new arrivals are former Rochford residents, so for the time being the problem has not been identified.

6. The medical facilities whilst reasonable at the moment are under daily pressures. This will not ease even if the local developments are limited to the current 3 approved sites.

7. The development of the Garrison Site in Shoeburyness has vastly increased the traffic using the cross country roads from the Anne Boleyn Pub on the Rochford Road, Sutton Road, Shopland Road, to the Rose Inn Pub at Silchester Corner. Traffic then turns left onto the Southend Road, onto Star Lane, Poynters Lane to Wakering Road & the Garrison Site.

8. NO NEW ROADS HAVE BEEN BUILT IN THE AREA TO ALLEVIATE THE INCREASING TRAFFIC FLOW DURING THIS EXPANSION PROGRAMME!

9. Neither Gt. Wakering nor Shoebury have benefitted in any significant way. The land from the old school 'Hinguar', has been turned into a 'Housing Development'. The new school was a necessity not a luxury!

10. Access & Egress for residents of Gt. Wakering all converge on the High Street/Shoebury Road and also now Star Lane. The residents of Alexandra Road already suffer daily chaos with Street Parking which was acutely aggravated by the development at its Southern End - Meeson Meadows.

11. Sufficient new housing needs to be available & affordable for local people. Two bedroom properties might improve the 'statistics' but do nothing for parents with 2 children of different sexes. The prices of the 2 bedroom properties on Star Lane, £300k towards the end of the development, will only attract well paid London workers! Again, a windfall for the developers but demoralising for local people. The consultation which took place in the village in the 1980's made a point of saying it wanted more affordable housing. It hasn't happened!


RDC STRATEGIC HOUSING & EMPLOYMENT LAND AVAILABILITY ASSESSMENT 2017 APP B SPECIFIC COMMENTS RE PROPOSED DEVELOPMENTS

1. Planning ref. CFS 153 - Land between Common Road & Chapel Lane
* This site is on the Dept. Of Environment's Flood Plain Map. We have been residents at this property for 40yrs. Over the past 5years it has become an increasing problem to obtain Household Insurance (Buildings & Contents). In fact many Insurers will not even quote!

* The proposed site is inhabited by badgers which are protected by the Protection of Badgers Act 1992. Building on this site and intentionally damaging or destroying a badger sett or disturbing a badger when it is occupying a sett is an offence.

* The proposed site is bordered on the Chapel Lane side by a 'Foul Water ditch'. This ditch takes the runoff from the High Street.

* Although by law the land owner is required to maintain this ditch no attempt has been made to support a free running flow of water.

* In 2016, Anglian Water had to create a new run-off from properties in Newstead Road where rear gardens were flooding on a regular basis. This new pipeline enters the Foul Water ditch opposite our property.

* Heavy rainfall already causes localised flooding on Chapel Lane. By building on this land the current problem is likely to be exacerbated because of the loss of natural drainage.

We would not support the development of this site!

2 .Planning refs. CFS 070, CFS 065, CFS 011,GF 03
* These sites all fall within the existing recognised boundaries of the village of Gt. Wakering.
* CFS 065 quite possibly falls within the Dept of the Environment's Flood Plain Map. Therefore householders will experience problems in obtaining Household Insurance, This is already a problem for householders on the most recent development off Seaview Drive.

* The same problems with regards to Infrastructure/Medical facilities/Schools & Transport will apply to these developments if granted Planning Permission.

3.Planning ref. CFS 057

* This site appears to encompass all the remaining land bounded by Star Lane, Poynters Lane & Alexandra Road & includes the Wild Life Site.

* Substantial improvements to the Access & Egress appear to be vital. However, In the past, Rochford District Council has always maintained that it was against any Access /Egress onto Poynters Lane as it would effectively join Gt. Wakering to Southend on Sea. Will this Policy change? If so, at what cost to the residents?

4. Planning refs. CFS 097, CFS 034, CFS 056

* All 3 of these proposed Housing Development sites lie to the South of Poynters Lane. Although technically within the Rochford District boundaries they will greatly increase the urbanisation of the existing Shoebury Housing Estates.

* Potentially creating problems for Southend on Sea, Unitary Authority as stated above.

* All other issues apply.

5. Conclusion

The current planned developments under SER9b will add 400 new housing units to a village of approximately 2500 dwellings. This Community does not have access to a User Friendly Transport system. There is no public transport to Shoeburyness Station for commuters. The existing bus routes now take much longer to reach Southend Central Bus Station due to re-routing. The last bus during the week does not support shift workers with evening & night shifts. Several hundred more vehicles (from the current developments) will be added to the already inadequate road structure. There appears to be a tendency when evaluating the local amenities (as per this latest plan) to assess them as being Excellent or Good. Even Good is stretching it a bit. This latest proposal would clearly see new units in excess of 1000 being added to the already saturated area. Just because it is a Greenfield shouldn't mean it's an easy target for Developers & Councils alike!

