Green Belt

REF: CFS166 - Paglesham Church End

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

Rochford District Council should provide their housing in the district at the level set by the Objectively Assessed Need of between 331 to 361 houses per annum. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these authorities are also under pressure to supply housing. Neighbouring authorities may also be looking to share their requirement with Rochford Council providing the shortfall. The authority should ensure they have a supply to meet the requirements, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints. The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Additional land should be included in the local plan for future residential development to meet the target of supplying the minimum 331 houses per annum. For this reason Option C. Several Small extensions to the existing area would be the best way to achieve the minimum of 331 houses per annum in the Rochford District. As detailed in the site SHLAA summary the site is located close to existing residential area so be considered a small extension to the existing area.

Point SP 2.2: How do we continue to support local facilities in our village and neighbourhood centres?

The development would support the village services of the public houses. The site be within 30m of one public house showing easy access.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

The development of the site would further increase the demand and support the need for the services provided in Paglesham improving the sustainability of these services.

Given the above, option A. should be adopted to retain the existing Core Strategy policy.

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

The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.
Given the above, the land in the Strategic Housing Land Assessment referred to above should be considered as it meets the requirements for new housing as set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites like the above from the Green Belt easier and hence the support for option B to amend the current Green Belt policy in the Core Strategy.

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | ROCHFORD PARK EAST, COOMBES FARM

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, to Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.

Please note that details relating to the land at Rochford Park East also formed part of Rochford District Council's 'Call for Sites consultation 2015'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land at Rochford Park East, Coombes Farm
The land at Rochford Park East is identified within the submitted plan (Appendix 1), but for clarity is 20.45ha in size and lies approximately 500m to the east of Rochford town centre and 900m east of Rochford mainline Railway Station. The site is bound by Stambridge Road and existing residential properties fronting Stambridge Road to the north, Stambridge Mills and Mill Lane to the east and the
River Road to the south. To the west, the site boundary abuts the existing urban area and includes allotment gardens that are accessed off Stambridge Road and Rocheway. Residential properties are located along the north eastern corner of the site. The site currently comprises agricultural land with a single Public Right of Way; other informal routes around the site are also used by local walkers. The public safety Zone associated with London Southend Airport lies outside the boundary of the site.
The allocated Stambridge Mills site is located to the South East of the Site, for which an application for redevelopment to provide 96 units was submitted in 2011 (11/00494/FUL). However, due to reliance on 3rd party land for mitigation measures the site has been considered undeliverable. This application was withdrawn.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing through the Local Plan process. Development of the site would provide an obvious and most suitable extension to the development boundary as the site is defined by strong defensible
boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. For this reason development of this site would provide a logical 'rounding off' of the existing urban area. Given the visual (and actual) separation for the wider countryside, the site also has very limited function in safeguarding the countryside from encroachment.

Development of the land at Rochford Park East would also promote growth within Rochford and the wider districts and will help support local employment which would otherwise result in the closure of local businesses and increasing the amount of derelict land elsewhere.
Further benefits of the development of the land at Rochford Park East are explained in more detail throughout these representations.

b. History
The Council will be aware of the history associated with the Site following the refusal of a planning application for 326 residential dwellings in November 2009, the subsequent appeal in May 2010 and a subsequent revised application in March 2012.
Since the determination of the previous schemes on the site, the introduction of the National Planning Policy Framework (NPPF) in 2012 has created an environment in which a proactive and positive approach to planning is essential. At the heart of the NPPF is the presumption in favour of sustainable development' which seeks to ensure the delivery of developments in support of economic growth and provision of the social needs within a community. By ensuring a high quality design, development on this site could wholly accord with the objectives within the NPPF and contribute towards delivering housing required within the District.
c. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and where it is consistent with achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.
Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];

Be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area [17];
 Seek to secure high quality design and good standard of amenity for all existing and future occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]

In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable development; and
 The Duty to Co-operate.

d. Emerging Local Plan Issues and Options Document

The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.

As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.

As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Rochford Park East, presents an opportunity for RDC to contribute positively to the South Essex housing need.
The key 'Core Purpose and Aims' of ASELA, pertinent to Rochford Park East are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.
e. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.
The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.
On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the sub-regional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However, projected completion rates indicate that a 20% buffer plus shortfall is unlikely to be met, although the shortfall is considered by RDC to be relatively minor at an estimated 166 dwellings over the five years.
When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore, when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.
Supporting Economic Growth and Employment
The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.
Protecting the Green Belt
The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.

The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development, 'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.
RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.
Delivering Infrastructure
In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focuses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London Southend Airport.
f. Ensuring the Delivery of Sustainable Development
Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land at Rochford Park East, Coombs Farm is currently located within the Green Belt, promotion of the site for residential development would provide significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location to London Southend Airport.
Rochford Park East, Coombes Farm
The land at Rochford Park East would be suitable for the sensitive expansion of Rochford, which would also help to improve associated infrastructure. It is also suggested that new landscaped parks and open spaces, extended allotments and a new pedestrian link with the town centre could be provided as part of the development, providing added benefits to both the local and wider area.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for Rochford Park East has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix 3).
Social
Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.
As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required housing need.
Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need
Economic
Rochford Park East is located adjacent to the town of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its suitability for residential development.
The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location less than 10min walk from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating 700 jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53 jobs are created in the wider economy.

Environmental
At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site.
Furthermore, the site is approximately 12minute walk from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. New pedestrian access from the allocated site of Stambridge Mills to the town centre would seek to incentivise this form of transport, therefore reducing the need to use private cars for short distances to and from the town.
Development of this site would also provide an opportunity to enhance the riverside walk linking the site between the town centre, Stambridge Mill and the River Roach estuary. By re-establishing this historic pedestrian link the proposal will help to enhance and benefit the associated ecology whilst also encouraging a healthy and more active lifestyle.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land at Rochford Park East meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the NPPF:
Table 1 Rochford Park East 1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. As such, no further development beyond the Site boundary would be possible; and
- The development of this site would provide a logical 'rounding off' of the existing urban area. 2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the west of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
- The location of Stambridge Mills is also significant in this context as the site is clearly well placed between this redevelopment and the existing urban area, therefore containing development on the site and providing a link from Stambridge Mills to the town. 3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, Stambridge Mills and the existing urban edge of Rochford; and
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006. 4. to preserve the setting and special character of historic towns
- Rochford Park East is not in or adjacent to any Conservation Areas and has no listed buildings or other heritage assets in proximity;
- The Inspector confirmed within the appeal decision that 'the character an Appearance of Rochford Conservation Area which encompasses the nearby town would be preserved' (Paragraph 110);
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.
Sustainable Development Scorecard Analysis
Taking the above information into account, the scorecard analysis of the proposed site at Rochford Park East has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 81% and a Parity score of 92%.
The Scorecard analysis shows that the proposed site scores very well for the elements on the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and flood risk alleviation potential.
Proposed development of the site also scores well on both the economic and social aspects, due to the site's proximity to Rochford Town Centre, local employment and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a sustainable location in which to accommodate additional growth due to the presence of a train station with frequent connections to central London and the town's significant range of services.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.
g. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land at Rochford Park East, Coombes Farm will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable, achievable and deliverable sites are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).
For the reasons given in Table 1, the land at Rochford Park East, Coombes Farm should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a logical 'rounding off' of the existing urban area and given the visual (and actual) separation for the wider countryside, the site has very limited function in safeguarding the countryside from encroachment. For these reasons, and the reasons set out above, it is considered that the proposed development site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

*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.

RE: Land to the west of Little Wakering Road and east of Cramps Farm Little Wakering

Point SP 1.1 (Objectively Assessed Need.) We have a real and identified for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

Response: Rochford District Council is required to provide between 331 to 361 houses per annum set out in the Objectively Assessed Need of. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are similarly under pressure to supply housing. Rochford District Council must provide this supply going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints.' The council must consider releasing more land from the Green Belt such as that explained above, and as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Response:

The Local Plan should incorporate additional land for development to achieve the obligation of delivering at least 331 houses per annum. For this reason option C. several small extensions to the existing area would be one good way to achieve the minimum housing requirements in the Rochford District. The land is surrounded by residential development and so would be considered a small extension to the settlement.

Point SP 2.2: How do we continue to support local facilities in our villages and neighbourhood centres?

The development would support the village services including shops and public houses. The site is within 800m to these services presenting easy access to these.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

The development of the site would further increase the demand and support the need for the village services in Little Wakering improving the sustainability of these services.

Option A. to retain the existing Core Strategy policy should be adopted.

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

Response: The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.

The five purposes of the Green Belt are:
1. to check the unrestricted sprawl of large built-up areas
2. to prevent neighbouring towns merging into one another
3. to assist in safeguarding the countryside from encroachment
4. to preserve the setting and special character of historic towns, and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

The Councils approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are:

1. Continue to protect the openness and character of the District's Green Belt
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identifies of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of development green tourism in the District.

The above land should be included in the local plan for residential development given the above points and requirements and one and two. There should also be an amendment to the current policy to release sustainable sites including this land from the Green Belt and hence the support for option B. to amend the current Green Belt policy in the Core Strategy.

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | LAND EAST AND WEST OF SUTTON ROAD

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, on Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.
Please note that details relating to the Land East and West of Sutton Road also formed part of Rochford District Council's 'Call for Sites consultation 2016'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land east and west of Sutton Road
The land east and west of Sutton Road is identified within the submitted plan (Appendix A1), but for clarity the site is divided into two sections by Sutton Road. The land to the west of Sutton Road is 56.3ha in size while the Land east of Sutton Road is 36.8ha. The site is located approximately 1km to the south east of Rochford Town Centre and Rochford mainline Railway Station. The site is bound by residential development to the east, employment and commercial facilities to the north (Purdeys Industrial Estate) and Temple Farm Industrial Estate to the south, Fossets Park to the South West. Reads of Sutton Road Nursery is located to the west of Sutton Road. The site is also bordered by an existing road network, including Shopland Road/Sutton Road to the north and Southend Road to the east. The site currently comprises agricultural land. The public safety Zone associated with Local Southend Airport lies outside the boundary of the site. The site can be accessed via Sutton Road and Fossetts Way.
New Hall Grade II listed building is located on the western side of Sutton Road and any new development on this site will have to be sympathetic to this heritage asset.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. Development of the site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing
Public Safety Zone to Southend Airport and the existing road network.
Promotion of this site for residential use will provide additional sustainable and infrastructure benefits to Rochford and the wider South Essex district. These benefits will include.

 Enable east/west connections without impacting on A1159;
 Provide access to the outer town retail uses and sport stadium potential to reduce impact on
A2259;
 Reconfiguration of Rochford/Southend Road at harp house roundabout;
 Provide better access to the airport to reduce highways impact on Warners Bridge Chase
residents and rebuilding Warners Bridge;
 Improvement to be made to Anne Boleyn roundabout on junction of Rochford Road and Sutton
Road, easing congestion within the district by providing a loop road;
 Provide landscape buffer to Shoplands Equestrian Centre heritage asset providing a through link
to Shopland and potential eastward connections; and
 Development of the site will also provide a landscape setting for Brookes and ecological site.
It is envisaged that the site is suitable for approximately 1,400 dwellings a primary school and a local centre. Alternatively the site could be suitable for industrial use, offices or a mixed use development. Development of the land east and west of Sutton Road will promote growth within Rochford and the neighbouring authorities. It will be of a scale to justify strategic infrastructure investment, in what should
be a key growth corridor for Rochford and Southend. Furthermore it will help support local employment and encourage economic growth. New development will ensure the long term vitality and viability of existing services and business in the local area, and encourage new businesses to locate to this location.
Further benefits of the development of the land east and west of Sutton Road are explained in more detail throughout these representations.

b. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and
the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - the plan should be prepared based on a strategy which seeks to meet
objectively assessed development and infrastructure requirements, including unmet requirements
from neighbouring authorities where it is reasonable to do so and where it is consistent with
achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the
reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on
cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.

Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];
 Be based upon and reflect the presumption in favour of sustainable development, with clear
policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area
[17];
 Seek to secure high quality design and good standard of amenity for all existing and future
occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]
In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with
respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable
development; and
 The Duty to Co-operate.

c. Emerging Local Plan Issues and Options Document
The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.
As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.
As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-
Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Land east and west of Sutton Road, presents an opportunity for both RDC and SBC to contribute positively to the South Essex housing and wider infrastructure investment need.
The key 'Core Purpose and Aims' of ASELA, pertinent to land east and west of Sutton Road are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.

d. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.

The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.

On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the subregional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's required housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAHN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However projected completion rates indicate that a 20% buffer plus shortfall is unlikely to not be met, although the shortfall is considered by RDC to be relatively minor at an
estimated 166 dwellings over the five years.

When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore,
when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.

Supporting Economic Growth and Employment

The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate
controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.

Protecting the Green Belt

The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.
The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development,
'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.

RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.

Delivering Infrastructure

In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focusses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London
Southend Airport.

e. Ensuring the Delivery of Sustainable Development

Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land to the east and west of Sutton Road is currently located within the Green Belt, promotion of the site for residential development provides significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location in relation to London Southend Airport.

Land East and West of Sutton Road

The land east and west of Sutton Road, is in a sustainable location, in close proximity to existing services and facilities as well as employment opportunities. It is suitable for residential development and would help to improve associated roads and infrastructure, easing congestion and providing better access to Rochford, Southend, and London Southend Airport. It is also suggested that new landscaped parks and open spaces which will provide a landscape buffer to Shoplands equestrian centre and heritage assets as well as providing a potential new link to Shoplands and eastward connections.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for land east and west of Sutton Road has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix A3).

Social

Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.

As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required
housing need. Development of this site could help to deliver approximately 1,400 homes towards RDC required housing need target.

Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need.
Development of this site would also bring improvements to the local infrastructure helping to provide better access to the town centre and London Southend Airport. These improvements will also help to ease congestion around the district and the wider area.

Economic

Land east and west of Sutton Road is located adjacent to the south east of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport and Temple Farm Industrial Estate. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its
suitability for residential development.

The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location which is within walking distance from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local
service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK
average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating a significant number jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53
jobs are created in the wider economy.
It is envisaged that development of this site could also provide new jobs as the proposal will look to include the erection of a new primary school and one local centre.

Environmental

At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site. Development of the site would also provide a landscape buffer to Shoplands equestrian centre heritage
asset, providing a through link to Shoplands and potential eastward connections. Within the site, development would provide a landscape setting for Brookes ecological sites.
Development of the site will also be sympathetic to New Hall Grade II listed building located on the western side of Sutton Road by securing a high quality design which will reflect the area.
Furthermore, the site is within walking distance from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land east and west of Sutton Road meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the
NPPF:

Table 1
Land East and West of Sutton Road
1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the north and Temple Farm Industrial estate to the south as well as the existing road network.
- The development of this site would provide a logical 'rounding off' of the existing urban area.
2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the North West of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, London Southend Airport, Fossetts Park and Temple Farm Industrial Estate.
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006.
4. to preserve the setting and special character of historic towns
- Land east and west of Sutton Road is not in or adjacent to any Conservation Areas. A high quality designed development which is sympathetic and aims to protect New Hall Grade II Listed Building.
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land
- There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.

