Gypsy, Travellers and Travelling Showpeople

Comment on Section SP1.5 Option C

My name is Jack Smith. I represent all the families living at Cherry Hill Farm. We have been living here for 15 years and although we are aware of the enforcement notice, we have over that 15 years established ourselves as a small, strong community. During that time our children have attended the local schools and grown up to have their own children who also attend local schools.

Some of the families suffer from ill health and disabilities such as cystic fibrosis, osteoporosis. I myself have had two strokes. One of the family's children suffers from a cyst on his brain and has cerebral palsy. Another child has congenital hypopituitarism and adrenal insufficiency and on steroids. We all support one another and wish to stay together as one community on this site which we own. We have capacity on our site to provide for the future needs of our families. We haven't got anywhere else to go and would end up on the roadside. We want our children to stay in full time education and near to local medical facilities.

The Council has failed to meet our needs.

My name is Paul Buckley and I have owned and lived on my site for 16 years with my wife and my four children. Over this time my children have attended local schools (The Westenings & Greenswood Academy). We are strongly established in the local community and I would wish for my children to be able to stay in the local area on this site, near to the rest of the family. Our culture and ancestry is very important to us; we enjoy the open space and having our animals on site, and wish to remain as a strong family unit on the same site site.

This is an objection to new local plans for more new houses to be built around the Rayleigh area.
ROADS ARE GRID LOCKED AT VARIOUS TIMES OF DAY ALREADY WE NEED A RING ROAD PUT IN BEFORE ANY MORE NEW DEVELOPMENT ITS SIMPLE NO NETWORK IMPROVEMENT NO BUILDING MAKE THE DEVELOPERS PAY

POLLUTION WILL INCREASE

GYPSY SITES ALREADY IN RAYLEIGH ARE SPREADING WITH NO COUNCIL CONTROL SO MAKE PROVISION FOR THEM IN LESS OVERPOPULATED TOWNS

LEAVE OUR OPEN FIELDS AS THEY HAVE BEEN FOR DECADES TO FILTER FUMES AND TO DRAIN OUR WATER AWAY WHEN WE GET FLASH FLOODING

WE ALL LIKE TO SEE GREEN AREAS BETWEEN OUR TOWNS MARKING BORDERS AND STOPPING THE SPREAD OF MORE CONCRETE

ARE PLANES GOING TO BE FORCED TO TAKE OFF OVER SEA OTHERWISE IF THEY ENCOUNTER ANY PROBLEMS THERE WILL BE NO OPEN SPACES TO TRY TO LAND


IF WE HAVE GOT TO BUILD WHY NOT IN SMALLER NUMBERS OVER MORE YEARS ALLOWING PEOPLE TO MAKE SURE THEY CAN COPE IN HOSPITALS AND ALL SERVICES

I am writing in connection with the proposed planning for up to 7500 new homes in Rayleigh Essex and a possible Gypsy and travellers site. I wish to object strongly to the development of these houses and the Gypsy site.

Rayleigh is already overpopulated and adding a 27% increase would cause numerous problems to infrastructure and road traffic which are already struggling. 7500 - 9000 new homes is unsustainable! I would like to put forward a request to reduce the target to 3,500 over the next 20 years, which equates to 175 a year of growth that we need for our own local needs.

In particular, I would like to strongly object to the plans at the bottom of the Chase / Bull Lane and the potential gypsy site. I find this completely unacceptable and you will have strong pushback from the people that live here. My primary reasons for objection are that this proposal is in direct contravention of various components of the following policies, government guidelines and previous statements made by the SMDC on this matter.

DCLG (2008) Designing Gypsy and Traveller Sites: Good Practice Guide
DCLG (2012) Planning and policy for traveller sites
SMDC (2014) Core Strategy Development Plan Document (pages 120-121)
SMDC (2011) Gypsy and Traveller Site Options and Issues Appraisal
Letter from SMDC to Frank Hopley. dated 23 February 2015, ref: DL/JF

No one in Rayleigh will want the travellers site, this is a nice clean area, where people walk their dogs and feel safe, having a travellers site would change everything and push housing prices down. This is completely unacceptable.

The consequence of this housing planning would be disastrous, getting to and from work which is already a nightmare, school, hospitals, shops and not forgetting the police, ambulance and fire service, gas and electric, sewage, water and broadband. The issues this will cause are endless and I hope you take this objection seriously.

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


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

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

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

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

Section 6.36
Support option B.

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

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

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

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

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


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

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





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

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

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

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

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

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

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

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

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

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

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

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


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

Dear Sir/Madam

Rochford local plan - Issues and Options

Thank you for the opportunity to consider your issues and options document produced as part of your new local plan. We have provided comments related to our remit.

Section 6 - Delivery homes and jobs

We welcome option A, supporting the effective use of brown sites, provided they are not of high environmental value. The justification for such a policy should set out how the local authority will deal with any contamination issues to ensure the protection of human health, ecological systems, property and the environment. The policy should refer to a tired approach to the development of contaminated land which meets good practice (CLR 11). We suggest the policy which outlines the steps to be taken for dealing with contamination, as detailed below

 A preliminary Risk Assessment (PRA) which has identied all previous uses and contaminants associated with those uses. A conceptual model of the site identifying sources, pathways and receptors and any unacceptable risks arising from contamination at the site.

 A site investigation and detailed assessment of risk to all potential receptors both on and off the site.
 An options appraisal and remediation strategy giving details of remediation measures proposed and how they will be undertaken.
 A verification report demonstrating completion of the remedial works.

Section 6.6.1.- Gypsy, Travellers and Travelling Showpeople

We feel this section should include the flood risk posed to pitches that maybe occupied by Gypsies, Travellers and Travelling Showpeople. Caravans, mobile homes and park homes intended for permanent residential use are classed as Highly Vulnerable. 'Highly vulnerable' development should not be permitted in Flood Zone 3 and the Exception Test is required in Flood Zone 2. If users of the development function as residents rather than holiday makers, in the event of a flood, they may have no other place of residence available and could lose all of their possessions. You should consider the flood zone 'compatibility' in accordance with Table 3 of the PPG.

Section 6.79 - Houseboats and Liveaboards

We feel that the houseboat section should include information in regards to flood
risk.
Although boats are water compatible, if the use of the boat is to be residential we
would then classify the development use as 'More Vulnerable'. Table 3 of the PPG
makes clear that this type of development is not compatible with Flood Zone 3b and
should not therefore be permitted. However if LPA confirmed they would classify
houseboats as 'water compatible' we would review our position.

We feel this section should also consider the pollution potential of houseboats. Our
main concern with the use of houseboats is the potential for waste water (including
but not limited to sewage) being discharged from boats into the environment. The
nutrients therein have the potential to cause deterioration of the water quality and
have a knock-on impact on the ecology and wildlife. We therefore ask that any policy on houseboats seeks to ensure that waste water is disposed of by a method other than direct discharge, and that it is passed through appropriate treatment before discharge to the environment. Protection of environmentally sensitive areas are identified within the plan but it should be noted that the Crouch and Roach estuaries are used for shellfish cultivation which is reliant on good water quality. A
deterioration in water quality could impact on this business and so houseboats in
these locations could have a particular impact.

Section 8 - Delivering Infrastructure - Waste Water

We feel that the plan should include recognition of the importance of waste water
infrastructure. We would recommend liaison with water companies and ourselves
throughout the plan period to ensure adequate capacity is available. Water
resources; security of supply in this zone remains at 100% according to the latest
update to Essex and Suffolk Waters WRMP. However, a new WRMP is currently at
draft stage, and plans should be checked against this document as soon as it
becomes available.

Southend and Rayleigh East Water Recycling Centres (WRC) are over capacity with
regards to their permit. Rayleigh West and Rochford have considerable capacity
remaining, so it is recommended that, in the short term, development be planned to
go to these two WRC. In the longer term we would strongly suggest remaining in
regular touch with Anglian Water regarding the preferred locations for development
and the possibility of upgrade works at Rayleigh East and Southend. The LPA
should be aware that Anglian Water are reluctant to commit to upgrades until there is development firmly planned, but that can take up to 10 years.

Section 8 - Water and Flood Risk Management

We welcome the reference to the Thames Gateway South Essex Flood Risk
Assessment (SFRA) and the South Essex SWMP. These are useful supporting
documents to understand the potential impacts on the flood risk management
infrastructure.
The DEFRA document "Flood and Coastal Resilience Partnership Funding - DEFRA
policy statement on an outcome-focused, partnership approach to funding flood and
coastal erosion risk management" is another useful document to support evidence
base with regard to funding deliverability of new and replacement flood defence
infrastructure. This document could be used to enhance the flood risk management
policy.
We continue working in partnership with Rochford Distric Council and the local Flood
Risk Management Authorities (RMA's) including and the local communities on
developing flood alleviation schemes for both fluvial and surface water flooding in
Rochford. These are discussed at the District Council led Rochford Flood Forum and
the Community Action Group meetings. Any additional partnership funding that could be generated from new development will help to enhance and accelerate their
delivery.

The proposed new development allocations should ensure that where possible
development does not impact on the Main Rivers of Crouch, Roach and their
associated tributaries and their modelled floodplains. As highlighted in the new Local
Plan development in areas should be located in Flood Zone 1 (low probability) less
than 1 in 1000 year (<0.1%) of fluvial flooding. This ensures that development is
sustainable and compliant with the principles of National Planning Policy Framework
(NPPF). It should contribute and minimise the risk of river flooding and flood
inundation to existing and future development in major conurbations in Rochford
District.
For all new development proposals there must be a robust application of the National Planning Policy Frameworks (NPPF) Sequential Test to avoid development in areas of flood risk wherever possible and to maintain the function of these land areas for natural processes. Any new proposals relating to flood defence schemes should draw on the guidelines highlighted in the attached documents.
Any development allocations highlighted in Local Development Plan should be
appropriately located according to the requirements of the National Planning Policy
Framework (NPPF) and any proposals in Flood Zone 3 highlighted blue on the
attached plan will be required to pass the Exception Test in the NPPF.
Any works associated with the development in, over, under or within 8m byelaw
distance of the "Main Rivers" may need our formal permit.

We believe the water and flood risk management section should also consider the
following points which are relevant to all proposed developments and whose
inclusion would enhance policy.

General Flood Risk Comments

All development proposals within the Flood Zone (which includes Flood Zones 2 and
3,as defined by the Environment Agency) shown on the Policies Map and Local
Maps, or elsewhere involving sites of 1ha or more, must be accompanied by a Flood
Risk Assessment.

Planning Practice Guidance (PPG)

The Local Plan should apply the sequential test and use a risk based approach to
the location of development. The plan should be supported by a Strategic Flood risk
Assessment (SFRA) and should use the NPPF Planning Practice Guidance (PPG).
The PPG advises how planning can take account of the risks associated with
flooding and coastal change in plan-making and the planning application process.
The following advice could be considered when compiling the Local Plan to ensure
potential development is sequentially sited or if at flood risk it is designed to be safe
and sustainable into the future.

Sequential Approach

The sequential approach should be applied within specific sites in order to direct
development to the areas of lowest flood risk. If it isn't possible to locate all of the
development in Flood Zone 1, then the most vulnerable elements of the development should be located in the lowest risk parts of the site. If the whole site is at high risk (Flood Zone 3), an FRA should assess the flood characteristics across the site and direct development towards those areas where the risk is lowest.

Finished Floor Levels

We strongly advise that proposals for "more vulnerable" development should include
floor levels set no lower than 300 millimetres above the level of any flooding that
would occur in a 1% (1 in 100) / 0.5% (1 in 200) Annual Exceedence Probability
(AEP) flood event (including allowances for climate change). We are likely to raise
an objection where this is not achieved in line with Paragraphs 060 of the NPPF's
Planning Practice Guidance which advises that there should be no internal flooding
in more vulnerable developments from a design flood.
We recommend "less vulnerable" development also meet this requirement to
minimise disruption and costs in a flood event. If this is not achievable then it is
recommended that a place of refuge is provided above the 0.1% AEP flood level.

Safe Access

During a flood, the journey to safe, dry areas completely outside the 1% (1 in 100) /
0.5% (1 in 200) AEP flood event, including allowances for climate change, should not involve crossing areas of potentially fast flowing water. Those venturing out on foot in areas where flooding exceeds 100 millimetres or so would be at risk from a wide range of hazards, including, for example; unmarked drops, or access chambers
where the cover has been swept away. Safe access and egress routes should be
assessed in accordance with the guidance document 'FD2320 (Flood Risk
Assessment Guidance for New Developments)'. We would recommend that you
refer your SFRA which has produced hazard maps following a breach/overtopping of
the defences?

Emergency Flood Plan

Where safe access cannot be achieved, or if the development would be at residual
risk of flooding in a breach, an emergency flood plan that deals with matters of
evacuation and refuge should demonstrate that people will not be exposed to flood
hazards. The emergency flood plan should be submitted as part of a FRA and will
need to be agreed with yourselves. As stated above refuge should ideally be located
300mm above the 0.1% AEP flood level including allowances for climate change. If
you do produce a flood safety framework as mentioned above, it will be important to
ensure emergency planning considerations and requirements are used to inform it.

Flood Resilience / Resistance Measures

To minimise the disruption and cost implications of a flood event we encourage
development to incorporate flood resilience/resistance measures up to the extreme
0.1% AEP climate change flood level. Information on preparing property for flooding
can be found in the documents 'Improving the Flood performance of new buildings'
and 'Prepare your property for flooding'.

Betterment

Every effort should be made by development to improve the flood risk to the local
area, especially if there are known flooding issues. Opportunities should also be
taken to provide environmental enhancements as part of the design, for example
naturalising any rivers on the site with a buffer zone on both sides.

Increases in Built Footprint (excluding open coast situations)

When developing in areas at risk of flooding consideration should be given to
preventing the loss of floodplain storage. Any increase in built footprint within the 1% AEP, including allowances for climate change, flood extent will need to be directly compensated for to prevent a loss of floodplain storage. If there are no available areas for compensation above the design flood level and compensation will not be possible then a calculation of the offsite flood risk impacts will need to be
undertaken. If this shows significant offsite impacts then no increases in built
footprint will be allowed. Further guidance on the provision of compensatory flood
storage is provided in section A3.3.10 of the CIRIA document C624.

Climate Change

The Environment Agency guidance 'Flood risk assessments: climate change
allowances' should be used to inform the spatial distribution of growth and the
requirements of Flood Risk Assessments (FRA) for individual applications.
The National Planning Practice Guidance provides advice on what is considered to
be the lifetime of the development in the context of flood risk and coastal change.
The 'Flood risk assessments: climate change allowances' guidance provides
allowances for future sea level rise, wave height and wind speed to help planners,
developers and their advisors to understand likely impact of climate change on
coastal flood risk. It also provides peak river flow and peak rainfall intensity
allowances to help planners understand likely impact of climate change on river and
surface water flood risk. For some development types and locations, it is important to assess a range of risk using more than one allowance. Please refer to this guidance.
https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances.
This advice updates previous climate change allowances to support NPPF and may
result in flood extents being greater than they have been in the past. This does not
mean out flood map for planning has changed, as these maps do not consider
climate change, but fluvial flood maps that may have been produced as part of
SFRAs and other flood risk studies may be out of date. FRAs submitted in support
of new development will need to consider the latest climate change allowances.

Environmental Permit for Flood Risk Activities

An environmental permit for flood risk activities may be required for work in, under,
over or within 8 metres (m) from a fluvial main river and from any flood defence
structure or culvert or 16m from a tidal main river and from any flood defence
structure or culvert.
Application forms and further information can be found at:
https://www.gov.uk/guidance/flood-risk-activities-environmental-permits. Anyone
carrying out these activities without a permit where one is required, is breaking the
law.
The Local Plan should consider this when allocating development sites adjacent to a
'main river'. A permit may be required and restrictions imposed upon the work as a
result in order to ensure the development does not have a detrimental impact upon
the environment and flood risk.

Sustainable Drainage Systems (SUDS)

We agree with the promotion of the use of SUDS within the policy on all
developments where geological conditions permit. However in order to ensure the
protection of the water environment, we feel any development must incorporate
appropriate pollution prevention measures and a suitable number of SUDS treatment
train components in line with requirements of Ciria C753 and the SUDS Manual.

Policy 10 - Biodiversity, Geology and Green Infrastructure

We welcome the inclusion of Strategic Objective 19: To protect, maintain and
enhance our district's natural environment, geology and biodiversity, including our
open spaces, recreational areas and our extensive coastline, as well as support
wildlife, to create habitat networks and reduce fragmentation.
We also welcome the inclusion of Strategic Objective 22: To mitigate and adapt to
the forecasted impacts of climate change, including the water environment, air
quality, biodiversity and flooding, support more efficient use of energy and natural
resources and facilitate an increase in the use of renewable and low carbon energy
facilities. We hope that innovative solutions to the issue of climate change be found,
including the use of natural flood management techniques.
Whilst we broadly support the policy protecting and enhancing the environment, but
feel more importance should be given to the water environment. The policy needs to
refer to the Water Framework Directive and all development need to show that it will
not have a negative impact on water bodies. We feel this is important in regards to
the proposed marina development at Wallasea Island. This could cause serious
impacts on the protected estuarine habitat and birdlife as well as a deterioration in
the WFD status of the Crouch and Roach Estuaries.
We welcome the importance given to green infrastructure and the benefits it can
provide to human health and the environment. We feel the policy could also promote
the enhancements developments could provide for overall biodiversity. Setting a
requirement that all new development must create a new priority habitat would
support Local Planning Authoritys duty under the Natural Environments Rural
Communities (NERC) Act 2006. Priority habitats include new wetlands created as
part of SuDs schemes, deciduous woodlands and wildflower meadows.

Section 10 - Air Quality

Whilst we have no direct comments in regards to the air quality policy it is worth
noting that any new development of within 250-500m of a site permitted by the us
could result in the proposed development being exposed to impacts, e.g. odour,
noise, dust and pest impacts. The severity of these impacts will depend on local
factors such as the size of the facility, the nature of the activities and the prevailing
weather conditions. If the operator can demonstrate that they have taken all
reasonable precautions to mitigate these impacts, the facility and community will coexist, with some residual impacts. In some cases, these residual impacts may cause local residents concern, and there are limits to the mitigation the operator can apply. Only in very exceptional circumstances would we revoke the operators permit. These factors should be considered when identifying areas suitable for development. The locations of waste sites can be found on our public register at
https://environment.data.gov.uk/public-register/view/search-all
We trust the advice we have given is useful and will contribute to the soundness of
the emerging local plan. We will continue to provide further advice and comments at
future statutory stages of the emerging local plan. Should you wish us to review any draft policies and text as well as technical documents and background studies, such
as strategic flood risk assessments or water cycle studies which may be used to
support your plan, we can offer this as part of our planning advice service.

This service will ensure that your evidence documents fully support the local plan
and ensure that environmental issues are addressed in an effective and timely way
contributing to sustainable development. As part of the planning advice service we
will provide you with a single point of contact who will co-ordinate access to our
technical specialists who will be able to provide bespoke advice and help you
prepare any supporting documents. We will be pleased to provide you with an
estimated cost for any work we would undertake as part of the service.

Comments: Hullbridge Parish Council agreed at the Full Council Meeting on Monday 12th February 2018 the following response regarding the Issues and Options Document:
Housing needs

An additional 7000+ dwellings would almost certainly be unsustainable without sever damage to the environment and character of the district. According to the Environmental Capacity Study 2015, only small scale expansion of existing settlements could be sustained. This might also rule out a new settlement although, because of the scale of the suggested housing need, that could well be the best option as it would likely include a new secondary school and employment opportunities.

As regards Hullbridge, further development, other than small infills within the main body of the village, would be unsustainable. Including the Malyons Farm development, which currently has outline planning permission and was described by RDC as providing a 'defensible greenbelt boundary', and numerous small developments, Hullbridge will have seen a 20%+ increase in dwellings since this stage of the current District Plan. As an example of those smaller developments, in Ferry Rd, North of Riverside School, 6 dwellings have been replaced by 40+. The village is over 5km from the nearest secondary school, railway station and shopping centre and, with only a single bus route, there is already a high level o traffic movement on local routes. This is compounded by through traffic to and from parts of the district further West. Even within the village, there is considerable traffic movement, particularly at the start and end of the school day.

It has been reported that some London councils have been bulk-buying properties on some of the large developments in the district. If this has happened, it is not natural migration and must be resisted in order to meet local need without overdevelopment.

Bungalows

There is a need to limit conversion/expansion in order to maintain supply. If new bungalows were designed with a low roof pitch this would prevent their conversion under permitted development rights and would also limit their visual impact, particularly on previously undeveloped land. It seems likely that many older homeowners, who wish to retain their independence but are looking to a future when they may become less active, would like to downsize to a small bungalow with a little garden rather than an apartment. Market versions of developments like Rydal Close and Mayfield Ave could well fill that need.

Houseboats

No live-aboard boats should be allowed outside existing marinas.

Tourism and Rural Diversification

Although tourism is welcomed, I am concerned that additional accommodation, businesses and tourist numbers could affect environmentally sensitive locations. Although dogs are required to be kept on leads in Hullbridge's Kendal Park Nature Reserve, there is no such restriction along the rest of the river bank where they can often be seen venturing onto the salt marsh and river bed, disturbing wildlife.

Highways Infrastructure

I would be opposed to highway changes or developments to the East which could encourage even more traffic on Lower Road. The previously-suggested Rochford Outer Bypass or a similar proposal would be equally unwelcome as it would increase pressure for development along its route, particularly where it linked to local routes. It would also, almost certainly, cross the Rayleigh Club golf course, making that use of the greenbelt between Hullbridge and Rayleigh no longer viable.

However they maybe potential to widen the A127 from 4 to 6 lanes from the M25 to as far east as the Bell without major impact of

I note that Lower Rd, East of Ferry Rd is shown as a bus route although there is no regular service except for school buses.

Education

It seems likely that the current secondary schools have little room for further expansion and is questionable whether there is a suitable location for a new one, other than possibly in a new large settlement.

In Hullbridge we have at least two pre-schools not one as in the document.

Greenbelt

The greenbelt to the East and West of Hullbridge village is important due to its proximity to the environmentally sensitive and protected River Crouch and that to the South is needed to prevent any merging with Rayleigh/Hockley. As previously stated, the currently-proposed Malyons Farm development was described by RDC as providing a 'defensible greenbelt boundary'.

Wallasea Island

Although this would seem to be a worthwhile project there have been comments from more than one source, that this has increased flow rates and erosion upstream on both the Crouch and Roach.

Outbuildings

Their use as living accommodation should only be allowed if they were originally built and used for another legitimate purpose and must remain ancillary to the main home and not allowed in greenbelt.

Hullbridge Sewage Plant

We do not think it will have the capacity to be able to cope with the proposed Malyons Farm Development let alone any other additional dwellings in the village or neighbouring Parishes.

Air Quality

Rayleigh Town was recorded as the highest for poor air quality, further developments will have impact and will intensity the situation.

Employment Land

We welcome land being used for Employment including Retail/Shops in the District.

Hospitals/Health Centres

Our local Hospitals and Health Centres would not be able to support people from any additional large scale development without considerable investment.

Traveller Sites

We would like the Michelin Farm Site to be developed as a proper site for Travellers.

Thank you for inviting Basildon Borough Council to provide comments as part of Rochford District Council's consultation on its Regulation 18 New Local Plan Issues and Options Document and Draft Sustainability Appraisal (SA) of the Rochford Local Plan 2017. Please accept this letter as the response of Basildon Borough Council to the consultation.