It will not be possible to support any of these proposals without a substantial investment in the local infrastructure.

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

I would like to lodge the following comments in connection with the following sites which have been included in the potential for development in the RDC plan.
1. RDC Reference COL38 land between Malvern Road and Branksome Avenue - Malvern Road play area.
This area is owned by RDC and was allocated and set aside as a play area when Malvern Road was initially built/developed. The attached letter from RDC legal services shows that following previous proposals to develop this land and objections from local residents that RDC committed to retain this as a public open space. I attended and made representation at Ashingdon Council meetings and their minutes also confirm they were prepared to take on and manage this for local residents. There were also proposals to make a bridleway across this piece of land and in the inquiry in May 2014 it was recognised as a public right of way due to its continuous use as a walkway between Malvern Road and Branksome Avenue.
Having lived adjacent to this piece of land for over 35 years I can confirm that it is used as a play area and is also regularly used by people accessing Beckney Woods. Beckney Woods is recognised as ancient woodland and these trees link into the woods and form part of the natural buffer between the woodland and the urban environment. Birds and animals use the play space too and there are frequently woodpeckers seen on the field.
Developing this piece of land would be detrimental to our community, remove the right of way and also add another burden to our overstretched infrastructure.

2. RDC Reference CFS023 land to the rear of Malvern Road and Harrogate Drive. This land is green belt and as such should be protected and maintained. It forms a buffer between Malvern Road and Beckney Woods which has ancient woodland status. It is recognised that there should be a buffer between urban development and ancient woodland and this field provides a natural buffer.
Development of this land would add pressure to our already overstretched infrastructure and would increase the use of schools, health services, roads water and sewage, all of which are struggling to meet the needs of our current population.

*THIS REPRESENTATION IS UNDERSIGNED BY 946 MEMBERS OF RAYLEIGH ACTION GROUP*

TO ROCHORD DISTRICT COUNCIL COUNCIL OFFICES SOUTH STREET ROCHFORD ESSEX SS4 1BW
FROM LINDA KENDALL *ADDRESS REDACTED*
PLUS THE UNDERSIGNED MEMBERS OF RAYLEIGH ACTION GROUP
NEW LOCAL PLAN ISSUES AND OPTIONS DOCUMENT
OBJECTION TO THE PROPOSALS CONTAINED IN THAT DOCUMENT.

This is a response to the expensively produced document of approximately 800 pages which outlines proposals for the development of Rochford District post 2025.

I wish to state that I consider the prospect of building a possible unconstrained additional 7500 dwellings is UNSUSTAINABLE in every way imaginable. My reasons are summarised briefly below.

There will be an expansion on these issues further in this document.
Housing
Traffic / Roads / public transport trains & bus capacity
Flooding
Health provision / hospitals / doctors / care provision
Schools / Education
Environment
Air Quality
Greenbelt protection
Housing demand

There is a need for housing to meet the natural growth in our district. The percentages of house building requirements do not match the current objective need. The actual objective is to provide for London overspill because of the mass influx of people that have arrived in our capital city in the past ten years. To suggest
otherwise is to be disingenuous.

The natural growth of the district can be met by RDC actively seeking out brownfield sites for development, small infill developments, use of degraded greenfield, the return of the use of flats over shops, in order to keep our
towns and villages alive and active, and finally the conversion of properties into larger units. All these measures will prevent the proposed maximum attack on our greenbelt and valuable farmland. I will cite the following examples of fairly recent developments:-
Gunn Close London Road (One bungalow morphed into 14 four bed houses)
Eon site London Road (one industrial site became 101 homes)
London Road / Station Approach (small scrubland site developed into numerous apartments). Lakeside
Downhall Road (back land development of multiple apartments).

I could continue to discuss developments throughout this particular small part of Rayleigh that are NOT included in the figures, to meet some central Government target, that should serve to meet the generic need for the area without mass building projects. Add to this the regular conversion of bungalows into 4/5 bed houses and the proposals to create cul-de-sacs from single dwelling plots, the capacity to house our increasing population could be met. The figures for generic growth in our district do not support by the kind of mass development envisaged.
It is claimed that developers, having secured planning permission, have been using a loop hole in the 'affordable housing' requirement by subsequently claiming the projects don't might the 20% profit threshold required. Thus very few houses are being build that are affordable for local people.

The maps of the areas to be suggested for development show a huge number to be built in the town of Rayleigh. It identifies enough land to build a minimum of 6000 suggested for Downhall and Rawreth Ward in the west of the district. This is in addition to the 700 not yet built as a result of the 2010 Local Plan (SER1) in the
same location.