Sustainable Development Scorecard Analysis

Taking the above information into account, the scorecard analysis of the proposed site east and west of Sutton Road has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 84% and a Parity score of 88%.
The Scorecard analysis shows that the proposed site scores very well for the elements of the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and reduce transport emissions as a result of the proximity to sustainable transport options.
The scheme also scores well on both the economic and social aspects, due to the site's proximity to London Southend Airport, Temple Farm and Purdeys Industrial estate and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a prominent location in which to accommodate additional growth due to the presence of two train stations (Rochford and London Southend Airport) with frequent, sustainable connections to central London and Southend-on-Sea.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.

f. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land east and west of Sutton Road will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area. It
is envisaged that development on the site could provide approximately 1,400 towards RDC's required housing need.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable,
achievable and deliverable sites, such as this one, are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

For the reasons given in Table 1, the land east and west of Sutton Road should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing Public Safety Zone to London Southend Airport and the existing road network.
Through development of the site there is also potential to make several infrastructure improvements to the local road network which will have wider benefits for the South Essex Districts.

REF: CFS121 - Land north of A127 Rayleigh

Point SP 1.1 (Objectively Assessed Need.) We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

Response:

Rochford District Council must provide between 331 to 361 houses per annum in the district as required for by the Objectively Assessed Need. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these authorities are similarly under pressure to supply housing. The authority should ensure they have a supply to meet the requirements, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints.' The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3. How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Response:

The above land should be included in the local plan for future residential development to meet the condition to supply at least 331 houses per annum. For this reason option C. Several small extensions to the existing area would be one good way to achieve the minimum of 331 houses per annum in the Rochford District. As detailed in the site SHLAA summary the site is located close to the existing residential area and be considered a small extension to the existing area.

Point SP 2.2: How do we continue to support local facilities in our village and neighbourhood centres?

The development would support the neighbourhood centre of Rayleigh.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

The development of the site would further increase the demand and support the need for services provided in Rayleigh thus improving the sustainability of these services.

Given the above option A. to retain the existing Core Strategy policy should be adopted.

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

Response:

The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to guarantee development is always sustainable.

The Five purposes of the Green Belt are:
1. to check the unrestricted sprawl of large built-up areas;
2. to prevent neighbouring towns merging into one another;
3. to assist in safeguarding the countryside from encroachment;
4. to preserve the setting and special character of historic towns; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

The Councils approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence.
3. Ensure existing lawful business in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regarding to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

The above land referred to in the Strategic Housing Land Assessment should be considered for development. The land meets the requirements for new housing as set out in points one and two above. The current policy should be amended to release sustainable sites like the above from the Green Belt and hence the support for option B. to amend the current Green Belt policy in the Core Strategy.

REF: CFS122 - Land north of Paglesham Road

Point SP 1.1 (Objectively Assessed Need.) We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

Response:

Rochford District Council has to provide from 331 to 361 houses per annum by the Objectively Assessed Need of. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are also under pressure to supply housing. The authority should meet their requirements and go beyond the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints.' The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Response:

To meet the requirement of 331 homes per annum additional land is required. For this reason option C. Several Small extensions to the existing area would be one good way to achieve the minimum of 331 houses per annum in the Rochford District. As detailed in the site SHLAA summary the site is located close to the existing residential area and be considered a suitable small extension to the existing area.

Point SP 2.2: How do we continue to support local facilities in our village and neighbourhood centres?

The development would support the facilities of the public house close to the site.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

Given the above option A. to Retain the existing Core Strategy policy should be undertaken.

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

Response:

The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always Sustainable.

The Five purposes of the Green Belt are:
1. to check the unrestricted sprawl of large built-up areas;
2. to prevent neighbouring towns merging into one another;
3. to assist in safeguarding the countryside from encroachment;
4. to preserve the setting and special character of historic towns; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

The Councils approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence.
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

The above land referred to the Strategic Housing Land Assessment should be considered, as it meets the requirements for new housing as set out in points one and two above. there should also be an amendment to the current policy to release this site from the Green Belt and hence the support for option B. to amend the current Green Belt policy in the Core Strategy.

*THIS REPRESENTATION HAS AN ATTACHMENT*

ROCHFORD DISTRICT LOCAL PLAN - ISSUES AND OPTIONS CONSULTATION (13 DEC 2017 - 7 MARCH 2018) - Persimmon Homes Representations

1.Introduction

Persimmon Homes welcomes the opportunity to comment on the Issues & Options version of the Rochford Local Plan.

Persimmon Homes are one of the UK's leading builders of new homes with a track record of delivery in the eastern region. They are particularly active in Essex therefore a developer with significant experience of both market and planning issues in the area, as well as being a 'user' of the development plan.

2Scope of representations

Persimmon Homes are promoting residential development at the following sustainable site that would assist Rochford meet its housing needs;

-Land between Western Road and Weir Farm Road, Rayleigh (Site ID CSF087) - this 4.18 ha site was advanced as part of the 2015 call-for-sites. Submitted alongside this letter of representation is a 'Site Deliverability Statement: Development at Land south of Kingswood Crescent, Persimmon Homes, February 2018'.

3Representations

Duty to Co-operate
One of the required outcomes of the Duty to Co-operate is the delivery of full objectively assessed housing needs (OAHN) for market and affordable housing in the housing market area (HMA) as set out in the NPPF (para 47) including the unmet needs of neighbouring authorities where it is reasonable to do so and consistent with sustainable development (NPPF para 182).

The Council defines its Housing Market Areas as including Basildon, Castle Point and Southend-on-Sea.

Local Authorities comprises Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council have formed the Association of South Essex Local Authorities (ASELA). We note that as of the end of 2017 ASELA have prepared a Memorandum of Understanding (MOU). Part of the aims of ASELA is to 'Open up spaces for housing, business and leisure development by developing a spatial strategy'.

It is evident from the experience at Castle Point that certain authorities have expressed a desire not to meet their full OAHN. It remains to be seen the establishment of this body will provide effective governance and a mechanism by which to ensure genuine co-operation to meet full OAHN. Many adjoining authorities within the northern part of Essex have not had to factor in meeting housing growth from ASELA Authorities and are significantly more advanced with their development plans than the majority of South Essex Authorities.

The need for market and affordable homes

Para 5.11 (p27) Strategic Priority 1

We are concerned that the Council's 'Strategic Priority 1: The homes and jobs needed in the area' is too narrow in its scope and does not accord with the NPPF

'To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs through prioritising the use of previously developed land first and working with our neighbours in South Essex'.

This implies that there is two routes to meeting housing and jobs; (1) opportunities on brownfield sites and (2) meeting unmet need via the Duty to Co-operate. The plans strategic policies should seek to deliver 'the homes and jobs needed in the area' in accordance with para 156 of the NPPF. The Council do not have the evidence to establish that it cannot meet its own development requirements. This strategic policy is unduly narrow and restrictive, does not accord with the NPPF and is not supported by evidence.

The issues and options document does not identify that the Council will undertake a Green Belt review. In terms of accommodating sustainable development that allows future generations to meet their needs, an assessment should be made of the wider sustainability issues of meeting its full OAHN housing requirements together with an assessment against the Green Belt purposes. This may lead to the identification of land released from the Green Belt to provide a portfolio of sites and is an arguable 'exceptional circumstance' for reviewing the boundary. The NPPF seeks to align Green Belt boundary review with sustainable patterns of development (paragraph 84).
There is a risk that constraining growth to previously developed land would not enable the Council to address its other strategic objectives, including supporting future housing need and addressing affordability issues (Objective 2) and supporting economic growth (Objectives 3 and 4). Unduly limiting growth would also not support Strategic Priorities 2 and 3 as this would limit growth in the economy and the opportunity to lever investment in infrastructure.

Strategic Priority 1 does not accord with the Governments policy to significantly boost housing supply. The draft amendments to the NPPF also sets out an expectation for objectively assessed needs to be accommodated unless there are strong reasons not to, including any unmet needs from neighbouring areas.

Objectively assessed needs

Council's SHMA identified objectively assessed housing need (OAN) for Rochford of between 331 and 361 dwellings per annum (dpa). 361 dpa is a 41% uplift on the 2014 based household projections. This level of housing is similar to the Government's standard methodology target.

The consultation identifies three options (p38):

A.meet our own needs as far as possible given environmental and other constraints

B.Work with other neighbouring LPAs to ensure the needs of the HMA are met

C.Consider a policy requirement to deliver a percentage of new market homes on schemes to be made available to residents of Rochford first.

These are not mutually exclusive options. The first two are requirements of the NPPF.

As detailed above, we are concerned that the Council's Strategic Priority has been too narrowly framed and is not NPPF compliant. In addition, the Council should commit to a Green Belt review to help it assess the extent it can meet full OAHN and comply with para 14 of the NPPF.

In relation to Option 'c', we consider that there is no national planning policy support to limit a percentage of market homes to qualifying residents of Rochford. Furthermore, such a policy would be anti-competitive and discriminatory. It is relevant to note that no surrounding authorities, including those within the HMA, have policy that seeks to restrict occupation of market homes. Such a policy should impede social mobility, including the need to provide houses to support economic growth.

The Council should plan to meet full OAHN which will ensure that the needs of Rochford are met in full, including for those who aspire or need to live in the borough in the future. We strongly suggest that the Council does not advance option 'C' as to do so would risk the soundness of the plan.

Affordable Homes (p39 - 6.32)

In line with the NPPF, the development plan needs to be deliverable. Levels of affordable housing need to be informed by an assessment of housing need and what developments can viably support. Para 173 of the NPPF is clear that 'the scale of development identified in the
plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened'.

The Council should look to establish the level of affordable housing based on a thorough understanding of development viability. As there is a high level of need, the Council should assess the potential to deliver a higher housing figure as this would increase the total supply.

Homes for older people and Adults with disabilities

Any policy on optional accessibility standards will need to be fully justified, as required by paragraph 56-007 in PPG, on the basis of need, viability and the accessibility and adaptability of the existing housing stock.

Council needs to consider the impact on viability of the scale of obligations and policy burdens sought, including delivering both the lower and higher accessibility standards set out in part M4 of the Building Regulations.

Part M4(3) should not be application to market homes. PPG states: "Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling."

(Paragraph 56-009).

Delivering our Need for Homes (p46)

We note the existing settlement hierarchy.

It is too early in the process to discount any of the options set out at para 6.48. It is considered that the Council should not unduly constrain itself and needs to fully investigate the options based on robust evidence. We consider that the Council should undertake a review of its Green Belt and assess the extent to which this could assist in meeting the full OAHN.

In terms of option 'E' 'A new settlement', the Council will need to consider the extent to which this could be delivered within the plan period, the associated complexities and the critical mass needed to ensure it would be sustainable.

Good Mix of Homes (p46-48)

We support Option A which retains a flexible approach to the type of market homes delivered. It is considered that a target a mix for affordable homes is appropriate, subject to flexibility to ensure that it can reflect the specific circumstances of the site.

Option C - The current adopted plan contains minimum habitable floorspace standards within Table 3. Whilst the 'National Technical Housing Standards - nationally described space standards' have superseded these by default, it is relevant to note that the Council Standards were derived from HCA and are in the most part are not as high as the NPSS. Therefore the previous plan assessed a less onerous standard.
Paragraphs 174 and 177 of the NPPF make it clear that via the Local Plan process LPAs should assess the cumulative impact of policy burden, including housing standards, to ensure that it does not put implementation of the plan at serious risk.

The new Ministerial Statement stated the following: "The optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the National Planning Policy Framework and Planning Guidance."

Accompanying this, Paragraph 001 Reference ID:56-001-20150327 of the NPPG made it clear that LPAs will need to gather evidence to determine whether there is a need for additional standards in their area and justify setting appropriate policies in their Local Plans. Paragraph 002 Reference ID 56-002-20160519 of the NPPG confirms that LPAs should consider the impact of using these standards as part of their Local Plan viability assessment.

The new NPPG section provided substantial guidance in terms of the implementation of the new regime including specific advice on the individual standards which are discussed below.

NPPG sets out clear criteria which Councils must satisfy in order to adopt optional NDSSs over and above the requirements of Building Regulations.

Where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:

*need - evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.

*Viability - the impact of adopting the space standard should be considered as part of a plan's viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.

*timing - there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.

The guidance effectively sets out three stages which must be overcome to ensure the NDSSs are only applied where needed and impacts are fully considered.

In the recently Housing White Paper the Government have confirmed their view that the fundamentals of the Building Regulations system remain sound and that important steps were taken in the last Parliament.

In relation to Space Standards, paragraph 1.55 states that "the use of minimum space standards for new development is seen as an important tool in delivering quality family homes. However the Government is concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. For example, despite being highly desirable, many traditional mews houses could not be built under today's standards.
We also want to make sure the standards do not rule out new approaches to meeting demand, building on the high quality compact living model of developers such as Pocket Homes. The Government will review the Nationally Described Space Standard to ensure greater local housing choice, while ensuring we avoid a race to the bottom in the size of homes on offer."

The above confirms the Government's intentions to review NDSSs. This does not have any immediate impact upon Colchester's emerging plan. However, it does demonstrate the Government's unease with a one size fits all approach and its desire to ensure greater local housing choice. Unfortunately, introduction of the NDSSs would narrow the choice available at the expense of affordability and viability.

Option E - We do not consider it appropriate to include a requirement for bungalows. This would reduce the density of development. In addition, modern homes are often capable of adaptable to assist accessibility.

In terms of density (p50), we support the Council's use of minimum density to ensure efficient use of land. The Council will need to ensure it is clear as to where higher minimum densities would be appropriate and assess where these should apply. If higher densities are applied in certain locations, policies should be framed to ensure that there is a recognition that new development may be of a scale and density which is distinct from the prevailing character of the area.

Renewable Energy Generation (p98)

The cost of any additional measures will need to be factored into an assessment of viability.

Planning Obligations and Standard Charges (p99)

The Council should ensure that reliance upon s106 with the associated pooling restrictions do not impede growth. The options do not consider the role of CIL.

Early Years and Childcare Provision (P109)

It is considered that whilst expanding existing education facilities may play a role, the scale of development may warrant identifying sites for education purposes. It is considered that this option should not be ruled out.

Open Space and Outdoor Sports and Recreation (p115)

The Council should not only review its policy, but look at the opportunities that development brings to secure new open space and Green Infrastructure.

As detailed in the attached promotional document, the development of part of land between Western Road and Weir Farm Road, Rayleigh (CSF087) provides the opportunity to formalise footpath routes and improve access to Green Infrastructure in this locality.
Green Belt (p121)

As detailed above, the Council needs to consider its options to meet its full OAHN, including the implications for the Green Belt in doing so. The Council need to undertake a review of its Green Belt to understand the degree to which land under this designation continues to support the purposes as set out in paragraph 80 of the NPPF and to consider whether there are any exceptional circumstances that would support amendments to the current boundary.

It is considered unhelpful to frame the options in relation to the current Core Strategy which addresses a different plan period and does not seek to meet the current OAHN.

Good Design and Building Efficiency (p135)

Paragraph 10.63 sets out seven options with regard efficiency standard in buildings.

We support option G not to have a policy on energy efficiency standards. Any other approach would be inconsistent with the Government's approach to building standards which it limits to those optional technical standards set out in the PPG.

Mix of Affordable Homes

It is evident that the Council needs to deliver more housing, including affordable housing. We consider that the Council's policy needs to be reviewed in light of evidence of need, viability and changes to national guidance. The government introduced 'affordable rent' in 2011 and this needs to be reflected in policy.

Self Build and Custom Homes

Emphasis should be on the local authority using their own land and as part of their overall housing strategy finding the necessary plots. Option A is inconsistent with national policy as it seeks to impose a proportion of self-build plots on developers. We recommend that the option B is the most appropriate.