Rochford District Council is in the first stages of consultation on the review of their current Local Development Plan, to ensure that the policies are robust, effective and up-to-date, in accordance with the Planning and Compulsory Purchase Act 2004.
Basildon Borough Council acknowledges that this is the first stage of consultation on the new Local Plan for Rochford, and that a number of issues and options are being considered. It is acknowledged that the Local Plan consultation document does not identify specific sites, and that more detailed planning policies will evolve as each consultation stage on the new Local Plan progresses. In view of this, Basildon Borough Council has considered the consultation documentation, its role as a neighbouring planning authority, and strategic and cross boundary matters which are covered by the Duty to Cooperate, and wishes to make a series of observations which Rochford should take into consideration when it prepares the draft version of its Local Plan.

SP1.1: Objectively Assessed Need (OAN)

Consideration has been given to the approach Rochford District Council has taken in determining its OAN for housing. It is clear from the evidence that the need identified within the Rochford District Issues and Options Report reflects more up-to-date national household projections, as required by the Planning Practice Guidance (PPG), taking into account matters such as economic growth and the need for affordable housing, and is informed by an up-to-date SHMA. A robust approach has been taken in considering the housing need within Rochford district, and no objection is being raised as to how the OAN figure has been calculated.
In relation to meeting its OAN, Rochford District Council is seeking to provide as much of the district's housing within the area, as far as possible, against the identified need, and given environmental and other constraints. Rochford District has also highlighted a commitment to work with neighbouring Local Planning Authorities (LPAs) to ensure that the housing need across the South Essex Housing Market Area is effectively met. In view of this, Basildon Council supports Rochford Council's intention to meeting its own needs, and to work effectively with neighbours to ensure that the need for housing in the South Essex Housing Market Area is collectively addressed. Basildon Borough Council will continue to support more effective joint working with Rochford as their new Local Plan emerges, in line with the Duty to Co-operate.
The aspiration to provide Rochford District residents with the opportunity to access a
percentage of new market homes on schemes as a priority is also noted. Basildon
Borough Council will recommend that any supporting policy requirement in relation to meeting the housing needs of residents should be backed with reasonable justification and evidence, in line with national policy and guidance.
Finally, attention is drawn to the emerging Basildon Borough Local Plan. Since the
Basildon Borough Draft Local Plan consultation in 2016, significant matters of principle in relation to the Basildon Local Plan have been considered and resolved. As a consequence, Basildon Council through several decision making processes, has taken the position that some changes should be made to either the Local Plan, or the process of preparing the Local Plan, in order to ensure it is sound. One of these changes arises from the fact that the suite of sites identified for inclusion in the Basildon Borough Local Plan does not meet the identified need for housing of between 19,440 and 19,720 homes. This gives rise to an unmet housing need, which when delivery issues are taken into account is around 4,000 homes for the plan period up to 2034. Following Basildon Borough Council's Infrastructure Growth and Development (IGD) Committee Meeting on the 16 January 2018, and in order to ensure that the Basildon Borough Local Plan is sound in regard to this matter, it has been recommended that assistance is formally sought from other LPAs in the Housing Market Area, to help Basildon Borough to meet its unmet housing need.
Basildon Borough Council therefore formally requests that Rochford District Council
considers whether they can assist in meeting some of Basildon Borough's unmet need in the Rochford District Local Plan.

SP1.5: Gypsy, Travellers and Travelling Showpeople

A need for 15 Gypsy and Traveller pitches up to 2018 was identified in the Rochford
District Core Strategy 2011. The Issues and Options Report however recognises the
recent changes made to legislation relating to Gypsies, Travellers and Travelling
Showpeople. Following the change in definition of Gypsies, Travellers and Travelling
Showpeople, a further Essex-wide Gypsy and Traveller and Travelling Showpeople
Accommodation Assessment (G&T and TS AA) was commissioned to understand the
implications for plan-making. A need for Gypsy and Traveller pitches was identified, but there was no need for Travelling Showpeople plots. The assessed need for Gypsy and Traveller pitches in Rochford District up to 2033 within the emerging G&T and TS AA 2017 for Rochford District could however still be met through the 15 pitch site allocated in the current Allocations Plan Policy GT1. This means that Rochford District can demonstrate a land supply up to 2033 (including a five year supply) for all Gypsy and Traveller households within the district, regardless of whether they meet the 2015 Planning Policy for Traveller Sites (PPTS) definition or not. Basildon Borough Council supports the approach Rochford District are taking in ensuring that their evidence base is up-to-date.

However, while the G&T and TS AA establishes a need for the plan period of 2013-2033, Rochford District's new Local Plan looks forward to 2037. It is therefore unclear how the Gypsy and Traveller needs for Rochford District will be met in the remainder of the plan period (2033-2037), and further evidence of this should be provided. Rochford District Council should carry out further work to re-assess the Gypsy, Traveller and Travelling Showpeople needs up to 2037, and should the need for pitches change in light of this, Rochford District Council should seek to update the Rochford Local Plan accordingly to continue to meet their full objectively assessed needs for Gypsy, Traveller and Travelling Showpeople.

There is also a concern that no acknowledgement has been made of the fact that there may be unmet needs arising from Greater Essex authorities for the provision of accommodation for Gypsies, Travellers & Travelling Showpeople within the Rochford Issues and Options Report, which is considered to be a shortcoming. Basildon Borough Council has agreed to work with Chelmsford City Council, Harlow District Council and Colchester Borough Council on behalf of the Essex Planning Officer's Association to develop a protocol for unmet Gypsy, Traveller and Travelling Showpeople need, should this situation arise in any local planning authority in Greater Essex. It is envisaged that this work will be carried out in 2018. Rochford District Council should therefore recognise and support the principle of this approach going forward, to ensure that there will be a technical approach in place to support any neighbouring authorities with any potential unmet Gypsy, Traveller and Travelling Showpeople need in the future. This is to ensure that a fair process is applied throughout Essex, and ensures compliance with the Duty to Cooperate.

SP3.1: Highways Infrastructure

The Rochford Issues and Options Report sets out different options for managing traffic in and around Rochford District. The report recognises that the A127 has known capacity and congestion issues. Consequently, Rochford Council has proposed to work with Essex County Council and Southend-on-Sea Borough Council, to develop a transport model for South Essex, which will cover the length of the A127. Basildon Borough Council supports this approach. Rochford Council's commitment within paragraph 8.18, to continue to work with neighbouring local authorities and the Highway Authority to promote strategic and more localised improvements to the highway network is also noted. This initiative is supported by Basildon Council. In particular, reference was made within paragraph 8.18, to the potential for a new link road from the A127 at Pound Lane/Cranfield Park Road to link to the A130 in Rochford District.

It should be noted that the proposed grade separated junction on the A127 at Pound
Lane, with the new link road to the A130 was identified within the Policy TS2 of the
Basildon Borough Draft Local Plan 2016 as part of the provision for new and improved transport infrastructure, essential to mitigate the impact of future housing and economic growth in Basildon Borough. It is expected that this junction will serve the development proposed at East Basildon and South Wickford, improve access to the A127 enterprise corridor, reduce pressure at the A132 Nevendon Interchange and Fairglen Interchange, as well as freeing up capacity for local traffic. This junction will therefore provide significant benefits for both the strategic and local road network. However, this proposal is substantially more expensive at around £130m, and raises issues around development viability.

The proposed improvement to highway infrastructure will therefore require support and funding from neighbouring authorities, to supplement developer contributions from the Department for Transport and South East Local Enterprise Partnership. As Rochford District communities could potentially benefit from the provision of the proposed grade separated junction on the A127 at Pound Lane, with the new link road to the A130, Basildon Borough Council formally requests that Rochford District Council should account for part funding of this junction within the new Local Plan for Rochford. As part of the transport modelling to support the Rochford Local Plan, and also within the Rochford Local Plan itself, Rochford District Council needs to also consider its relationships with neighbouring authorities when allocating growth locations. Basildon Borough is most likely to be affected if growth is concentrated to the west. It is therefore important that Rochford District Council ensures collaborative engagement and continual working between local planning authorities, with the highway authority, and with transport providers to ensure that strategic transport links are capable of accommodating the additional transport pressures that are likely to arise as a result of future population growth, particularly to the west of the Rochford District area.

SP3.2: Sustainable Travel

The main road linking Basildon Borough with Rochford District is the A127, which is well documented to experience capacity challenges, particularly in peak periods. Rochford District Council should ensure that new development have accessible services, and enables people to reduce the need to travel by private car, as much as possible, particularly as the district experiences high levels of car ownership and high levels of outcommuting. In addition, the South Essex Economic Development Needs Assessment (EDNA) 2017 identifies the A127 Enterprise Corridor as an important employment location in South Essex. The role of this corridor will be retained and grown, with the aim of attracting new investors to the corridor. Enhanced public transport connectivity between towns in Rochford District and this employment area in Basildon Borough should therefore be sought by Rochford District as part of the strategy for improving sustainable travel choices across the District and into South Essex.

SP4.3: Open Space and Outdoor Sports and Recreation

Basildon Council welcomes the opportunity to work with Rochford District Council and other neighbouring authorities in South Essex, to prepare more strategic level evidence of needs across the sub-region for open space, sports and recreation, in line with national policy, and to identify ways to improve connectivity between green spaces through the provision of green corridors.

Duty to Co-Operate

In order for the Rochford District Local Plan to be found procedurally sound, it will need to take account of a broader range of issues and opportunities affecting neighbouring areas and the wider region, considering and addressing strategic cross-boundary issues.
Attention is drawn to the joint-working that is underway in South Essex, which aims to deliver a more coordinated planning, regeneration and investment agenda to benefit the combined local communities. It is expected that the development of a Joint Strategic
Planning and Infrastructure Framework (SPIF) would set the strategic growth objectives for South Essex and provide the "effective mechanism" required to determine how unmet development needs from individual local authority areas would be met.
Building on this foundation, it is also relevant to mention the South Essex 2050 which is a unified long-term place vision for the South Essex area, with the addition of Brentwood Borough Council. This work, due to conclude in early 2018, is expected to determine how the work on the Joint SPIF and its inter-relationships to South Essex Local Plans will be prepared and managed in the future, and could accelerate the conditions needed to deliver the shared housing & job ambitions, enabled by significant improvements to transport & other infrastructure.
This shared support demonstrates that LPAs across the region have been engaging
constructively and actively, to maximise the effectiveness of Local Plan preparation in the context of strategic cross-boundary matters, and contribute to fulfilling the requirement for Local Planning Authorities to work together under the "Duty to Co-operate", as set out in the Localism Act 2011.
Basildon Borough Council is satisfied with the degree of engagement with regard to the Rochford District New Local Plan, and welcomes the opportunity to continue to work with Rochford District Council and other neighbouring authorities in the region on the content of the new Local Plan and its approach to strategic, cross-boundary matters such as housing growth, employment growth, and infrastructure provision through the Duty to Cooperate.

General Observations

It is noted that some of the evidence base, which will inform and support Rochford District Council's emerging Local Plan, is still underway. Some of this has been commissioned jointly with other LPAs, including Basildon Council. While it is not possible for Basildon Council to comment on the forthcoming evidence at this time, Basildon Borough Council will continue to work with Rochford District Council in the preparation of any joint evidence base work to ensure that it is comprehensive and appropriate for what the Local Plan will cover.

Rochford District Council should further identify options, strategic growth areas and
policies informed by up-to-date evidence and, through publication of a draft Local Plan, invite further representations from LPAs and other stakeholders.

Basildon Borough Council welcomes further engagement with Rochford District Council to ensure that the observations raised in this response are duly considered and to continue working together on strategic planning priorities through the Duty to Co-operate.

Draft Sustainability Appraisal of the Rochford Local Plan

Basildon Borough Council has reviewed the content of the Draft Sustainability Appraisal of the Rochford Local Plan, and can confirm that on this occasion, Basildon Borough Council has no comments to make, as it covers all the matters you would expect to see in such a document.

Thurrock Council has considered the Issues and Options document and the supporting Duty to Cooperate Topic Paper and has the following observations to make with regard to the Duty to Cooperate. Thurrock Council confirms it is satisfied with the level of consultation and engagement to date with regard to the emerging Rochford Local Plan.
The Rochford Issues and Options document clearly identifies in a number of its objectives and policy options the key strategic and cross boundary issues where it states the Council will work with the other South Essex local authorities and with individual organisations under the Duty to Cooperate. It is noted for example that homes and jobs, transport and other infrastructure are key issues identified for collaboration and joint working.
Rochford Council has also produced a Duty to Cooperate Topic Paper that sets out the legislative and policy context for the Duty to Cooperate and how Rochford has sought to meet its requirements. The topic paper highlights that there had been a need for more effective joint working between the South Essex local authorities and for arrangements that result in clear outcomes to address strategic cross boundary issues.
Thurrock Council welcomes and supports the continued involvement and participation of Rochford District Council in joint working and collaboration with the
other South Essex authorities including Thurrock. It is noted that Rochford Council has been and continues to be involved with the other South Essex authorities in the preparation of a range of technical evidence. Furthermore Rochford Council along with the other South Essex authorities and Essex County Council signed a Memorandum of Understanding in 2017 that includes a key set of principles and arrangements to improve the effectiveness of joint working including a commitment to prepare a Strategic Planning and Infrastructure Framework.
Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.
In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.
More recently the ASELA Councils have begun considering more detailed arrangements for joint strategic planning including an expression of interest in becoming a pilot for the Government's proposed Statement of Common Ground, the commissioning of further technical studies and the consideration of the exact nature and status of the joint spatial strategy including the possibility of producing a Joint Strategic Plan (JSP). Rochford District Council as a member of ASELA and in supporting the joint planning arrangements will also need to consider the level of resource and commitment that it can provide towards the new joint planning arrangements and its own emerging and future local plan(s) production.
A key issue for Rochford Council will be the need to consider how the emerging New Local Plan will align with the preparation of the joint strategic planning both in terms of the content and nature of the local plan(s) that the Council intends to prepare but also in the timing and production of such documents especially if the South Essex Councils agree to move forward with the option of a statutory joint strategic plan.
The importance placed by the Government on better joint working is set out in the draft revision to the NPPF published in March 2018 reflecting statements in the housing White Paper and previous consultation. The draft NPPF includes greater provision to produce joint plans and also proposes changes to the "effective" and "positively prepared" soundness tests for local plans to encourage agreements and joint working. The "effective" test also requires local authorities to evidence cross -boundary issues and joint working in a Statement of Common Ground.

Strategic Objective 1
Thurrock Council fully supports Rochford Council in seeking to deliver housing to meet its Objectively Assessed Housing Need. However it is considered the Objective should be rewritten as it could infer that housing will be primarily delivered through PDL and then working with South Essex Neighbours but not other potential sources.

Strategic Priority 1: The homes and jobs needed in the area.
Delivering Homes and Jobs
SP1.1: We have a real and identified need for affordable homes in the district and an aging 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 twenty years?
Thurrock Council supports an approach under Strategic Priority SP1.1 and Option1 for Rochford District Council to seek to fully accommodate the upper end of its Objectively Assessed Housing Heed (OAHN) within the district during the proposed plan period of 2017-37.
The Issues and Options document sets out that the recommended range of Objectively Assessed Housing Need for Rochford is between 331-361 dwellings per annum as evidenced from the 2017 Addendum to the South Essex Strategic Housing Market Assessment. The Council has identified that taking into account the shortfall of housing delivered in 2014-2017 from the OAN base date that this results in a projected housing need for the plan period 2017-2037 of between 7,181 and 7,881 dwellings.
The Government published in September 2017 draft potential options for a standardised methodology for assessing OAN. The draft paper recommends a target for Rochford District of 362 dwellings a year. This is only 1 dwelling a year more difference compared to the higher end of the current OAN range. It is accepted that the Government methodology is only draft and there are uncertainties as to when the final methodology will be published and whether the OAN figure for authorities will have altered significantly. Revised population and household projections are also due to be published by the Government and will need to be considered as part of the assessment of any revised OAN figures. Therefore at this stage there remains uncertainty on the future figure of OAN for Rochford. The Council will need to take into account the expected changes to the methodology, population and household projections along with other evidence for housing need as it moves to the next stages of plan preparation.
It is recognised that at this stage of the preparation of the Rochford Local Plan that the Council has not fully assessed the potential capacity of the district to accommodate the currently identified OAN. Thurrock notes that Rochford Council is continuing to develop the evidence base to support its local plan and is to undertake further work to review policy and environmental constraints, infrastructure restrictions and site deliverability in order to determine the level of housing that can be accommodated in the borough.
The Issues and Options document states that based upon current evidence including the 2017 Strategic Housing and Employment Land Availability Assessment (SHELAA) that the Council has identified insufficient sites for housing within the urban area to meet the OAHN identified for the plan period. Thurrock Supports the approach that the Council its taking to consider further the potential capacity of the borough to meet its own OAHN including the ongoing call for sites, a review of the Green Belt and landscape assessment, and further development of infrastructure requirements.

Until Rochford Council has fully assessed the policy constraints and capacity within the district it is unclear whether there is a potential unmet need. Furthermore Rochford Council will need to consider any implications of unmet need arising from other authorities in the housing market area.
Thurrock Council requests to be kept informed of any shortfall of housing provision arsing in Rochford during the preparation of the New Local Plan. Such matters will be increasingly be considered as part of the joint working arrangements and preparation of the South Essex joint strategic planning including the ongoing development of the evidence base and monitoring.
Thurrock Council also supports the approach of Rochford in Option 2 of SP1.1 of working with other Councils across South Essex to address the strategic cross-boundary matters such as housing need and distribution and unmet housing need. This key strategic issue will be considered as part of the joint strategic planning and as this will provide a strategic framework to inform the emerging Rochford Local Plan.
Rochford Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a spatial options study including a high level housing land and capacity assessment and further infrastructure studies.
The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Rochford District and the approach to be taken in the New Local Plan.
SP1.3:- How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district.
Thurrock Council supports the approach that Rochford Council has identified in the Issues and Options document with the six potential options representing realistic ways to deliver the additional homes required in the district. It is considered that a combination of a number of these options for delivering housing supply are likely to provide the source of housing capacity to meet OAHN for the plan period.
The 2017 Rochford Council SHELAA sets out that currently the Council land trajectory has identified there is sufficient suitable, available and achievable land to deliver a total of 3499 dwellings with most having planning permission but also including an additional 935 dwellings on land identified through existing allocations without permission or other sites assessed though the SHELAA, the call for sites and are predominantly on urban land.
As noted in the Issues and Options document there is currently insufficient appropriate sites to accommodate the projected OAHN for Rochford during the plan period and sourced from the urban area. In seeking to assess the potential options to accommodate the shortfall in housing supply the Council will need to carefully consider the balance between the levels of housing need and the environmental capacity and other policy constraints.

It is identified in the Rochford SHELAA that through the ongoing call for sites process the Council have identified significant additional potential capacity but the suitability of these sites to come forward for housing will be subject to the further assessment of environmental capacity and review of other policy constraints such as the Green Belt that are being undertaken as part of the local plan process.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAHN including discussion with adjoining authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in to accommodate part of their housing need.
SP1.5: How do we sustainably meet our need for Gypsy and Traveller pitches over the next 20 years?
The Issues and Options document sets out the needs for Gypsies and Travellers arising in Rochford to 2033 as identified from the recently published Gypsy and Travellers Accommodation Assessment (GTAA) of 2018. The Council states it has potential pitch provision through an allocation to meet most of the identified needs of Gypsy and Travellers up to 2033 regardless of whether the Gypsy and Travellers meet the current planning definition. The Issues and Options documents sets out a range of alternative options to meet this need, including giving careful consideration to provision for the needs of those households that no longer meet the planning definition of Gypsy and Travellers.
Thurrock supports the overall approach of Rochford Council to accommodate its own Gypsy and Travellers need. However it is noted that the assessment of need based on the most recent GTAA only covers the period to 2033. It is considered the Rochford Council will need to further review the GTAA to ensure it has identified the Gypsy and Traveller need to cover the whole plan period. Clarification is sought that the Council will accommodate this need within the borough. At this stage it is unclear what in terms of potential unmet Gypsy and Traveller need there is across Essex and in particular South Essex. Rochford Council along with the other authorities in South Essex will need to consider this matter as part of the Duty to Cooperate process.
SP5.1: 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 wider South Essex area?
Thurrock Council supports Option B for taking the Green Belt policy forward in the New Rochford Local Plan that includes the potential amendment of existing policy.
The Council should continue to review the potential supply of sites from the urban area and other brownfield sources including the review of density assumptions and the other potential sources of supply from the urban area. However if the Council has exhausted all other reasonable alternatives in order to accommodate its OAN including discussion with other authorities it should consider there are exceptional circumstances to justify the release of Green Belt land in order to accommodate this
need. It should be noted that a number of other South Essex authorities including Basildon, Brentwood and Thurrock are proposing to release land from the Green Belt in order to accommodate part of their Housing and other development needs.

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.

1. INTRODUCTION

Rochford District Council (RDC) is currently consulting on the Draft New Local Plan Issues and Options (the Draft Local Plan) Regulation 18 document. This consultation represents the first stage in preparing a new Local Plan for the District of Rochford. Once prepared, the Local Plan will include the required strategies, policies and proposals to guide future planning across the District; and will replace the current suite of Adopted Development Plans (up to 2025).

Essex County Council (ECC) supports the preparation of a new Local Plan for RDC and welcomes the opportunity to comment on the Issues and Options consultation. A Local Plan by setting out a specific vision and policies for the long-term planning and development of the District can provide a platform from which to secure a sustainable economic, social and environmental future to the benefit of residents, businesses and visitors.

A robust long-term strategy will provide a reliable basis on which RDC, ECC and its partners may plan and provide future service provision and required community infrastructure for which they are responsible. ECC will also use its best endeavours to assist on strategic and cross-boundary matters under the duty to cooperate, including engagement and co-operation with other organisations for which those issues may have relevance.

2. ECC Interest in the Issues and Options Consultation

ECC aims to ensure that local policies and related strategies provide the greatest benefit to deliver a buoyant economy for the existing and future population that live, work, visit and invest in Essex. As a result ECC is keen to understand, inform, support and help refine the formulation of any development strategy and policies delivered by Local Planning Authorities. Involvement is necessary and beneficial because of ECC's roles as:
a. a key partner within Greater Essex, the Association of South Essex Local Authorities (ASELA) and, Opportunity South Essex Partnership (OSE); promoting economic growth, regeneration, infrastructure delivery and sustainable new development;
b. major provider and commissioner of a wide range of local government services throughout the county;
c. the strategic highway and transport authority, including responsibility for the delivery of the Essex Local Transport Plan; Local Education Authority including early years and childcare; Minerals and Waste Planning Authority; Lead Local Flood Authority; lead advisors on public health; and adult social care in relation to the securing the right housing mix which takes account of the housing needs of older people; and d. as an infrastructure funding partner, that seeks to ensure that the proposals are realistic and do not place an unnecessary (or unacceptable) cost burden on ECC's Capital Programme.

3. DUTY TO CO-OPERATE

The duty to cooperate (the Duty) was introduced by the Localism Act in November 2011. The Act inserted a new Section 33A into the Planning and Compulsory Purchase Act 2004. This placed a legal duty on all local authorities and public bodies (defined in regulations) to 'engage constructively, actively and on an ongoing basis' to maximise the effectiveness of local and marine plan preparation relating to strategic cross boundary matters, and in particular with County Councils on strategic matters.