Traffic and Road network

This western part of the district is unfortunate to suffer an almost daily gridlock on our roads.
London Road, Rawreth Lane and Watery Lane are the arteries that feed most of the villages and small towns to the east. They are all regularly at a standstill. 7500 extra dwellings will result in at least 15,000 more vehicles.
The increase in traffic on our roads will be UNSUSTAINABLE if this plan is implemented.

Promises of the 'jam tomorrow' of roundabouts and traffic improvements have no prospect of delivery due to the piecemeal nature of the developments already approved. There have been suggestions from other objectors that a substantial upgraded road be developed towards the east of the district. Taking a route whereby Watery Lane / Lower Road are fed by vehicles, directly via the A130, bypassing Rayleigh. We cannot support this idea because it will serve to open up much of our remaining greenbelt to further development to the detriment of the villages further east in our district. We cannot agree to make the situation worse for our neighbouring villages.

70,000 vehicles pass through the A127 Fairglen Interchange daily, serving Rochford, Southend, South Benfleet and beyond, making it the busiest junction in South East Essex. To increase the volume of vehicles by 15,000, in
this area alone, is not sustainable.

Essex County Council have a serious shortfall in funding. It will result in no major improvements in the road network for the foreseeable future in this district. Refer to addendum 1 showing ECC Summary of infrastructure project costs and funding gaps.(2016-2036)

Public Transport

There is limited opportunity to increase the train capacity on the Greater Anglia line at peak times because of the terminus at Liverpool Street is currently at its' peak capacity. Trains are overcrowded now so how can they accommodate more passengers.

Bus transport is somewhat irregular and completely unavailable in many parts of the district.

Cycle. The distances and the terrain preclude the use of cycles except for those who are super fit.

Walking

Due to the distances covered it is impractical to expect residents to walk or most of their daily requirements. For instance, the elderly and families will not be able to walk from Hullbridge to Rayleigh and carry necessary groceries, a distance of 3 miles plus. It is simply not practical and to suggest otherwise is a ridiculous fantasy.
Families use cars. That is a fact of life for almost every activity i.e. shopping, travel to work/school (many youngsters have to be ferried to and from school due to the distances involved) and for the opportunity to even use the somewhat remote leisure facilities.

Flooding
Where are the measures to tackle the flood risk to many of our riverside communities? Extreme weather is becoming a norm and the building of huge estates with piecemeal flood alleviation measures is unsustainable. Evidence is readily available to the RDC that clearly identifies pinch points in the flood defences
of this area.

Air Quality
Rayleigh town centre, as acknowledged in the report, has a dismal record on AIR POLLUTION. Being at consistently illegal levels of nitrogen dioxide. This is damaging our children's health and well being and with a possible link to dementia. Increasing the traffic will exacerbate this problem.

Health Provision
Residents have difficulties accessing their doctors in a timely manner. It is routine at the moment for the local surgeries to offer appointments three weeks after they are requested.

Our three hospital Southend , Basildon, and Broomfield have all issued notices that they are on 'black alert' over the past year. Indicating they have NO BEDS available. There is no provision made in the proposals to increasing the capacity in our health service to meet the increased demand.

The gap in funding for adult social care is not addressed in this proposed plan.
Refer ECC Summary of Infrastructure project costs and funding gaps (2016-2036).

Schools
Evidence is available that Rayleigh Primary Schools are over-subscribed. Rayleigh Primary and Glebe School state they have no capacity at present. Some parents are face with travelling across the district to different schools to educate their children.

As discussed in a Guardian newspaper article developers have managed to wriggle out of providing a planned schools, after securing their planning permission, by persuading authorities that the development would be made
'unviable'.

I cite the situation on the Hall Road Development where a school was promised and now is not to be provided.

Also the planning for the site North of London Road was recently given the go ahead by the District Councillors and the school was left as a 'pending' provision with no firm promise of it being built. The education of our children should not be left to a chance that a developer MIGHT provide the facilities.

Refer ECC Summary of Infrastructure project costs and funding gaps (2016-2036).

Greenbelt

There is no possibility of delivering the number of dwellings proposed without the destruction of vast swathes of our remaining greenbelt which is against the policies contained in the National Planning Policy Framework. NPPF. Our Prime Minister and Minister for Housing has stated repeatedly 'there should be no building on
greenbelt until every other opportunity has been explored'.

To Summarise.