Development of Previously Developed Land in the Green Belt (p156)

As part of the Green Belt review the Council should look at opportunities to develop previously developed sites in the Green Belt. In undertaking this exercise, the Council should look at the opportunities this presents to build sustainable extensions to settlements and the benefit that may arise in terms of providing affordable housing within settlements that may not otherwise arise. Sites of former glasshouses and redundant agricultural buildings close to or within settlements offer opportunities for housing.

I would be grateful if you could acknowledge receipt of these representations.

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council in
support of land to the south of the former Adult Community Learning Centre ("ACL Centre"),
Rocheway, Rochford (hereby referred to as the "Site").
1.2 The Site is owned by Essex County Council ("ECC") and is currently designated as open space in
the adopted Local Plan. It is used under licence for 10 months of the year by Hambro Colts, a local
youth football team which has aspirations to relocate back to its original home in Rayleigh and is
working collaboratively with ECC to do so. The site is not used for any other purpose despite its
designation.
1.3 The New Local Plan presents Rochford District Council (RDC) with an opportunity to take a
comprehensive approach to the consideration of open space provision alongside housing and
employment strategies, considering the re-provision of existing open spaces where this would
support sustainable patterns of development, where appropriate. This should be informed by
emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
1.4 In this context we therefore consider that the Site has excellent residential redevelopment potential
taking account of its sustainable location within walking distance of Rochford town centre and the
opportunity presented by the extant planning permission for the redevelopment of the former ACL
Centre, granted under 17/00102/FUL, which would provide means of vehicle access to the Site
from the north.
Summary of representations
1.5 Taking account of the above, our representations may be summarised as follows:
● We consider the RDC should plan to meet its full objectively assessed housing need across
the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order
settlements in the hierarchy, such as Rochford;
● We consider that RDC needs to undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate.

2.0 The Site

2.1 The extent of the Site is shown on the accompanying plan at Appendix 1 of this document. The Site is currently designated as open space under adopted policy OSL1 and it falls within the Green Belt.

*PLEASE SEE ATTACHMENT FOR MAP* Above: The Site in context. Note its proximity to Rochford town centre approximately 400 metres to the west.

2.2 The Site is formed of playing fields to the south of the former ACL Centre, constructed in the mid-
1930s as a school which was later converted to its most recent use. The designated open space to the south of the ACL was therefore originally intended as a playing field for the school and not as a purpose built public space.

2.3 The Site is defined by strong physical hedgerow boundaries to its western, southern and eastern sides. Designated amenity open space at Millview Meadows is immediately to the west of the site and arable agricultural land is to the east. The Site located within easy walking distance of Rochford town centre's many services, facilities and retail offer via safe, convenient and well-lit pedestrian routes. Rochford town centre also offers regular bus routes to Southend-on-Sea and Rayleigh and mainline railway links to London Liverpool Street and London Southend Airport. The Site is considered to be sustainably located.

The playing pitches on the Site are currently used under licence for 10 months of the year by the
Hambro Colts, a Rayleigh-based youth football team, for training purposes and on matchdays. The
pitches remain unused for the remainder of the monthly schedule. The Hambro Colts temporarily
relocated from Rayleigh to the current Rocheway Site some years ago, but due to a lack of
available alternative site in the Rayleigh area, have not been able to return to their home location.
It is the club's ultimate intention to do so and is in collaboration with ECC to ensure that suitable
facilities can be delivered equitably.

2.5 Taking account of these existing constraints, we recognise that the appropriate manner for this development potential to be realised is through the new Local Plan, in full consultation with the relevant statutory bodies. This would ensure that any requirements for the quanta and location of open space re-provision may be devised in a collaborative way and in accordance with emerging evidence of need. We also propose that the Green Belt boundary is amended as part of the new Local Plan so that the Site may be included within a revised development boundary for Rochford.

3.0 The Evidence Base
Strategic Housing Land Availability Assessment
3.1 The Strategic Housing and Economic Land Availability Assessment (SHELAA), prepared in 2017,
identifies that the Site is suitable, available and that housing development is achievable. A copy
of that assessment is contained at Appendix 2 of this document.
Open Space Provision
3.2 The evidence of relevance to the Site includes the Open Space Study (2009) and Playing Pitch
Strategy (2012), both prepared by RDC in support of its adopted Development Plan. They
identified at the time of their publication that:
● The Site is one of 48 outdoor sports facilities in the District, which collectively provide a total of
1.6 hectares per 1000 population (excluding golf courses) across Rochford. This falls slightly
short of the recommended 1.8ha per 1000 population standard;
● When provision is assessed across the District by ward, the ward in which the Site is located
has an identified surplus in provision;
● There is an imbalance in geographical spread of play space provision - players tend to reside
on the western side of the District (i.e. Rayleigh and to the west of the District in Wickford and
Basildon) thus clubs travel further to the east (including Rochford) to use pitches.
● There is a shortage of mini and junior football pitches - note that during its preparation, the
Playing Pitch Strategy identified the opening of a new facility at Priory Chase in Rayleigh which includes three mini pitches and two junior pitches. As this new facility was not considered as part of the study, it is considered that this provision would contribute to the shortage - both in terms of geographical spread and type of playing space; and
● Outdoor sports facilities are one of the least visited types of open space, assessed as being only moderately needed in the District, after other types of open space such as natural and semi-natural greenspaces, amenity spaces and play space;
● The Site at Rocheway is listed in the Open Spaces Study as an "Outdoor Sports Facility" but, unlike other such facilities listed in the document, is not individually assessed. The evidence therefore provides no overall conclusion or commentary on the quality or suitability of the Site for recreational purposes at present. We would expect this to be updated and to include the Site as part of the evidence base underpinning the new Local Plan.

3.3 It is possible to ascertain from the above that any historic under-provision of playing pitches in the District may have been met by the introduction of new dedicated play space in the western side of the District, thereby re-balancing an uneven geographical spread previously weighted more heavily to the east.

3.4 It is there of utmost important that RDC updates its assessment of open space provision and need as part of the new Local Plan, including all sites currently designated as open space including an assessment of the Rocheway Site.

4.0 Responses to Issues and Options Questionnaire

4.1 Taking account of the above, we set out our responses to the questions raised in the Issues and Options document which are of relevance to Rochford and to the Site.

Strategic Priority 1: The homes and jobs needed in the area
Question SP1.1 - We have a real identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?
Our comments on the identified issues in respect of objectively assessed housing need:

4.2 We support RDC's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District.

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

Our comments on the identified options in respect of objectively assessed need:

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

4.5 Taking account of the issues highlighted above, we consider that Option A is the most appropriate; RDC should seek to provide as much of the district's housing need within its own area. If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

4.6 RDC should therefore plan to meet its full OAHN within its own administrative boundaries as part of the new Local Plan.

Question 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?
Our comments on the issues:

4.7 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011), as follows:

TIER SETTLEMENTS
1 Rayleigh;
Rochford / Ashingdon;
Hockley / Hawkwell.
2 Hullbridge;
Great Wakering
3 Canewdon
4 All other settlements

4.8 The table shows that Rochford sits within the top tier of settlements in the adopted Core Strategy.

Having regard to its sustainable location with easy access to public transport opportunities including mainline rail and London Southend Airport, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core
Strategy was adopted.

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

We consider that option D is the most appropriate method of meeting RDC's housing needs.
Taking account of the district's spatial and environmental characteristics, existing settlement
hierarchy and structure, several fewer larger extensions to existing sustainable settlements
including Rochford provide the only realistic method of delivering on the scale required to meet
RDC's full OAHN.
4.11 Our reasoning for this approach is because options A and B would drastically alter the character
of existing settlements and residential land allocations to the extent that would be damaging to
existing character and environmentally. Furthermore these options would be ineffective in meeting
the scale of OAHN the Plan needs to accommodate over the next 20 years.
4.12 We do not consider that Option C would deliver sufficient CIL or s106 receipts to enable the
cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

4.13 Option E would require such substantial infrastructure and funding to make development both acceptable and deliverable and this would seriously inhibit the ability of development to deliver other planning policy objectives, such as affordable housing provision. In any event, we do not consider that the district displays the type of spatial characteristics that could allow it to successfully accommodate a new settlement under Option E.

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

Strategic Priority 4: Supporting Health, Community and Culture

Question SP4.3 - How do we plan to meet the needs for open space, sports and recreational facilities across the district over the next 20 years?
Our comments on the identified issues:

4.15 We note and support RDC in updating its evidence on the demand for playing pitches and that this is needed to inform the planning of future provision. We also support the collaboration with neighbouring authorities on a strategic scale because this would capture trends of movement to and from areas of open space that might otherwise remain unidentified. It is evident from the existing evidence base (refer to section 3 of this document above) that it is not possible for RDC to make informed (and therefore sound) decisions on spatial planning matters without first having a full appreciation of the quantum and quality of all existing open space within the District, including the Rocheway Site.

We also consider that the updated evidence should form part of a comprehensive strategy that considers housing and economic development needs in the round. This is particularly important because as Rochford is a Green Belt authority, it falls to be considered under Framework paragraph 84 in which RDC will need to consider the need to promote sustainable patterns of development as part of a Green Belt Review. Furthermore, Framework paragraph 74 allows the replacement of existing open space with equivalent or better provision in terms of quality and quantity in suitable locations.

4.17 Where under-utilised open space exists in sustainable locations, it would be inappropriate for RDC to overlook the development potential of such sites if such opportunities were considered alongside proposals for their re-provision in more suitable locations, where appropriate.

4.18 The policy approach to this is supported by National Planning Policy Framework paragraph 158 which, in respect of plan-making, says that "local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated and that they take full account of relevant market and economic signals." Furthermore, paragraph 70 says that planning policies and decisions should ensure an integrated approach to considering the location of housing, economic uses and community facilities and services."

4.19 We consider that RDC should use the Local Plan Review to comprehensively consider its approach to the provision and location of open spaces so that opportunities for their use and participation in sport may be maximised. Such an approach would enable new development to be delivered in the most sustainable locations, boosting the health of the community, therefore delivering a range of wider sustainability objectives.
Our comments on the identified options:
4.20 The options set out are:
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.

4.21 We consider that RDC should pursue option B. We recognise the value of designated existing open space but the policy must be updated where relevant to properly reflect the most up-to-date evidence of identified local need. This should take account of shifts in patterns of development, take account of new development and changing trends in use of open space, including playing pitches. Crucially the evidence needs to fully assess in quantitative and qualitative terms the quality of all presently designated open spaces across the district, including the Rocheway Site.

4.22 The designated open space at the Site on Rocheway is only used by one youth football team under licence for 10 months of the year. It is not used by any other group at any other point despite its open space designation. If the existing youth football team were to relocate to premises better suited to its requirements, coupled with an emerging RDC open space strategy that enables the re-apportionment of open space where evidenced, this would present an excellent opportunity for the Site to be re-allocated for residential development; in a sustainable location. This would make
best use of underutilised land and would promote sustainable patterns of development. We recognise and would support the reapportionment of designated playing pitches undertaken in full collaboration with Sport England.

Strategic Priority 5: Protecting and Enhancing our Environment

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 the wider South Essex area?

Our comments on the issue are as follows:

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

4.24 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries
(paragraph 84). Furthermore, it says that local planning authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).
4.25 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.
Our comments on the options:
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.

4.26 We support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's FOAN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A Green
Belt Review would enable RDC to assess land parcels against the five Green Belt purposes:
● to check the unrestricted sprawl of large built-up areas;
● to prevent neighbouring towns merging into one another;
● to assist in safeguarding the countryside from encroachment;
● to preserve the setting and special character of historic towns; and
● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4.27 Only once the Green Belt Review is complete, RDC may then come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

5.0 Summary

5.1 These representations have been prepared on behalf of Essex Housing, Essex County Council, in support of the Land south of the former Adult Community Learning Centre, Rocheway, Rochford.
5.2 The site is currently designated as open space in the Local Plan but it is only used by one youth football team, Hambro Colts, who have aspirations to relocate back to a suitable site closer to their original home in Rayleigh. The Colts are in collaboration with ECC to enable them to do so.
Allocation of this underused, yet sustainably located, parcel of land for residential development would enable Rochford District Council to:
● Promote sustainable patterns of development in the New Local Plan; and
● Plan for open space and playing pitch provision in a comprehensive manner, taking account of
emerging evidence of need, housing and employment growth.
5.3 Our review of RDC's evidence base of relevance to open space provision reveals that it needs to be fully updated as part of the new Local Plan process and that its scope needs to include all sites currently designated as open space. The evidence underpinning the adopted Development Plan suggests that this is presently not the case. Only with a comprehensive assessment of such provision could RDC make fully informed, robust and therefore sound planning policy decisions on the District's growth.
5.4 In conclusion we therefore consider that:
● RDC should plan to meet its full objectively assessed housing need across the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order settlements in the hierarchy, such as Rochford;
● RDC should undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate. This should be informed by emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
● The Site is considered favourably in the SHELAA in which it is defined as suitable, available and that development would be achievable.

RE: Land south of Pooles Lane, Hullbridge

Point SP 1.1 (Objectively Assessed Need.) We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

Response:

Rochford District Council should provide the housing in the district as required by the Objectively Assessed Need of between 331 to 361 houses per annum. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are also under pressure to supply housing. Neighbouring Authorities may also be relying on Rochford to meet their deficit in supply. Rochford District Council should ensure they have a supply to meet their minimum requirements, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints.' To achieve this the Council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below to meet the demands.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Response:

Additional from that land already in the SHLAA the above land should be included in the local plan for future development to meet the target of supplying at least 331 houses per annum. For this reason option C. (Several Small extensions to the existing area) would be one good way to achieve the annual housing requirement in the Rochford District. This site would be considered a small extension to the existing residential area and help meet Rochford Councils requirements.

Point SP 2.2: How do we continue to support local facilities in our village and neighbourhood centres?

The development would support the village services including shops and public houses. The site would be within 800m to these services showing easy access to these.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

The development of the site would further increase the demand and support the need for the village services in Hullbridge improving the sustainability of these services.

Given the above option A. should be adopted to retain the existing Core Strategy policy.

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

Response:

The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as repeated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always Sustainable.

The Five purposes of the Green Belt are:
1. to check the unrestricted sprawl of large built-up areas
2. to prevent neighbouring towns merging into one another
3. to assist in safeguarding the countryside from encroachment
4. to preserve the setting and special character of historic towns, and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

The Councils approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are
1. Continue to protect the openness and character of the District's Green Belt
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regarding to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

The above land should be considered, as it meets the requirements for new housing set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites along with the above from the Green Belt easier and hence the support for option B. to amend the current Green Belt policy in the Core Strategy.

REF: CFS111/CFS112/CFS113/CFS114/CFS124 - Land around Stambridge

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

Rochford District Council has a duty to provide between 331 to 361 houses per annum by the Objectively Assessed Need. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are also under pressure to supply housing and suffer similar limitations on development. Neighbouring authorities may even rely on Rochford to supply their shortfall. Rochford Council should ensure they meet the requirement and go further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints. The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Response:

Future development can only be met with additional land and to comply with the target of supplying 331 houses per annum. For this reason option C. Several small sections to the existing area would be the best way to achieve the minimum of 331 houses per annum in the Rochford District. As detailed in the site SHLAA summary the site is located close to the existing residential area and be considered a small extension to the existing area.

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

Response:

The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

Given the above the land referred to in the Strategic Housing Land Assessment should be considered as it meets the requirements for new housing as set out in points one and two above. There should also be an amendment to the current policy to release this land from the Green Belt, hence the support for option B to amend the current Green Belt policy in the Core Strategy.