The National Planning Policy Framework (NPPF) provides detail on how strategic planning matters should be addressed in local plans (paragraphs 178-181). Local planning authorities are expected to work 'collaboratively with other bodies to ensure that strategic priorities across local authority boundaries are properly coordinated and clearly reflected in individual local plans' (paragraph 179). 'Strategic priorities' to which local planning authorities should have particular regard are set out in paragraph 156 of the NPPF.

Specific guidance on how the Duty should be applied is included in the Planning Practice Guidance (the PPG). This makes it clear that the Duty requires a proactive, ongoing and focussed approach to strategic matters. Constructive cooperation must be an integral part of plan preparation and result in clear policy outcomes which can be demonstrated through the examination process.

The PPG makes it clear that the Duty requires cooperation in two tier local planning authority areas and states 'Close cooperation between district local planning authorities and county councils in two tier local planning authority areas will be critical to ensure that both tiers are effective when planning for strategic matters such as minerals, waste, transport and education.
ECC will use its best endeavours to assist RDC on strategic and cross-boundary matters under the duty, including engagement and co-operation with other organisations for which those issues may have relevance e.g. Highways England. In accordance with the Duty, ECC will contribute cooperatively to the preparation of a new Rochford Local Plan, particularly within the following broad subject areas,
 ECC assets and services. Where relevant, advice on the current status of assets and services and the likely impact and implications of proposals in emerging Local Plans for the future operation and delivery of ECC services.
 Evidence base. Guidance with assembly and interpretation of the evidence base both for strategic/cross-boundary projects, for example, education provision and transport studies and modelling.
 Sub-regional and broader context. Assistance with identification of relevant information and its fit with broader strategic initiatives, and assessments of how emerging proposals for the District may impact on areas beyond and vice-versa.
 Policy development. Contributions on the relationship of the evidence base with the structure and content of emerging policies and proposals.
 Inter-relationship between Local Plans. Including the Essex Minerals Local Plan Adopted 2014 and the Essex and Southend-on-Sea Waste Local Plan Adopted 2017.

ECC acknowledges and supports the production of a new Local Plan by RDC ensuring an up-to-date Local Plan. This can facilitate new job opportunities, attract investment in new and improved infrastructure, protect the environment and ensure new homes meet the needs of a growing population, which are sustainably located, and achieve the right standards of quality and design.

RDC has already undertaken work with ECC under the Duty to Co-operate during the past year, in addition to the joint and regular meetings established with the South Essex authorities, including RDC and ECC, through specific South Essex Strategic Planning DTC Groups for Members and Officers respectively to explore cross boundary matters.

The on-going duty to co-operate work that RDC has undertaken with ECC to date is acknowledged and this consultation provides the first opportunity for ECC to review the emerging issues and options in their entirety. ECC shall continue to work with RDC and provide as appropriate the latest ECC strategies and evidence to inform and shape the draft Local Plan, which will require further changes as the spatial strategy emerges and the site allocations are considered and assessed both individually and cumulatively, to test and establish the infrastructure requirements. This includes but is not limited to ECC service areas such as Highways; Infrastructure Planning; Education and Early Years and Child Care provision; Independent Living; Flood and Water Management; Public Health; and Minerals and Waste Planning. ECC will continue to work with RDC in respect of the evidence base to contribute cooperatively with RDC in the preparation of the new Local Plan through to examination.

4. ECC RESPONSE TO DRAFT NEW LOCAL PLAN ISSUES AND OPTIONS CONSULTATION DOCUMENT (DECEMBER 2017)

ECC's response to the draft Plan Issues and Options consultation document is set out below and corresponds to the format and chapters within the consultation document, however this is preceded by a summary of the key issues.

4A Summary

 Duty to co-operate. In accordance with provisions of the Localism Act 2011, ECC will contribute cooperatively with RDC in preparation of the new Local Plan. This will primarily cover an assessment of the impact on the transport and highway network (as Local Highway Authority), the need to ensure additional school places (as Education Authority), consideration of surface water management (as Lead Local Flood Authority), and links to minerals and waste planning (as Minerals and Waste Planning Authority) as well as advice on Public Health as the Lead advisor.
ECC notes that the Issues and Options consultation is primarily thematic and does not present options covering spatial proposals or site allocations. In moving forward the focus will need to be on the further assessment of the spatial options and emerging spatial strategy, which will vary according to the location, nature and mix of new developments being considered. ECC wish to be proactively engaged with the assessment of the spatial options and site allocations, given the importance of infrastructure provision and funding to the Draft Plan, which will vary for each spatial option and site allocations, given their respective individual and cumulative infrastructure requirements, generating their own, individual and cumulative impacts and opportunities on the delivery of ECC service areas. This will be essential to enable ECC to continue to inform and identify the issues and opportunities for ECC services, to ensure the Local Plan is deliverable, in accordance with the tests of Soundness and that the right infrastructure is in place at the right time.
A particular focus will be the impacts of any proposed new large urban extensions or new settlements to assist RDC determine an appropriate strategy if those options progress as part of its preferred growth and development strategy.
In addition to the above ECC will continue to contribute co-operatively with RDC through the wider collective South Essex arrangements, to address cross boundary strategic planning and infrastructure matters, through the Association of South Essex Local Authorities (ASELA), and the emerging South Essex 2050 vision associated work streams, and preparation of a South Essex Joint Strategic/Spatial Plan (JSP);and through the South Essex Transport Board and the Opportunity South Essex Partnership (OSE). With the exception of the formation of ASELA and the preparation of a JSP, the majority of the issues and options identified have regard to this wider engagement.
 Housing provision. ECC acknowledges RDC is seeking to meet housing needs in full over the plan period. However, ECC acknowledges highway and transportation constraints, and in its role as Highway Authority will provide the necessary assessments to determine impacts (including cross boundary impacts) and mitigation measures, as RDC seeks to adopt a preferred growth and development strategy. The new Local Plan should also emphasise the need to provide infrastructure (secured through developer funding) as part of any new housing proposals. ECC welcomes the importance and consideration given to the provision of adult social care and extra care (encompassing aged and vulnerable people), within ECC's Independent Living programme.
 Infrastructure Provision and Funding. ECC agrees that Infrastructure is critical to support sustainable growth and it will be essential to ensure RDC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future. We welcome the acknowledgement of ECC's role in the provision of Local and Strategic infrastructure. Further comments are provided on the spatial strategy and on the implications for ECC services and infrastructure, ranging from large urban extensions to less growth at settlements lower in the settlement hierarchy

ECC will take a pro-active position to engage with RDC to ensure the delivery of new homes and employment is at the right location and of an appropriate scale to identify and deliver the necessary level of infrastructure investment, as part of a viable and deliverable plan. ECC seeks clarification on the size of residential sites / extensions being considered when compared to large residential urban extensions / new settlements.

ECC wish to explore and understand the potential implications of the nature and scale of developments on financial contributions, given the pooling of contributions under the CIL Regulations and hence potential viability and delivery issues which will be very different for each of the spatial options being considered. As outlined in 4.6 above, the new Local Plan should emphasise the need to provide infrastructure (secured through developer funding) as part of any new development proposals, to ensure the new plan is both viable and deliverable. Given the importance of infrastructure provision and funding for the new Local Plan, ECC wishes to work with RDC to ensure the necessary infrastructure funding (including all funding streams) and delivery evidence is fully considered as part of the assessment of all the spatial options. This is to ensure the preferred strategy is viable, deliverable and sound.
 Transport and highways. ECC, will work with RDC (in consultation with Southend on Sea and the South Essex authorities) to enable further transport and highway impact assessments to be undertaken to inform the preparation of the RDC Local Plan and in accordance with the ASELA workstreams and JSP.
There is overall support for proposals promoting the importance and need for improvements to the A127 Strategic Road Network, however greater emphasis should be placed on the role and importance of sustainable travel as part of a long term integrated transport solution, including walking, cycling, bus and rail. Adequate transport and highway provision will need to be evidenced including transparency of funding, viability and deliverability to unlock sustainable growth in new homes and employment, at a scale necessary to bring forward the level of investment needed to provide significant improvement to the highway and transport infrastructure.
In respect of the A127/A130 Fairglen Interchange, ECC would not support any new development and employment allocations (beyond the current adopted Local Plan employment allocations) until the proposed long term transport scheme for the junction is implemented. ECC supports the need for a range of highways and sustainable transport improvements to existing employment areas including, London Southend Airport and the airport business park and will continue to seek funding through bids to Central Government, SELEP and S106 contributions.
 Sustainable transport. ECC recommend greater emphasis is placed on sustainable transport including passenger transport as part of a wider sustainable growth strategy to underpin future development opportunities and to ensure an integrated transport package of solutions are developed for the District and in respect of its relationship and connectivity to Southend, South Essex, Essex and London.
 Minerals and Waste Planning. ECC will engage with RDC in the site assessment process to ensure new allocations appropriately address the minerals and waste safeguarding policy requirements within the adopted Essex Minerals Local Plan and the Essex and Southend-on-Sea Waste Local Plan. ECC wishes to draw attention to the dual requirements of these Local Plans concerning minerals and waste safeguarding, operations, sustainable use of minerals in construction, and the location of waste management uses within employment areas.
 Flood and Water Management. ECC wish to work with RDC to provide points of clarification and to ensure the most up to date evidence is used to underpin the preparation of the Local Plan including the strategy and site assessments. This will include reference to the Environment Agency's revised climate change allowances and the subsequent revisions to the South Essex Surface Water Management Plans, due to be published in 2018.
 Economic Growth. ECC welcomes proposals to ensure the protection and provision of suitable employment land and appropriate uses within the District, with the pre-eminent importance of London Southend Airport to the economy whilst seeking opportunities for rural diversification, tourism, retail, leisure, and town centres, to meet the life cycle needs of business including "Grow on Space" and development of skills and training opportunities.
ECC welcomes and supports the importance and economic role played by London Southend Airport as an international gateway, and the A127 corridor and London-Southend Victoria railway line for connectivity with South Essex, the rest of Essex and London. A key priority will be to enable investment in infrastructure and economic growth, including, for example, the A127 including passenger transport and ultrafast broadband, as well as developing options to support the alignment of skill provision to meet the local needs in accordance with the Economic Plan for Essex (2014) and the National Industrial Strategy The provision of jobs and infrastructure to support economic growth will be essential, including the need to provide social, physical and green infrastructure and are also being explored by ASELA through the Industrial Strategy workstream and the JSP.
 Superfast Broadband ECC recommend upgrading all broadband references to "ultrafast broadband" to promote the Governments next broadband programme; and refer to the BT Open Reach policy for providing FTTP connections on new development of houses of 30+units, free of charge to the developer https://www.ournetwork.openreach.co.uk/property-developers/site-registration.aspx
 Education ECC Support the use of ECC Planning School information and recommend a number of updates to reflect ECC's change in policy and standards (minimum size of new schools and use of ECC model infrastructure delivery policy). ECC wishes to engage with RDC as the new Local Plan progresses to preferred options stage to enable appropriate "scenario testing" of the preferred options for education requirements.
ECC will continue to work with RDC to ensure education needs are appropriate and adequately assessed as preparation of the new Local Plan continues. ECC will undertake a further assessment of the potential delivery and resource requirements for accommodating anticipated pupil change through "scenario testing" as and when RDC confirms its preferred spatial option for growth and development and the specific sites.
In respect of Special Education Needs, this should be acknowledged in the new Local Plan, and sites allocated specifically provision for children/young people with Special Educational Needs either within the existing school provision or the wider community. ECC wish to engage with RDC to identify requirements and opportunities.
 Early Years and Childcare. In addition to the above, support the use of the ECC evidence, however recommend a number of changes to explicitly refer to "Early Years and Childcare provision" and for consistency in approach. There will be a need to update the EYCC information to ECC
 Skills. ECC will engage with RDC and can provide advice and updates, including on the full range of post 16 education and training provision and on the revisions to the ECC Developers' Guide to Infrastructure Contributions, to include the need for large scale developments to adopt an Employment and Skills Plan; and reference to the new Essex Employment and Skills Board's 2017-18 as an evidence base and the seven priority sectors. ECC wish to work with RDC to identify and promote opportunities for skills and training development to align skills with jobs.
 Public Health. ECC welcome and are supportive of the links and inclusion of health and well-being throughout the Issues and Options Report; and offer support to assist the preparation of the Local Plan, for example the development of the health and well-being policy, greater involvement with employment opportunities for local residents; support for skills, training, education and employment opportunities; improvements to air quality.
ECC support and welcomes consideration on phasing and release of affordable housing; use and application of the revised Essex Design Guide, including key concepts for inclusive and adaptable housing (e.g.. dementia friendly principles and social cohesion); housing mix, provision for older people (including care homes) and active design principles including active and sustainable travel principles.
ECC recommend use and reference to the revised Essex Design Guide within the new Local Plan design policies and the supporting text.
ECC wish to work with RDC to provide support and advice in respect of the Health and Well-being policy; policies on "fast food" outlets; Education, Skills and Employment policies and the Good Design policies.
 Independent Living Support the general approach and inclusion of and reference to ECC's Independent Living Programme for Older People and Adults with Disabilities.
 Environment (natural, built and historic), ECC welcomes the broad approaches to protect and enhance the environment, and recommends a more holistic approach and links to the wider objectives of promoting growth and healthy communities, which can be provided through the natural environment, be it green infrastructure for climate change mitigation and adaption, building design and efficiency, creation and accessibility to open spaces, green spaces (including greenways and green corridors). ECC wishes to explore these opportunities and cross benefits further as incorporated within the revised Essex Design Guide (2018) and to ensure the biodiversity and geodiversity evidence base is up to date and consistent with the NPPF.
In respect of the Historic environment further consideration and assessment is required on conservation areas and listed buildings and the archaeological and historic records of designated and non- designated sites. ECC welcomes the opportunity to explore this further with RDC to ensure the evidence base is up to date and consistent with the NPPF.
 Sustainability Appraisal ECC considers the SA to be a good example of an initial Regulation 18 'Issues and Options' appraisal, exploring the sustainability considerations of a wide range of strategic options and assessing them to the same level of detail. However, ECC recommends that a number of the options within the SA/SEA are expanded to reflect the ranges in the Issues and Options consultation Report.

4B ECC Detailed Response to the Issues and Options Consultation

INTRODUCTION (SECTION 1)

Paragraph 1.5 ECC recommend that this paragraph is amended to clearly recognise that the Essex Minerals Local Plan 2014 (MLP) and Essex and Southend-on-Sea Waste Local Plan 2017 (WLP) form part of the statutory development plan for Rochford District. The Minerals and Waste Planning Authority (MWPA) is pleased to note that the mineral and waste plans are appropriately referenced further into the plan at relevant sections and shown to have relevance to Rochford, but it may be beneficial to qualify the extent of the Development Plan at the outset.

Paragraph 1.12 ECC welcomes and supports the preparation of a Draft Habitat Regulations Assessment to inform and accompany the preparation of the draft Local Plan

TELL US YOUR VIEWS (SECTION 2)

Next Steps

ECC service areas and functions would wish to work with RDC in the preparation of the Local Plan as it progresses to assess the suggested sites and the selection of preferred sites, with regards to the impact and opportunities on ECC services and infrastructure, to ensure sites selected are sustainable. Details on this are set out in Section 2A above and throughout the response below.
ECC as the MWPA is keen to enter into engagement with RDC with regard to proposed site allocations considered through the Local Plan process. This is to ensure that any future site allocations made by RDC appropriately address mineral and waste safeguarding matters in line with adopted policies. ECC recommend early engagement within the site assessment process, for effective collaboration and consistency across the wider Development Plan. Further details of the policy requirements are set out in the Essex Minerals Local Plan Adopted 2014 and the Essex and Southend-on-Sea Waste Local Plan Adopted 2017 For the avoidance of doubt, the considerations that may arise from the MWPA in relation to these sites would be as informatives only; there is no intention to influence the site assessment process and/or any scoring mechanism designed by RDC.

OUR CHARACTERISTICS (SECTION 3)

Figure 1 ECC recommends that the content of this map is reviewed to ensure it clearly presents the local and strategic context and characteristics of the district. For example greater use of graphics and annotations including:
 Annotations for the strategic road network (A127, A130 and A13), with specific emphasis on the A127 as the key strategic highway route for Rochford will demonstrate its importance within the local highway network 9
 The London - Victoria Railway line and stations should be clearly annotated, as well as inclusion of the wider network for context, for example the C2C line from Southend to London Fenchurch Street.
 Inclusion / indication of the existing bus networks and connectivity with surrounding areas, to demonstrate the passenger transport services within the area.
The above provides background and context for the Highway and Transportation network (including Sustainable travel) within the district and wider connectivity, including strengths and areas for improvement, and the need for the provision of sustainable access. This would also provide context for the national and local pictures presented in section 4 and the relationship with London (and the rest of Essex).

Our Economy

Paragraph 3.8 ECC recommend that reference is made to the wider rail network and specifically Cross Rail, which connects to the London - Victoria Line at Shenfield and will link to the wider London, and west of London, area.
Paragraphs ECC considers greater emphasis should be placed on the relationship
3.7 - 3.8 and connectivity between the District, Southend, South Essex, Essex and London, including the 2011 data presented in Figures 2 and 3. Whilst the data is of assistance, it is recommended that the mode of transport used to make journeys is also presented. This additional information would be required to inform the base assumptions for likely future modal choice that would arise as a consequence of further development. Equally this could help to demonstrate where the more significant concentration of improvements may be required to promote suitable sustainable cross boundary transport provision, which could affect the levels of car journeys undertaken by encouraging modal shift.
Paragraph 3.12 ECC consider that there is an opportunity to promote the potential benefits / outcomes for the local economy arising from improvements to the transport network, for example greater connectivity for residents and businesses, or an increase in flight destinations served by London Southend Airport.
Paragraph 3.14 ECC recommends the inclusion and reference to the Outer Thames Estuary SPA list of European sites.

Our Communities

Paragraph 3.23 ECC notes that this paragraph seeks to set out the Education provision across the district however there is no reference to either Early Years and Childcare (EYCC) or Special Education Needs (SEN) provision. ECC recommends that EYCC is incorporated and set out in Strategic Priority 4.4 and paragraphs 9.30 to 9.36 and SEN is referred to in Strategic Priority 4.3 and paragraphs 9.17 - 9.29.

Key Community Characteristics
ECC recommends greater recognition is given to the role and contribution of Passenger Transport, in respect of both existing and new provision of services to support the ageing population. ECC wish to explore this further with RDC in the preparation of the Local Plan, to promote an inclusive strategy for existing and new residents.
OUR SPATIAL CHALLENGES (SECTION 4)
ECC General Comment
ECC notes that this section sets out the National and South Essex picture and relationship to London, however it is recommended that this is expanded to provide a specific "county policy context." ECC welcomes the reference to ECC services throughout the document, however the inclusion of a wider "County Policy Context" would provide a clear and strategic policy framework, reflecting two tier context and delivery of ECC services and functions. ECC can provide appropriate supporting text links to relevant ECC policies and strategies. It is also recommended that within the wider context reference is also made to the adjoining Essex authorities outside the "South Essex" area including Maldon DC given the importance of the River Crouch.
ECC recommends that the following ECC policies and strategies are included and referred to within a new "county policy" context and delivery proposals:
 Essex Vision and Priorities 2017/21
 Essex Organisation Strategy, 2017 - 2021
 Economic Plan for Essex (2014)
 Children in Essex get the best start in life 2014-2018.
 People in Essex enjoy good health and wellbeing 2014-2018
 People in Essex have aspirations and achieve their ambitions through education, training and life-long learning 2014-2018
 People in Essex can live independently and exercise choice and control over their lives 2014-2018.
 Essex Transport Strategy, the Local Transport Plan for Essex (June 2011)
 ECC's Passenger Transport Strategy - Getting Around In Essex 2015.
 A127 Corridor for Growth - An Economic Plan 2014
 Essex children and Young People's Strategic Plan 2016 Onwards (2016)
 Essex Early Years and Childcare Strategy 2015-2018
 Commissioning school places in Essex 2017-2022
 Essex County Council Local and Neighbourhood Planners' Guide to School Organisation
 ECC Independent-Living-Programme-Position-Statement October 2016
 ECC Developers' Guide to Infrastructure Contributions (2016)
 Essex Minerals Local Plan Adopted 2014
 Essex and Southend-on-Sea Waste Local Plan Adopted 2017
 ECC Sustainable Urban Drainage Design Guide 2016
 Greater Essex Growth & Infrastructure Framework (2016)
 Superfast Essex Broadband

National Picture

Paragraph 4.3 ECC advises that the SELEP Strategic Economic Plan is now due to be completed during 2018.

Paragraph 4.5 ECC welcomes and is supportive of increasing employment opportunities for the District and would wish to engage with RDC to explore these opportunities further. This is consistent with ECC's Essex Outcomes Framework, through the development of the Essex Economic Growth Strategy and, the Economic Plan for Essex, including South Essex as one of four growth corridor. These corridors collectively form the locations for housing and employment, to secure future growth. These roles are based on location characteristics, local economic history and linkages to surrounding areas. Critically, these corridors will provide a mix of housing, which will allow new and existing residents to stay and develop in the District / County. ECC is a partner of the Association of South Essex Local Authorities (ASELA), which extends beyond the SELEP federated area of South Essex, to include Brentwood BC. ECC supports the emerging 'South Essex 2050 Ambition' for the area and the commencement of a Joint Spatial Plan (JSP) to provide a framework for the future growth ambitions of the area. ECC recommend that the role of ASELA and the emergent JSP is taken into account in the preparation of the Local Plan

ECC can provide additional information on the Essex Growth Commission Report (2017), ECC's Grow on Space study, as well as the specific economic strategies and engagement being developed by ECC and with partners, including OSE, promoting economic growth, regeneration, infrastructure delivery and sustainable new development, and having regard to the National Industrial Strategy.
ECC would welcome the opportunity to provide additional information in respect of the health profiles for the District, to assist with the identification of skills, training and employment opportunities, as well as the development of a health impact assessment process for developments.

ECC also considers there to be an opportunity to explore and promote opportunities in the area for employees and residents, with greater emphasis placed on accessibility and promotion of passenger transport as part of a wider package of transport solutions, and to optimise and improve the current passenger transport accessibility to the area.

Paragraph 4.6 ECC welcomes the reference that "infrastructure is critical to support sustainable economic growth" and the recognition of the need to work with partners, including ECC, under the duty to co-operate, to deliver Strategic and Local infrastructure.

ECC has provided further information throughout this response to inform the preparation of the new Local Plan, as it relates to ECC services and functions, to ensure are appropriately considered within the Local Plan. ECC recognises the need for essential infrastructure to be identified, to support the level of proposed growth within the Issues and Options consultation. ECC has and will continue to work with RDC to identify the appropriate infrastructure requirements and mitigation measures which need to be developed, including the preparation of the Infrastructure Delivery Plan, before the plan progresses to the Preferred Options stage,. This is explored further within the respective strategic priorities, themes and options below.

ECC recommends that RDC refer to the "ECC's Developers' Guide to Infrastructure Contributions" (2016), for details of the necessary contributions required from new development for the provision of essential infrastructure, to inform the ongoing evidence base and the delivery and viability assessments.

Paragraph 4.10 ECC welcomes the reference to minerals and waste as a strategic, cross boundary matter subject to the Duty and ECC is keen to enter into engagement with RDC with regard to proposed site allocations considered through the Local Plan process and that this is undertaken at the site assessment stage of the Local Plan, as referred to above under "Tell Us Your Views".