Due to the evident unsustainable nature of the present Issues and Options document I would make a request to consider the following :-

I propose a compete rethink of the document and would ask the Members of Rochford District Council and Members of Parliament representing constituencies in South East Essex namely:-
Mark Francois MP mark.francois.mp@parliament.uk
Rebecca Harris MP rebecca.harris.mp@parliament.uk
Sir David Amess MP amessd@parliament.uk
Stephen Metcalfe MP stephen.metcalfe.mp@parliament.uk
John Barron MP baronj@parliament.uk
James Dudderidge MP james@jamesdudderidge.com
To call for a scheme to build a new Garden City on the Dengie Peninsular with a road and rail bridge over the River Crouch linking Southend to the north of the county. Links could be provided to provide further development in future. This would help to preserve the semi-rural nature of South East Essex and prevent the total URBANISATION of our part of Essex. They could call on the new proposed Infrastructure Policy, announced recently by the the Government, to help fund the roads and bridge.

Members of Parliament representing constituencies along the Cambridge to Oxford corridor and those serving Kent constituencies have secured such funding for Garden Cities with all the necessary infrastructure, roads, hospital, schools etc. This is in order to protect their residents. I call on all our local Members of Parliament to
step up and try to protect our people in the same manner. A copy of this objection will be distributed to the Parliamentary members named for their attention.

Signed

*THIS REPRESENTATION WAS SUBMITTED ON BEHALF OF NIKKI BUTCHER BY TRACY WADE*

As you will see from her address she particularly objects to GF01 - Land north west of Hockley Station, Hockley, SS5 5AE - Railway embankment, which is directly opposite her property. As noted the road is a narrow access road with no vehicular access to the land, which would be difficult to add safely as it is also on a crescent road. The vacant land supports and protects wildlife and habitat of the nearby Marylands Woods and nature reserve. In addition the land would not be suitable for similar housing to the current semi-detached bungalows and the potential for flats would not be in keeping and overlook her and other properties severely impacting privacy especially hers and others with dormer extensions.
Please confirm receipt of her objections to her email address and keep her informed of future meetings.
The current pressure from Government on Local Authorities to build thousands of houses in rural areas and particularly on green-belt/fields is unacceptable and knee jerk reaction due to different successive Governments failure to plan strategically or forecast needs and exacerbated when Council Housing stock was sold off at excessively reduced cost under the "Right to Buy" knowing they did not have funding for building programmes to replace let alone increase the stock.
Rather than spreading the housing across the Country the focus is to build closer to London and other Cities and Towns where there are higher levels of employment therefore need. However, housing is limited and becomes more expensive due to demand from the increase of internal migration and immigration, whether driven by social, family, economics, asylum or humanitarian. Inner City Authorities are already sending people to this area for emergency housing paying private landlords excessive amounts. In many areas including Hockley and its local towns and villages the infrastructure, in particular transport/healthcare/schools/social care/utilities, is currently not sufficient for existing residents let alone the recent and current medium/large building developments already passed by the Planning Department.

Having reviewed the Issues and Options Document (and draft Sustainability Appraisal) and Rochford District Council - Strategic Housing and Employment Land Availability Assessment 2017-Appendix C - Site Assessment Forms, I have the following General Objections for the overall Plan and @ TABLE 2 - Objections to Specific Site Assessments identified for proposed development.
General Objections:
No Cohesive Plan:
Reading the Site Assessments the sections headed Infrastructure Assessment indicate that other than 3 sites, there is no significant investment needed for utilities and no sites require significant investment for transport. Taken individually this might be the case but when 15 sites have the potential to accommodate 500+ dwellings @30 per Ha, it would seem to be a serious oversight by the Assessor. In any event this is a wider plan for the District and taken as a whole the number of proposed sites would indicate significant investments would be required and the following MUST be improved before any further development plans are passed or built in to the planning agreements, with no options to default.

Inadequate Transport Network
Road - The road system can barely accommodate the current population let alone the new developments currently under construction, particularly those in Rochford, Ashingdon, Hawkwell. Rochford District has 1 designated Orange Secondary Road which joins Rayleigh-Hockley-Hawkwell-Southend and this has already been highlighted in Local Authority Reports as needing urgent improvements/widening due to volume of traffic-we are still waiting for a feasible solution! All other roads are designated Yellow-less than 4 metres or White-Other Road drive-track. The location of the River Crouch, it's tributaries and marsh lands, to the north of the district means any expansion of road systems is restricted to existing populated areas. Even if it was possible it would impact Maldon District which also has a poor road network. Planning must also take account of the commercial vehicles-cars, which have increased with more online purchasing not just the domestic vehicles approx. 1-2 per household for current population and proposed from current and future developments.
The road networks, with recognised pinch points, Rochford/Ashingdon/Hockley railway bridges; Spa roundabout; Rawreth mini roundabout; Rayleigh one way system, are just a few, to the wider road system. There are only 4 A roads A127; A130; A13; A12, all of which are already congested and access to the A13 & A12 is via the A127 & A130. This impacts journeys to local jobs/schools as well as those travelling further to the M25, all junctions of which are congested on a daily basis during rush hours. The development and growth of Southend Airport although beneficial to Commerce has brought more traffic in to the area too.
The development plans identify sites adjacent to many of the existing roads so if they are built before the road sysetm is improved how can they be widened or land made available for new roads [not just access roads and ornate roundabouts to the sites].
Even if the local road system was improved the increase in local traffic to the already congested A Roads which could not cope. The Plans indicate working with other Government and Highways Departments to improve the wider infrastructure but there is nothing concrete and overall austerity and poor road conditions, pothole epedemic would indicate these Plans are not realistic. During normal road conditions vehicles queue to access most junctions on the A roads and during rush hours and/or bad conditions they queue to get on and off at junctions from Wickford to Southend.