REF: CFS075 - Land at Canewdon Hall Farm, Canewdon

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

Rochford District Council must provide between 331 to 361 houses per annum in the district as required for by the Objectively Assessed Need. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these authorities are equally under pressure to supply housing. The authority should ensure they have a supply to meet the requirements, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints. The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Response:

Additional land should be included in the local plan for future development to meet the target of supplying no less than 331 houses per annum. For this reason Option C. Several Small extensions to the existing area would be one good way to achieve the annual house obligation in the Rochford District. As detailed in the site SHLAA summary the site is located close to the existing residential area and should be considered a suitable small extension to the existing area.

Point SP 2.2. How do we continue to support local facilities in our village and neighbourhood centres?

The development would support the village services including shops and public houses. The site would be within 575m to these services showing easy access to these.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

The development of the site would increase the demand and support the need for the village services in Canewdon improving the sustainability.

Given the above option A. should be adopted to retain the existing Core Strategy policy.

Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?
The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

Given the above the land referred to in the Strategic Housing Land Assessment should be considered. The land meets the requirements for new housing set out in points one and two above. There should also be an amendment to the current policy to release this sustainable site from the Green Belt, hence the support for option B to amend the current Green Belt policy in the Core Strategy.

REF: CFS058 - Land South of Anchor Lane, Canewdon

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

Rochford District Council should provide between 331 to 361 houses per annum in the district as required for by the Objectively Assessed Need. Rochford Council should not rely on neighbouring authorities Duty to Cooperate to assisting in providing this. Neighbouring authorities are also under pressure with similar constraints to supply housing at themselves may rely on neighbouring authorities to meet their underperformance. Rochford District Council should ensure they achieve the minimum requirements, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints. The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Additional land should be included in the local plan for future development to meet the target of supplying at least 331 houses per annum. For this reason Option C. Several Small extensions to the existing area would be one good way to achieve the minimum of 331 houses per annum in the Rochford District. As detailed in the site SHLAA summary the site is located close to existing residential area and be considered a small extension to the existing area to make use of the services Canewdon already benefits from.

Point SP 2.2: How do we continue to support local facilities in our village and neighbourhood centres?

The development would support the village services including shops and public houses. The site would be within 650m to these services showing easy access to these.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

The development of the site would further increase the demand and support the need for the village services in Canewdon improving the sustainability of these services, as set out in the SHLAA suitability summary.

Given the above option A. should be adopted to retain the existing Core Strategy policy.

Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?
The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

Given the above the land referred to in the Strategic Housing Land Assessment should be considered in the local plan. The land meets the requirements for new housing as set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites like this from the Green Belt easier and hence the support for option B to amend the current Green Belt policy in the Core Strategy.

REF: CFS067 - Land at Three Ashes Farm, Rochford

Point SP 1.7: How do we sustainably meet business needs over the next 20 years?

Response:

The land referred to above would contribute towards the expansion of existing employment land at Purdeys Way. The land is also close to London Southend Airport, and so could assist in realising the economic potential of London Southend Airport. The site would assist the borough in delivering land to support the additional 3,000 new jobs over the plan period and as required by the former East of England Plan 2008.

At point 6.90 two constraints of the commercial development are the limited transport links, and rural nature of the district. The site is close to bus services, train services, the road network and air travel. The land is surrounded by residential and commercial land and so although currently in arable cultivation, does not offer open countryside views from any angle and so would not adversely impact the rural nature of the district.

Given the above option A. to continue to support employment growth within the current employment growth policy should be adopted, but ensure additional land is included in this.

Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?
The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

Given the above the land in in the Strategic Housing Land Assessment referred to above should be considered, as it meets the requirements for employment land as set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites like this from the Green Belt and hence the support for option B to amend the current Green Belt policy in the Core Strategy.

REF: CFS090 - Land south of Paglesham Road, Paglesham East End

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

Rochford District Council should provide the housing in the district as required for by the Objectively Assessed Need of between 331 to 361 houses per annum. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are also under pressure to supply housing. The authority should ensure they have a supply to meet this, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints. The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Response:

Additional land should be included in the local plan for future development and to meet the target of supplying at least 331 houses per annum. For this reason option C. Several Small extensions to the existing area would be one good way to achieve the minimum of 331 houses per annum in the Rochford District. As detailed in the site SHLAA summary the site is located close to the existing residential area and be considered a suiable small extension to the existing area.

Point SP 2.2: How do we continue to support local facilities in our village and neighbourhood centres?

The development would support the village services including public houses. The site would be within 10m to these services showing easy access to these.

'Core Strategy policy RTC3 seeks to protect retail uses within residential areas and will only permit the loss of such retail uses where it has been clearly demonstrated that a retail use in the location is not viable and that the proposed alternative use will still offer a service to the local community that meets day-to-day needs.'

The development of the site would further increase the demand and support the need of the village services in Paglesham improving the sustainability of these services.

Given the above option A. should be adopted to retain the existing Core Strategy policy.

Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?
The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

Given the above the land in in the Strategic Housing Land Assessment referred to above should be considered, as it meets the requirements for new housing as set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites like this from the Green Belt easier and hence the support for option B to amend the current Green Belt policy in the Core Strategy.

RE: Land north of Rectory Road and west of Windsor Gardens, Hawkwell

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

Rochford District Council should provide the housing in the district as required for by the Objectively Assessed Need of between 331 to 361 houses per annum. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are also under pressure to supply housing. The authority should ensure they have a supply to meet this, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints.' The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

The above land could meet at least one year's housing supply if it was developed at the minimum density of 30 houses per hectare by producing approximately 435 homes.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Additional land should be included in the local plan for future development to meet the duty of providing at least 331 houses per annum. For this reason Option C. Several Small extensions to the existing area would be one good way to achieve the minimum of 331 houses per annum in the Rochford District.

The land is bound by residential development and as below would confirm with its removal from the Green Belt as it would not have an impact of the openness of the countryside given its neighbouring surroundings of the leisure centre, residential development and close proximity of the railway line.


Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?
The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

The above land should be considered as it meets the requirements for new housing as set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites like this from the Green Belt easier and hence the support for option B to amend the current Green Belt policy in the Core Strategy.

RE: Land at Newhouse Farm, Great Wakering

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

Rochford District Council should provide the housing in the district as required by the Objectively Assessed Need of between 331 to 361 houses per annum. Rochford Council should not rely on neighbouring authorities Duty to Cooperate as these areas are equally under pressure to supply housing. The authority should ensure they have a supply to meet the requirements, going further than the proposed option A. 'Seek to provide as much of the district's housing need within our area, as far as possible, given environmental and other constraints. The council must consider releasing more land from the Green Belt, as detailed in the response to Point SP 5.1 below.

Point SP 1.3: How do we plan to facilitate the delivery of our need for new homes over the next 20 years within the district?

Additional land should be included in the local plan for future development to meet the target of supplying at least 331 houses per annum. For this reason Option C. Several Small extensions to the existing area would be one good way to achieve the minimum of 331 houses per annum in the Rochford District. Given the small size of the site, the land should be considered as a small extension to the residential boundary.

Point SP 5.1: How do we balance protection of the district's Green Belt that the meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district and the wider South Essex area?
The principle of the Green Belt is to keep a sense of openness between built up areas. The development of the Green Belt should only happen in exceptional circumstances, but as reiterated by Government publications the plan-led system should review the existing Green Belt boundary to ensure development is always sustainable.
The Five purposes of the Green Belt are:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The Council's approach to the Green Belt is set out in the Core Strategy adopted in December 2011. The four objectives of the Core Strategy for the Green Belt are;
1. Continue to protect the openness and character of the District's Green Belt.
2. Ensure the minimum amount of Green Belt is allocated to meet the District's housing and employment needs, and that extensions to the residential envelope are in sustainable locations, which retain the individual identities of settlements and prevent coalescence
3. Ensure existing lawful businesses in the Green Belt are able to continue to function and contribute to the local economy, as appropriate, having regard to the impact on the openness and character of the Green Belt.
4. Ensure appropriate forms of diversification are encouraged to support the local rural economy and help achieve the vision of developing green tourism in the District.

The above land should be considered to removal from the Green Belt, as it meets the requirements for new housing as set out in points one and two above. There should also be an amendment to the current policy to release sustainable sites like this from the Green Belt easier and hence the support for option B to amend the current Green Belt policy in the Core Strategy.

*THIS REPRESENTATION INCLUDES MAPS AND TABLES WHICH ARE CONTAINED WITHIN THE ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Great Wakering', Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Great Wakering from the Green Belt alongside the provision of a strategic
site-specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) and offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 considers the site, surroundings and suitability;
* Section 3 considers the strategic policy context;
* Section 4 outlines the District's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 summarises the relevant procedural considerations;
* Section 7 responds to specific questions raised by the consultation; and
* Section 8 sets out the case for exceptional circumstances and concludes the
report.

2. SITE, SURROUNDINGS AND SUITABILITY

2.1 The Site extends to approx. 127 acres / 51 hectares, located on the southern
edge of Great Wakering, as shown in Appendix 1.

2.2 The site is located in the south-east of the District, directly to the south of Great
Wakering. Southend Victoria Railway Station is located approximately 6.2km to
the west of the site; Southend Airport is located approximately 7.5km to the
north-west and the Essex coastline is located approximately 1.1km to the southeast
of the site as shown in Figure 1 below.

Figure 1: Land at Great Wakering in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.


Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, with intermittent trees and
hedgerows on all sides, with built form associated with Great Wakering, including
residential properties adjacent to the north, east and western boundaries. The
Great Wakering Primary School adjoins the north-western corner of the site and
an existing farm and associated buildings is located to the south and partially
dissects the site.

2.6 The site is bound by Poynters Lane to the south and Shoebury Road to the east,
with the built extent of North Shoebury situated approximately 600m to the west
and Shoeburyness approx. 425m to the south.

Site Deliverability
2.7 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

2.8 Table 1 below provides a summary of the site's suitability to accommodate
development, indicating the local planning policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Residential and community land uses to the
north, east and west;
Agricultural (arable) land to the south.
Flood Zone Primarily located in Flood Zone 1 (lowest probability) with a small area of the site within Flood Zone 2 & 3 in the south-east corner. Given the size of the overall site, it is envisaged that any future scheme can be designed around this and provide suitable flood risk mitigation.
Public Rights of Way Yes
A single PROW runs through the centre of the site in a north-south direction.
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape
Character Area No
Contamination No
Conservation Area No
The Great Wakering Conservation Area is located 100m to the north of the site beyond intervening existing residential properties
Listed Buildings No
The Great Wakering Conservation Area (approx. 100m to the north) contains a number of Listed Buildings
Area of Archaeological Importance /
Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No
The Foulness Coast SSSI is located approx. 400m to the south-east at the closest point
SSSI Impact Risk Zone Yes
Associated with the Foulness Coast SSSI
National / Local Nature Reserve No
RAMSAR Site No
The Foulness Coast RAMSAR is located approx. 400m to the south-east at the closest point
Special Area of Conservation No
The Essex Estuaries SAC is located approx. 1km to the south-east at the closest point
Special Protection Area No
The Foulness Coast SPA is located approx. 400m to the south-east at the closest point
Site of Nature Conservation Importance No
Ancient Woodland No
Sustainability The site is located directly adjacent to Great Wakering which is identified as a Second Tier Settlement within the adopted Core Strategy
(2011), which benefits from a reasonable range of social and community infrastructure (services and facilities) and access to public transport. Accordingly, Great Wakering is considered to be a reasonably sustainable location suitable to
accommodate additional growth to meet identified housing needs and ensure the future vitality and viability of the town and associated community services.

2.9 As demonstrated in Table 1 above, the site is therefore identified as suitable for
development with no insurmountable physical, technical or environmental
constraints to development.

Site Availability

2.10 The site is under single freehold ownership and comprises open arable
agricultural land on the southern edge of Great Wakering.

2.11 There are no legal constraints to the availability of the land for development.

2.12 The landowner is willing to make the site available for development and Taylor
Wimpey (a national housebuilder) is actively promoting the site through the
emerging Local Plan.

2.13 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available for development within the emerging
Plan period.

Site Viability

2.14 The site comprises open arable agricultural land (i.e. Greenfield Land) and whilst appropriate mitigation will be required to address potential flood risk and
ecological considerations, it is not anticipated that there will be any abnormal
costs associated with the development of this site as may be expected on
previously developed (brownfield) land.

2.15 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Development Vision

2.16 Taking into account the characteristics of the site, it is envisaged that a suitable
and deliverable development can be accommodated at the site without reducing the 'gap' in built-form between Great Wakering and North Shoebury/Shoeburyness to the south and west and allowing for suitable flood mitigation and ecological measures to the south-east.

2.17 The promotion of this site assumes that 60% of the site (approx. 30.6ha) will be developable at an average density of 35 dwellings per hectare, equating to a total
potential yield of circa 1,100 new homes.

Conclusions - Implications for the New Local Plan
* The site is suitable for residential development with no insurmountable
environmental, technical or social infrastructure constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in years 2020-2036)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing
3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt
3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.
3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional circumstances', through the preparation of the Local Plan. At such time, LPAs should consider Green Belt boundaries having regard to their intended
permanence in the long term, so that they should be capable of enduring beyond
the Plan period (paragraph 83). The implication of this criteria being that where
significant development pressure exists and exceptional circumstances are
warranted to develop in the Green Belt, it is considered appropriate for LPAs to
seek to remove such sites from the Green Belt through the Local Plan-making
process in order that they can deliver sustainable development to meet their
identified development needs.

3.10 The Government's consultation on a Revised NPPF (March 2018) seeks to define what constitutes 'exceptional circumstances' at paragraphs 135 and 136 as
follows:

135. Once established, Green Belt boundaries should
only be altered in exceptional circumstances, through
the preparation or updating of plans. Strategic plans
should establish the need for any changes to Green Belt
boundaries, having regard to their intended permanence
in the long term, so they can endure beyond the plan
period. Where a need for changes to Green Belt
boundaries has been demonstrated through a strategic
plan, detailed amendments to those boundaries may be
made through local policies, including neighbourhood
plans.

136. Before concluding that exceptional circumstances
exist to justify changes to the Green Belt boundaries, the
strategic plan-making authority should have examined
fully all other reasonable options for meeting its
identified need for development. This will be assessed
through the examination of the plan, which will take into
account the preceding paragraph, and whether the
strategy:
a) makes as much use as possible of suitable brownfield
sites and underutilised land;
b) optimises the density of development, including
whether policies promote a significant uplift in minimum
density standards in town and city centres, and other
locations well served by public transport; and
c) has been informed by discussions with neighbouring
authorities about whether they could accommodate
some of the identified need for development, as
demonstrated through the statement of common ground.

3.11 It is anticipated that the above definitions will be incorporated within a revised
NPPF to be published in Summer 2018.

3.12 The NPPF (2012) continues that when drawing up or reviewing Green Belt
boundaries, LPAs should take account of the need to promote sustainable
patterns of development (paragraph 84). Sustainable patterns of development
are not defined in policy. However, this is considered to relate to taking into
account a range of additional factors beyond the contribution towards Green Belt
purposes. These factors might include local development needs, public transport
availability and local highways capacity and accessibility to local services and
social infrastructure. With regard to sustainability, it is necessary to recognise
the wider and updated context of how sustainable development is defined in the
NPPF as set out in paragraph 7 whereby it should contribute towards social,
economic and environmental objectives.