Paragraph 4.17 ECC recommends that the "Challenge" on how to deliver infrastructure to support new homes should also seek to incorporate new open space Suitable Accessible Natural Greenspace (SANG) as part of new residential developments to avoid recreational impacts on European sites in accordance with the Habitat Regulations. Further details on this aspect are incorporated within the revisions to the Essex Design Guide (revised EDG) to be published February 2018.
Please also refer to ECC comments in respect of paragraph 9.42 (options for Open space and outdoor recreation) and paragraph 10.29 (options for Greenways)

OUR VISION AND OBJECTIVES (SECTION 5)

Draft Vision

Paragraph 5.9 ECC is supportive of the emerging draft vision which is considered in accordance with the NPPF and the three dimensions for sustainable development; and ECC welcomes the inclusion and reference to health.

Strategic priorities

1. The homes and jobs needed in the area
2. Provision of retail, leisure and other commercial development
3. Provision of infrastructure, including transport, digital, flood risk, coastal management, minerals and energy
4. Provision of Health, security, community and cultural infrastructure and other local facilities, including EYCC, Education and Youth Facilities
5. Climate Change and Environmental protection and mitigation

It is noted that the Strategic Objectives in support of Strategic Priorities 1, 2, 4 and 5, do not refer to or recognise the role of sustainable transport to deliver these Strategic Priorities. ECC recommends further consideration is given to incorporate the principles of sustainable transport and travel within the new Local Plan in accordance with the Essex Local Transport Plan.

Strategic Objectives

SP1 The homes and jobs needed in the area

SO1 ECC support the objective to facilitate the delivery of sufficient, high quality and sustainable homes, combined with SO6 for all homes and commercial buildings to be built to the highest attainable quality, design and sustainability standards.
SO3 ECC welcomes the positive move towards supporting sustainable travel, however this only refers to improvements for new developments, whereas opportunities should be sought to overcoming existing shortfalls in sustainable connectivity.
SO5 ECC is supportive to the inclusion of skills, training, education and employment, and ECC Public Health would welcome the opportunity to work with RDC to explore the employment opportunities for residents. ECC considers that this could be included and assessed as part of the Health Impact Assessment process for developments, skills, training and employment opportunities.
ECC recommends this Strategic Objective amended to specifically refer to EYCC provision alongside the provision of good schools.
SO6 ECC support the objective for all homes and commercial buildings to be built to the highest attainable quality, design and sustainability standards in combination with SO1.
ECC recommends ECC recommends that these strategic objectives should also include consideration for new housing and commercial development to have reasonable access to green spaces. ECC can provide examples, where distance standards have been applied to protect and promote an accessible network of green space, including for example the Bristol Parks and Green Space Strategy 2008, with walking distance/ time to parks and green space. https://www.bristol.gov.uk/policies-plans-strategies/bristol-parks-and-green-space-strategy .
This would provide a cross over benefit between a number of the Strategic Priorities including SP1 (SO1 and 6); SP3 (SO 9 and 11), and SP4 (SO15 and 16).

SP 2 Provision of retail, leisure and other commercial development

SO 8 ECC suggest the objective should include accessibility to services and green spaces.

SP3 Provision of infrastructure, including transport, digital, flood risk, coastal management, minerals and energy

SO 9 ECC recommends that the reference to "broadband" is replaced by "Ultrafast Broadband". ECC acknowledges the current rollout programme is "Superfast Broadband", however it is recommended that the draft new Local Plan should refer to "Ultrafast Broadband" to reflect the Government's next roll out initiative, thereby providing longevity to Local Plan policy and distinguishing new provision from the "standard broadband" which is not considered fast enough. This should be applied throughout the document

SO 9 & 11 ECC recommends that these strategic objectives should also include consideration for new housing and commercial development to have reasonable access to green spaces. Please refer to ECC's comments to SO6 above and the Bristol Parks and Green Space Strategy example.

SO11 ECC support this Strategic Objective which also supports "air quality".

SO12 ECC welcomes the reference to 'encouraging adherence to the waste hierarchy' and making 'best use of mineral deposits' but considers that these statements could be afforded slightly more clarity. Supporting the waste hierarchy and ensuring a sustainable use of minerals requires that existing facilities and infrastructure are safeguarded to ensure that they are able to continue to make their planned contribution to the mineral and waste strategies operating in the County. Whilst already covered by MLP Policy S8 and WLP Policy 2, it is considered beneficial for this to be incorporated into the Rochford LP objectives. ECC suggests amendments to SO12 as follows:

"SO12: To plan for effective waste management by encouraging adherence to the waste hierarchy, working with Essex County Council to make best use of mineral deposits resources and mineral and waste facilities, including safeguarding resources and infrastructure, supporting renewable energy generation and energy efficiency as part of all new homes and commercial premises developed, as well as supporting efficient water use."

The requirement to safeguard mineral development is recognised in paragraph 10.21 and therefore the proposed modification is in accordance with that recognition. There is however no similar recognition for waste facilities, which the proposed modification to Strategic Objective 12 would then cover.

SO13 ECC can advise that any new plans for coastal change management should also involve the other partners of the Essex Coastal Forum, given that the Forum has the responsibility for policy changes to the Essex and South Suffolk Shoreline Management Plan

SP4 Provision of Health, security, community and cultural infrastructure and other local facilities, including EYCC, Education and Youth Facilities

SO15 ECC supports this strategy, which is supportive of the England Coast Path being created by Natural England, to be subsequently implemented by Essex Highways, for the economic and health benefits of the community and is consistent with the other Strategic Objectives.

SO 15 ECC support this strategy which would also support air quality, but should be amended to specifically include reference to "air quality".

SO 15 & 16 ECC recommends that these strategic objectives should also include consideration for new housing and commercial development to have reasonable access to green spaces. Please refer to ECC's comments to SO6 above and the Bristol Parks and Green Space Strategy example.

SP5 Climate Change and Environmental protection and mitigation

SO19 ECC supports the inclusion of this objective and strategic priorities for conservation and enhancements for the natural environment which is considered to be in accordance with NPPF (paragraph 156), however ECC recommends that the objectives should be further amended, to include policies which seek to minimise the impacts to biodiversity in accordance with paragraph 117 of the NPPF. Please refer to ECC in paragraph 10.1 below for further details on this matter.

SO22 ECC welcomes the objective, however recommend that "Green (and Blue) Infrastructure" is specifically referenced within the objective to read as follows:
"To mitigate and adapt to the forecasted impacts of climate change, including the water environment, air quality, biodiversity, flooding and green and blue infrastructure, support more efficient use of energy and natural resources and facilitate an increase in the use of renewable and low carbon energy facilities."
This is considered necessary to recognise the important role of this infrastructure for climate change mitigation and adaption, through micro-climate control, water management (SUDS), air quality, carbon sequestration and reduce biodiversity loss, which in turn strengthens communities through improved health and wellbeing and building resilience.

DELIVERING HOMES & JOBS (SECTION 6)

ECC General Comments

ECC recommend all references to the provision and requirements for future broadband are prefaced by "Ultrafast". ECC acknowledges the current rollout programme is "Superfast Broadband", however it is recommended that the draft new Local Plan should refer to "Ultrafast Broadband" to reflect the Government's next roll out initiative, thereby providing longevity to Local Plan policy and distinguishing new provision from the "standard broadband" which is not considered fast enough, this also applies to paragraph 6.127.

Paragraph 6.4 ECC notes that Green infrastructure is only mentioned in its wider District context. However, due to the rural nature of the district ECC would recommend that localised Green Infrastructure (GI) design principles are incorporated as part of a proposed housing development, specifically large developments such as Garden Communities and Urban Extensions. The would be in accordance with the NPPF and the Core Planning Principles on conserving and enhancing the natural environment, including the following statement in Paragraph 114 that Local Planning Authorities should "Set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure."
ECC recommends that this principle is also incorporated within Strategic Priority SP5.2 to protect, manage and enhance important habitats, nature conservation areas, geo-diversity and greenways

SP1.1 Need for Market, Affordable and Specialist Homes

Paragraph 6.30 Options on how to meet Objectively Assessed Need for housing:
A. Seek to provide as much for the district as possible, subject to environmental constraints;
B. Work with neighbouring authorities to ensure housing need across the South Essex strategic housing market is effectively met; or
C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first come basis first-served basis for a limited period of time

ECC Comments

Options A-C: ECC does not consider these options as presented to be mutually exclusive and would expect RDC to explore all options (and combinations) when planning to meet housing need. ECC would anticipate that RDC would seek to comply with the "Mechanism for the Consideration of Unmet Housing Need", as endorsed by the Essex Planning Officers Associations in September 2017, which comprises all Local Planning authorities within Greater Essex (including RDC)

Affordable Homes

Paragraph 6.31 Options for the affordable housing threshold:
A. Reduce the threshold for provision a part of a scheme (potentially in line with emerging national policy);
B. Retain the current threshold for the provision of affordable homes as part of a development scheme;
C. Do not have a policy threshold for the provision of affordable homes (potentially rely on emerging national policy and guidance to set the minimum threshold)

ECC Comments

ECC does not consider Options A and B, as presented to be mutually exclusive and would expect a combination of options to support the delivery of affordable housing within the district. ECC considers that additional sensitivity analysis of the thresholds would be appropriate to ensure they are effective and viable.
ECC recommend that consideration is given to the phasing and release of affordable homes on new development sites. This would enable the affordable homes provision to be both inclusive and adaptable throughout the life-course and further details are incorporated within the revised EDG. This is a key concept within the EDG to incorporate wider design feature such as dementia friendly principles (as promoted by the RTPI) and ECC's Independent Living Programme both of which should be considered. Furthermore the location of properties within new developments should seek to ensure social cohesion within the communities, including the reduction of social isolation (in accordance with NPPF paragraph 50).

ECC recommend that further consideration is given to locational "accessibility" in the provision of affordable housing. For example, to ensure the affordable housing provision is located with good passenger transport and a range of sustainable travel modes, to ensure social inclusion. This is to minimise the risk of a broad spread of affordable housing in low numbers located in relatively inaccessible areas, with limited to no potential to secure improvements in passenger transport provision. Further details are available within ECC's "Passenger Transport Strategy - Getting Around In Essex" (2015).

In respect of identification of "key worker homes" and supporting the needs of healthcare providers ECC considers that this could also be addressed via within the provision of affordable homes. .ECC recommends RDC engage with healthcare employers on their current workforce strategies so as to support recruitment and retention of healthcare staff. ECC would welcome the opportunity to assist with this stakeholder engagement.

ECC does not support Option C for the reasons stated within the justification, it is considered contrary to the NPPF (paragraph 50, third bullet 3) where authorities are required to set policies, where there is an identified need for affordable housing and the emerging vision and strategic objectives of the draft Local Plan, for example SO2 "To plan for the mix of homes needed to support our current and future residences, in particular viably addressing affordability issues and supporting our again population "
Paragraph 6.32 Options for the proportion of affordable homes to be provided:
D. Retain the current affordable homes requirement of 35% where a scheme meets the threshold, subject to viability;
E. Increase the proportion of homes that we require developers to provide as affordable housing, subject to viability

ECC Comments

Options D-E: ECC does not consider these options as presented to be mutually exclusive and would expect a consistent approach to be developed in principle, to support the delivery of the appropriate proportion of affordable housing, based on robust evidence ECC consider additional sensitivity analysis of the thresholds would be appropriate to ensure they are effective and viable.

Please refer to ECC's comments to paragraphs 6.30-6.31 above, which equally apply to these options. For example ECC recommend that consideration is given to the phasing and release of affordable homes on new development sites. This would enable the affordable homes provision to be socially inclusive and adaptable, as set out in the revised EDG, which now includes wider design features such as dementia friendly principles, to ensure social cohesion within the communities, including the reduction of social isolation for specialist housing, and including independent living units for older people and adults with disabilities.

ECC consider the provision of specialist housing including ECC's Independent Living Programme for Older People and Adults with Disabilities, to be within the definition of "affordable housing" and it should be included within the appropriate housing mix (see paragraph 6.33 below).

Homes for Older People and Adults with Disabilities

Paragraph 6.33 Options for the Provision of Homes for Older People and Adults with Disabilities:
A. Continue the current approach to applications for specialist homes - on an ad hoc basis as applications are received based on available evidence
B. Include a policy on housing mix which requires the provision of specialist homes, such as wheelchair accessibility (part M Category 3), independent living units, sheltered and extra-care housing, over a certain threshold.

ECC Comments

ECC welcomes the acknowledgement of and reference to ECC's Independent Living (IL) Programmes for Older People and Adults with Disabilities to support the provision of specialist housing, based on evidence and in accordance with the NPPF and national policy.

ECC supports a revised version of Option B, to ensure the positive provision of specialist housing to meet the needs of residents, in accordance with ECC's strategies, guidance and evidence including:
 ECC's IL Programmes for Older People and Adults with Disabilities , for the respective demand and need for units across Essex by district, for example the IL Position Statement for Older People (2016) identified a shortfall of 129 units (19 rental and 110 ownership) required in the District for the period 2015 and 2020
 ECC Developers' Guide to Infrastructure Contributions (2016) (for securing the appropriate funds) and regard to the revised EDG for appropriate locational and design guidance

ECC can provide updates on the demand and need for IL units for both Older People and Adults with Disabilities, and would welcome the opportunity to engage with RDC, on an ongoing basis to ensure the most up to date information is available to inform and shape the preparation of the Local Plan.

SP1.2 Care Homes

Paragraph 6.35 ECC welcomes the reference to and ongoing engagement with ECC and would wish to maintain this engagement to inform the requirements and provision within the preparation of the Local Plan

Paragraph 6.36 Options for providing care homes in the district:
A. Continue the current approach to applications for specialist homes - on an ad hoc basis as applications are received based on available evidence.
B. Include a policy on housing mix which requires the provision of specialist homes, such as wheelchair accessibility (part M Category 3), independent living units, sheltered and extra-care housing, over a certain threshold

ECC Comments

Options A-B: ECC would anticipate combination of options (including the option in paragraphs 6.30-6.35) to support and ensure the appropriate mix of provision including care homes in accordance with the NPPF and based on evidence.
ECC recommend that consideration is given to the need to ensure provision is accessible, appropriate and inclusive to ensure integration within the community and has regard to the health and social care requirement a set out in the revised EDG and the details set out above in response to Paragraph 6.33, options for the provision of specialist housing.

ECC would welcome the opportunity to engage with RDC on these matters further to ensure the preparation of a legally compliance, effective and sound local plan.

SP1.3. Delivering our Need for Homes

ECC General Comment

The Issues and Options within this section provide a clear overview of the key planning issues facing the District and what the new Local Plan should address in respect of meeting the needs for homes. However, it is recommended that further consideration should be given to the following.
 Infrastructure provision and funding. The new Local Plan should ensure there are clear policies for the full provision, enhancement and funding of infrastructure arising from planned development. Mechanisms include planning obligations, the use of a Community Infrastructure Levy (CIL), and the ability to negotiate specific contractual obligations for major strategic sites, in accordance with the Garden City principles defined by the Town and Country Planning Association (or subsequent updated guidance) and wider definition of sustainable development outlined in the NPPF. This will ensure the delivery of sustainable development in accordance with the NPPF, including the three dimensions to achieve sustainable development (paragraphs 6 -10), the presumption in favour of sustainable development (paragraph 14) and the 12 core planning principles (paragraph 17).

At the heart of the NPPF is a presumption in favour of sustainable development. For plan-making this means local planning authorities should positively seek opportunities to meet the development needs of their area, and Local Plans should boost significantly the supply of housing to ensure the full objectively assessed needs for housing over the plan period. The NPPF includes the delivery of sufficient community and cultural facilities and services to meet local needs as a core planning principle.

There is a clear expectation that local authorities should make provision for funding for new school places from Section 106 contributions and CIL. ECC alone does not have the capital resources to fund the construction of early years' and child care places, primary schools or secondary schools. There appears to be a view developing that the provision of sufficient school places is the sole responsibility of ECC assisted by the DfE in the form of 'basic need' funding, as the District and Borough councils are not the local education authority. The expectation is that the DfE will fund any shortfall in school places that result from large new housing developments.

ECC wish to draw attention to paragraph 72 of the NPPF, which states 'The Government attaches great importance to ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities.' ECC does not view financial contributions for education as optional. If this is the case then there will be no DfE and or ECC funding available, to provide all the school places required as a result of a growing school population and the need to create additional school places to meet the needs generated by new housing developments. ECC recommends that it is made clear in the new Local Plan that there is a requirement for financial contributions from developers to fund the full additional early years and childcare, primary and secondary school pupil places (including post 16) generated from new development to ensure that new housing developments are sustainable in terms of educational and childcare provision. ECC considers that this would accord with NPPF paragraph 72 and reiterates the requirements in the ECC Local and Neighborhood Planners' Guide to School Organisation and the ECC Developers' Guide to Infrastructure Contributions (2016). Further information on this issue is provided later in this response.
ECC welcomes the recognition that infrastructure is critical to support sustainable growth and to make sure RDC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future and the acknowledgement of ECC's role in the provision of Local and Strategic infrastructure. ECC wishes to be proactively engaged with the assessment of the spatial options and site allocations, given the importance of infrastructure provision and funding to the Draft Plan, which will vary for each spatial option and site allocations, given their respective individual and cumulative infrastructure requirements, generating their own, individual and cumulative impacts and opportunities on the delivery of ECC service areas.
 Flooding and its impact on development. This is broadly mentioned but will significantly influence future development locations. The main river and surface water flood risk areas should be clearly identified and the new Local Plan should provide appropriate policies in relation to flood risk. ECC is the Lead Local Flood Authority for surface water management and is revising the South Essex Surface Water Management Plan (SWMP) taking into account the recent changes in the EA's Climate Change Allowances. ECC recommends the provision of sustainable drainage systems (SuDS) and the revised SWMP as part of new development. Further information on this issue is provided later in this response.
 Broadband. While highlighted in the document, ECC recommend that "broadband" is distinguished from other telecommunications infrastructure, and specified in policy as a necessary infrastructure requirement for new development.. This will support relevant strategic and local objectives relating to economic growth particularly in rural Rochford. This will have a wider impact on growth and productivity, as increased broadband coverage will support businesses and attract investment to Essex. It also has the potential to increase opportunities for home-working and remote-working, reducing the demand on travel networks at peak periods. The importance is demonstrated by recent census returns which show that the biggest change in journey to work patterns in the last 20 years has actually been the increase in people working from home.

 Minerals and Waste provision and safeguarding requirements (please see section 2 "Tells Us Your views).

It is recommended that the above policy requirements are considered when preparing the new Local Plan and developing the overarching spatial strategy. Further information is provided below and in Sections 7 - 11.

Paragraph 6.46 ECC welcomes the positive recognition and importance placed on reducing inequalities and improving congestion levels, by ensuring the provision of new homes will include a variety of modal travel options. ECC recommends engagement and close working with ECC's Sustainable Travel Team and raising awareness of the local cycle action plans which also include some infrastructure elements

ECC recommends greater emphasis is placed on the creation of and access to more sustainable travel options within new developments, including connectivity to existing settlements for both housing and employment.

Paragraph 6.48 Options to provide a realistic strategy for delivering new homes:
A. Increase density within the existing residential area - which would require an amendment to our 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

ECC Comments

ECC does not consider these options as presented to be mutually exclusive. ECC would anticipate the Spatial Strategy to be developed with a range or combination of the options, based on evidence and in accordance with the NPPF and in particular the overarching principles of the NPPF.

ECC recommends that consideration is given to the wider "duty to co-operate" in emerging national policy (housing white paper) requiring local authorities (including RDC and ECC) to place greater emphasis on the development of Joint Strategic Priorities to address strategic cross boundary planning matters. The formation of ASELA to develop the South Essex 2050 vision with a set of strategic priorities and JSP will provide the context for RDC to consider the requirements of the South Essex Strategic Housing Market Area and to explore whether there are any unmet housing needs within the area.

ECC welcomes the recognition that infrastructure is critical to support sustainable growth and to make sure RDC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future, and the acknowledgement of ECC's role in the provision of Local and Strategic infrastructure. ECC wishes to be proactively engaged with the assessment of the spatial options and site allocations, given the importance of infrastructure provision and funding to the Draft Plan, which will vary for each spatial option and site allocations, given their respective individual and cumulative infrastructure requirements, generating their own, individual and cumulative impacts and opportunities on the delivery of ECC service areas.

ECC considers that any large scale housing developments will need to include appropriate infrastructure such as schools, community facilities and improvements to the roads. In contrast, a larger proportion of small scale or piecemeal developments are less likely to secure funding for the necessary infrastructure requirements. Furthermore infrastructure provision is likely to have a major impact on the phasing, delivery and viability of development(s) and this would need to be considered as part of the overall strategy.

ECC recommend consideration is given to the cumulative scale of development required to secure the necessary supporting infrastructure and the mechanisms available to secure developer contributions (be it S106 contributions, pooling of contributions or via the Community Infrastructure Levy). ECC consider this to be essential in the preparation of a new local plan, to ensure it complies with the legal duty to co-operate, meets the tests of soundness and is effective, viable and deliverable. ECC expect RDC to prepare a sound and deliverable Local Plan, having regard to the available levels and sources of investment available to deliver the supporting infrastructure.

ECC recommends consideration is also given to the respective infrastructure funding streams available to deliver and implement strategic infrastructure, be it the ECC Developers' Guide to Contributions, the Opportunity South Essex Partnership, the South Essex Local Enterprise Partnership, and Government Departments/agencies, such as the Department for Transport agencies, as well as changes in the national policy and legislation for the S106 and CIL.

ECC can advise in principle, that subject to the scale of the development being considered, Option E may have the potential to bring forward the level of investment needed to provide significant improvement to the highway and transportation infrastructure. However, in the absence of a location or scale for any new settlement ECC cannot recommend its preference for Option E over and above any other options put forward. Again, subject to the scale of development the other options including smaller size settlements may not bring the level of investment required. In essence this reflects the "critical mass" in the scale of development required to enable effective infrastructure and service planning, which it may not be possible to secure with a number of smaller developments given the effect of the CIL Regulations (Regulation 123) and the restrictions on pooling contributions.

SP1.4 Good Mix of Homes

Paragraph 6.58 Options identified in relation to the broad approach for considering the type and size of new homes:
A. Retain the current policy on types of homes, which takes a flexible, market-driven approach to types
B. Include specific reference to the size and types of homes referred to 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

ECC Comments

ECC would anticipate a strategy to be developed based on evidence and in accordance with the NPPF. Please refer to ECC's comments in response to the options in paragraphs 6.30 - 6.36 above paragraph 11.5 below which are considered relevant to this option.

ECC does not support Option D for the reasons stated in the justification, it is considered contrary to the NPPF (paragraph 50) and the emerging vision and objectives of the draft Local Plan, for example SO2 (as referred to in response to paragraph 6.31 above).

SP1.5 Gypsy, Travellers and Travelling Showpeople

Paragraph 6.78 Option identified to meet the needs of Gypsies and Travellers:
A. Retain the current criteria-based policy (Core Strategy policy H7)
B. Retain the current allocated site (Allocations Plan policy GT1)
C. Allocate a number of smaller Gypsy and Traveller pitches / sites to meet needs
D. Consider a mobile home policy for those no longer falling within the Gypsy and Traveller definition
E. Prepare a more detailed criteria-based policy
F. Do not have a policy on Gypsy and Traveller provision
ECC Comments
ECC does not consider these options to be mutually exclusive. ECC would expect RDC to develop a combination of options based on evidence and in accordance with the NPPF and the Planning Policy for Traveller sites 2015 (PPTS), requiring an inclusive approach for all gypsies and travellers, both members of the travelling and settled communities.