Inadequate Rail Services - trains are already very busy and on the Southend to Liverpool Street Line people who pay thousands of pounds per year normally have to stand from Billericay. The C2C Line is a little better but the increase in housing will increase passengers from the start of each line meaning more people will be standing unless Rochford Concil can confirm the Railways have the ability to invest at the same time in order to accommodate the expected numbers by adding trains or carriages. Again how realistic is this, schedules are already tightly timed and there is limited ability to add trains especialy where lines converge at Shenfield, Wickford, Romford, Stratford etc., extra carriages may be limited by the current length of platforms and in many cases there is no potential to expand because of lack of land/access.
Inadequate Bus Services - routes and timetables are limited leading to many people using private vehicles.
Supply of Utilities [water/electricity/gas/telecoms/waste treatment/recycle] - privately operated companies have not proven their ability or commitment to meeting extra demands for the Essex County target of 185,000 new homes. The land in this area consists of waterways, marshland and prone to flooding. Over development will place additional pressure on the waterways, sewage, drains which cannot cope with the resulting runoff, struggling now.
Inadequate Civic Amenities - to date austerity programmes and historic lack of investments for schools, health, transport, roads and maintenance have eroded Civic Amenities and Services, in particular Health and Care Services to the point of crisis. Outsourcing and so called partnerships with private companies such as Carillion failing catetrophically leading to tax payers having to fund losses to keep essential services being delivered. Local Authrites current plans are to reduce/cost save and merge in line with the lack of funding not to increase, impove which would be needed to prepare for this radical Plan. This is not scaremongering but supported by the intended merger of Basildon, Southend and Broomfield Hospitals. Identifying Car Parks, Police Stations, Council Offices and Land for development to residential when the need for these will increase with the proposed increase in population. How can Planners think an increase in housing and resulting population needs can be met when Government and Local Authorities do not have a cohesive plan, most only have 3-5 year plans anticipating changes in governments and local authorities which result in different priorities, back-tracking and ultimately wasting money, time and resources.
Land Identification & Development
Table 1 below is a breakdown by location and site. There are a total of 226 sites identified which allocate approximately 1084 hectres and calculating properties @30 per Ha totals over 32519, which is much higher than the 7500 required. This means that not all the sites will be required.
Table 1 Breakdown of the Site Assessments
Location Ashingdon Canewdon Great Stambridge/ Stambridge Wakerings [Great/Little] Hawkwell Hockley Hullbridge Leigh/ Southend Rawreth Rayleigh/Eastwood Rochford Wickford
# Sites Identified 16 10 4 17 14 22 22 4 11 55 49 2
Ha Identified 49.6 38.4 11.28 121.79 67.1 64.7 87 9.26 103 252 275 5.76
Proposed No @30 per Ha 1487 1151 338 3654 2013 1941 2601 278 3093 7555 8235 173

I object to any sites being adopted that will not provide the housing required by Government/Local Authority Quotas to provide social/affordable housing due to the size of the site and/or impacting the green-belt/field land, in particular woodland/vacant/open/grassland and historic land/buildings and placing additional burden on the existing poor road networks and civic communities.
Those sites designated as Woodlands, most of which have ancient relevance in this area and particuarly Hockley, ancient/listed buildings, open spaces, community buildings, car parks and any land where the development would impact a public/official right of way, footpath; bridlepath as well as any adopted one's should be removed from consideration. In fact they should be ring fenced from future plans and maintained or invested in for the use and enjoyment of the current and expected increase in population.
Land Identified as Gypsy & Traveller's Sites
I object to the proposed sites for Gypsy & Traveller's. The 10 sites account for 16.5 hectres which for normal housing allocation would equate to 495. This is excessive for the area when there are only 12 authorised sites in Essex - 1 in Basildon @25 plots; 2 chelmsford @ 22 plots & 2 Maldon @ 26 plots, not including the current 3 unauthroised plots in Leigh and Rawreth. Locating sites adjacent to agricultural/open land could encourage unauthorised spread and the traditional trades/work they do could lead to build up of and unlawful disposal of scrap metal, hazardous high risk waste, rubble and other construction waste & materials, which will adversely impact wildlife, land, waterways and the environment generally.