3.13 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.14 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.15 In summary, the NPPF and anticipated revisions to the NPPF, supports the longstanding principles of Green Belt protection, whilst acknowledging that the
objectives of the planning system continue to evolve, reflecting current land use
pressures and social needs. The Government's priority is to deliver growth and
sustainable development through harmonising, wherever and whenever possible,
the social, economic and environmental processes that deliver sustainable places.
Policy also reinforces the plan-led system which gives planning authorities the
power to undertake Green Belt reviews to help inform the emerging spatial
strategies necessary in order to meet development needs. The role and function
of the Green Belt therefore needs to be considered within this overarching context
to assist in the delivery of sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 The following seeks to highlight the significant development needs within the
District and the associated need to bring forward suitable and sustainable Green
Belt sites in order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
(upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy.

4.8 RDC should carefully consider the significant social implications associated with
not meeting objectively assessed / identified needs, which in particular is likely to
exacerbate an increasing affordability problem for all sections of the community.
Not meeting objectively assessed needs is likely to increase pressure on RDC to
find affordable homes for young people and families and accommodation for an
ageing population whilst also making it harder for local businesses to find and
retain employees.

Supply

4.9 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.10 The NPPF requires (paragraphs 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.11 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.12 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.13 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.14 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.15 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.16 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.17 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible; however, it has indicated that it may not be able to meet all of its needs within its own boundary.

4.18 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas within the Borough. The Council's proposed New Local Plan (2016) sought
to meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.19 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Councils and accordingly any flexibility in housing supply in Chelmsford is likely to
be taken up by these authorities in the first instance.

4.20 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southend, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.21 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.22 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.23 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities' unmet housing needs and are facing their own significant challenges
in meeting identified needs.

4.24 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Great Wakering.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 The following therefore provides an assessment of the site's contribution towards
the purposes of the Green Belt in order that the potential 'harm' of its loss can be
appropriately considered.

Green Belt Purpose 1: To check the unrestricted sprawl of large built-up
areas

5.7 The original purpose of the Metropolitan Green Belt was to restrict the outward
expansion of Greater London. In this instance, Southend-on-Sea is also
considered to be a 'large built-up area' of interest.

5.8 The site is located beyond the relevant built-up areas and intervening
development (particularly on the site's western boundary) exists between the
areas of North Shoebury and Shoeburyness.

5.9 Accordingly, the site cannot be considered to contribute to a wider Green Belt
network that provides a strategic barrier against the outward sprawl of large
built-up areas.

5.10 It is therefore concluded that the site provides limited or no contribution to the
first Green Belt purpose.

Green Belt Purpose 2: To prevent neighbouring towns from merging

5.11 The site is located on the southern edge of Great Wakering and is bound by
intervening development on its western edge and by Poynters Lane to the south.

5.12 It is envisaged that a suitable development could be designed at this location to
ensure that the existing 'gap' between Great Wakering and North Shoebury and
Shoeburyness to the south and west is not reduced, with Poynters Lane ensuring
a long-term defensible boundary further to the south.

5.13 It is therefore concluded that the site is not capable of acting as a gap or break
between two or more definable settlements and therefore is not considered
capable of making any contribution to the Green Belt objection of preventing
neighbouring towns from merging.

Green Belt Purpose 3: To assist in safeguarding the countryside from
encroachment

5.14 The site is recognised to be a countryside location on the edge of Great Wakering and accordingly any development at this site will, by necessity, result in
encroachment on the countryside. However, it is important to consider a range of
factors including land and environmental designations, land uses and urbanising
features which may detract from the quality and function of the countryside at
this location.

5.15 The site is not subject to any statutory or local landscape or ecological
designations which might otherwise contribute towards the quality of the
countryside at this location. Accordingly, the 'quality' of the landscape is
considered to be of limited value.

5.16 Moreover, in terms of land uses, the site comprises an arable agricultural field
which is enclosed by the existing built extent of Great Wakering to the north, east
and west and Poynters Lane to the south. Accordingly, there is a strong
urbanising influence on this site detracting from the quality and function of the
countryside at this location.

5.17 As such, the site is enclosed on all sides by existing built form or significant urban infrastructure and is not considered to represent a contiguous element within the wider countryside due to its effective isolation by existing physical barriers and
urbanising features. Furthermore, the site's quality in terms of landscape and
ecological designations further detract from the 'value' of the countryside at this
location.

5.18 Accordingly, it is considered that the site is only capable of having a 'partial'
contribution to the third purpose of the Green Belt.

Green Belt Purpose 4: To preserve the setting and special character of
historic towns

5.19 This purpose of the Green Belt is to perform a 'girdle' role, as a green ring around historic settlements and/or to provide the landscape context to historic features that preserves historic setting by keeping land open.

5.20 The Great Wakering Conservation Area is bordered in all directions by existing
development that has grown around it as the settlement has expanded and as
such the setting of the Conservation Area and the heritage assets contained
therein is now predominantly within the wider setting of the settlement rather
than the surrounding countryside.

5.21 Accordingly, the site is not considered to play a strong role in complementing the setting or special character of the Conservation Area due to the presence of the
existing intervening development. It is therefore concluded that the site does not
contribute towards the preservation of the historic setting and special character of
Great Wakering.

5.22 Consequently, the site is not capable of contributing to the fourth purpose of the Green Belt.

Green Belt Purpose 5: To assist in urban regeneration, by encouraging
the recycling of derelict and other urban land

5.23 The objective of this purpose is to constrain the supply of development land in
order to encourage the recycling of previously developed sites which would not
otherwise be developed, and therefore assist in urban regeneration. This
objective can only be realised if there is a supply of derelict and other urban land
that is capable of being recycled and which is deliverable.

5.24 This purpose of the Green Belt is particularly difficult to quantify but ultimately
relies on a supply of suitable brownfield land to meet objectively assessed
housing needs. As set out in Section 4, this is not the case. Furthermore, it is
considered reasonable to assume that some of this brownfield land will likely be
subject to delivery constraints and therefore in practice is unlikely to come
forward in the short-term (whether or not this site is removed from the Green
Belt).

5.25 Accordingly, in the context of an insufficient supply of deliverable brownfield land to meet housing needs and the resulting requirement to identify suitable
alternative sites to accommodate growth, it is confirmed that in practice the
significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.26 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against these Green Belt purposes (as
summarised in Table 2 below), it is shown to only provide a limited contribution
to these stated purposes.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5) To assist in urban regeneration, by encouraging the
recycling of derelict and other urban land
Limited or no contribution

5.27 Accordingly, the value of this site to the Green Belt is therefore
considered to be limited and by virtue, any harm arising from its removal
from the Green Belt is also limited.

5.28 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. PROCEDURAL CONSIDERATIONS

6.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Great Wakering) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

6.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite its supposed permanence, the Green Belt can
be reviewed by Local Authorities through their Local Plan reviews (paragraph 83),
which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

6.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

6.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

6.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the
necessary certainty that the Local Authority can deliver the development required
to meet its needs and spatial objectives. Moreover, the exceptional circumstances
required to release the Green Belt in the first instance will likely not exist unless
the benefits associated with any development clearly outweigh the potential
harm. The inference being that the Green Belt will not usually be released unless
for development purposes. It is therefore considered that the removal of land
from the Green Belt and the subsequent allocation for an alternative land use are
intrinsically linked.

6.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

6.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

6.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

6.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period, which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

7. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

7.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

7.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

7.3 The consultation document suggests three options for meeting identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

7.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

7.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

7.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

7.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question 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?

7.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement.

7.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

7.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs, it is therefore
clear that no single 'approach' as identified by the consultation will be sufficient to
provide all the homes RDC needs in the next Local Plan period. As such, RDC will
need to consider a combination of delivery strategies to meet their identified
housing needs, including larger extensions to the residential areas.

7.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the
sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

7.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

7.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Great Wakering, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the District as a whole.

7.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

8. SUMMARY AND CONCLUSIONS

8.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Great Wakering, in response to the current Local Plan Issues & Options
consultation by RDC.

8.2 The purpose of these representations has been primarily to respond to questions
raised within the consultation in respect of the amount of growth required and the
distribution of development over the next Plan period, and seeks to set out the
case for a revision to the Green Belt boundary to remove Land at Great Wakering
from the Green Belt alongside the provision of a strategic site-specific policy that
allocates the site for residential development in the emerging Local Plan.

8.3 The site at Great Wakering is deliverable (suitable, available and viable) and
offers the opportunity to accommodate a high-quality development of
approximately 1,100 new homes.

8.4 These representations demonstrate that the promotion of Land at Great Wakering is not exclusive to any one particular 'spatial approach' as set out in the
consultation document and instead highlights the site's suitability to contribute
towards the District's housing needs in all circumstances (in line with the
sustainable development principles of the NPPF), and accordingly sets out the
following case for exceptional circumstances to justify a revision to the Green Belt
boundary:

i) The Strategic Policy Framework:
* Local Plans should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need.
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives.
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being.
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate that 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Great Wakering is identified as a sustainable settlement and the
site is demonstrated to be suitable for release from the Green Belt
and capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

8.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Great Wakering to deliver approximately 1,100 muchneeded
and high-quality new homes consistent with the policies of the NPPF.

8.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

8.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure that a positive policy position for the
site is taken forward to deliver real benefits for the local community and the
District as a whole.

*THIS REPRESENTATION INCLUDES MAPS AND FIGURES, PROVIDED IN ATTACHMENT*

1. INTRODUCTION

1.1 This Report has been prepared by Pegasus Group on behalf of Taylor Wimpey in
respect of 'Land at Hawkwell', to the south of Hockley in Essex.

1.2 These Representations are submitted in response to the current consultation by
Rochford District Council (RDC) on the 'New Local Plan Issues & Options
Consultation' (December 2017) which seeks to identify the strategic spatial vision
for the District for the next 20 years (2017-2037).

1.3 The purpose of these Representations is primarily to respond to questions raised
within the Issues & Options consultation, particularly in respect of the amount of
growth required and the distribution of development over the next Plan period,
and seeks to set out the case for a revision to the Green Belt boundary to remove
Land at Hawkwell from the Green Belt alongside the provision of a strategic site specific policy that allocates the site for residential development in the
emerging Local Plan.

1.4 The representations highlight the site is deliverable (suitable, available and
viable) in the short-term and offers the opportunity to accommodate a highquality
development of approximately 400 new homes.

1.5 In response to the questions posed by the Issues & Options consultation, this
Report is structured as follows:
* Section 2 describes the site and its surrounding context;
* Section 3 considers the strategic policy context;
* Section 4 outlines the Borough's housing needs;
* Section 5 assesses the site against Green Belt purposes;
* Section 6 considers the site's deliverability;
* Section 7 summarises the relevant procedural considerations;
* Section 8 responds to specific questions raised by the consultation;
* Section 9 summarises and concludes the report.

2. SITE AND SURROUNDINGS

2.1 The Site extends to approx. 22.7 hectares, with a potential developable area of
approx. 10.5 hectares, located on the southern edge of Hockley, to the west of
Main Road (B1013) and north of Gustedhall Lane, Hawkwell as shown in
Appendix 1.

2.2 The site is located in the south-west of the District, approximately 1.5km south of Hockley train station, approximately 7km north-west of Southend-on-Sea central
station, approximately 4.2km to the east of Rayleigh train station and
approximately 3km west of Rochford train station as shown in Figure 1 below.
Figure 1: Land at Hawkwell in Context

2.3 Despite its close proximity to London, Rochford is a predominantly rural District
with 74% of the Borough designated at Green Belt.

2.4 Figure 2 below highlights the relationship between the site and its immediate
surroundings.

Figure 2: The site and immediate surroundings

2.5 The site comprises agricultural (arable) land, bordered by existing trees and
hedgerows on all sides, with built form associated with Hawkwell village, including
residential properties, community uses (Belchamps Scout Activity Centre) and
commercial units located to the north and east and agricultural land to the south
and west.

2.6 The site is situated within the 'Upper Roach Valley' Landscape Character Area,
with Hockley Woods Site of Special Scientific Interest (SSSI), Local Nature
Reserve and Ancient Woodland located approximately 270m to the north-west
and Gustedhall Wood and Potash Wood (Ancient Woodlands) located
approximately 150m to the south and south-west and south-east respectively.

2.7 Table 1 below provides a summary of local policy, environmental, heritage and
flood risk designations of relevance to the future potential of the site and in
particular, highlights the lack of constraints affecting the site. Extracts of the
relevant policy maps are enclosed at Appendix 2.

Table 1: Site Characteristics
Characteristic Details
Existing Use Agricultural (arable) farmland
Green Belt Yes
Neighbouring land uses Employment, residential and community land
uses to the north and east; Agricultural (arable) land to the south and west.
Flood Zone Flood Zone 1 (lowest probability)
Public Rights of Way Yes - PROW's run along the sites northern and western boundaries
Area of Outstanding Natural Beauty (AONB) No
Upper Roach Valley Landscape Character Area Yes
Contamination No
Conservation Area No
Listed Buildings No (NB: Mount Bovers Grade II Listed Farmhouse is located on the site's north-western boundary and Sweynes Grade II Listed Farmhouse is located on the site's north-eastern boundary)
Area of Archaeological Importance / Area of High Archaeological Potential No
Scheduled Monument No
Historic Parks & Gardens No
World Heritage Site No
Sites of Special Scientific Interest (SSSI) No (Hockley Wood SSSI located approx. 270m to the north-west
SSSI Impact Risk Zone Yes (associated with Hockley Wood SSSI
National / Local Nature Reserve No (Hockley Wood LNR located approx. 270m to
the north-west)
RAMSAR Site No
Special Area of Conservation No
Special Protection Area No
Site of Nature Conservation Importance No
Ancient Woodland No (NB: Hockley Wood, Gustedhall Wood and Potash Wood all located within close proximity)

3. STRATEGIC POLICY CONTEXT

3.1 The starting point for determining the case for development at the site is the
National Planning Policy Framework (NPPF), with which the new Local Plan should
be in accordance. The section below provides an overview of the key national
policy considerations of relevance to the site (which are considered to be focussed
on housing and Green Belt matters).

National Planning Policy Framework

3.2 The NPPF (2012) sets out the Government's planning policies for England and
how these are expected to be applied. It provides a framework within which local
people and their accountable Local Authorities can produce their own distinctive
Local Plans, which reflect the needs and priorities of their communities. The NPPF
must therefore be taken into account in the preparation of Local Plans and is a
material consideration in Planning decisions.

3.3 The NPPF establishes a firmly positive 'pro-development' national policy position,
which is underpinned by the 'presumption in favour of sustainable development'.
The Government has made it clear that the NPPF represents a significant stepchange
in national policy.

3.4 The NPPF aims to proactively drive and support sustainable economic
development to deliver the homes and infrastructure that the country needs. The
NPPF states that every effort should be made to objectively identify and then
meet the development needs of an area and respond positively to wider
opportunities for growth. It continues that emerging Local Plans should take
account of market signals, such as land prices and housing affordability, and set
out a clear strategy for allocating sufficient land which is suitable for development
in their area, taking account of the needs of residential and business
communities.

Housing

3.5 As acknowledged by the Housing White Paper 'Fixing our Broken Housing Market'
(February 2017), the Government recognises that the housing market in England
is 'broken and the cause is very simple: for too long, we haven't built enough
homes'1.