ECC would anticipate provision to be made for travellers who meet the planning definition, may be meet the definition or do not met the definition to be in accordance the Greater Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment 2016-2033 (GTAA) published in January 2018.
Furthermore ECC would anticipate the emerging strategy and emerging policy to take into account the Transit Recommendations within the Essex GTAA prepared by EOPA and considered to be a strategic cross boundary issue for the Greater Essex authorities.

SP1.6 Houseboats and Liveaboards

Paragraph 6.82 ECC welcome and support the commitment to work with other neighbouring authorities and relevant bodies such as the Marine Management Organisation (MMO), Natural England (NE) and the Environment Agency (EA). ECC and partners would be able to assist in monitoring and the assessment of impacts arising from the proposed approach to Houseboats and Liveaboards. This could include identifying an appropriate scale / limit for the number of houseboats that could be permitted to moor in a particular area.

Paragraph 6.83 ECC considers the statement regarding the extent of land use planning control "to only extend as far as the mean high tide" to be incorrect and should be amended. ECC can advise that Land Use planning control extends to Low Water Mark, whilst the Marine Planning system extends to High Water Spring Tide, therefore there is an overlap of the 2 planning systems in the intertidal area. This correction also provides an opportunity to work with the MMO in developing evidence and an emerging policy.

Paragraph 6.84 ECC considers further exploration of the infrastructure requirements is necessary, in addition to the reference to the need for provision of toilets for houseboats with a permanent mooring, and to also include the infrastructure provision required for boats which are moored temporarily. It is important that the boats do not discharge waste into the marine environment and hence they would need to be equipped with holding tanks and to use pump out facilities to discharge this type of waste appropriately.
Paragraph 6.86 Options to address the mooring of houseboats in the district:
A. Retain the existing policy
B. Amend the existing policy to strengthen criteria
C. Allocate specific areas of coastline where such uses may be acceptable
D. Amend the definition in the Development Management Plan

ECC Comments

ECC would anticipate a strategy to be developed based on evidence and in accordance with the NPPF and other national policy. ECC considers additional evidence and engagement is required, and recommend that this is explored further with EPOA and / or Essex Coastal Forum.

ECC welcome the consideration of the need for a policy on houseboats/ liveboards as part of the review of the current polices to ensure they are based on the most up to date evidence. This would be appropriate given the growth in occupation and experiences elsewhere in the country (especially in London) where living on a boat is proving to be an attractive proposal, and in certain areas demand has outstripped available mooring. Whilst it may be a lifestyle choice for many, the result is an increasing number of houseboats across the Essex coast, especially in areas commutable to London.

SP1.7 Meeting Business Needs;

Paragraph 6.87 ECC recommends consideration is given to the contribution made by the environmental / Green Infrastructure (GI) to provide a network of multi-functional high quality green spaces and other environmental features, which together deliver multiple environmental, social and economic benefits. ECC can provide advice and evidence from the findings of a Forestry Commission report on the economic value of Green Infrastructure, to overcome barriers to businesses, whilst improving people's quality of life, health and wellbeing, which is available here:
https://www.forestry.gov.uk/pdf/nweeconomicbenefitsofgiinvestigating.pdf/$file/nweeconomicbenefitsofgiinvestigating.pdf

Paragraph 6.92 ECC notes the emerging Local Plan seeks to facilitate a diverse, modernised economy providing high value employment, and supports this aspiration. Paragraph 6.105 states that the Economic Development Needs Topic Paper 2017 advocates employment land increases to primarily facilitate B1 and B2 uses. Whilst ECC does not object to this, it is considered important to ensure that any strategy seeking to grow the economy does not preclude opportunities for waste management, with such facilities often being sited on industrial / employment land. Whilst, waste related developments are employers in their own right, economic activity generates waste, and a cost effective, local waste solution supports economic development across the spectrum. It is recognised that there is nothing in the Issues and Options consultation that indicates such opportunities would be precluded, and indeed ECC notes the role that Rawreth and Star Lane industrial estates play in this regard, but ECC as the MWPA welcomes the opportunity to make this point. It is requested that reference is made to supporting appropriate 'sui generis' uses when defining appropriate use classes on employment land.

Paragraph 6.94 Please amend the reference to "Ultrafast broadband" for the reasons set out in response to Section 6 and paragraphs 6.96 and 6.127.

Paragraph 6.96 ECC supports this statement and the need for improvements to the highway networks / sustainable travel choices to support businesses and economic growth; and to enable people to work in the local area.

Paragraph 6.96 Options to support employment and economic growth in the district
A. Continue to support employment growth within the current employment growth policy
B. Update the current employment growth policy to include reference to broadband
C. Update the current employment growth policy to further support new businesses at each stage of their lifecycle - in particular to reflect the need for grow-on space
D. Include specific reference in the current employment growth policy to tourism; and
E. Include specific reference to supporting sustainable travel options and promoting highways improvements

ECC Comments

ECC would expect all of the options to contribute to RDC meeting its need for employment and economic growth; and would expect RDC to prepare a sound and legally compliant Local Plan, based on evidence and in accordance with the NPPF.
ECC welcomes proposals to ensure the protection and provision of suitable employment land and appropriate uses within the District, with the pre-eminence of the importance of London Southend Airport to the economy whilst seeking opportunities for rural diversification, tourism, retail, leisure, town centres, to meeting the life cycle of business needs including "Grow on Space" and development of skills and training opportunities.

ECC welcomes and supports the importance and economic role played by London Southend Airport as international gateway and the A127 corridor and London-Southend Victoria railway line for connectivity with South Essex, the rest of Essex and London. A key priority will be to enable investment in infrastructure and economic growth (for example the A127 including passenger transport; ultrafast broadband) as well as developing options to support the alignment of skill provision to meet the local needs in accordance with the Economic Plan for Essex (2014) and the Government's Industrial Strategy as are being explored by the ASELA through the Industrial Strategy workstream and the preparation of the JSP. The provision of jobs and infrastructure to support economic growth will be essential, including the need to provide social, physical and green infrastructure.

ECC recommends consideration is given to the role and contribution of waste related developments as employers in their own right, economic activity generates waste, and a cost effective, local waste solution supports economic development across the spectrum. ECC recommends the inclusion and reference to 'sui generis' uses when defining appropriate use classes on employment land (see paragraph 6.92 above and 6.105 below).

In respect of Option B and the reference to Broadband, ECC acknowledge the importance of this infrastructure to support economic growth. Please refer to ECC's comments in response to paragraph 8.44 and the options for communication and broadband provision, as well as the references above to "Ultrafast" broadband.

In respect of Option C, ECC welcomes and supports the reference to the ECC "Grow on space" report 2017 and its findings seeking to address the lifecycle needs of businesses. This is also consistent with the Essex Economic Commission.

In respect of option D and the references to rural diversification and tourism ECC considers the development and promotion of the Essex Coast Path could provide opportunities for the local economy. ECC considers there is a need to have regard to the role and contribution of the environment and in particular investment in Green Infrastructure to attract new businesses and opportunities which will help to create employment, including for example regeneration projects which together can deliver multiple environmental, social and economic benefits. Further details and examples are set out in response to paragraph 4.6 above.

In respect of Option E, ECC supports the need for a range of highways and sustainable transport improvements to existing employment areas, including London Southend Airport and the airport business park and will continue to seek funding through bids to central Government, SELEP and S106 contributions, as set out in response to SP1.3 (ECC general comment) above and Paragraph 6.48.
As explained, ECC would anticipate the inclusion and promotion of sustainable modes of travel to support the community (both residents and businesses) to be embedded in the emerging strategy in conjunction with other options, to support employment and to deliver the wider principles in the emerging vision and spatial strategy, in accordance with the Essex LTP, Economic Plan for Essex and the A127 Corridor for Growth An Economic Plan. Please also refer to ECC comments regarding Highway Infrastructure in section 8.

SP1.8 Need for Jobs;

Paragraph ECC notes that the emerging Local Plan seeks to facilitate a diverse,
6.105 modernised economy providing high value employment. This aspiration is supported. Paragraph 6.105 states that the Economic Development Needs Topic Paper 2017 advocates employment land increases to primarily facilitate B1 and B2 uses. Again, this is not objected to but it is important that any strategy seeking to grow the economy does not preclude opportunities for waste management, with such facilities often being sited on industrial / employment land. As explained in response to paragraph 6.92 & 6.96 above regarding waste management developments as employers in their own right ECC recommends that reference is made to supporting appropriate 'sui generis' uses when defining appropriate use classes on employment land.

Paragraph 6.111 Options to support economic growth in the district over the next 20 years:

A. Develop specific policies for each employment site to protect certain uses
B. Reconsider the allocation of Rawreth and Star Lane industrial estates back to employment
C. Review new employment land allocations that do not have planning permission
D. Retain current strategy and allocate additional employment land
E. Promote improvements to quality of building stock and intensification of existing sites
F. Strengthen policy stance on access improvements
G. Do not have a policy on employment land

ECC Comments

ECC does not consider these options to be mutually exclusive and would expect RDC to develop a policy based on evidence and in accordance with the NPPF and the National Planning Policy for Waste 2014 (NPPW).

ECC would expect all of the options A-F to contribute to RDC meeting its need for economic growth, taking into account ECC's comments in respect of Paragraph 6.96 above to support employment and economic growth in the district. ). ECC would expect a Rochford Employment Land Review to be prepared and for the following evidence to be taken into account -, the South Essex Economic Development Needs Assessment; the Governments Industrial Strategy, SELEPs Economic Plan, OSE economic objectives, Thames Estuary Commission, the Economic Plan for Essex and ASELA's emerging South Essex 2050 vision and emerging industrial strategy workstream and JSP.

provide an effective multi modal interchange for the Airport, with improved connectivity and realistic sustainable travel option for all users.

Paragraph 6.114 ECC supports the development of the Airport business park and the associated highway and cycling network improvements

Paragraph 6.115 ECC acknowledges the need for investment in the highway / transport network around London Southend Airport and will continue to seek funding through bids to Central Government, SELEP and S106 contributions.
ECC considers there to be a need to promote and encourage a package of sustainable travel options, for residents and businesses to travel sustainably, with the highway improvements referred to also including improvements to bus journey times and bus priority measures, to promote sustainable travel (including buses) as a realistic sustainable travel option. Further contributions through a combination of s106 and S278 and CIL funding should be secured through appropriate new developments to address the sustainable travel agenda when opportunities arise.
Paragraph 6.116 ECC acknowledges and supports the need for transportation improvements to the A127 to facilitate growth within the District and South Essex; and recommend that reference is made to the joint ECC and Southend on Sea BC A127 Route management Strategy entitled A127 Corridor for Growth - An Economic Plan 2014

Paragraph 6.117 Options in relation to London Southend Airport:
A. Retain and update the Core Strategy policy supporting London Southend Airport's growth
B. Retain the existing policy in the Allocations Plan
C. Retain the existing policies in the JAAP
D. Continue to support surface access improvements in and around London Southend Airport

ECC Comments

ECC does not consider these options to be mutually exclusive. ECC would expect RDC to develop a combination of options based on evidence and in accordance with the NPPF.

ECC recommends that RDC should consider and clarify the "in principle" inter-relationship and compatibility between the JAAP and the new emerging Local Plan. For example, is the intention to incorporate the provisions of the JAAP within the new Local Plan, or will the JAAP continue to be a separate standalone document, subject to its own review?

In respect of Option D, ECC considers that the JAAP clearly sets out the associated access improvements for London Southend Airport, and that this would be appropriate option to address the passenger transport and sustainable travel options, as part of an integrated travel solution. ECC considers there to be a need to actively promote and improve passenger transport provision and connectivity, rather than solely relying on highway improvements to provide benefits for passenger transport, as any additional highway capacity may be absorbed by continual increases in demand by motorists, in the absence of realistic alternative travel options.

SP1.10 Supporting Tourism and Rural Diversification

Paragraph 6.121 ECC notes the comments regarding the lack of rural passenger transport services. However, it is of concern that the emphasis for the solution is solely placed on improvements to roads and the cycling network. In order for RDC to improve accessibility to the rural parts of the District, whether for tourism, employment or other reasons, it is considered that the most effective and viable approach would be the development of a District transportation strategy. This would have the benefit of setting out aspirational networks for all sustainable travel options including walking, cycling and passenger transport. There are a range of options that could be considered from traditional timetabled services to demand responsive operation or a combination of services to optimise technology. ECC would wish to engage with RDC to explore the options, which could be of particular value and support for tourism and rural diversification.

ECC considers investment to improve and create new Green Infrastructure such as woodlands, nature reserves and greening town centres would be appropriate and would benefit tourism, through attracting new visitors, and support retail and tourism sectors.

ECC considers transport and accessibility to be vitally important for tourism and investing in the Green infrastructure would provide opportunities to encourage alternative modes such as walking and cycling. This would improve accessibility to green spaces, whether by the distance from home and businesses; or by the creation of green links/greenways including enhancements to the existing Public Rights of Way network (including cycleways). Thus providing alternative traffic free cycling and walking routes, as well as wildlife corridors.

ECC considers that this would need to be developed in partnership with stakeholders including ECC and public transport providers to improve the accessibility of green spaces, to be as easy as possible. ECC would welcome the opportunity to explore this further, as outlined in ECC's response to SO6 above, regarding the proximity of new developments to green space.

Paragraph 6.127 Please amend the reference to "Ultrafast broadband" for the reasons set out in response to Section 6 and paragraphs 6.94, 6.96 and 6.127.

Paragraph 6.128 Options for tourism and rural diversification:

A. Continue to support current defined forms of green tourism and rural diversification as set out in our current policies
B. Expand the current approach to include other forms of rural diversification
C. Do not support rural diversification

ECC Comments

ECC does not consider options A and B to be mutually exclusive. ECC would expect RDC to develop a combination of the options based on evidence and in accordance with the NPPF, and to evolve as part of the overarching economic growth strategy (see paragraphs 6.96 and 6.116 above).

In respect of Option B (rural diversification) ECC supports this option in principle (subject to evidence) to provide an opportunity to retain employment in the first instance which may then lead to creation of new jobs. ECC recommends that the following factors are further explored:

 Accessibility Issues - there is potential to expand the current policy approach to address accessibility issues raised by ECC (paragraph 6.121). ECC recommends further investigation is required in respect of the wider passenger transport improvements to support access to tourism and rural areas, tourism. It is considered that this could include a range from timetables to the "on demand" bus services, as realistic alternatives; which goes beyond improvements to roads and cycle networks.
 Tourism and consideration of the potential benefits of the England Coast Path, and opportunities for tourism and rural diversification including for temporary camp sites if for example there is an increase in events specifically using the coast such as Maldon District's Council annual Saltmarsh 75 event.
 Potential provision for waste management facilities suited to the rural environment (such as anaerobic digestion or composting), as part of rural diversification in accordance with NPPW

ECC recognise that Policy GB2 in the Core Strategy and Policies DM12 and DM13 in the Development Management Plan do not act to constrain the rural diversification opportunities highlighted above and a continuation of this stance may be appropriate, based on evidence.

ECC does not support Option C for the reasons stated within the justification, it is considered contrary to the NPPF (and the emerging vision and objectives for the draft Local Plan.
SUPPORTING COMMERCIAL DEVELOPMENT (SECTION 7)

SP2.1 Retail, Leisure and Town Centres

Paragraphs 7.12 In respect of the Retail and Leisure Study update 2014, ECC
and 7.17 notes the reference to "catering needs" and recommend that this should also include "A5" fast foot outlets, to avoid clustering and high concentrations of A5 premises within the district. ECC strongly recommends that RDC review the existence and pattern of A5 premises, which can be undertaken using the FEAT tool (http://www.feat-tool.org.uk/), which is a fast food tool which provides details on fast food outlets for districts including A5, fast food retailers. ECC Public Health is aware of the emerging evidence base on high energy foods and obesity, including recent publications from Public Health England for spatial planners on fast food restrictions. ECC Public Health would welcome the opportunity to provide advice and to work with RDC on this matter.

Paragraph 7.20 Options for the district's town centres:
A. Retain current Core Strategy policies
B. Retain current policies in the Rayleigh Centre Area Action Plan
C. Retain current policies in the Rochford Town Centre Area Action Plan
D. Retain current policies in the Hockley Area Action Plan
E. Review the town centre Area Action Plans
F. Do not have policies on town centres

ECC does not consider these options to be mutually exclusive. ECC would expect RDC to develop a combination of options based on evidence and in accordance with the NPPF.

As set out in response to paragraph 6.117 in respect of the JAAP, ECC recommends that RDC should consider and clarify the "in principle" inter-relationship and compatibility between these Area Action Plans and new emerging Local Plan. For example, is the intention to incorporate these Area Action Plans into the new Local Plan, or will they be separate standalone Area Action Plans subject to their own reviews?
DELIVERING INFRASTRUCTURE (SECTION 8)

SP3.1Highways Infrastructure

Paragraph 8.17 ECC welcomes and supports the references and importance given to the Essex and Southend "A127 A Corridor for Growth - An Economic Plan (2014)" and the need for investment in the highway and transportation network, in accordance with the Essex LTP. ECC will continue to seek funding through bids from central Government, SELEP and S106 contributions as appropriate (CIL?) (as stated in 6.111 above).

ECC can advise that work is progressing on the next phase of the A127 Route Management Strategy, with the Options Appraisal and Strategy Report, in conjunction with the South Essex authorities, the London Borough of Havering, Transport for London and Highways England, to promote the importance of the A127 to facilitate growth across the area. In respect of improvements to the strategic transport network, ECC can confirm that the 'short term' funded transport scheme for the A127/A130 Fairglen Interchange is planned for implementation by 2022/23. ECC is also preparing a Joint A13 Route Management Strategy with Southend on Sea BC and Thurrock BC Highway Authorities.

In moving forward it is considered that RDC's approach to the Highways and Transportation will need to take into account the ASELA South Essex 2050 vision and emerging Infrastructure workstreams and the JSP.

Paragraph 8.18 ECC welcomes the reference to work with ECC as the Highways Authority and neighbouring authorities to promote strategic and more localised improvements to the highways network. ECC will continue to work with RDC on an ongoing basis to ensure these strategic matters are addressed collectively within the respective emerging Local Plans and a wider South Essex Joint Strategic Plan.

Paragraph 8.20 Options for the Local Highway Network:

A. Retain current policies on the local highway network
B. Prioritise local highways and junctions between Rayleigh, Hockley and Rochford (B1013), to support and direct funds to improve the local highway network
C. Prioritise local highways and junctions by upgrading the east to west connection north of Rayleigh, Hockley and Rochford, to support and direct funds to improve the local highway network
D. Do not have a specific policy on the local highway network

ECC Comments

ECC does not consider these options to be mutually exclusive. ECC would expect RDC to develop a combination of options in consultation with ECC as highway and transport authority, based on evidence (including transport modelling) and in accordance with the NPPF.

ECC would anticipate the strategy for the local highways network to be a combined approach as part of an integrated package of transport solutions (including sustainable travel options) and for this to be embedded within the Local Plans' spatial strategy.

As stated in response to SP1.3 and paragraphs 6.46 and 6.113 above, ECC considers greater emphasis should be placed on an integrated transport solution, in accordance with the Essex LTP to move away from the traditional reliance on road improvements, which is only part of the solution. For example, the inclusion and promotion of sustainable modes of travel (in addition to the outcomes of the transport modelling work) would support the community (both residents and businesses) in respect of transport and travel through the main towns and improve rural transport options. There is a need to ensure the appropriate approaches for the local highway network also take into account the requirements and inter-relationship with the wider local and Strategic networks as well as cross boundary issues / impacts.

Strategic Highways Network Transport

Paragraph 8.21 ECC welcome the reference for RDC to work with ECC and Southend BC (as the Highways Authorities) in the development of a transport model for the length of the A127, however please refer to ECC's update on the A127 Route Management Strategy in paragraph 8.17 above.

ECC can advise that the A127 comprises three highway authorities (Southend on Sea, ECC and the London Borough of Havering (LBH)), as such the A127 Route Management Strategy is being extended to incorporate the LBH. Furthermore LBH and the seven south Essex authorities (including ECC) have signed a Statement of Common Ground in respect of the importance of the A127 to facilitate growth.
ECC is engaging with the South Essex authorities in respect of a potential South Essex transport model which would be consistent with ECC's aspirations for an Essex wide model, drawing on the modelling work to date. This will however need to take into account the Highways England modelling information, including for example the Lower Thames Crossing.

ECC can also advise that Highways England would wish to be engaged in emerging Local Plans, to ensure any potential "ripple effect" of development is considered in respect of their transport network, for example the M25, A12 and sections of the A13 within South Essex.

Paragraph 8.21 Options identified for the strategic highway network:
A. Support improvements to the strategic highway network
B. Do not have a specific policy on the strategic highway network

ECC Comments
ECC would expect RDC to prepare a policy approach to the strategic highway network in consultation with ECC as highway and transport authority, based on evidence (including transport modelling) and in accordance with the NPPF.
In respect of Option A, ECC would anticipate the policy for the strategic highways network to be a combined approach as part of an integrated package of transport solutions (including sustainable travel options) and moving away from the traditional reliance on road improvements, which is only part of the solution. This would be in accordance with the Essex Local Transport Plan, and the A127 and emerging A13 Route Management Strategies as set out in response to paragraphs 8.17-21 above, and in response to SP1.3, paragraphs 6.46 and 6.111.
ECC does not support Option B for the reasons stated within the justification; it is considered contrary to the NPPF, the Essex LTP and A127 Route Management Strategy and the emerging vision and strategic objectives in the draft Local Plan.

SP3.2 Sustainable Travel

Paragraph 8.22 ECC welcome the desire for a modal shift towards more sustainable ways to travel, given that car use is the dominant mode of transport. ECC recommends there to be a need to change the modal shift in the short term, with greater emphasis placed on promoting alternative travel options (walking, cycling, passenger and public transport) and given greater weight in the Local Plan, to ensure these facilities are planned in now, to enable the options and benefits to be realised during the plan period. Greater emphasis is required on an integrated transport solution, and moving away from the traditional reliance on road improvements, which is only part of the solution.

Paragraph 8.22 ECC notes the reference to the Rayleigh Town Centre AQMA, however recommend this should be expanded to include reference to the National Air Quality Plan published by DEFRA in July 2017 which designates a site on the A127 to the east of Rayleigh Weir.

Paragraph 8.24 ECC welcomes the reference to Public Transport and recognition of the importance and connectivity to the rural areas and cross boundary connections, however there is a need to recognise that Public Transport is of value to everyone (all residents and employers) and not solely to residents who do not have access to private vehicles. There is a need for a change in emphasis, with the principles of alternative sustainable travel and accessibility (including passenger transport) to be embedded within the Local Plans' emerging spatial strategy to deliver the "vision" for the district and modal shift in transport. ECC recommends that RDC actively engages and works with the local transport operators in the District as well as ECC to develop services.

For example, there is the opportunity to explore innovative ways to deliver a more demand led public transport service to broaden accessibility away from the scheduled bus service. It could bring improved frequencies and less complex journeys by being able to be more responsive to demand for specific journeys, and provide quicker interchanges between modes. How this is supported could be explored within the context of paragraph 8.30, and may have potential to form part of the solution to air quality issues identified in paragraph 8.31.