Objections to Specific Site Assessments
TABLE 2 - Objections to Specific Site Assessments
Ref Address Designation Ha Dwellings @30pHa
CFS024 Land north of Merryfields Avenue, Hockley, SS5 5AL Woodland 1.25 38
The land is a long thin strip behind a residential area and to the other side the Marylands Nature Reserve with open land tracks and footpaths recreational areas beyond that. This is a small development which would have a very poor access/layout and not benefit the government quotas for social/affordable housing. The Woodland area supports and protects the existing Nature Reserve from the negative impact of the existing domestic dwellings. Nature does not stop at the current boundary of the Nature Reserve and has naturally spread to the woodland. Development would severely impact the existing wildlife from birds, bats, badgers, foxes, butterflies and their food sources including vegetation, insects and their habitat in this area and those from the Nature Reserve which benefit from the woodland, some of which will have spread to this area with nests/burrows or territories/tracks. The development has an awkward, sloped, narrow access through narrow congested roads to reach Plumberow Avenue. The Woodland is currently providing a natural soak away but there is still a build up during heavy rainfall at the end of Marylands Avenue, where the access would be, because of the poor drainage system. As a small development they would not have to contribute to improving the infrastructure nor allocate social/affordable housing so for the overall Development Plan it should not be adopted as other sites would provide more properties to meet the government/local authority quotas and contribute to improving the infrastructure.
GF01 Land north west of Hockley Station, Hockley, SS5 5AE - Railway embankment Vacant-wooded area 0.37 11
This land has no current vehicular access and is part of the railway embankment made up of a long thin strip. Access could only be achieved from a section of Mount Crescent which is a narrow access road to a small development of semi-detached bungalows. The specific section only has a footpath on the opposite side to the site and sharp bends to both ends which could cause pedestrian and vehicular hazards. Although the dimensions of the site are not clear the size would only accommodate 11 or less individual dwellings if the proposed development was in keeping with the current housing stock. The land size and proximity to the railway does not afford itself to this type of housing stock but flats would not be in keeping with the current housing stock and overlook existing dwellings living accommodation impacting their privacy as the majority have extended their living accommodation and bedrooms in to their loft. Looking at buildings along the existing railway track in the vicinity there are none that are built as close as this proposed development and I assume there is a reason for this, whether from the point of view of residents who would be on top of the railway and affected by noise/vibration of the busy train services from Southend to London Liverpool Street, which will have to increase. Or the need for the railway provider to maintain the railway and a sufficient boundary to expand or protect the line from anything that could impact it i.e. building fire. The wooded area although not designated as part of the ancients woods is linked to Marylands Wood to one side thereby supporting and protecting the existing wildlife from birds, bats, badgers, foxes, butterflies, voles etc. and their food sources including vegetation, insects in this area and those from the nearby Nature Reserve benefiting which benefit from the wooded area, some of which will have spread to this area with nests/burrows or territories/tracks. The wooded area currently provides a natural soak away for the existing houses protecting the railway, which will be lost and the new development and runoff could adversely impact the railway. As a small development it will not contribute to the goal of the government quotas to increase social housing stock nor will it have to contribute to the local infrastructure, therefore, as part of the overall Development Plan it should not be adopted as other sites would provide more properties to meet the government/local authority quotas and contribute to improving the infrastructure.
CFS019 Land adjacent to Newhall Road and Lower Road, Hockley, SS5 5JU Woodland/Vacant 1 30
The land is behind a current residence and adjacent to a well-used track accessing walks and open spaces. If full potential of dwellings was agreed it would not be in keeping with existing land use or residence and could lead to a precedence to use other vacant/woodland adjoining to be developed. The development would have to join a country road with limited lighting near a bend. As a small development they would not have to contribute to improving the infrastructure nor allocate social/affordable housing so for the overall Development Plan it should not be adopted as other sites would provide more properties to meet the government/local authority quotas and contribute to improving the infrastructure
CFS023 Land north and east of Malvern Road, Hockley, SS5 5JA Grass Field/Track 5.6 168
The land is adjacent to a residential area on one side but the majority would be adjacent to Beckney Woods and open land tracks and footpaths with very few dwellings. These open spaces, footpaths, adopted tracks connect the existing ancient woods from Hockley, Ashingdon, Rochford, Hawkwell. If full potential of dwellings was agreed it would begin to box in the Woods which will severely impact the access the open spaces for human use but more importantly access from one area to another for wildlife from birds, badgers, foxes, butterflies and their food sources including vegetation, insects. The development would have to join a minor road with limited lighting and at the bottom or an existing hill. As a small development they would not have to contribute to improving the infrastructure nor allocate social/affordable housing so for the overall Development Plan it should not be adopted as other sites would provide more properties to meet the government/local authority quotas and contribute to improving the infrastructure
CFS030 Creek View, Beckney Avenue, Hockley, SS5 5NR - Vacant/Woodland 0.18 5
The land is adjacent woodland on all sides adjacent to Beckney Woods with no dwellings. These woods lead to adjacent open spaces, footpaths, adopted tracks connecting the existing ancient woods from Hockley, Ashingdon, Rochford, Hawkwell. Such a small development will have little benefit to the focus of the Government quotas for social housing but will severely impact the access to the open spaces for human use but more importantly access from one area to another for wildlife from birds, badgers, bats, foxes, butterflies and their food sources including vegetation, insects and their habitat. The development would have to join a track with limited lighting with one access to road system joining Plumberow Avenue which is already congested. As a small development they would not have to contribute to improving the infrastructure nor allocate social/affordable housing so for the overall Development Plan it should not be adopted as other sites would provide more properties to meet the government/local authority quotas and contribute to improving the infrastructure