1 DCLG Housing White Paper (2017) 'Fixing our Broken Housing Market'

3.6 A key objective of the NPPF is therefore to boost significantly the supply of
housing (paragraph 47). In order to achieve this Local Planning Authorities
(LPAs) should:
* Use their evidence base to ensure that their Local Plan meets the full,
objectively assessed needs for market and affordable housing in the housing
market area, as far as is consistent with the policies set out in the Framework,
including identifying key sites which are critical to the delivery of the housing
strategy over the plan period [our emphasis];
* Identify and update annually a supply of specific deliverable sites sufficient to
provide five years' worth of housing against their housing requirements with
an additional buffer of 5% (moved forward from later in the plan period) to
ensure choice and competition in the market for land. Where there has been a
record of persistent under delivery of housing, LPAs should increase the buffer
to 20% (moved forward from later in the plan period) to provide a realistic
prospect of achieving the planned supply and to ensure choice and competition
in the market for land; and
* Identify a supply of specific, developable sites or broad locations for growth,
for years 6-10 and, where possible, for years 11-15.

Green Belt

3.7 With regards to the Green Belt, the NPPF seeks continued protection of Green
Belts (paragraph 17) and states that the fundamental aim of Green Belt policy is
to prevent urban sprawl by keeping land permanently open (paragraph 79). It
continues to identify 'openness' and 'permanence' as essential characteristics of
the Green Belt.

3.8 Paragraph 80 of the NPPF highlights that the Green Belt serves the following five
purposes:
i) To check the unrestricted sprawl of large built-up areas;
ii) To prevent neighbouring towns from merging into one another;
iii) To assist in safeguarding the countryside from encroachment;
iv) To preserve the setting and special character of historic towns; and
v) To assist in urban regeneration, by encouraging the recycling of derelict
and other urban land.

3.9 The NPPF states that Green Belt boundaries should only be altered in 'exceptional
circumstances', through the preparation of the Local Plan. At such time, LPAs
should consider Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the Plan period (paragraph 83). The implication of this criteria being that where significant development pressure exists and exceptional circumstances are warranted to develop in the Green Belt, it is considered appropriate for LPAs to seek to remove such sites from the Green Belt through the Local Plan-making process in order that they can deliver sustainable development to meet their identified development needs.

3.10 The Government's Housing White Paper (February 2017) acknowledges at
paragraphs 1.38 & 1.39 that the NPPF does not define what constitutes
exceptional circumstances and therefore proposes to amend and add to national
policy through a revised NNPF (anticipated to be published in Summer 2018) to
make clear that:
"Authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements, including:
* Making effective use of suitable brownfield sites and the opportunities offered by estate regeneration;
* The potential offered by land which is currently underused, including surplus public sector land where appropriate;
* Optimising the proposed density of development;
and
* Exploring whether other authorities can help to meet some of the identified development requirement"

3.11 The NPPF continues that when drawing up or reviewing Green Belt boundaries,
LPAs should take account of the need to promote sustainable patterns of
development (paragraph 84). Sustainable patterns of development are not
defined in policy. However, this is considered to relate to taking into account a
range of additional factors beyond the contribution towards Green Belt purposes.
These factors might include local development needs, public transport availability
and local highways capacity and accessibility to local services and social
infrastructure. With regard to sustainability, it is necessary to recognise the
wider and updated context of how sustainable development is defined in the NPPF
as set out in paragraph 7 whereby it should contribute towards social, economic
and environmental objectives.

3.12 The NPPF reaffirms the definition of Green Belt boundaries, stating (paragraph
85) that when defining boundaries, LPAs should:
i) Ensure consistency with the Local Plan strategy
for meeting identified requirements for
sustainable development;
ii) Not include land which it is unnecessary to keep
permanently open;
iii) Where necessary, identify in their plans areas of
'safeguarded land' between the urban area and
the Green Belt, in order to meet longer-term
development needs stretching well beyond the
plan period;
iv) Make clear that the safeguarded land is not
allocated for development at the present time;
v) Satisfy themselves that Green Belt boundaries will
not need to be altered at the end of the
Development Plan period; and
vi) Define boundaries clearly, using physical features
that are readily recognisable and likely to be
permanent.

3.13 The NPPF also carries forward previous Green Belt policy regarding 'inappropriate development', which is by definition, harmful to the Green Belt and should not be approved except in Very Special Circumstances' (VSC's) (paragraph 87). Accordingly, when considering any planning application, Local Planning Authorities should ensure that substantial weight is given to any harm to the Green Belt and VSC's will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other
considerations.

3.14 In summary therefore, the NPPF supports the long-standing principles of Green
Belt protection, whilst acknowledging that the objectives of the planning system
continue to evolve, reflecting current land use pressures and social needs. The
Government's priority is to deliver growth and sustainable development through
harmonising, wherever and whenever possible, the social, economic and
environmental processes that deliver sustainable places. Policy also reinforces the
plan-led system which gives planning authorities the power to undertake Green
Belt reviews to help inform the emerging spatial strategies necessary in order to
meet development needs. The role and function of the Green Belt therefore needs
to be considered within this overarching context to assist in the delivery of
sustainable development.

Conclusions - Implications for the New Local Plan
* The Local Plan should identify (allocate) a supply of specific developable
sites to meet RDC's objectively assessed housing needs in full as far as is
consistent with the policies of the NPPF; and
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries consistent with the policies of the NPPF in the context of
achieving sustainable development (including the aim of significantly
boosting the supply of housing) and the exceptional circumstances test.

4. HOUSING NEED

4.1 The Housing White Paper (February 2017), the NPPF (2012) and the
accompanying National Planning Practice Guidance (NPPG, 2014) confirms the
Government's commitment to boosting housing supply.

4.2 Assessing the development needs of RDC and identifying specific and deliverable
sites in order to facilitate this is therefore a critical aspect of the Local Planmaking
process.

4.3 In reference to the proposed 'case for development' outlined above, the following seeks to highlight the significant development needs within the District and the associated need to bring forward suitable and sustainable Green Belt sites in
order to meet identified housing needs.

Need

4.4 The District's objectively assessed need has been investigated as part of the
evidence base in support of the new Local Plan. As highlighted above, the NPPF
requires the new Local Plan to meet the full objectively assessed needs for the
market area, as far as is consistent with the policies set out in the framework.

4.5 The South Essex Strategic Housing Market Assessment (SHMA, May 2016) and
SHMA Addendum (May 2017) endorsed by the Council through the publication of
the Local Plan Issues & Options consultation, identifies the following objectively
assessed housing need, including taking account of the shortfall in
housing delivery since 2014.

Table 2: RDC Projected Housing Need against Emerging Targets
Baseline Need Objectively Assessment Housing Need (SHMA
Addendum 2017)
331 homes per annum
(lower end of range)
361 homes per annum
*upper end of range)
Baseline need (2017 -
2037)
6,620 7,220
Baseline need (2017-2037)
plus shortfall from 2014
7,181 (Shortfall of 561) 7,871 (Shortfall of 651
homes)
Source: RDC New Local Plan Issues & Options Document 2017

4.6 This compares with the adopted Core Strategy (2011) requirement of just 4,750
net additional dwellings in the period 2006 - 2025 (i.e. 250 dwellings per
annum). The above therefore represents a significant increase in housing need
which the District is required to meet in full as far as consistent with the policies
of the NPPF.

4.7 The Council is also right to consider the scale of the housing challenge in the
context of the Government's recent consultation on 'Planning for the right homes
in the right places (September 2017)' which amongst its proposals included a
standardised methodology for calculating housing need. Using this standardised
method generates a housing need figure of 362 net additional homes per
annum (i.e. total 7,240 new homes between 2017 - 2037). It is
anticipated that the proposed standardised methodology for calculating housing
need will be incorporated within a revised NPPF, to be adopted in Summer 2018
and accordingly RDC should be planning for housing delivery in line with the
emerging targets to ensure the New Local Plan is consistent with emerging
national planning policy. RDC should carefully consider the significant social
implications associated with not meeting objectively assessed / identified needs,
which in particular is likely to exacerbate an increasing affordability problem for
all sections of the community. Not meeting objectively assessed needs is likely to
increase pressure on RDC to find affordable homes for young people and families
and accommodation for an ageing population whilst also making it harder for local
businesses to find and retain employees.

Supply

4.8 The relevant supply considerations comprise RDC's historic delivery rates and the identified supply of deliverable housing land as recorded within the Council's
Annual Monitoring Reports (AMR) and Strategic Housing and Economic Land
Availability Assessment (SHELAA, 2017).

4.9 The NPPF requires (paragraph's 159 and 161) that LPA's produce a land
assessment which enables realistic assumptions about the availability, suitability
and achievability of land to meet identified development needs for the duration of
the plan period. The SHELAA (2017) forms part of RDC's core evidence base in
support of the new Local Plan which helps identify deliverable land for
development against the assessment criteria set out in the NPPF. The SHELAA
provides an interim position on identified supply within the District based on the
latest published information.

4.10 Accordingly, an important aspect of the SHELAA is to use the results of the site
assessments (and existing housing land supply data, site completions and an
allowance for windfall development) to produce a housing supply trajectory.

4.11 The SHELAA (2017) concludes at paragraph 7.9 and 7.10 that:
"There is land available in the district which is both
suitable and achievable to deliver 935 dwellings, in
addition to those sites which already have planning
permissions and which therefore already form part of the
Council's housing trajectory.
The Council's housing land trajectory, which includes the
sites considered as part of this assessment in addition to
allocated sites and sites with extant permissions, has
found that there is sufficient suitable, available and
achievable land to deliver a total of 3,499 dwellings in
the district across the next 10 years."

4.12 Accordingly, the following table highlights the inherent shortfall of available (and unconstrained) land to meet the identified housing needs within RDC.

Table 3: Identified Shortfall in Housing Supply against Emerging Targets
Baseline Need Objectively Assessment Housing
Need (SHMA Addendum 2017)
Identified Need
(Standardised
Methodology)
331 homes per
annum (lower
end of range)
361 homes per
annum *upper
end of range)
362 homes per annum
Baseline need
(2017 - 2037)
6,620 7,220 7,240
Baseline need
(2017-2037) plus
shortfall from
2014
7,181 (Shortfall
of 561)
7,871 (Shortfall of
651 homes)
-
Identified Supply 3,499 3,499 3,499
Surplus /
Shortfall
-3,682 homes -4,372 homes -3,741 homes

4.13 The Council's own evidence base and consultation document therefore highlights the significant scale of the housing supply shortfall faced by the District and it is therefore appropriate for the Council to consider releasing suitable and
sustainable Green Belt sites in the early part of the New Local Plan to contribute
towards the District's identified and urgent housing land supply shortfall.

Duty to Cooperate

4.14 Following the revocation of Regional Spatial Strategies, the Localism Act 2011
introduced a legal requirement on Local Planning Authorities, County Councils in
England and public bodies to engage constructively, actively and on an ongoing
basis to maximise the effectiveness of Local Plan preparation in the context of
strategic cross boundary matters, including to establish the potential for unmet
housing needs to be met by neighbouring local authorities.

4.15 The following provides a brief review of the potential for RDC's neighbours to
accommodate any unmet housing needs arising from the New Local Plan.

4.16 Basildon Borough Council is located to the west of RDC and approximately 63% of its land area is designated as Green Belt, as identified in their adopted Local Plan (1998). The Borough is working towards the submission (final) stage of its planmaking to deliver the new homes the Borough needs as far as possible, however
it has indicated that it may not be able to meet all of its needs within its own
boundary.

4.17 Castle Point Borough Council, located to the south-west of RDC comprises
approximately 56% Green Belt which is tightly drawn around the existing urban
areas with the Borough. The Council's proposed New Local Plan (2016) sought to
meet a fraction of its need identified in the South Essex SHMA with fewer new
homes planned than previously on its Green Belt land. This approach did not
meet the legal requirements of the Duty to Cooperate as found by a Planning
Inspector in January 2017. As reported within the RDC consultation document, if
Castle Point can demonstrate that it is unable to meet all of its housing needs
within its own boundaries, it will need to work closely with neighbouring areas
such as RDC to identify and agree an approach to delivering any potential unmet
need.

4.18 Chelmsford City Council located to the north-west of RDC comprises
approximately 38% Green Belt, situated at the southern end of the City's
administrative area. Chelmsford City has published its Preferred Options version
of their Local Plan, which proposes to meet the city's needs in full, plus a 20%
buffer to provide flexibility) within its own boundaries. However, Chelmsford falls
within a separate housing market area with Braintree, Colchester and Tendring
Council's and accordingly any flexibility in housing supply in Chelmsford is likely
to be taken up by these authorities in the first instance.

4.19 Southend Borough Council is located to the south of RDC and is predominantly
urban encompassing the settlements of Leigh, Chalkwell, Westcliff, Prittlewell,
Southchurch, Southen, Thorpe Bay and Shoeburyness. The Green Belt encloses
the urban areas within Southend and it is anticipated that given its significant
constraints, the Borough may be unable to meet all of its identified housing needs
within its own boundaries. As with Castle Point, the Borough will need to work
closely with other LPAs as part of the Duty to Cooperate to address any potential
unmet needs.

4.20 Thurrock is located further to the south-west of Castle Point Borough Council, but forms part of the same Housing Market Area (South Essex) and comprises
approximately 65% Green Belt. Thurrock is also in the process of preparing its
new local plan and identified within its most recent consultation that since 2006,
the Borough had under-built by some 6,184 homes against adopted targets. The
Borough is clearly struggling to meet its own housing targets and is therefore
likely to look to its neighbours to help meet any unmet housing needs.

4.21 In summary, RDC's neighbours are all similarly highly constrained by the Green
Belt and facing significant challenges in meeting identified housing needs within
their own administrative areas. Indeed, where neighbouring Local Authorities,
have sought to 'duck' their responsibilities in terms of meeting their identified
needs by relying on neighbouring authorities to pick up the shortfall without
proper cooperation in place, such plans have been found 'unsound' by an
Independent Planning Inspector and their Local Plans withdrawn.

4.22 Accordingly, it is considered unrealistic for RDC to rely on its neighbours to help
meet any unmet development needs as its neighbours are similarly highly
constrained by Green Belt, are already making provision to accommodate other
authorities unmet housing needs and are facing their own significant challenges in
meeting identified needs.

4.23 In summary, it is not appropriate for RDC to rely on its neighbours under the
Duty to Cooperate to accommodate any unmet housing needs.
Conclusions - Implications for the New Local Plan
* The new Local Plan should identify (allocate) a supply of specific developable
sites (or broad locations for growth) to accommodate the District's
objectively assessed housing needs (i.e. a minimum of 7,181 net additional
homes) as far as is consistent with the policies of the NPPF;
* Insufficient non-Green Belt sites exist to meet housing needs in full and
therefore it is appropriate to identify additional deliverable, suitable and
sustainable Green Belt sites to contribute towards identified housing need;
* Given the scale of the identified shortfall in housing land supply against
identified needs, the new Local Plan should identify an additional supply of
land from suitable and sustainable Green Belt sites to come forward in the
early part of the Local Plan period, in order to deliver the Council's
sustainable development objectives; and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and its
neighbours to accommodate any unmet housing need as neighbouring Local
Authorities are similarly highly constrained by Green Belt and facing similar
challenges in meeting their own identified housing needs.

5. GREEN BELT MATTERS

5.1 The following section seeks to demonstrate that the site is suitable to contribute
towards the development needs identified in Section 4 above in respect of the
Green Belt which represents the key Planning Policy constraint against the
development of Land at Hawkwell.

5.2 The Green Belt designation carries significant weight as a material consideration
in planning policy and development management. The NPPF is explicit that
changes to Green Belt designations should only be altered in exceptional
circumstances through the Local Plan process (paragraph 83), in the context of
promoting sustainable development as set out in the NPPF (having regard to
social, economic and environmental factors).