Paragraph 8.27 ECC recommend that reference is made to the Rochford Cycling Action Plan 2018; prepared by Essex Highways and further information on the Essex Cycling Strategies is available here:
http://www.essexhighways.org/getting-around/cycling/cycle-programme.aspx.
Please note for consistency of terminology the references to "Cycle "Storage" within this paragraph should be change to "Cycle "Parking".

Paragraph 8.28 For clarity, ECC recommends that greater references should be made to "cycling" and "cycling networks", to help distinguish the nature of the routes being referred to, for example by inserting "cycle" before "routes to link homes" within this paragraph.

Paragraphs ECC welcomes the reference to the positive role of "Green Infrastructure"
8.27, 8.28 within this section which highlights the high dependency on cars, and that
and 8.32 other sustainable modes of travel should be encouraged.

In respect of the approach to car use, consideration should be given to the provision for charging points for electric cars (see also comments under Renewable Energy Generation). Further consideration is required on the practicality of long term public transport provision with the likely changes in car ownership patterns in 20 years' time, arising from the Government's commitment to ban the sale of new diesel and petrol vehicles from 2040 and responses from the car industry and possible growth in the use of electric vehicles, be it hybrid or pure electric vehicles, with sales projected to increase to around 10% of new vehicles by 2025. The industry anticipate the share of Electric Vehicles will continue to rise and that by 2025 Electric Vehicles will be more affordable than internal combustion vehicles, even without Government subsidies.

The need for and provision of Electric Vehicle charging points should be explored further and ECC's Environment team wish to engage with RDC on this matter, including sharing examples of good practice in emerging and new Local Plans.
Paragraph 8.30 ECC would welcome the opportunity to work closely with RDC on the development and implementation of Travel Plans for all new developments, or extensions to existing businesses, or where the development will have a significant impact on the highway. The ECC Sustainable Travel team would welcome the opportunity to explore this further with RDC and recommend reference is made to ECC's Passenger Transport Strategy - Getting Around In Essex 2015.

Paragraph 8.33 ECC would welcome the opportunity to work with RDC to explore the issues raised (bullet points 1-6) in relation to sustainable travel choices for communities across the district, which could be addressed through the Local Plan. Further consideration is required regarding the role and importance of realistic sustainable travel options to support the growth in the District.

Key issues ECC would like to explore further with RDC include:

Fifth bullet point - ECC considers the proposal to re-route the bus services away from Marked Square in Rochford Town Centre to be unsound. The removal of buses from this key location would be contrary to the principles of sustainable and accessible communities, and the strategic objectives in the Local Plan including the need for a modal shift in transport towards realistic and sustainable travel options for all. For example; if buses could not serve this area then residents would be encouraged to travel by car, adding further traffic to the already congested road network.

Sixth & Seventh bullet point - Further clarification is required on the nature of the issues.

Paragraph 8.34 ECC supports the proposal for setting a more challenging mode share; and would wish to work with RDC to explore and develop these issues and opportunities further within the context of the emerging new Local Plan.

Paragraph 8.35 ECC welcomes the opportunity to work with RDC and partners to explore and help shape new and improved passenger transport options across the District, as part of ongoing "duty to co-operate" engagement in the preparation of the Local Plan.

Paragraph 8.36 ECC consider the reference to SERT, which concerns bus services to be unclear within this paragraph on cycling.

Paragraph 8.37 Options identified to support Sustainable Travel
A. Retain the current policy on public transport
B. Support the development of a rapid public transit system for South Essex
C. Retain the current policy on travel plans
D Lower the threshold to require travel plans to be prepared for schemes under 50 homes
E. Retain the current policy on walking and cycling
F. Do not have policies on sustainable travel

ECC Comments

ECC would expect RDC to develop a combination of options A-E, in consultation with ECC as highway and transport authority, based on evidence and in accordance with the NPPF.

ECC would anticipate the approach to support sustainable travel to be a combination of options, as part of an all-encompassing, integrated package of transport solutions (including highway network improvements) and for this to be embedded within the Local Plans.

ECC recommend RDC has regard to NPPF (section 4 Promoting Sustainable Transport and section 8 Promoting Healthy Communities), the Essex Local Transport Plan, the A127 and emerging A13 Route Management Strategies, ECC's Sustainable Travel Strategy, and evidence (including transport modelling the Cycle Action Plan and South Essex Active Travel programme), and ECC's Passenger Transport Strategy - Getting Around in Essex (2015).

In respect of Option A, ECC considers this to have the potential for greatest advantages to prepare the District for its future transportation needs, including the potential for a more demand- led model, to work alongside scheduled bus and rail services. ECC would anticipate the need to consider this as part of a wider cross boundary engagement, with neighbouring authorities, ECC and transport providers. ECC would welcome the opportunity to engage with RDC on this matter.
In respect of Option D, ECC recommend that the threshold for travel plans is considered further to take into account the thresholds within EPOA Guidance for Health Impact Assessments 2008; where active and sustainable travel is already considered. ECC is currently reviewing the EPOA Guidance for Health Impact Assessments, to ensure it is up to date and relevant. ECC would welcome the opportunity to work with RDC on the development of this aspect within the Local Plan.

In respect of Option E, ECC considers the current approach in policy T6 positively encourages people to travel sustainably.

ECC does not support Option F for the reasons stated in the Justification, it is considered contrary to national policy, the Essex Local Transport Plan, and ECC Passenger Transport Strategy and the emerging vision and strategic objectives of the draft Local Plan.

SP3.3 Communications Infrastructure,

Paragraph 8.43 ECC recommends that reference is made to the BT Openreach policy of providing FTTP connections to any new development of houses over 30 properties, free of charge to the developer. Further information is available on the BT Open reach web link: https://www.ournetwork.openreach.co.uk/property-developers/site-registration.aspx

This provides the framework for implementation of superfast broadband within new residential developments

Paragraph 8.44 Options identified for communications infrastructure:
A. Retain the existing policy on telecommunications infrastructure
B. Amend the existing policy to include specific reference to improving broadband and mobile coverage
C. Ensure that all commercial and residential developments over a certain threshold are conditioned to deliver appropriate broadband infrastructure
D. Do not have a policy on telecommunications infrastructure

ECC Comments
ECC would expect RDC to develop a combination of options A-C based on evidence and in accordance with the NPPF. ECC would anticipate the strategy for the communication infrastructure to be a combined approach embedded within the Local Plan.

As set out in response to Section 6, paragraphs 6.94, 6.96 and 6.127, ECC recommend all references to the provision of and requirements for future broadband are pre-fixed by "Ultrafast". ECC acknowledge the current rollout programme is "Superfast Broadband", however it is recommended that the draft new Local Plan should refer to "Ultrafast Broadband" to reflect the Government's next roll out initiative, thereby provide longevity in the draft Local Plan and to distinguish the standards for new provision from the "standard broadband" which is not fast enough.

ECC also recommends that reference is made to the BT Openreach policy of providing FTTP connections to any new development of houses over 30 units, free of charge to the developer. Further information is available on the BT Open reach web link: https://www.ournetwork.openreach.co.uk/property-developers/site-registration.aspx
This provides the framework for implementation of superfast broadband within new residential developments.

In respect of Option B, ECC considers this to be a positive approach to develop infrastructure resilience to support the growth ambitions within RDC. ECC recommends that the needs of both residents and businesses are incorporated within the policy requirements for good communication infrastructure provision.

ECC would welcome the opportunity to work with RDC to ensure the latest policies; guidance and evidence are taken into account to inform the principles, strategies and policies and site allocations within the emerging Local Plan.

ECC does not support Option D for the reasons stated in the justification, and considers it to be contrary to the NPPF (paragraphs 42-43) and the emerging vision and strategic objectives of the Local Plan, for example SO9.

SP3.4 Water and Flood Management,

Paragraph 8.45 ECC wish to draw RDC's attention to the requirements of NPPF paragraph 100, which requires development in areas at risk from all forms of flooding should be avoided and not just fluvial and coastal flooding. This is in line with national guidance which states:

In plan-making, local planning authorities apply a sequential approach to site selection so that development is, as far as reasonably possible, located where the risk of flooding (from all sources) is lowest, taking account of climate change and the vulnerability of future uses to flood risk. (Paragraph: 001 Reference ID: 7-001-20140306 https://www.gov.uk/guidance/flood-risk-and-coastal-change)
ECC notes that the South Essex Strategic Flood Risk Assessment 2011 is in the process of being updated given the changes to the Environment Agency (EA) climate change allowance.

ECC also recommends that the following guidance and evidence
published since 2011, should be taken into account in the preparation of
the Local Plan:
 EA - Risk of Flooding from Surface Water (RoFSW) maps;
 ECC Sustainable Urban Drainage Design Guide 2016
 ECC Essex SUDS Design Guide 2016;
 South Essex Surface Water Management Plan (2012 and emerging
revision due 2018);
 ECC Developers' Guide to Infrastructure Contributions (2016)

ECC also advises that the following Assessments and Strategies are
currently being updated and once complete should also be taken into
account as part of the Local Plan and Sustainability Appraisals evidence
base:
 The Preliminary Flood Risk Assessment for Essex; and
 The Essex Flood Risk Management Strategy
ECC would welcome the opportunity to work with RDC to ensure the latest
policies; guidance and evidence are taken into account to inform the
principles, strategies and policies and site allocations within the emerging
Local Plan.

Paragraph 8.46 & 8.48 Whilst the preferred intent of management in the Shoreline
Management Plan might be to maintain or upgrade defences along the
coast, there is no guarantee that funding will be available to deliver these
preferred policies. It is therefore appropriate that RDC seeks to secure
funding from development or other sources to potentially allow a funding
contribution towards any coast flood or erosion schemes especially given
the new approach of 'partnership funding' which now applies.

Paragraph 8.47 ECC welcome the positive consideration and approach to locate
& 8.48 development, within the lower flood risk areas, whilst taking into account
climate change, the vulnerability of future uses to flood risk and the impact
on water supply from a changing climate.

Paragraph 8.49 ECC can advise that the South Essex Surface Water Management Plan (2012) is being updated and this includes revisions to the Critical
Drainage Areas. The review is scheduled to be completed in 2018 and
ECC would welcome the opportunity to work with RDC and to provide this
additional information to inform preparation of the Local Plan, in particular
the emerging spatial strategy and the assessment of site allocations.

Paragraph 8.50 In respect of the reference to below and above ground SUDS features,
ECC's requires priority to be given to the provision of above ground
SUDS features (with the exception of soakaways) and that below ground
SUDS features should only be considered acceptable, if it is
demonstrated that above ground SUDS features are not viable. In all
cases ECC would require any features to provide acceptable levels of
water quality treatment/ storage requirements

Paragraph 8.50 & 8.51 ECC welcomes and supports the use of SUDS to alleviate flooding and that it should be incorporated in to new developments, domestic and
commercial. SUDS can provide great opportunity to improve our
environment and, linked with Green Infrastructure, could create a more
balanced and natural ecology in our communities. SUDS can help meet
the growing demands to deliver GI by creating green open spaces which
encourage biodiversity, habitats, wildlife corridors and health and
wellbeing.

Paragraph 8.51 ECC recommend that the emphasis of the statements within this
paragraph are changed, to encourage SUDS on all new developments,
including minor developments, and should not be limited to the major
developments which are subject to statutory consultation with ECC as the
LLFA.

ECC recommend that the last sentence in this paragraph should be
changed to reflect the overall requirements and application of SUDS
design principles, to read as follows:

"In some instances, financial contributions could be sought to improve
surface water drainage infrastructure through a standard CIL charge for
example (considered in detail below)."

Further information is available within the ECC Sustainable Drainage
Systems Design Guide (2016) and ECC will work with RDC on this matter
in the preparation of the Local Plan.

Paragraph 8.53 ECC welcome the positive consideration and approach to locate
development, within the lower flood risk areas, whilst taking into account
climate change, the vulnerability of future uses to flood risk and the impact
on water supply from a changing climate.
ECC recommend that reference is made to the Environment Agency's
revised climate change allowances, further details are available here:
https://www.gov.uk/guidance/flood-risk-assessments-climate-changeallowances

Paragraph 8.56 ECC recommends that new developments should be supported by
infiltration and groundwater testing. Further details are set out within the
ECC Sustainable Drainage Systems Design Guide (2016).

Paragraph 8.58 Options identified to minimise flood risk:
A. Retain the existing flood risk policy for coastal flooding
B. Revise Core Strategy policy ENV3
C. Continue to apply SUDS policies
D. Do not have a policy on flood risk

ECC Comments

ECC would expect RDC to develop a combination of options A-C based on evidence and in accordance with national policy including the NPPF.

ECC will engage with RDC on an ongoing basis in the preparation of the Local Plan to ensure it is based on the most up to date Guidance and evidence including the ECC SUDS guide, the revised South Essex Surface Water Management Plan, as well as the latest EA climate change allowances.
ECC does not support Option D for the reasons stated in the justification, it is considered contrary to national policy (including paragraphs 99-108).

SP3.5 Renewable Energy Generation

Paragraph 8.62 ECC note and support the reference to the Rayleigh Town Centre Air Quality Action Plan (AQAP) in respect of the need to explore different measures including for example provision for electric vehicles (Electric Charging Points).

Paragraph 8.64 & 8.65 ECC welcome the recognition of the need for charging points in urban centre car parks. ECC is currently preparing a strategy for Electric Vehicles and would welcome the opportunity to work with RDC, including on the need for new policies to promote the provision of Electric Charging Points for new domestic and commercial developments (see paragraphs 8.22-8.37 above). This is required to support the need for this new infrastructure with a variety of Electric Charging Points required to meet the anticipated grown in Electric Vehicles, which could not be solely met by urban car parks.

Paragraph 8.66 Options identified to support renewable energy provision within the district:
A. Retain the current policies on renewable energy
B. Include a specific policy on electric vehicle charging points
C. Do not have a policy on renewable energy

ECC Comments

ECC does not consider these options to be mutually exclusive and would expect
RDC develop a combination options A & B based on evidence and in accordance with the NPPF and other national policy.

In respect of Options A and B, ECC would support a review of the current policies and amendments to ensure they are in accordance with the most up to date evidence (including developments in technology) and national policy and guidance.

ECC consider the policy should be amended to include the provision for Electric Vehicles Charging Points. ECC would welcome the opportunity to explore these requirements further with RDC in the preparation of the local plan, including the policies and infrastructure requirements for the provision of Electric Charging Points, and consideration given to engaging the key stakeholders.

ECC does not support Option C for the reasons stated in the justification, it is considered contrary to national policy and the Essex Local Transport Plan, supporting evidence and the emerging vision for the Local Plan.

SP3.6 Planning Obligations and Standard Charges;

Paragraph 8.73 ECC welcome the reference to and identification of the issues raised in respect of the delivery of infrastructure provision associated with a large number of small sites, as set out in ECC's earlier comments in response to paragraph 6.48 (options to provide a realistic strategy for delivering homes).

ECC a statutory authority responsible for the provision of specific infrastructure in support of communities and the preparation of Local Plans, would wish to engage with RDC on an ongoing basis in the preparation of the Local Plan and Spatial Strategy, especially as the Local Plan progresses to consider specific sites and spatial strategy. ECC can also provide details of our policies, strategies, guidance and standards in respect of the delivery of specific infrastructure and the respective levels of growth required, for example:
 the ECC Developers' Guide to Infrastructure Contributions (2016); and
 the Essex County Council Local and Neighbourhood Planners' Guide to School Organisation (2018).

Please be advised that the latter Guide includes changes and updates to ECC's policy for the minimum size and land requirements for new primary and secondary school provision, please also refer to Section 8 below.

ECC can confirm that the issues do arise and that, subject to the scale of development, small schemes may not bring the level of investment required. In essence this reflects the "critical mass" in the scale of development required to enable effective infrastructure and service planning, which it may not be possible to secure with a number of smaller developments given the effect of the CIL Regs (Regulation 123) and restrictions on the pooling of contributions.

Paragraph 8.75 Options for planning obligations and standard charges:
A. Retain the existing policy and provisions in current local plan policy
B. Do not have a policy on planning obligations and standard charges

ECC Comments

ECC would expect RDC to prepare a policy for planning and obligations and standard charge, based on evidence and in accordance with the NPPF.

ECC considers there to be a requirement to retain an appropriate and up to date policy for securing the necessary Planning Obligations and Standard Charges in accordance with the NPPF, the Planning Practice Guidance, the forthcoming changes in national policy on this matter, and the ECC Developers' Guide to Infrastructure Contributions and the recommended 'Infrastructure delivery and impact mitigation' policy set out in Appendix B to the Essex County Council Local and Neighbourhood Planners' Guide to School Organisation (2018). With reference to ECC comments in response to paragraph 6.48 and 8.74 above, the principle of "pooling" restrictions and applying standard charges to smaller sites is not sufficient to meet the substantial levels of investment required to enable the provision of the appropriate infrastructure.

ECC therefore recommends that RDC's existing planning t policy is amended to take into account the latest material considerations and that RDC uses the best practice policy for "Infrastructure delivery and impact mitigation policy' (referred to above) to deal with pooled contributions, and to list any on-site facilities (new schools or extra land to expand existing schools) within the individual housing allocation policies. It is necessary to separately designate land to be allocated for Education use as D1 use class. This is considered necessary to avoid residential hope value being attributed to school land as part of any development viability assessment.

ECC recommends that the use of the best practice policy approach, referred to above is applied to the provision of other specific infrastructure, as outlined in ECC Developers' Guide to Infrastructure Contributions (2016).

ECC would welcome the opportunity to work with RDC on an ongoing basis to develop an effective approach through the preparation of the Local Plan.

SUPPORTING HEALTH, COMMUNITY AND CULTURE (SECTION 9)

SP4.1 Health and Well-being;

ECC welcomes and strongly supports the approach taken by RDC regarding health within this section. ECC considers the approach to be very positive towards Public Health and the wider issues of health have been considered and the promotion of Public Health with reference to the NPPF. ECC would welcome the opportunity to work with RDC in the development of this policy in conjunction with their planning and Health and Wellbeing team; and can provide advice on a range of supporting evidence and good practice available to inform the preparation of the local plan. This includes:
 FEAT tool (http://www.feat-tool.org.uk/), which allows authorities identify the various types of food retailers within their districts, including A5, fast food retailers.
 RTPI dementia friendly practice guidance- http://www.rtpi.org.uk/knowledge/practice/dementia-and-town-planning/
 Sports England Active Design- https://www.sportengland.org/media/3426/spe003-active-design-published-october-2015-email-2.pdf
 Public Health England - Health profiles- https://fingertips.phe.org.uk/profile/health-profiles
Paragraph 9.11 Options to promote health and wellbeing:
A. Retain the existing policy in current local plan policy
B. Ensure that land is specifically for healthcare
C. No policy on healthcare needs
D. Build on the existing healthcare policy to address wider health and well-being issues

ECC Comments

ECC would expect RDC to develop a combination of options based on evidence and in accordance with the NPPF.

ECC as a lead advisor for Public Health will engage with RDC on an ongoing basis in the preparation of the Local Plan and Spatial Strategy, especially as the Local Plan progresses to consider specific sites and spatial strategy. ECC can also provide details of its policies, strategies, guidance and standards in respect of the delivery of specific infrastructure and the respective levels of growth required.

In respect of Option D, ECC is supportive of this approach to refresh and build upon the existing health and wellbeing policy and ECC Public Health would welcome the opportunity to work with RDC in the development of this policy in conjunction with their planning and Health and Wellbeing teams.

ECC considers this approach should include greater recognition of the role of the natural environment and Green Infrastructure within the communities' health and wellbeing, including opportunities in preventing and treating ill health, as well as promoting wellness, including greater access and use of green space

ECC does not support Option C, for the reasons stated within the justification, it is considered contrary to national policy, the emerging vision for the Local Plan, ECC's vision for Essex and the revised EDG.

SP4.2 Community Facilities;

Paragraph 9.15 Options for Community Facilities:
A. Retain the existing policy in current local plan policy
B. Strengthen provisions in the existing policy
C. No policy on community facilities

ECC would expect RDC to prepare a policy option based on evidence and in accordance with the NPPF.

ECC would anticipate the provision of a range of community infrastructure in support of Local Plans, would wish to engage with RDC on an ongoing basis in the preparation of the Local Plan and Spatial Strategy, especially as the Local Plan progresses to consider specific sites and spatial strategy. Further details are set out in Section 2B above and in response to Section 4 of the Issues and Options Report.
In terms of future provision, opportunities for the co-location of services and maximising the use of existing buildings will be encouraged, to respond to the increasingly integrated models of service provision and provision for multi-purpose facilities. There is increasing emphasis on the integration of other form of community infrastructure, such as libraries and community spaces.

New provision is therefore likely to be in the form of a co-located community hub/library. This will be dependent on the level of population growth and the demographic of that population, along with the service requirements of future library provision. It is therefore likely that new provision could be made at some of the larger growth locations, particularly if there is a need for other community facilities, e.g. health centres, community halls etc. However, at this stage it is not possible to identify specific needs or costs of provision. It is not possible to identify specific needs or costs at this stage. Co-location may be something that should be encouraged but this would be more of a policy focus, possibly through a masterplanning approach, for the new development.

Funding will need to come from developer contributions and will be delivered through the masterplanning of new development sites.

ECC does not support Option C for the reasons stated in the justification, it is considered contrary to national policy, the emerging vision and objectives of the draft local plan and would not enable the necessary infrastructure to be appropriately planned for and delivered to meet the needs of the local community (residents and businesses).

SP4.3 Education and Skills;

ECC note the scope of Strategic Priority 4.3 (this section) mainly concerns Educational facilities; however there is no acknowledgement of or reference to the provision and requirements for Special Education Needs, either within schools or the wider community. ECC recommends that this is addressed, to consider and demonstrate the needs of the residents and the contribution that it can make. ECC welcome the opportunity to work with RDC to explore this further and can provide additional information on ECC's policies, strategies and evidence in respect of the requirements for this service, to be taken into account in the preparation of the Local Plan.

Paragraph 9.17 ECC welcomes the references within this paragraph, however the reference to "Nursery Education" should be changed to "EYCC provision" and this change should be incorporated throughout the document. Equally the reference to the need to ensure that there is sufficient capacity within "schools" should be amended to specifically refer to "EYCC provision" in addition to schools

Paragraph 9.22 & 9.27 ECC advises that the Essex Employment and Skills Board (ESB), through its 2017-18 Evidence Base, has identified seven priority sectors for Greater Essex including: construction, logistics, advanced manufacturing and engineering, IT/digital, healthcare and finance and insurance. To address shortages in these areas the ESB works in partnership with skills training providers, employers and other partners to offer an Education and Industry, Science, Technology, Engineering and Maths programme, to all secondary schools. These taster day opportunities, open to the District's schools would complement the District's Career Taster Days and continue to promote apprenticeships and access to skills and training. ECC welcomes the opportunity to explore this further with RDC in the preparation of the Local Plan.