CFS040 Eastview House and Haslemere, Church Road, Hockley SS5 4SS Residential 1.3 39
The land is already residential but backs on to open land and opposite/near two new developments under construction. This is a minor road which is a cut through for traffic trying to avoid Rayleigh/Rawreth and is already very busy and current developments increasing use of these minor roads. It passes some very old properties and church has limited access under railway bridge and one way system to reach the access road at a difficult point on Aldermans Hill. The stables and other horse-riders use these back roads to access the bridleways in Hockley/Hullbridge. Such a small development will have little benefit to the focus of the Government quotas for social housing but will severely impact the access roads and further impact on local wildlife and habitat. As a small development they would not have to contribute to improving the infrastructure nor allocate social/affordable housing so for the overall Development Plan it should not be adopted as other sites would provide more properties to meet the government/local authority quotas and contribute to improving the infrastructure
CFS039 Plots 1/2/3 New Hall Estate, Greensward Lane, Hockley, SS5 5J Trinity Wood House Woodland 0.18 5
CFS064 Land north and east of Folly Chase, Hockley, SS5 4SF - Agricultural/Vacant/Residential/Woodland 9.03 271
CFS074 Land south of Mount Bovers Lane, Hockley SS5 4J Agricultural 22 660
CFS150 Land on the north side of Victor Gardens, Hockley SS5 4DY Woodland/Vacant 2.02 61
CFS160 Northlands Farm, 65 High Road, Hockley, Essex, SS5 4SZ Farm 5.94 178
CFS161 57 High Road, Hockley, Essex, SS5 4SZ Dwelling 1.6 48
CFS169 Meadowlands, Victor Gardens, Hockley, SS5 4DY Residential with Large Garden 5.15 155
COL96 Grass SLA, Appleyard Avenue, Hockley, SS5 5AY Vacant-woodland-Council 0.07 2
EXP09 Land Opposite Maryon House, Bullwood Hall Lane, Hockley SS5 4TD Agricultural 0.16 5
The above proposed sites have similar reasons for not being adopted within the Plan. They are adjacent to Ancient Woods/Open Spaces/Listed or Ancient Buildings/Monuments some have TPOs. These open spaces, footpaths, adopted tracks connect the existing ancient woods from Hullbridge, Hockley, Ashingdon, Rochford, Hawkwell. If full potential of dwellings was agreed it would begin to box in the Woods and open spaces which will severely impact the access the open spaces for human use but more importantly access from one area to another for wildlife from birds, badgers, bats, foxes, butterflies and their food sources including vegetation, insects and their habitat. The developments are close to new medium/large developments some still under construction off of Hall Road, Rectory Road, Main Road, and full impact on local infrastructure and roads yet to be assessed. The developments would have to join already busy, poorly maintained yellow designated roads or minor roads which feed in to yellow designated roads some of which would create awkward junctions either at top/bottom of existing hills. The small developments would not have to contribute to improving the infrastructure nor allocate social/affordable housing so for the overall Development Plan they should not be adopted as other sites would provide more properties to meet the government/local authority quotas and contribute to improving the infrastructure. I am not aware of the requirements for medium developments to contribute to the social/affordable housing stock but it would be minimal. Although I as many would prefer no development the overall Development Plan should look at potential sites which will provide the housing required whilst impacting the least woodland/vacant/open/grassland and historic land/buildings in our green belt/field land and impact on road and civic communities. That means larger sites outside of the existing villages/towns with the potential to meet the government/local authority quotas, address the need for social housing, contribute to improving the infrastructure, civic amenities, utilities and incorporate an appropriate road network and more access roads to the existing road, which may also have tolerance around to widen roads with least impact during and after construction i.e. CFS097/CFS121.
CFS156 Lime Court and Poplar Court, Greensward Lane, Hockley, Essex, SS5 5HB & SS5 5JB Residential Care Home 0.6 18
This is a care home in the village and valued by many people. How would reducing care facilities within the village benefit the overall Plan? Renovation and improvements should mean that it can remain in use without significant cost or impact on the community.
BFR2 Eldon Way Land next to station - close to railway line, where will industry go to if all changed to residential Industrial/Leisure 4.6 138
This is an existing industrial estate with mechanics, physiotherapist, chiropodists; tyre dealer, upholsterer etc. There are very few local mechanics to take vehicles to this is close to the station so beneficial for those dropping off vehicles. Although there are some unused buildings they should be completed and current site renovated with local industry in mind. Many cannot relocate to high street because the type of business is not retail or they cannot afford to relocate to the high street. The local businesses need to remain. Making this residential will increase vehicular and pedestrian access to an already busy cul-de-sac, which joins the access road at an awkward and busy junction. The number of houses would not benefit the overall Plan and aim for social housing.
COL22 Public Car Park, Southend Road, Hockley, SS5 4PZ Public Car Park 0.24 7
This is the only car park in Hockley and used by many to access local shops, library, doctors, pharmacist and other essential amenities. Local minor roads are narrow and although they have various parking restrictions they are normally for 1 or 2 hours within the day therefore people will choose the times they shop and any parking will cause congestion. The main road is the only designated secondary road through Hockley and parking on the main route will cause unnecessary congestion.
EXP14 Warren House 10-20 Main Road, Hockley SS5 4QS - Retail/Offices 0.03 1
This is an existing retail and residential building. The High Street is dying already because of high rates and little help for small businesses changing this to residential would not seem to benefit the goal of the government quotas for social housing or help the local community. Hockley High Street needs support and funding to improve the shopping experience, encourage new business, to bring in money and commerce. Development will severely impact the only main road through Hockley. This site should not be developed.