5.3 As highlighted in Section 4, there is an inherent shortfall in available (and
unconstrained land) to meet identified housing needs. Moreover, the Council's
'Environmental Capacity Study (2015)' identifies that based on the lower South
Essex SHMA (2013) figure of 240 new homes per year between 2026 - 2031
(total 1,200 new homes), i.e. beyond the current plan period of the Core
Strategy, it is uncertain as to whether the District has the environmental capacity
to accommodate this level of growth; and is unlikely to be able to accommodate
additional homes from other areas. The study identifies the Green Belt as a
major constraint to development within the District and recommends a Review of
the Green Belt is undertaken.

5.4 Within this context it is our view that exceptional circumstances exist to amend
the Green Belt boundary in RDC to warrant the release of this site from the Green
Belt. The main purpose of this section is to set out an assessment of the 'value'
of the site in Green Belt terms in order that the 'harm' of its loss can be
appropriately considered.

5.5 Key to establishing whether a site is suitable for release from the Green Belt in
order to contribute towards the district's objectively assessed development needs
is to understand the 'value' of the site in Green Belt terms when assessed against
the national purposes of Green Belt set out in the NPPF.

5.6 Accordingly, Pegasus Group has undertaken an independent review of site's
contribution towards the purposes of the Green Belt as defined by the NPPF. The
full Appraisal is enclosed at Appendix 3 and summarised in Table 4 below.

Table 4: Summary of the Site's Contribution to Green Belt Purposes
Green Belt Purpose Assessed Site Contribution
1) To check the unrestricted sprawl of large built-up
areas
Limited or no contribution
2) To prevent neighbouring towns from merging Limited or no contribution
3) To assist in safeguarding the countryside from
encroachment
Partial contribution
4) To preserve the setting and special character of
historic towns
Limited or no contribution
5.7 The fifth purpose of the Green Belt ('to assist in urban regeneration, by
encouraging the recycling of derelict and other urban land') is to constrain the
supply of development land in order to encourage the recycling of previously
developed sites which would not otherwise be developed, and therefore assist in
urban regeneration. This objective is difficult to quantify but can only be realised
if there is a supply of derelict and other urban land that is capable of being
recycled and which is deliverable.

5.8 As highlighted in Section 4, the Council's evidence base highlights that there is an inherent shortfall of available and (unconstrained) land to meet identified housing
needs. Accordingly, in the context of an insufficient supply of deliverable
brownfield land to meet housing needs and the resulting requirement to identify
suitable alternative sites to accommodate growth, it is considered that in practice
the significance of the site's contribution towards the fifth Green Belt purpose is
limited.

5.9 In summary, the NPPF confirms that the fundamental aim of the Green Belt is to
keep land permanently open as a means of achieving its five key purposes.
However, when assessing the site against the Green Belt purposes it is shown to
only provide a limited contribution to these stated purposes. Accordingly, the
value of this site to the Green Belt is therefore considered to be limited
and by virtue, any harm arising from its removal from the Green Belt is
also limited.

5.10 In conclusion, the site is therefore considered to be suitable to be taken forward through the Local Plan process to deliver an appropriate scale of development in a sustainable location in order to contribute towards the District's significant identified housing needs.

5.11 Moreover, the analysis enclosed at Appendix 3 provides a robust 'Green Belt &
Landscape Strategy' for the site to ensure appropriate mitigation is inherently
designed into any future development to protect and preserve the sites interface
with the settlement and wider Green Belt and Upper Roach Valley setting as
explained further in Section 6 below.

Conclusions - Implications for the New Local Plan
* In preparing the new Local Plan, RDC should consider revising Green Belt
boundaries in the context of achieving sustainable development (including
the aim of significantly boosting the supply of housing) and the exceptional
circumstances test; and
* The site makes a limited contribution to Green Belt purposes and
accordingly the release of the site would not give rise to significant 'harm'
in Green Belt policy terms.

6. SITE DELIVERABILITY AND DEVELOPMENT VISION

6.1 Critical to the case for development at this site is demonstrating deliverability in
order to confirm that the site is capable of contributing towards the District's
identified development needs.

6.2 The following therefore provides a 'high-level' review of the deliverability of Land
at Hawkwell.

Site Suitability

Access and Highways

6.3 These representations are supported by an assessment of local highways and
access constraints and opportunities enclosed at Appendix 4.

6.4 The accompanying evidence provides a review of RDC's latest Local Plan evidence base, an overview of sustainability matters and identifies a potential access
arrangement.

6.5 The accompanying report concludes that:
* The site is within a good range of a number of local services and facilities,
including Hockley Railway Station for long distance journeys;
* Local travel characteristics indicates that existing residents in the vicinity of
the site have the highest public transport and lowest private car use for
commuting patterns in the district - a pattern considered likely to reflect that
of any future residents at the site;
* That suitable and safe access can be designed to enable vehicular and
pedestrian/cyclist access in accordance with local guidance; and
* The development of the site for approximately 400 dwellings would equate to
just circa three additional vehicles per minute on the highway network.
* The site could provide a suitable package of off-site highways improvements
commensurate with the impact of the scheme to further enhance the
accessibility of the site and promote opportunities for sustainable travel.

6.6 Accordingly, there are no insurmountable highways and access constraints at the
site, which is considered to present a significant opportunity to contribute towards
RDC's sustainable transport objectives.

Landscape and Townscape

6.7 The site is located within the Green Belt and the Upper Roach Valley Landscape
character area which seeks to protect a 'green lung' and landscapes of value
(noting it also aims to promote recreation).

6.8 The accompanying 'Landscape and Visual Analysis' (Appendix 3) considers the
constraints and opportunities at the site and proposes a robust landscape
strategy to demonstrate that the site can accommodate a sensitively designed
residential scheme with only limited landscape and visual effects at a localised
level and that such impacts can successfully be avoided or reduced through
appropriate mitigation.

6.9 Such an approach addresses the interface between the settlement edge and the
wider countryside and how this can influence prospective amendments to the
Green Belt boundary. The use of the existing landscape components to guide the
landscape strategy ensures a robust and enduring boundary to the Green Belt in
line with national policy and maintains the integrity of the wider Upper Roach
Valley.

6.10 Accordingly, the proposals would represent a limited landscape impact adjacent
to the existing urban fringe and presents a positive contribution in terms of
improved green infrastructure and recreational opportunities.

Flood Risk

6.11 The site is located within Flood Zone 1 (lowest risk) as defined by the
Environment Agency and is therefore sequentially preferable and considered
suitable in principle for residential development in flood risk terms.
6.12 Any future planning application at this site would need to be supported by a site specific flood risk assessment and surface water drainage strategy, incorporating
Sustainable Urban Drainage Systems (SUDS).

Ecology

6.13 The site is not subject to any statutory or local environmental / ecological
designations.

6.14 Hockley Woods Site of Special Scientific Interest (SSSI), Local Nature Reserve
and Ancient Woodland located approximately 270m to the north-west and
Gustedhall Wood and Potash Wood (Ancient Woodlands) located approximately
150m to the south and south-west and south-east respectively. Moreover, the
current agricultural land use of the site is considered to be of low ecological
value.

6.15 Accordingly, there are no ecological constraints at this site restricting future
delivery and development of the site will provide an opportunity to introduce
enhanced wildlife habitats and ecological corridors through the site to link the
Hockley Woods with surrounding Ancient Woodlands to improve the function of
the site as part of a wider Green Infrastructure Network.

Heritage
6.16 The site is not designated as a Conservation Area or Archaeological Site, nor does it contain any Listed Buildings or Scheduled Monuments.

6.17 Accordingly, the site is not constrained by any heritage assets and the site is not considered to be particularly sensitive to change from a heritage perspective.

Social Infrastructure

6.18 Hawkwell is identified as a 'first-tier' settlement within the adopted RDC Core
Strategy (2011), being grouped with Rochford, Ashingdon and Hockley and is
therefore considered to be one of the District's most sustainable settlements
benefiting from a range of local facilities and services, including:
* Bus Stops (Mount Bovers Lane) on site's north-eastern corner with regular
services to Hockley and Rayleigh;
* GP surgery and pharmacy (approx. 600m north-east);
* Dentists (approx. 750m north and 1.1km north-west);
* Westerings Primary Academy (approx. 400m north);
* Greensward Academy (approx. 1.7km north);
* Belchamps Scout Activity Centre (approx. 100m north);
* Clements Hall Leisure Centre (approx. 500m north-east)
* Hockley Train Station (approx. 1.5km north);

6.19 Hawkwell also benefits from its close proximity to Hockley which supports a good range of local retail and employment opportunities

6.20 Accordingly, Hawkwell is recognised to be one of the District's most sustainable
settlements that can comfortably cater for the day-to-day needs of the local
community and provide access to a range of other services including community,
recreational, education and health facilities and is therefore capable of
accommodating an additional sustainable level of development to ensure the
future vitality and viability of the town and associated community services.

6.21 It is noted in Section 9 of the Issues & Options document that there is a need /
requirement for an early years and childcare provision in Hawkwell. The site at
Hawkwell therefore provides an opportunity to address this through the provision
of a purpose-built facility.

Overall Site Suitability

6.22 The above assessment highlights the opportunity presented by the site to
contribute towards the District's housing needs at a sustainable location and
demonstrates that's there are no insurmountable physical, environmental or
technical constraints precluding the development of land at Hawkwell as
illustrated by the enclosed Constraints & Opportunities Plan at Appendix 5.

Development Vision

6.23 The site therefore presents a key opportunity to deliver the District's spatial and sustainable objectives over the next Plan period and the following 'development
vision' for the site has evolved following further detailed investigation into the
site's constraints and opportunities as set out above.

6.24 Accordingly, the Illustrative Development Framework enclosed at Appendix 6
incorporates the following key design principles in response to the detailed
investigations as set out within this report.

i) Development Vision:
* The Concept Design sets out our vision for the future of the site
(Land at Hawkwell) to deliver approx. 400 new homes and
associated public open space and green infrastructure
enhancements.
* There is also an opportunity to provide a purpose-built facility
for early years childcare should it be required, to meet any
identified need.

ii) Housing Principles:
* Opportunities to deliver a mix of dwelling types, tenures and
sizes on the site, including for first-time buyers, family,
affordable homes and older persons housing;
* The site therefore seeks to provide much needed new homes for
all sections of the community.

iii) Townscape Principles:
* Potential developable area of 12.1 hectares;
* Development density of approx. 35 dwellings per hectare to
optimise the capacity of Green Belt land whilst being
sympathetic to the site's surroundings, consistent with national
policy.

iv) Landscape Principles:
* Development Envelope:
o Restricted spatial extent of the development envelope
(to the eastern part of the wider site) to ensure that built form does not encroach on the higher parts of the site to the west, thus protecting the wider extent of the Upper Roach Valley and maintaining consistency with the existing prominent settlement edge;
o Maintain openness in the western part of the wider site area to provide a substantial and robust buffer to the wider Green Belt context;
o Reintroduction of some former landscape patterns;
o Restricted to the northern and southern edges to provide a stand-off to nearby visual receptors;
o Restricted to the eastern edge to provide a stand-off to the existing boundary vegetation;
o Development envelope to be divided by a proposed central 'greenway';
o Incorporation of a 'density strategy' to ensure the more sensitive areas on the western and southern edges of the site incorporate lower density and higher density directed to the least sensitive parts of the site;
* Existing Vegetation Strategy:
o Retain and enhance existing vegetation across the site wherever possible;
o Enhancement of existing vegetation, including appropriate management, replacement planting and new planting to reinforce boundaries and improve species
diversity;
* Green Infrastructure and open space:
o Inclusion of green corridors throughout the site, focused on providing suitable buffers to adjacent landscape components and visual receptors;
o Inclusion of pockets of green infrastructure and open space on the eastern edges of the site, forming the lower parts of the site these can complement the approach to SUDS and provide multi-functional landscape spaces;
o Provision of new public access routes through a network of open spaces across the site, but also as an integral part of the residential layout;
o Provision of new recreational access in the form of informal parkland' areas in the western part of the site;
o Incorporating a substantial 'greenway' through the core of the site, providing a green link (visual and physical) between Main Road and the wider countryside to the
west and having reference to historic field patterns - this area will also be an opportunity to create a high quality and multi-functional open space;
o A particular focus on green infrastructure creation on the western part of the site so as to deliver a robust physical green edge to the settlement that supports an enduring boundary to the Upper Roach Valley and to the Green Belt - this can include substantial woodland planting that will provide closer physical connectivity between areas of ancient woodland; and
o A strategy for landscape planting that will complement
and enhance the existing green infrastructure network,
including substantial hedgerows, tree belts and
woodlands to provide green infrastructure connectivity.
* Environmental Considerations:
o Where appropriate, utilising existing landscape features
to inform and guide the drainage strategy, including use
of existing drainage ditches and the lower parts of the
site to develop sustainable drainage patterns that can, in
turn, complement strategic landscape proposals;
o Approaches to existing vegetation and proposed green
infrastructure/open space include potential compatibility
with ecological and biodiversity objectives through
retaining and enhancing habitats as appropriate.
* Green Belt Considerations:
o Use of existing and proposed landscape elements and features to define a robust and enduring boundary to the Green Belt

v) Ecology Principles:
* Potential for significant ecological improvements (for species
and habitats) through new tree planting and creation of green
corridors through the site.

vi) Access and Movement Principles:
* Vehicular access to be provided via Main Road;
* Opportunity to link the development with existing Public Rights
of Way around the site.

6.25 The enclosed Development Framework Plan therefore represents a deliverable,
sympathetic and sustainable vision for the site, however it is envisaged that this
concept will evolve further through further site investigations and stakeholder
engagement and consultation.

Site Availability

6.26 The site is under single ownership and comprises an arable agricultural field on
the western edge of Hawkwell.

6.27 There are no legal constraints to the availability of the land for development and the landowner is willing to make the site available for development and is actively promoting the site through the emerging Local Plan.

6.28 The site is under option by Taylor Wimpey, one of the country's largest
housebuilders and accordingly the site is considered to be available for residential
development and the potential to provide a purpose-built facility for early years
childcare (if required).

6.29 It is therefore anticipated that subject to the removal of the Green Belt
designation, that the site will be available, deliverable and suitable for
development in the early part of the new Local Plan period.

Site Viability

6.30 The site comprises a 'greenfield' agricultural site and accordingly it is not
anticipated that there will be any abnormal costs associated with the
development of this site as may be expected on previously developed
(brownfield) land.

6.31 As such, it is to be acknowledged that the site is wholly capable of delivering the Council's policies, particularly with regards to Affordable Housing provision.

Conclusions - Implications for the New Local Plan

* The site is suitable for residential development with no insurmountable
environmental or technical constraints;
* The site is located within a sustainable location, suitable to accommodate
new development;
* The site is available for development now and is being actively promoted by
a willing landowner and developer;
* Residential development is confirmed to be a viable opportunity at this site;
* The Development Framework represents a deliverable (suitable, available
and viable) and sustainable vision for the site that is 'landscape-led' and
responds sympathetically to its environment to demonstrate how the site
could be developed to deliver approx. 400 new homes, new Public Open
Space and Green Infrastructure; and
* Accordingly, for the purposes of preparing the new Local Plan, the site
should be treated as a deliverable source of housing land with an
expectation of completions achievable in the early part of the plan period
(subject to the removal of the Green Belt designation).