Paragraph 9.23 ECC would like to advise RDC that it is in the process of updating the referenced ECC Developers' Guide to Infrastructure Contributions (2016), to include planning obligations and standard charges for contributions to support the full range of post-16 provision, where need is sufficiently evidenced. This is as a result of students 16-18 being required to stay in some form of education or training. This would support workforces, support apprenticeships and work with local colleges to address identified skills gaps. This also reflects ECC's overarching Lifelong Learning Strategy 2014 - 2018 and supporting strategies

Paragraph 9.26 ECC requests that the references to the scale of residential development that would generate the need for a viable new school are updated, to reflect section 2.2 of the recently published Essex County Council Local and Neighbourhood Planners' Guide to School Organisation (the Planners Guide) i.e. circa 1,400 houses for a 2 form entry primary school and 4,500 houses for a 6 form entry secondary school.

ECC's School Organisation Team welcomes the opportunity to assist in the preparation of the Local Plan and the next stage will be for ECC to 'scenario test' the preferred option to identify the education infrastructure required to mitigate the cumulative impact of allocations and permitted development.

Paragraph 9.27 Please refer to ECC's comments in paragraph 9.22 above, ECC would welcome the opportunity to explore this further with RDC in the preparation of the Local Plan.

Paragraph 9.29 Options identified to plan for education and skills development in the future:

A. Retain the current policies on schools provision
B. Ensure that land is specifically allocated for schools
C. Do not have a policy on meeting education needs
D. Update the current employment growth policy on skills and continue to support skills development through a skills training academy
E. Promote apprenticeships through planning

ECC Comments

ECC does not consider these options to be mutually exclusive. ECC would expect RDC to develop a combination of the options based on evidence and in accordance with the NPPF.

In respect of this section and the range of Options, ECC recommends that they are expanded to explicitly incorporate the requirements and provision of Special Education Needs within schools and the wider community. ECC welcomes the opportunity to work with RDC on an ongoing basis to ensure this is addressed in the development of the Local Plan, in accordance with ECC's overarching Lifelong Learning Strategy 2014 - 2018 and supporting strategies, which include the provision of services from pre-birth to 24 for children with Special Educational Needs or Disabilities.
Further details are also available within
 Essex Early Years and Childcare Strategy 2015-2018;
 ECC Local and Neighborhood Planners' Guide to School Organisation; and the
 ECC Developers' Guide to Infrastructure Contributions (2016).
In respect of Options A and B, ECC does not consider there to be a need for separate education infrastructure policies as before. ECC recommends that RDC uses the best practice policy set out in Appendix B to the ECC Local and Neighborhood Planners' Guide to School Organisation, as set out in response to SP3.6 and paragraphs 8.73 and 8.75 above)regarding an appropriate and effective approach to pooled contributions, and to list any on-site facilities (new schools or extra land to expand existing schools) within the individual housing allocation policies.

It is necessary to separately designate land to be allocated for Education use as D1 use class. This is considered necessary to avoid residential hope value being attributed to school land as part of any development viability assessment.

In respect of Option C, ECC does not support this approach for the reasons stated in justification, it is considered contrary to the emerging vision and strategic objectives of the draft local plan, to national policy and would fail to comply with "Duty to Co-operate" in the preparation of a sound, legally compliant and deliverable local plan, as it would not enable the necessary educational infrastructure to be appropriately planned for and delivered to meet the needs of the local community (residents and businesses).

In respect of Option D, ECC recommends the current employment growth policy on skills and supporting skills development are amended and based upon the most up to date evidence and strategies, to determine the requirements for the future. For example ECC would wish to reserve the position on the proposal for construction of a specific academy; ECC recommends further investigation of the skills system is required to ensure it more closely reflects the needs (both now and emerging) of current and new employers. ECC would wish to engage and work with RDC on these matters including the need to address the social determinants of health.

In respect of Option E, ECC welcomes and is supportive of the approach to using development as a way of supporting local apprenticeships. ECC is in the process of updating the referenced ECC Developers' Guide to Infrastructure Contributions (2016), to include planning obligations and standard charges for contributions to support the full range of post-16 provision, where need is sufficiently evidenced.
This is as a result of students 16-18 being required to stay in some form of education or training. This would support workforces, support apprenticeships and work with local colleges to address identified skills gaps. ECC would wish to engaged and work with RDC in the development of these matters in the preparation of the Local Plan, to ensure it reflects the latest evidence and strategies, including for example (but not limited to) ECC's overarching Lifelong Learning Strategy 2014 - 2018.

SP4.4 Early Years and Childcare Provision;

Paragraph 9.30 Overall ECC is generally supportive of the approach to EYCC, as presented, however please be advised that the ECC Strategy "Essex Early Years and Childcare Strategy 2015-2016 will be reviewed late 2018. ECC would welcome the opportunity to work with RDC on an ongoing basis to ensure the draft Local Plan is prepared based upon the most up to date ECC strategies and objectives as well as the latest EYCC sufficiency data, which is reviewed annually. ECC wishes to be engaged with the next stages of the Local Plan and the consideration of site allocations and their assessments to ensure full consideration is given to the opportunities and impacts on EYCC infrastructure requirements and delivery matters arising from both individual and cumulative site allocations.

Paragraph 9.31 ECC recommend that the emphasis and role of the EYCC service as referred to is changed to correctly reflect the role and provision of EYCC services, which is for every child to achieve a good level of development and best start in life, and not for parents employment. The provision of EYCC facilities is a key service which supports parents wishing to re-enter employment, continue with their current employment or to pursue further or higher education. Please refer to the Essex Early Years and Childcare Strategy 2015-2018 for further clarification, which includes ECC's vision that "Children in Essex get the best start in life to enable them to reach their full potential". The access to high quality education is one of the fundamental influences on the long term life chances of children living in Essex. Furthermore this strategy forms part of ECC's broader Lifelong Learning Strategy 2014 - 2018, for children from pre-birth to 19 and pre-birth to 24 for children with Special Education Needs or Disabilities.

Paragraph 9.32 ECC welcomes and supports the reference to the EYCC sufficiency data (at August 2016) presented within table 11, however please be advised that this data is monitored and updated on an annual basis, and more recent information is now available. ECC would welcome the opportunity to work with RDC on an ongoing basis as the draft Local Plan is prepared, to ensure it based upon the most up to date and relevant ECC strategies and objectives including this EYCC sufficiency data (as referred to in paragraph 9.30 above).

Paragraph 9.33 ECC recommends that all references to nursery education is changed to "Early Years and Childcare Provision". ECC notes the reference to "Childrens Centres" within the paragraph and can advise that the provision of these service had been changed is and is now call "Essex Child and Family Well-being Service" as set out in paragraph 9.35. ECC recommends that all references to "Childrens Centres" throughout the draft Plan are now changed to "Essex Child and Family Well-being Service". Further information and evidence is available on ECC's website as follows: http://www.essex.gov.uk/Education-Schools/Early-Years-Childcare/Pages/Children%E2%80%99s-centres.aspx

Paragraph 9.34 & 9.35 ECC recommends that the references to "PB" are changed to "pre-Birth" to provide the clarification on the nature of the services being provided.

Paragraph 9.36 Options Identified for the provision of early years and childcare facilities:

A. Retain the current policies on schools, early years and childcare
B. Ensure that land is specifically allocated for schools, early years and childcare
C. Do not have a policy on early years and childcare facilities
ECC Comments
ECC would anticipate the strategy for early years and childcare facilities to be developed with a combination of the options, based on evidence and in accordance with the NPPF

In respect of this section and the range of Options, ECC recommends that they are expanded to explicitly incorporate the requirements and provision of Special Education Needs within EYCC and the wider community. ECC welcomes the opportunity to work with RDC on an ongoing basis to ensure this is addressed in the development of the Local Plan, in accordance with ECC's overarching Lifelong Learning Strategy 2014 - 2018 and supporting strategies, which include the provision of services from pre-birth to 24 for children with Special Educational Needs or Disabilities.

Further details are also available within:
 Essex Early Years and Childcare Strategy 2015-2018;
 ECC Local and Neighborhood Planners' Guide to School Organisation and the
 ECC Developers' Guide to Infrastructure Contributions (2016)
In respect of Option A, ECC is supportive of a broad approach in respect of Education and EYCC to ensuring there is sufficient provision. There is however a need to ensure that the policies are updated to reflect current and future need for the community. ECC recommends that the following are taken into account:
 ECC's Essex Early Years and Childcare Strategy 2015-2018;
 the implementation of the Government's Extended Funding Entitlement offer (30 hours) introduced in September 2017;
 ECC's emerging strategy for the "Essex Child and Family Service",
 the most up to date EYCC Sufficiency Data; and
 the Infrastructure delivery requirements set out in ECC Developers' Guide to Infrastructure Contributions (2016).

ECC would welcome the opportunity to continue to work with RDC, to ensure the most-up to date and relevant Strategies, guidance and evidence is used to inform the broad policy approach as well as the wider preparation of the draft Local Plan.

In respect of Option B, ECC is supportive of this approach to ensure specific land is allocated for the provision of schools and EYCC facilities. ECC would welcome the opportunity to continue to engage with RDC on this matter, and draw your attention to the requirements of the ECC Developers' Guide to Infrastructure Contributions (2016), the ECC Local and Neighborhood Planners' Guide to School Organisation, as well as ECC's comments above to paragraph 9.36 and the Options identified to plan for education and skills development in the future.

ECC does not support Option C, for the reasons stated in the justification, it is considered contrary, national planning policy and would fail to comply with the "Duty to Co-operate" in the preparation of a sound, legally compliant and deliverable Local Plan, the emerging vision and objectives, and it would not enable EYCC and educational infrastructure to be appropriately planned for and delivered to meet the needs of the local community (residents and businesses).

SP4.5 Open Space and Outdoor Sports and Recreation

Paragraph 9.37 ECC welcomes and supports the provision of Open Space, Outdoor Sports and Recreation (both formal and informal) and supports the preparation of up to date evidence with the joint South Essex Playing Pitch Strategy, in co-operation with Active Essex, as well as the need to commission a new Open Space Study incorporating Green space and infrastructure.

ECC recommends further consideration is given to the wider role of and value of green space to support healthy communities including general landscape value, green infrastructure, biodiversity, green corridors and country parks for the provision of managed informal passive and active recreational space for all residents.

Paragraph 9.42 Options identified for open space, outdoor sports and recreation:
A. Retain, and where necessary update, the existing overarching policy on open spaces
B. Retain, and where necessary update, our current policy on existing open space
C. Retain, and where necessary update, our current policy on new open space
D. Retain, and where necessary update, our current policies
ECC would expect RDC to develop a combination of the options, based on evidence and in accordance with the NPPF.

ECC would expect this to include the South Essex Playing Pitch Strategy and the Open Space and Green Infrastructure Study to be commissioned) and in accordance with the NPPF and guidance, including the emerging EDG (to be published February 2018) and Sport England's Active Design Principles, to create and promote healthy communities.

ECC recommend that further consideration is given to connectivity investment and improvements between green spaces through the provision of green corridors and enhancement of existing and new Green Infrastructure, which would provide a number of key benefits. This includes
 Climate change adaptation and mitigation
 Health, wellbeing and social cohesion
 Economic growth and investment
 Wildlife and habitats

This would support the creation of stronger communities and these benefits could be achieved through good planning and management to ensure green space is supplied and maintained. ECC would wish to engage with RDC on an ongoing basis in the preparation of the Local Plan, especially as the plan progresses to consider specific sites and spatial strategy.

In respect of Option C, ECC recommends that the "Challenge" on how to deliver infrastructure to support new homes should also seek to incorporate new open space Suitable Accessible Natural Greenspace (SANG) as part of new residential developments to avoid recreational impacts on European sites. Further details on this aspect are incorporated within the revisions to the emerging EDG. ECC also consider that this approach and option is cross referenced to the challenges set out in paragraph 4.17 and the approach to Greenways in paragraph 10.29 (Option H).

SP4.6 Indoor Sports and Leisure Centres

Paragraph 9.50 Options to address the provision of the indoor sports and leisure centres:
A. Retain the existing policy
B. Do not have a policy on indoor sports and leisure centres

ECC Comments

ECC would expect RDC to develop a policy approach based on evidence and in accordance with the NPPF.

ECC support Option A, subject to the need for any amendment arising from the new / emerging evidence base.

ECC does not support Option B, for the reasons stated within justification, it is considered contrary to the NPPF and the emerging vision and strategic objectives of the draft local plan.

SP4.7 Facilities for Young People;

Please refer to ECC's comments in response to SP4.3 - 4.5 above regarding community facilities; Education and Skills; Open Space and Outdoor Sports and Recreation; and Indoor Sports and Leisure Centres.

ECC would welcome the opportunity to work with RDC to ensure the latest ECC policies; guidance and evidence are taken into account to inform the principles, strategies and specific policies within the emerging Local Plan, please also refer to the Revised EDG.

SP4.8 Play Space Facilities;

Please refer to ECC's comments in response to SP4.3 - 4.5 above regarding community facilities; Education and Skills; Open Space and Outdoor Sports and Recreation; and indoor sports and leisure centres.

ECC would welcome the opportunity to work with RDC to ensure the latest ECC policies; guidance and evidence are taken into account to inform the principles, strategies and specific policies within the emerging Local Plan, please also refer to the Revised EDG.

PROTECTING AND ENHANCING OUR ENVIRONMENT (SECTION 10)

Paragraph 10.1 Overall ECC welcomes the Strategic Priority SP5

ECC supports the inclusion and strategic priority 5 (and SO19) regarding conservation and enhancement of the natural environment, broadly in accordance with NPPF (paragraph 156). ECC recommends that the objectives should be further amended, to include policies which seek to minimise the impacts to biodiversity in accordance with NPPF paragraph 117, which sets out the need for planning policies to:
 plan for biodiversity at a landscape-scale across local authority boundaries;
 identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation;
 promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan;
 aim to prevent harm to geological conservation interests;

ECC recommends that this is developed under the Duty to Co-operate with neighbouring authorities to both identify the wildlife corridors and to implement them through planning policies.

ECC consider the following Acts, Strategies and Guidance to be relevant and recommends that these are taken into account and used as appropriate:
 NERC Act 2006 concerning biodiversity duties for public bodies;
 England Biodiversity Strategy 2020; Net Gain initiative;  DEFRA's biodiversity metric calculator; and
 Essex Biodiversity Validation Checklist.

SP5.1 Green Belt

Paragraphs 10.5 ECC notes and supports RDC's desire to protect the Green Belt,
10.15 whilst also seeking to meet the emerging vision and strategic objectives for the District, including the preparation of evidence incorporating a review of the Green Belt boundary for plan making purposes in accordance with the NPPF.
ECC supports this approach and welcomes the opportunity to work closely with RDC on this matter, in accordance with ECC's Full Council motion in December 2014 and 2017, to support the Essex District, Borough and City Councils which when developing their Local Plans, seek to protect Green belt sites from inappropriate development and to ensure that housing development cannot occur where there is insufficient infrastructural provision. ECC will not support Local (Development) Plans unless adequate resources are identified from developers, local councils and/or Government grants to ensure that sufficient infrastructure, including roads, schools, medical facilities, parking, sewerage and drainage, is provided in a timely manner and in a way that balances the needs to promote economic growth and provide housing for residents whilst protecting their quality of life.

In 2017 ECC called on the Secretary of State for Communities and Local Government to issue urgent statutory guidance, which removes the opportunity for this exploitation and protects valued greenfield sites from predatory development.'

Paragraph 10.16 Options in relation to the Green Belt:

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

ECC Comments

ECC would expect RDC to develop a policy option based on evidence and in accordance with the NPPF. In respect of both Options A and B, ECC recommend a Review of the Green Belt boundary as part of the evidence base to inform the preparation of the Local Plan and its emerging spatial strategy, in accordance with NPPF (paragraphs 83-85), to set the framework for Green Belt and settlement policy.

ECC would welcome the opportunity to work with RDC to ensure the latest ECC policies; guidance and evidence are taken into account to inform the principles, strategies and specific policies within the emerging Local Plan.

ECC does not support Option C, for the reasons stated within the justification and would expect RDC to take any decision based on robust evidence and in accordance with the NPPF.

SP5.2 Biodiversity, Geology and Green Infrastructure

Paragraph 10.17 ECC welcomes the overall approach to protect and enhance the natural environment by RDC, including a review of the evidence base to ensure decisions are based upon the most up to date biodiversity and geodiversity information.

ECC recommends the inclusion and reference to the Outer Thames Estuary SPA within the list of European sites.

Paragraph 10.19 ECC note that Green Infrastructure (GI) is only referred to in its wider District context (see ECC comments to paragraph 6.4). However, due to the rural nature of the District, ECC considers localised GI design principles should be incorporated as part of a proposed housing development, specifically large developments such as Garden Communities and Urban Extensions. This would be in accordance with the NPPF and the Core Planning Principles and in particular paragraph 114 for conserving and enhancing the natural environment, by setting out the strategic approach within the Local Plans.

ECC recommends the principles in NPPF paragraph 114 are incorporated within Strategic Priority SP5.2 to protect, manage and enhance important habitats, nature conservation areas, geo-diversity and greenways.

Paragraph 10.20 ECC recommends Local Geodiversity/Geological Sites (LoGS) are added to the list of local sites. These are in addition to Local Wildlife sites (LoWS) and would be in accordance with NPPF paragraph 117.

Paragraph 10.21 As outlined above in response to Strategic Objective 12, ECC welcomes the reference to 'encouraging adherence to the waste hierarchy' and making 'best use of mineral deposits' but considers that these statements could be afforded slightly more clarity. Supporting the waste hierarchy and ensuring a sustainable use of minerals requires that existing facilities and infrastructure are safeguarded to ensure that they are able to continue to make their planned contribution to the mineral and waste strategies operating in the County. Whilst already covered by MLP Policy S8 and WLP Policy 2, it is considered beneficial for this to be incorporated into the Rochford LP objectives (see suggested change to Strategic Objective 12 above).

ECC welcomes and supports the reference to the requirement to safeguard mineral development recognised in paragraph 10.21 and consider the proposed modification to Strategic Objective12 to be in accordance with this recognition. However, it is noted that there is no similar recognition for waste facilities, which the proposed modification to Strategic Objective 12 would then cover.

Paragraph 10.22 ECC supports the approach outlined in this paragraph and polices DM25-DM27 which are considered to be in accordance with NPPF paragraph 118 to deliver biodiversity and the requirements of the NERC Act

Paragraph 10.26 ECC welcome and support the development of an Essex-wide strategy in respect of Recreational Disturbance Avoidance Mitigation Strategy, however note that this would mitigate for recreational disturbance impacts, in-combination with other plans and projects.

Paragraph 10.27 Options in relation to Biodiversity and Geodiversity in the district:
A. Retain or amend our current broad policy on sites of nature conservation importance
B. Do not have a policy on sites of nature conservation importance

Paragraph 10.28 Options identified to support and protect local habitats which have important ecological value:
C. Retain our current policy on trees and woodlands
D. Retain our current policy on other important landscape features
E. Retain our current policy on species and habitat protection
F. Update our current policy on Local Wildlife Sites
G. Condense and merge our current policies on nature conservation
Paragraph10.29 Options identified in relation to greenways in the district:
H. Retain our current policy on greenways
I. Do not have a policy on greenways

ECC Comments

Options A- I: ECC does not consider the options to be mutually exclusive. ECC would expect RDC to develop a combination of the options based on evidence and in accordance with the NPPF and guidance, whilst also having regard to the evidence presented in sections SP4.5 and 4.6 and ECC comments (see above).

ECC would wish to engage with RDC on an ongoing basis in the preparation of the Local Plan, especially as the plan progresses to consider specific sites and spatial strategy.

In respect of Option A, ECC welcomes and supports the proposal to commission a joint South Essex Open Space and Green Strategy, which shall subsequently inform this Local Plan. ECC also welcomes the importance assigned to nature conservation sites, the identification and enhancement of local wildlife/green corridors and networks to build biodiversity resilience to climate change allowing species dispersal within the urban landscape. These corridors will also provide a provision of greenways for walking and cycling; improve accessibility to green spaces and should have regard to the cycle network in the Rochford Cycling Action Plan.

ECC consider there to be the additional benefits including the health and wellbeing agenda, as well as improving the attractiveness of a place and potential to attract visitors and investment to the area.

In respect of Options C-G (local habitats) - Whilst ECC does not disagree with these options, consideration should be given to the preparation of one policy, incorporating all the policies referred to (within options C-G and ENV1). This would enable a holistic approach to be taken to our natural environment, with the elements considered as a "whole", within Option G.

In respect of Option G, if developed, ECC recommends that the policy is expanded to include "greenways" (please refer to ECC's comments in sections SP4.5 and 4.6 above in relation to open space and outdoor recreation and green infrastructure).
ECC supports Option H (Greenways), in principle, if it is not incorporated within Option G, as suggested above. ECC consider there to be a need to ensure "greenways" are captured, in accordance to NPPF, and having regard to the wider benefits as outlined above in respect of biodiversity; resilience to climate change, protecting the health of the green space, green infrastructure, open space, outdoor recreation, sustainable travel options and to promoting healthy communities.

ECC does not support Options B and I, for the reasons stated within their justifications, they are considered contrary to national policy and the emerging Local Plans strategy and vision.

SP5.3 Wallasea Island and the RSPB Wild Coast Project

Paragraph 10.34 Options identified for Wallasea Island and the RSPB's Wild Coast Project:
A. Retain the current policy which supports the Wallasea Island Wild Coast Project
B. Continue to support further development at Essex Marina as per current policy
C. Do not support further development at Essex Marina

ECC Comments

ECC would expect RDC to develop a policy approach for based on evidence and in accordance with the NPPF.

In respect of Option A, ECC would anticipate the strategy for Wallasea Island and the RSPB's Wild Coast project, to be developed with a combination of the options, based on evidence and in accordance with the NPPF including consideration for a project level HRA and appropriate mitigation for recreational disturbance.
ECC would recommend the need for a holistic approach within the context of the wider emerging spatial strategy, as well as the other emerging strategies in respect of open space, green space, nature conservation, rural diversification, tourism green infrastructure and sustainable travel. A balanced approach is considered necessary to both support the Wallasea project and improvements to accessibility, whilst ensure this would be sustainable with minimal ecological impact to ensure its survival and viability as a visitor destination.

In respect of Options B & C in relation to the Essex Marina, ECC would expect a policy approach to be developed based on evidence and in accordance with the NPPF.

SP5.4 Landscape Character;

Paragraph 10.35 ECC notes and welcomes inclusion of this section and the importance and use of Landscape Character Assessments as part of the baseline criteria for any development proposal. The principle of this approach is supported and should ensure the existing landscape elements are retained and that any new elements should enhance the overall landscape character.

Paragraph 10.44 Options identified for Landscape Character:
A. Retain the current policies on the Upper Roach Valley
B. Retain the current policies on the Coastal Protection Belt
C. Develop a broad policy on landscape character
D. Ensure consistency throughout Development Management Plan policies in relation to supporting development in appropriate landscape character areas and special landscapes.
E. Do not have a policy on landscape character

ECC Comments

ECC would anticipate a combination of the options A-D to be developed based upon evidence and in accordance with NPPF.

ECC does not support Option E for the reasons stated within the "justification", it is considered contrary to NPPF (paragraph156).

SP5.5 Protecting and Enhancing Heritage and Culture

Paragraph 10.45 ECC notes and welcomes the reference to the EDG, within this section and throughout the Issues and Options Report; however as this EDG is being revised and now includes sections such as Green infrastructure, Garden Communities and SUDS, which could form other key adoptable guidelines for future development.

ECC recommend that the new revised EDG is taken into account in the ongoing preparation of the draft Local Plan and ECC would welcome the opportunity to work with RDC on this matter.