General Comments
With regards to the planned developments the lack of funding from Government and Local Authorities in housing has led to the need for "Partnerships" with private developers. Historically this has proven to be less beneficial to the community if not managed and audited by relevant authorities. Realistically developers are there to make profit and now the need has aligned with a boyant housing market they are using this to pressurise local authorities to agree planning on a signifcant amount of land some of which has been stockpiled for years during the recession. Although these developments include some social/affordablel housing the majority will be for sale and the people who need the housing i.e. low paid, homeless, emergency housed or private landlords receiving benefits, elderly, disabled, key personnel, will not be able to afford them outright or access funds thereby not reducing the population the local authority will still be obliged to house through emergency/private landlords.
There should be an open and transparent review of the recent developments Planning have passed and balance the real value to the Community and whether the quotas have reduced pressure for housing on the local authorities:
* How many homeless/registered council tennants/emergency housed have or will be accommodated
* What contribution did they make:
o No of Schools or monetary contributions
o No of Healthcare centres or monetary contributions
o No of Road widening/improvement to existing or monetary contributions to highways
o No of improvements to existing utilities/drainage/sewage or monetary contributions to providers
before passing any future planning.
Also whether they made the most of the land to reduce the need for future developments, not just focussing on the profit. The "partnership" between private and local authorities must be more focussed on benefiting both parties not loaded towards the developers and shareholders, fair profit margins and more social/affordable housing is essential. Also focus on designs that make the most of the land available not the developers preferred "detached family homes" because it is not suitable for today's diverse families or sustainable. We are an Island and will run out of land eventually and those requiring homes do not fit mum, dad and 2.1 children. Local Authorities should be making developers focus on developing properties that benefit the people that need social/affordable housing and capitalize on the space including utilizing basements for parking or additional accommdation; apartments for 1st time buyers, 1 parent familities and GF accommodation for elderly and disabled to encourage more community living, play areas, retail, health care, schools etc. We cannot continue to canabalise the green belt and agricultural land. Local Authorities should be valuing open spaces for the future environment and support farmers to use the agriculture land to benefit the community and increase productivity at reasonable prices rather than importing the majority of food stuffs we could grow.
That means that first choice should be brown-belt, then larger green-belt/field sites to meet the quotas, but outside of the existing villages/towns, with the potential to include the requirement for social housing and affordable housing, contribute to improving the infrastructure, civic amenities, utilities and incorporate an appropriate road network during construction as well as increasing access roads to the existing road, which may also have tolerance around to widen roads using land from the new site as well as having the least impact during and after construction i.e. CFS097/CFS121. Any developments that will be adjacent to a greenbelt/greenfield designated land should have an enforced 3 metres boundary to reduce the impact on any wildlife, plants and habitat that exists.