7. PROCEDURAL CONSIDERATIONS

7.1 The purpose of this section is to provide RDC with comfort that the removal of the site (Land at Hawkwell) from the Green Belt and the subsequent 'strategic'
allocation for residential development in the first part of the new Local Plan is the
appropriate and proper mechanism for doing so.

Green Belt Review

7.2 The NPPF attaches great importance to the Green Belt, highlighting its
fundamental aim of preventing urban sprawl by keeping land permanently open
(paragraph 79). However, despite their supposed permanence, the Green Belt
can be reviewed by Local Authorities through their Local Plan reviews (paragraph
83), which should take account of the 'need to promote sustainable patterns of
development' (paragraph 84). That includes the negative consequences of
channelling development towards urban areas or to areas beyond the Green Belt
rather than existing boundaries. Any changes to the Green Belt should therefore
take effect through the Local Plan reviews and then only in 'exceptional
circumstances'.

7.3 Guidance contained within the NPPF and NPPG in addition to various ministerial
statements and correspondence with the Planning Inspectorate, in combination
with the growing emphasis on Localism is clear that it is up to Local Authorities to
determine planning matters themselves, including the future of their Green Belt.
Therefore, if significant benefits associated with meeting local housing needs exist
in combination with other local benefits, then the opportunity exists to justify the
release of land from the Green Belt for development to ensure that the Green Belt
does not become an obstacle to delivering 'sustainable patterns of development'
(NPPF paragraph 84) which might otherwise restrict the ability of Local
Authorities to best meet the future development needs of their communities.

Strategic Allocations

7.4 It is our view that the new Local Plan should set out the strategic levels of
development (based on identified needs) to be delivered across the Local Plan
area and identify the broad locations where growth/development will take place
(to include strategic allocations).

7.5 Accordingly, it is logical when reviewing Green Belt boundaries to 'backfill' any
released Green Belt land with an appropriate site allocation to provide the necessary certainty that the Local Authority can deliver the development required to meet its needs and spatial objectives. Moreover, the exceptional circumstances required to release the Green Belt in the first instance will likely not exist unless the benefits associated with any development clearly outweigh the potential harm. The inference being that the Green Belt will not usually be released unless for development purposes. It is therefore considered that the removal of land from the Green Belt and the subsequent allocation for an alternative land use are intrinsically linked.

7.6 Such an approach is supported by the NPPF whereby paragraph 157 states that
Local Plans should:
* Plan positively for the development and infrastructure required in the area to
meet spatial objectives;
* Indicate broad locations for strategic development on a key diagram and land
use designations on a proposals map; and
* Allocate sites to promote development and flexible use of land, bringing
forward new land where necessary, and provide detail on form, scale, access
and quantum of development where appropriate.

7.7 The above approach to removing and re-allocating Green Belt land as strategic
allocations through the emerging Local Plan is therefore the correct approach and
is supported at a national level.

7.8 In conclusion, it is therefore considered that the implementation of a spatial
strategy that identifies Green Belt land for release and which allocates such land
for development through a Strategic Allocation within the new Local Plan will
enable RDC to plan positively to ensure that the District can deliver the strategic
levels of development it needs in line with the requirements of the NPPF.

7.9 The consequences of deferring any allocation of the site to the latter stages of the Local Plan would be:
i) To create a policy void in the interim period creating uncertainty for
investment and the delivery of key spatial objectives for the District; and
ii) To unnecessarily delay development of a sustainable and deliverable site
which can contribute towards the District's housing needs in the early part
of the New Local Plan period , which as highlighted above is important in
the context that the Council's own evidence base indicates towards an
inherent shortfall in available housing land to meet identified needs.

Conclusions - Implications for the New Local Plan
* Guidance at all levels is clear that it is up to Local Authorities to determine
where development should and shouldn't go;
* The preparation of a new Local Plan provides the appropriate mechanism to
review the Green Belt boundary and release sites for development where this
promotes sustainable patterns of development and exceptional circumstances
apply; and
* The new Local Plan should plan positively and support the release of the site
from the Green Belt and replace with a Strategic Allocation to be delivered in
the early part of the new Local Plan to demonstrate that the spatial objectives
of RDC can and will be delivered.

8. REVIEW OF PROPOSED LOCAL PLAN APPROACHES

8.1 The following section seeks to draw the above together to provide a succinct
response to the key issues and specific questions raised within the Issues &
Options consultation, particularly in relation to the amount of growth RDC should
plan for over the next plan period and how it should be distributed.

Question SP1.1: How do we sustainably meet our need for market and
affordable homes over the next 20 years?

8.2 As set out in Section 4 (Housing Need), the scale of the housing challenge needs
to be considered in the context of the clear shift at the national level to
significantly increase the delivery of new homes to 'fix our broken housing
market'.

8.3 The consultation document suggests three options for meet identified housing
needs, namely:
* Option A: Seek to provide as much of the District's housing need within our
area, as far as possible, given environmental and other constraints;
* Option B: Work with neighbouring Local Planning Authorities to ensure that
housing need across the South Essex Housing Market is effectively met; and
* Option C: Consider a policy requirement to deliver a percentage of new
market homes on schemes to be available to residents on a first-come, firstserved
basis for a limited period of time

8.4 It is considered that the options presented by the consultation are 'noncommittal' to meeting the District's identified housing needs and fail to recognise the scale of the housing challenge, particularly in light of the Council's
'Environmental Capacity Study (2015) which indicates has a very limited capacity
to accommodate new growth.

8.5 It is considered that RDC should plan to meet their objectively assessed
housing need in full and/or as calculated using the Government's
proposed standardised methodology to deliver between 331 - 362 new
homes per annum across the new Local Plan period consistent with
adopted and emerging national planning policy.

8.6 Moreover, as set out above, it is unrealistic for RDC to rely on the Duty to
Cooperate and for its neighbours to meet any unmet need as these authorities
are similarly constrained.

8.7 RDC should carefully consider the significant social costs and implications
associated with not meeting identified housing needs in full, which in particular is
likely to exacerbate an increasing affordability crisis for all sections of the
community. Should RDC not meet their identified needs in full as the current
consultation indicates, then it is likely to increase pressure on the Council to find
affordable homes for young people and families and accommodation for an ageing
population, whilst also making it harder for local businesses to find and retain
employees.

Question SP1.3: How do we plan for and facilitate the delivery of our
need for new homes over the next 20 years within the?'

8.8 The Issues & Options consultation document presents five approaches for how
future growth might be distributed:
* Option A: Increase density within the existing residential area;
* Option B: Increase density on allocated residential sites;
* Option C: Several Small extensions to the existing residential area;
* Option D: A number of fewer larger extensions to the existing residential
area; and
* Option E: A new settlement

8.9 The consultation document does not provide any estimation of the potential
number of new homes each option might deliver, apart from in relation to Option
A, whereby the accompanying SHELAA (2017) identifies the potential for 38 sites
within the existing urban areas in the District to come forward over the next plan
period "which may be appropriate to be considered for the delivery of [just] 935
new homes".

8.10 Accordingly, given the scale of the housing challenge and the inherent shortfall of available and unconstrained housing land to meet identified needs (as set out in
Section 4 above), it is therefore clear that no single 'approach' as identified by
the consultation will be sufficient to provide all the homes RDC needs in the next
Local Plan period. As such, RDC will need to consider a combination of delivery
strategies to meet their identified housing needs, including larger extensions to
the residential areas.

8.11 Accordingly, it is considered appropriate for 'Option D' (i.e. a number of fewer
larger extensions to the existing residential area'), being supported by a review of
the Green Belt, to form part of the overall spatial strategy for the next plan period
whereby development is distributed across the District according to the sustainability and suitability of sites to accommodate new growth and protect the
Green Belt where the Green Belt meets its stated purposes. This approach
provides an opportunity to meet local housing needs where such needs are
generated and enables suitable and sustainable sites to come forward in the early
part of the new plan period to seek to address the pressing need for new housing
(including making up the existing backlog in housing delivery) now.

8.12 Such an approach ('Option D') also provides opportunities to improve local
infrastructure provision through the careful use of financial contributions from
development together with on-site provision of facilities where appropriate to
make settlements more sustainable.

8.13 Accordingly, allowing settlements to grow sustainably beyond existing boundaries according to their ability to accommodate growth, such as at Hawkwell, as one of the most sustainable settlements in the District, will have positive benefits for the future vitality and viability of the local area and for the sustainability of the
District as a whole.

8.14 In conclusion, the inclusion of 'Option D' as part of a combination of spatial
strategies for meeting the District's identified housing needs is considered to
represent a sustainable approach to plan-making to contribute towards RDC's
future development needs.

Conclusions - Implications for the New Local Plan
* The new Local Plan should seek to meet identified housing needs in full in
recognition of the scale of the 'housing challenge';
* The plan should support the sustainable distribution of development across
the District according to the suitability and sustainability of settlements and
sites to accommodate growth to ensure the future vitality and viability of
settlements and the District as a whole;
* It is appropriate for 'Option D' (i.e. larger extensions that relate well to the
existing residential areas), being supported by a review of the Green Belt, to
form part of the emerging Spatial Strategy for the new Local Plan; and
* Hawkwell is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and capable of
contributing towards the District's identified housing needs.

9. SUMMARY AND CONCLUSIONS

9.1 These Representations are submitted on behalf of Taylor Wimpey in support of
Land at Hawkwell, in response to the current Local Plan Issues & Options
consultation by RDC.

9.2 The purpose of these representations has been primarily to respond to questioned raised within the consultation in respect of the amount of growth required and the distribution of development over the next Plan period, and seeks to set out the case for a revision to the Green Belt boundary to remove Land at Hawkwell, from the Green Belt alongside the provision of a strategic site-specific policy that allocates the site for residential development in the emerging Local Plan.

9.3 The site at Hawkwell is deliverable (suitable, available and viable) in the shortterm and offers the opportunity to accommodate a high-quality development of
approximately 400 new homes.

9.4 These representations demonstrate that the promotion of Land at Hawkwell is not exclusive to any one particular 'spatial approach' as set out in the consultation
document and instead highlights the site's suitability to contribute towards the
District's housing needs in all circumstances (in line with the sustainable
development principles of the NPPF), and accordingly sets out the following case
for exceptional circumstances to justify a revision to the Green Belt boundary:

i) The Strategic Policy Framework:
* Local Plan's should identify (allocate) a supply of specific
developable sites to meet objectively assessed needs.
* In preparing a new Local Plan, it is appropriate to consider
revisions to the Green Belt consistent with the objectives of
achieving sustainable development (including the aim of
significantly boosting the supply of housing) and the exceptional
circumstances test.

ii) The following development needs exist:
* The District's objectively assessed housing needs identify a need
for between 7,181 - 7,871 new homes in the period 2017 - 2037
(i.e. 331 - 362 dwellings per annum).
* Insufficient non-Green Belt sites exist to meet housing needs in full
and therefore it is appropriate to identify additional deliverable,
suitable and sustainable Green Belt sites to contribute towards
identified housing need;
* Given the scale of the identified shortfall in housing land supply
against identified needs, the new Local Plan should identify an
additional supply of land from suitable and sustainable Green Belt
sites to come forward in the early part of the Local Plan period, in
order to deliver the Council's sustainable development objectives;
and
* It is not appropriate for RDC to rely on the 'Duty to Cooperate' and
its neighbours to accommodate any unmet housing need as
neighbouring Local Authorities are similarly highly constrained by
Green Belt and facing similar challenges in meeting their own
identified housing needs.

iii) The site is capable of contributing towards identified housing
needs on the following grounds:
* Green Belt matters:
o Where the Green Belt is identified as not meeting NPPF
purposes, it is appropriate to review the Green Belt through
the Local Plan process.
o The site makes a limited contribution to the purposes of the
Green Belt and therefore it is appropriate for the site to be
released from the Green Belt.
* The site is deliverable on the following grounds:
o The site is suitable for development in terms of:
* Sustainable location;
* Access and highways;
* Landscape/townscape;
* Flood risk;
* Biodiversity;
* Heritage; and
* Social infrastructure - health & well-being
o The site is available, being promoted by a willing landowner
and a willing national housebuilder (Taylor Wimpey) and is
therefore available for residential development only; and
o The site is viable; and
o Development Vision:
* Following detailed investigation into the site's
environmental and technical constraints and
opportunities, a deliverable and sustainable concept
has been developed that is 'landscape-led',
integrates sympathetically with its surroundings and
optimises the development potential of the site to
contribute towards RDC's significant housing needs.

iv) Procedural considerations:
* The Local Plan-making process provides the appropriate
mechanism for reviewing the boundary of the Green Belt.
* Following the removal of the site from the Green Belt, it is
appropriate to 'backfill' with the inclusion of a Strategic Allocation in
the first part of the new Local Plan (as opposed to subsequent Site
Allocations) to avoid a policy vacuum.

v) Proposed Local Plan Approach:
* It is clear there exists an inherent shortfall of available (and
unconstrained) land to meet identified housing needs within RDC
and that no single spatial strategy will be sufficient to meet
identified needs;
* It is appropriate for 'Option D' (i.e. larger extensions that relate
well to the existing residential areas), being supported by a review
of the Green Belt, should form part of the emerging Spatial
Strategy for the new Local Plan; and
* Hawkwell is identified as a sustainable settlement and the site is
demonstrated to be suitable for release from the Green Belt and
capable of contributing towards the District's identified housing
needs.

vi) Exceptional Circumstances:
* The combination of the above factors is considered to warrant the
'exceptional circumstances' necessary to justify the release of this
site from the Green Belt to deliver the much-needed new homes
RDC needs and to contribute towards the sustainable development
objectives of the District, balanced with the need to protect the
Green Belt where the Green Belt meets its stated purposes.

The Opportunity

9.5 In conclusion, the evidence presented within these representations highlights the
suitability of Land at Hawkwell to deliver approximately 400 much-needed and
high-quality new homes consistent with the policies of the NPPF.

9.6 The site therefore offers the potential to play a significant role in achieving
sustainable patterns of development in the District, sufficient to warrant the
exceptional circumstances required to justify the release of this site from the
Green Belt.

9.7 Taylor Wimpey has a successful track record working with RDC and are keen to
continue to work collaboratively with the Council and local stakeholders in the
preparation of the new Local Plan to ensure a positive policy position for the site
is taken forward to deliver real benefits for the local community and the District
as a whole.

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

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

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

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

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

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

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

 Strategic Priority 5.1

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

2.0 Our Response to the Issues and Options

The Vision

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

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

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

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

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

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

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

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

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

2.8 Our comments relate specifically to objectively assessed housing need:

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

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

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

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

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

2.14 We therefore support option A.

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

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

2.16 Our comments on the Options are therefore as follows:

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

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

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

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

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

For this reason, we consider option C unsuitable.

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

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

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

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

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

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

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

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

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

Strategic Priority 5: Protecting and Enhancing Our Environment

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

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

2.28 We consider that option B is the most suitable approach

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

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

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

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

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

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

3.0 The Opportunity - Land at Lubards Lodge Farm, Rayleigh

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

Sustainable location

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

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

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

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

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

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

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

Deliverability

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

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

Benefitting from planned highways improvements

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

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

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

Green Infrastructure

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

Green Belt

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

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

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

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

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

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

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

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

Evidence supporting this submission

Landscape

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

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

Ecology

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

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

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

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

Highways and Access

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

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

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

Floods and Drainage

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

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

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

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

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

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

4.0 Conclusion

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Traffic and Road network

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

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

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

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

Public Transport

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

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

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

Walking

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

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

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

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

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

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

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

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

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

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

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

Greenbelt

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

To Summarise.

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

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

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

Signed