SP5.6 Good Design and Building Efficiency

Paragraph 10.54 ECC recommend that this section is updated to reflect the updates and changes within the revised EDG 2018, which now specifically addresses health and wellbeing requirements. ECC can confirm that Sports England has been engaged with the revisions to the EDG, to include the Sport England - Active Design Principles 2015; which is supported by Public Health England and is consistent with the overall approach to health and wellbeing.

Paragraph 10.57 ECC recommend that a reference should be included to require the sustainable use of minerals in the construction of approved developments. This would be consistent with Strategic Objective 12 which aims to make best use of mineral resources, in accordance with the NPPF.

Paragraph 10.62 Options identified in relation to ensuring design principles are appropriate:
A. Retain the existing policies on design.
Ensure design policies make specific reference to Secured by Design, and the need to strike an appropriate balance between urban design and security.
C. Retain current guidance within our Supplementary Planning Documents.
D. Develop specific design principles for individual towns and villages building on the current guidance within our Supplementary Planning Documents.

ECC Comments

ECC would anticipate a combination of the options A-D to be developed based upon evidence and in accordance with NPPF.

ECC recommends the following Guidance and Evidence is also taken into account to inform the emerging Local Plan:
 The Revised EDG (to be published in February 2018)
 Sport England - Active Design Principles 2015 (which provide updates which specifically include health and well-being requirements and the creation of inclusive and active places. ECC can confirm that Sports England has been engaged with the revisions to the EDG, to include the; which is supported by Public Health England and is consistent with the overall approach to health and wellbeing.

In respect of Option A, ECC considered this option would need to be amended to take into account changes in national policy and guidance, including the removal of the Code for Sustainable Homes.

In respect of Option B, ECC consider the guidance within the Revised EDG to be applicable and relevant.

Paragraph 10.63 Options for building efficiency standards for new homes, and new commercial and industrial buildings.
E. Remove reference to the Code for Sustainable Homes and replace with a simpler policy on water efficiency.
F. Continue to drive up energy efficiency standards for new homes through replacing the Code for Sustainable Homes with one that focuses on energy, thermal and water efficiency in particular.
G. Do not have a policy on energy efficiency standards for new homes.
H. Retain existing policy on BREEAM.
I. Amend the existing policy on BREEAM to apply to only certain types of buildings.
J. Include a specific policy on the efficiency of conversions, extensions and alterations to existing homes.
K. Do not have a policy on energy efficiency standards for conversions, extensions and alterations to existing homes.

ECC Comments

ECC would anticipate a combination of the options E-F and H-J to be developed based upon evidence and in accordance with NPPF (paragraph 156).

In respect of Option E, whilst the removal of reference to the "Code for Sustainable Homes" would be appropriate, there would be a need to ensure an appropriate approach to water efficiency is developed, in accordance with the NPPF to address the broad principles being developed within the emerging vision, strategic objectives and spatial strategy (as outlined in Option C) and to incorporate the standard for energy efficiency within Option F to promote sustainable development, and resilience to climate change, in accordance with the NPPF.

In respect of Option J, this is supported by ECC and is considered to be consistent with best practice, for example the approach contained in Uttlesford District Council's Supplementary Planning Document on home extensions to reduce carbon dioxide emissions from existing building.

ECC does not support Options G & K, for the reasons stated within the respective justifications, they are it is considered contrary to the NPPF (paragraph 156) and the emerging vision and strategic objectives of the draft Local Plan.

SP5.7 Air Quality

Paragraph 10.64 ECC recommends that the scope and content of this section is expanded to include the latest national policy advice including the "National Air Quality Plan (2017)" published by DEFRA in July 2017, and the designation of the A127 to the east of Rayleigh Weir as an area having possible air quality issues.
Paragraph 10.69 ECC recommends inclusion and reference to the adoption of the AQMP for Rayleigh should be updated to say it was adopted in 2017 as this document has been issued after the date of adoption

Paragraph 10.72. Options in relation to Air Quality:

A. Retain the existing policies on air quality
B. Continue to promote clean air initiatives, such as sustainable ways to travel and renewable energy projects
C. Support, where appropriate, the actions put forward in the Rayleigh Town Centre Air Quality Action Plan
D. Do not have a policy on air quality
ECC Comments
ECC would anticipate a RDC to develop a combination of options, based on evidence and in accordance with the NPPF and DEFRA's National Air Quality Plan (2017), which specifically designates the A127 to the east of Rayleigh Weir as having possible air quality issues.

ECC recommends that consideration is also given to the use and role of wider sustainable development principles including green infrastructure, green spaces and green design principles to provide an opportunity to enhance the environment and support wider health.

ECC does not support Option D, for the reasons stated in the justification, it is considered contrary to NPPF (Paragraph 156), the National Air Quality Plan (Defra 2017) legislation, and the emerging vision and strategic objectives of the draft local plan.

DETAILED POLICY CONSIDERATIONS (SECTION 11)

ECC notes the majority of the issues identified within this section concern detailed matters, below the overarching strategic polices and principles addressed in the preceding sections of the ECC response to the Issues and Options consultation.
The principle of the approach is noted, however, ECC would anticipate all the themes and options to be developed, based on evidence and in accordance with the NPPF, taking into account the outcomes of the wider emerging spatial strategies and principles being developed within this Issues and Options consultation, as part of the preparation of the Local Plan.

In addition to the above, ECC can provide the following detailed comments on specific themes:

D.P1.1 Mix of Affordable Housing

Paragraph 11.5 Options to address the split between affordable housing products:
F. Retain the current affordable homes split (80% social and 20% intermediate) where a scheme meets the prescribed threshold
G. Amend the split taking into account any changes in national planning policy and guidance (if the definition of affordable homes is widened to include other products)
H. Do not have a prescribed split in a policy

ECC Comments

ECC would anticipate a RDC to develop a combination of options, based on evidence and in accordance with the NPPF

Please refer to ECC's comments in response to SP1.1 (see Paragraphs 6.30, 6.31 and 6.32) above which equally apply to this option; and in particular ECC's recommendations for consideration to be given to the provision of key worker homes through the affordable housing schemes, to support the needs of healthcare providers (see paragraph 6.31)

DP1.8 Options for development of Brownfield (Previously Developed) Land in the Green Belt in the future
A. Retain the current policy on previously developed land
B. Do not have a policy on previously developed land

ECC Comments

ECC would anticipate the approach to the development of Brownfield Land in the Green Belt, to be developed based on evidence and in accordance with the NPPF, as stated in ECC's response to SP5.1 and paragraph 10.16 regarding the policy approach to Green Belt, the need for a Review of the Green Belt Boundary.

ECC does not support Option B for the reasons stated within the justification, and it is considered contrary to the NPPF (paragraphs 79-92).

DP1.10 Parking standards and Traffic Management

Paragraph 11.57 Options identified for Parking and Traffic Management:
A. Retain our broad policy on parking standards and remove our Development Management Plan
B. Retain our current approach to traffic management
C. Do not have policies on parking and traffic management.

ECC Comments

ECC would expect RDC to develop a combination of options A and B, based on evidence and in accordance with the NPPF.

Please also refer to ECC's response to highway infrastructure (Section 8) regarding the Local and Strategic Highway Network and Sustainable Travel. There is a need for greater emphasis to be placed on an integrated package of transport solutions, which is applicable to Parking Standards and Traffic Management. Please also refer to ECC's earlier comments in Sections 6-8, regarding the development of sustainable communities, and in particular active design principles, promotion of healthy communities and the revised EDG to be applicable. This is necessary to ensure a holistic approach and consistency across the emerging vision and strategic objectives within the draft Local Plan.

In respect of Option B, this is partially supported by ECC, given the need to ensure that the policy is strengthened to provide an appropriate level of off street parking and to fully mitigate the impact of development (as set out in the traffic management plan), however there may be the potential to combine these options into one policy.

ECC would welcome the opportunity to explore this further with RDC as part of the preparation of the Local Plan.

ECC does not support Option C, for the reasons stated in the justification; it is considered contrary to NPPF (paragraph 156 & 157), the Essex LTP, EPOA's Parking Standards Design and Good Practice Guide; and the revised EDG.

D.P1.11 Home Businesses

Paragraph 11.61 Options to deal with home businesses:
A. Retain the current policy
B. Take a more restrictive approach to home businesses
C. Take a more flexible approach to home Businesses
D. Do not have a policy on home businesses

ECC Comments

ECC would expect RDC to develop a combination of the options A-C, based on evidence and in accordance with the NPPF.

In respect of Option C, ECC would support a more flexible approach to home businesses, taking into account the balances within this section and the inter-relationship and links to ECC's earlier comments regarding the ambition for communication infrastructure (improvements to broadband coverage and speed) as well as the need for "grow on space", to accommodate businesses as they become more successful and need more space from which to operate.

Further details on this are set out in ECC's response to meeting business needs (SP1.7 and paragraph 6.87); the options to support employment and economic growth (paragraphs 6.94 & 6.96); and Communication Infrastructure and the options to improve broadband coverage and speed including ultrafast broadband (SP3.3 and paragraphs 8.43 & 8.44).

ECC's considers there to be a need for a holistic approach and consistency across the emerging vision and strategic objectives within the draft Local Plan.

ECC does not support Option C for the reasons stated within the justification, it is considered contrary to the emerging vision and strategic objectives within the draft Local Plan.

DRAFT SUSTAINABILITY APPRAISAL

ECC consider the SA to be a good example of an initial Regulation 18 'Issues and Options' appraisal, exploring the sustainability considerations of a wide range of strategic options and assessing them to the same level of detail.
Whilst not a criticism of the SA, it is considered that the options explored surrounding OAN possibilities within the Plan could be expanded upon within the SA. The Plan, at Table 2 (South Essex Housing Market Area - OAN for new homes (Source: South Essex SHMA Addendum 2017)) indicates a range of between 331 and 361 homes per year. Although the upper and lower figures displayed are perhaps not distinctively different to warrant separate assessment within the SA under the Regulations, RDC may want the SA to consider assessing indicative higher and lower figures in future iterations. If felt necessary, this could also be expanded to assess reasonable spatial strategy options / permutations under different scenarios regarding levels of growth (i.e. at which level of growth would certain spatial strategy options be considered reasonable). Further, it may also be considered necessary to assess the figure included for the District in the recent DCLG consultation which set a standardised methodology for calculating housing needs. This is in consideration of the Plan being at an early stage of preparation and uncertainty as to what might be the District's OAN later on in the plan-making process.

ECC notes the reference throughout the SA and the Issues and Options Report, to 'a combination of options' and considers that whilst this may be a logical option in most cases, care needs to be taken as to what form a 'combined' policy would contain and aspire to.

ECC recommends that the "Climate Change" section should include a reference on whether the proposal will support the findings/priorities of the South Essex Surface Water Management Plan (2012 and emerging 2018 revision).

Representations to the Rochford District Council New Local Plan: Issues and Options Document Consultation
Michelins Farm, Rayleigh
Submitted on Behalf of Equation Properties Limited

We are instructed by our client, Equation Properties Limited ('Equation'), to submit the enclosed representations to the New Local Plan: Issues and Options Document Consultation.
Representations can be made until 7 March 2018 and on the basis that this letter is submitted within those timescales we trust that our comments will be taken into account.

1 Summary Representations
Equation:
 Objects to the retention of Michelins Farm for Gypsy and Traveller Accommodation (SP1.5 Option B);
 Support the allocation a number of smaller Gypsy and Traveller pitches / sites to meet the needs of the local area (SP1.5 Option C);
 Supports the relocation of Rawreth Lane Industrial Estate for employment uses (SP1.8 Option B);
 Supports the continued allocation of Michelins Farm given the strong commercial interest in developing the site for a range of employment uses (Classes B1(c), B2 and B8) (SP1.8 Option C); and
 Supports the allocation of new employment land to meet the identified demand for new employment floorspace across the district (SP1.8 Option D).
Our reasoned justification is set out below.

2 Site Context
The Michelins Farm site extends to 9.8 hectares and comprises 'degraded' greenfield land. In the adopted Development Plan, the majority of the site (8.8 hectares) is allocated for employment use under Policy NEL1. This submission relates principally to the 1 hectare site on the south west corner of the Michelins Farm site allocated for Gypsy and Traveller Accommodation (Policy GT1).
Existing access onto the wider site is gained from the A1245. The site is relatively flat, however, there is a significant increase in the height of the land on the northern boundary where it meets the train line. Pylons are situated to the north west and south west of the site, and the land is believed to be contaminated.

3 Planning History
There is no planning history of relevance, albeit there was a pre-application exercise undertaken in 2015 which promoted the entire 9.8 hectare Michelins Farm site for employment development. This was the extent of the employment land demand at that point, which has only increased since.

4 Policy Context

The Department for Communities and Local Government published the updated Planning Policy for Traveller Sites document in August 2015 to help achieve the Government's overarching aim 'to ensure fair and equal treatment for travellers, in a way that facilitates the traditional and nomadic way of life of travellers while respecting the interests of the settled community'. One of the Government's specific aims in respect of traveller sites is 'to enable provision of suitable accommodation from which travellers can access education, health, welfare and employment infrastructure'.

In terms of Plan-making, Policy B: Planning for Traveller Sites states that:
'Local Plans must be prepared with the objective of contributing to the achievement of sustainable development.

To this end, they should be consistent with the policies in the National Planning Policy Framework, including the presumption in favour of sustainable development and the application of specific policies in the Framework, and this planning policy for traveller sites.'

Furthermore, the Planning Policy for Traveller Sites sets out the requirement that Local Planning Authorities should ensure that traveller sites are economically, socially and environmentally sustainable. This is to be achieved by ensuring site provide access to appropriate health services, ensure that children can attend school on a regular basis, provide a settled base that reduces both the need for long-distance travelling and provide for proper consideration of the effect of local environmental quality (such as noise and air quality) on the health and wellbeing of any travellers.

The National Planning Policy Framework (NPPF), which was adopted in March 2012, sets out the Government's planning policies for England and should be read in conjunction with the Government's Planning Policy for Traveller Sites. Fundamentally, Paragraph 151 of the NPPF states that:
'Local Plans must be prepared with the objective of contributing to the achievement of sustainable development.'

In terms of preparing planning policies, Paragraph 37 states that such policies should 'aim for a balance of land uses within their area so that people can be encouraged to minimise journey lengths for employment, shopping,
leisure, education and other activities.'

We note that a need for 15no. Gypsy and Traveller pitches up to 2018 was identified in the adopted Core Strategy as a result of the policies in a former regional plan (East of England Plan (2008)). To address this need, Policy GT1 of the Rochford District Council Allocations Plan (adopted February 2014) identified land at Michelins Farm to accommodate the required pitches. Section 3.306 of the Allocations Plan relates to the Gypsy and Traveller allocation at Michelins Farm stating:
'It is essential that the site is managed in a way that ensures it is open and accessible to the traveller community. Specifically, there will be a need to ensure that travellers, in appropriate circumstances, can be offered a pitch when required as part of the process of dealing with unauthorised sites in the district. On that basis, the Council's preference is for the creation of a new municipal site that will be positively managed for the benefit of the traveller community and will ensure that a pitch can be offered when required in a simple and straightforward way. To this end the Council will seek to acquire this land and will ensure that it is appropriately managed by or on behalf of the Council.'

The allocated pitches were to be delivered by 2018; however, in the 4 years since the site's allocation, it has not come forward for the development of traveller and gypsy accommodation. The site cannot be considered as 'open and accessible to the traveller community' being located in an isolated area surrounded by a substantial employment allocation and infrastructure (roads, railway line and pylons). This situation will be intensified when the allocated land is developed for employment uses which segregate the traveller site. Whilst the policy defends against this position, it is difficult to see how the two land uses can coexist, with the traveller site potentially prejudicing the delivery of valuable economic development.
When allocating a site for gypsy and traveller accommodation, the relationship to and impact on surrounding land uses is a material consideration. Typically, employment uses are located away from residential development.

Similarly, residential development is generally not supported on contaminated land. The use of Michelins Farm for gypsy and traveller pitches is contrary to the Government's overarching aim of ensuring fair and equal treatment for travellers. Costly remedial work would be required for the use of Michelins Farms for traveller accommodation. Furthermore, due to the 24/7 operation of employment sites and the nature of traveller living accommodation (Caravans, Mobile Homes, etc.) noise from the adjoining site, should it be developed for employment uses as envisioned, would have a major negative impact on the sensitive residential use. Conversely the location of the traveller site could prejudice the operation of future occupiers of the employment land, which would potential deter development coming forward.

5 Issues and Options

The Issues and Options Documents sets out the Draft Vision for 2037 as:
'Rochford District is a green and pleasant place with a focus on business and high quality homes supported by accessible and responsive services and facilities, creating healthy and sustainable communities.'

In terms of the Vision for Rochford's Society, it states that:

'We (Rochford District Council) have worked with Essex County Council and other infrastructure and service providers to ensure that appropriate facilities are delivered to support strong and sustainable communities, and provide residents and visitors with choice about how they live, work and travel.'

As previously discussed, the site currently allocated for gypsy and traveller is situated in an isolated location and cannot be considered as being a sustainable location for residential development in line with the Draft Vision.

SP1.5: How do we sustainably meet our need for Gypsy and Traveller pitches over the next 20 years?

We note that a need for Gypsy and Traveller pitches was identified in the most recent Essex Gypsy and Traveller Accommodation Assessment 2017 (GTAA).
The Issues and Options Documents notes that Rochford District Council's assessed need up to 2033 could be met at the currently allocated site at Michelins Farm. The Document further notes that the allocated site is in the early stages of delivery, but it is envisaged the site will be delivered in the short term, however no evidence is provided to support this. As previously noted, significant remediation is likely as well as considered highways access and utility provision in order for it to be utilised for gypsy and traveller accommodation. The associated costs would, therefore, make the development of the site for domestic use financially unviable.

In terms of the Options given in respect of meeting the need for gypsy and traveller pitches our client objects to Option B - to retain the currently allocated site at Michelins Farm for Gypsy and Traveller Accommodation. The site's remote location means residents of the site would have restricted access to local amenities, education, employment opportunities and healthcare. There are limited public transport links to and from the site and as a result, any development on the site would be highly dependent on the use of the private car. This would result in a highly unsustainable development, contrary to the NPPF and Planning Policy for Traveller Sites.

To achieve truly sustainable development, which ensures the fair and equal treatment for travellers, we strongly support Option C which would allocate a number of smaller Gypsy and Traveller pitches / sites to meet needs throughout the district. This would provide residents with 'suitable accommodation from which travellers can access education, health, welfare and employment infrastructure' in line with the Government's aim for gypsy and traveller accommodation.

The lack of traveller development on the site since its allocation is indicative of the both the limited demand and cost of delivering pitches. The integration of this land within the adjoining employment allocation would be more appropriate, for which there is demand, as identified in the Economic Development Needs Topic Paper 2017.

SP1.8: How do we plan for and facilitate the delivery of our need for new jobs over the next 20 years?

The Economic Development Needs Topic Paper 2017 'combined scenario' suggests that there is a need for a minimum of 7 hectares of 'new' employment land between 2016 and 2036. It is anticipated that over this period, that there will be a reduced demand for warehousing in the district, and a greater demand for manufacturing / industrial (B1c / B2) uses on 6 hectares and higher density office (B1) developments on a further 1 hectare of land.

This requirement equates to total employment creation of 1,242 jobs over the projection period (2016-2036), which equates to job creation of approximately 62 jobs per year. This additional requirement highlights the logic of allocating the whole of the Michelins Farm site for employment, incorporating the existing gypsy and traveller allocation (GT1). Equation would support the allocation of new employment land in this respect, given the level of existing occupier demand.

Equation also support the continued allocation of Michelins Farm given the strong commercial interest in developing the site for a range of employment uses (Classes B1(c), B2 and B8) (SP1.8 Option C). Equation also supports the reallocation of Rawreth Lane Industrial Estate for employment uses (SP1.8 Option B). The estate has a high level of occupancy and there has been no interest in the site for residential developers. Moreover, given the demand for new employment floorspace, Equation is concerned that displacement of businesses from Rawreth Lane Industrial Estate to Michelins Farm will create yet more pressure on the need for additional employment land to meet demand. There is demand for Michelins Farm along, without relocation pressures from Rawreth Lane, such that we consider that a further 1 hectare can be allocated (the gypsy and traveller site) which would contribute towards the 7 hectare requirement identified in the Economic Development Needs Topic Paper 2017. Equation therefore supports the allocation of new employment land to meet the identified demand for new employment floorspace across the district (SP1.8 Option D).

6 Conclusion

Equation objects to the retention of Michelins Farm for Gypsy and Traveller Accommodation (SP1.5 Option B); supports the allocation a number of smaller Gypsy and Traveller pitches / sites to meet the needs of the local area (SP1.5 Option C); supports the reallocation of Rawreth Lane Industrial Estate for employment uses (SP1.8 Option B); supports the continued allocation of Michelins Farm given the strong commercial interest in developing the site for a range of employment uses (Classes B1(c), B2 and B8) (SP1.8 Option C); and supports the allocation of new employment land to meet the identified demand for new employment floorspace across the district (SP1.8 Option D). We would be grateful if you would keep us informed of the progress of the Draft Local Plan. Should you have any questions, please do not hesitate to contact me.

*PLEASE SEE ATTACHMENT FOR FULL RESPONSE INCLUDING PHOTOGRAPHS*

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 sucessive Governments failure to plan strategically or forecast needs and exascerbated 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 imirgration, 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.

Transport
Road - The road system can barely accommodate the current population let alone the new developoments 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.

Rail - 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.
Bus - routes and timetables are limited leading to many people using private vehicles.
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.

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.

I'm writing to strongly object to the proposed development of land between Eastwood Road Rayleigh and the A127 for new housing. The road infrastructure, together with the stress on existing utilities, not to mention the additional work load for the already stretched emergency services, makes this proposal extremely detrimental to Rayleigh, Eastwood and it's residents and businesses. I understand this is not the only redevelpment proposal for the Rayleigh area so these issues will be compounded further

In addition I note that the provision for a "Travellers" site forms part of the proposal. This is totally unacceptable to the local residents, for all the reasons listed above, as well as potential devaluing of property prices in the vacinity.

Please could you acknowledge my objections to the proposal

*THIS REPRESENTATION INCLUDES SEVERAL ATTACHMENTS*

New Local Plan 2018. Issues and Options Documents

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

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

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

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

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

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

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

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

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

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

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

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

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

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


Section 1 (cont).

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

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

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


Section 1 (cont).

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

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

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

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

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

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

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

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


Section 3 (cont

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

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

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

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

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


Section 3 (cont.

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

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

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

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

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

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

Section 4

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

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

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

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

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

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

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

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

Section 5 (cont

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

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

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

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

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

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

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


Section 6 (cont

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

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

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

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

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

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

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

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

Section 6 (cont

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

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

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

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

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

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

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

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

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

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

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

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

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

Section 8 (cont


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

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

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

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

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

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

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

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

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

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

Page 156. Extensions etc. No comment

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

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

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

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

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

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

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

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

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

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

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

My name is Vic Foyle. I have lived at my property for about 34 years with my wife and children. I have a personal consent (ref CU/0168/96/ROC). This was allowed on appeal which gave consent for us to stay on the site. However this is a personal permission for Mr. & Mrs. Foyle. My son still lives with us and we would like him to continue living at our property when me and my wife have gone. At the moment it worries me as this isn't possible. We are well known in the area and in the community. We keep our animals on the land and love our way of life.