B. Amend the current Green Belt policy in the Core Strategy

Option B

In paragraph 3.3 "The area home to around 3,320 businesses...." the verb "is" is missing.

Paragraph 3.5 "The workplace and resident earnings in the district are below average compared to Essex and the UK." This is not true. It is true for workplace earnings but not for resident weekly earnings which at 670.9 are higher than Essex (594.0) and UK (539). The statement is also inconsistent with the first sentence of the next paragraph "The area is a generally prosperous part of the country,"

Paragraph 3.14 "'green part' of the South Essex". The word "the" is superfluous.

Figure 5: Ecological Map of the District. I think this is a bit out of date. Should not the whole of the eastern side of Wallasea island be shown as a local wildlife site? Also metropolitan green belt and sites of special scientific interest are shaded in the same colour.

The summary of statistics in paragraph 3.20 is muddled. "The proportion of residents aged 20 to 64 is expected to remain relatively stable over the next 20 years." is inconsistent with "An increase in the older proportion of residents compared to the rest of the population has the potential to lead to a smaller workforce and higher dependency needs."

Paragraph 4.3. "Through the Growth Deal, SELEP can direct Government monies towards specific projects across the LEP area - including schemes to deliver new homes, jobs and infrastructure - which can competitively demonstrate a growth return for the investment." My comment is that the criterium 'can competitively demonstrate' pushes investment towards homes and jobs at the expense of infrastructure, as it is easier to demonstrate growth from the former than the latter. But, adequate infrastructure is a necessary enabler of growth. If you use an unsuitable analysis method, you get the wrong answer.

Paragraph 4.5. The words "we must not over-burden investment in business." are meaningless and make the whole sentence incomprehensible. Delete these and the first word "Whilst" and the sentence makes sense.

Paragraph 4.13. The word "however" occurs twice in one sentence, which is incorrect.

Paragraphs 4.13 and 4.15. If Castle Point and Southend really are unable to meet their housing obligations then perhaps RDC could offer them some land in the extreme south east of the district, which is reasonably near Shoebury rail station, provided that central government funds the much needed relief road from the A130 to Shoebury, crossing the Crouch somewhere between Hullbridge and Fambridge and crossing the Roach. Southend and Castle Point would pay for the necessary flood defences for the new homes.

Twenty two Strategic Objectives is far too many! The document would be more convincing if you called the five Strategic Priorities the five Strategic Objectives and put the other points under them as numbered bullet points. Many of these are not strategic and they are not objectives; they are job descriptions of what the council is expected to do.

Putting homes and jobs first might be what central government want but it is not what the existing residents want. These two are interdependent - build more homes and you have to create jobs for the people to work in; create more jobs and then you cannot fill the jobs until you have built homes for the workers. The first priority should be what you have at number three: transport, waste management, and flood risk. You can forget about telecoms, water supply, wastewater and the provision of minerals and energy as these will all be provided by the private sector.

Paragraph 6.12. "Affordability can be measured by comparing the lowest 25% of earnings to the lowest 25% of house prices, which gives an affordability ratio." This is written the wrong way round and would give a ratio of 0.103. It should be written "Affordability can be measured by comparing the lowest 25% of house prices to the lowest 25% of earnings, which gives an affordability ratio."

Tell Us More SP1.1: Affordable homes and ageing population.
Surely the district council's responsibility is restricted to ensuring that sufficient land is available for development and that there are no unreasonable planning hurdles put in the way of developers. The net completions graph shows that the actual number of houses built depends on the overall state of the economy and the economics of the housing market. The district council has no control over either of these. Central government has only minor influence, even if they think otherwise.

6.30 Option: A Option C sounds like a good idea but will not work. If you are thinking of the children of existing residents then in many cases those children who would like to buy a home here will not currently be residents here. They may be renting elsewhere (in my case in South Woodham Ferrers and the Isle of Man). You would have to come up with a definition of something like a "right to residence" rather than "resident". The whole concept is fraught with difficulties.

6.21 Option: C Market forces will sort out what gets built and options D and E are then irrelevant.

6.33 Option: A

If there is a particular requirement for providing additional assistance for certain sectors of the population then try persuading central government to allow you to increase the rates paid by everybody already in the district and put that money away, securely, in a fund earmarked for that purpose.

Tell Us More SP1.2: Care homes Option: A

Paragraph 6.45. I do not agree with this statement: "We need to demonstrate that we have considered all the options before considering the Green Belt."

The original idea of the Green Belt has become distorted over time. The idea was that existing towns and cities would be surrounded by a belt of green land to prevent urban sprawl. (It is usually cheaper to build on greenfield instead of brownfield sites and so without this "belt" developments will always expand outwards, leaving a neglected and eventually derelict inner core, as in many USA cities.) In Rochford District we have a lot of Green Belt land which is not a belt around anything - it is just a vast expanse of undeveloped land.

Instead of infilling within existing developments and nibbling away at what really is the green belt immediately adjacent to them, something a lot more radical is needed and if central government are going to keep handing down housing targets then they must be prepared to provide the necessary infrastructure. It is this:
Build the relief road previously mentioned from the A130 to Shoebury, crossing the Crouch somewhere between Hullbridge and Fambridge and crossing the Roach. It needs to be a high capacity dual carriageway feeding directly onto the A130 and not at Rettendon Turnpike. The Fairglen interchange needs to be substantially improved (not the current inadequate proposals) to handle the extra traffic between the A130 and the A127 in both directions. The new road needs direct exits to both Battlesbridge and Shoebury stations and 2 or more exits to allow new developments to be built on this huge area of green land which is not green belt at all. A bus service will provide transport from the new developments to both stations. Obviously, schools, health, drainage, and power infrastructure will be needed as well but it will be cheaper to provide it out here than adding to existing conurbations. Flooding is an issue but the existing villages have to be protected against flooding anyway.

Tell Us More SP1.3: New homes ...
Option: E All of the other options are just short-term tinkering.

Tell Us More SP1.4: Good mix of homes
Option: A (The policy on affordable housing in conjunction with market forces takes care of this.) Option E is also worth considering but will only be viable if option E has been chosen in SP1.3.

I do not agree with the statement "This approach would therefore not be appropriate." in Option I. What justifies the "therefore"? It would be sensible to adopt option I and not have a specific policy. If you want to build bungalows you will probably have to accept a lower density than the current minimum, if you want to have an area of affordable housing then a good way to keep the costs down is to go for a higher density. Not to have a specific policy does not mean that there is no policy at all. Why constrain yourselves unnecessarily?

Paragraph 6.70 "There is no need has been identified..." remove "There is"

Tell Us More SP1.5: Gypsys and Travellers Option B

Tell Us More SP1.6: Houseboats Option B

Tell Us More SP1.7: Business needs Options B, C, and E

Tell Us More SP1.8: New Jobs Options B, D, E, F

Tell Us More SP1.9: Southend airport Implement all options A, B, C, D

Paragraph 6.127 "The availability of broadband in more rural areas is a constraint to the development of tourism in the district; nowadays visitors need access to promotional and other material electronically to help them navigate around (although paper copies are still
important)." This is just not true. Do you mean broadband or do you mean 3G/4G phone coverage? Local businesses need broadband, tourists do not.

Tell Me More SP1.10: Tourism and rural diversification Option B

Tell Us More SP2.1: Retail and leisure Options A, B, C, D If it ain't broke, don't fix it!

Tell Us More SP2.2 Local facilities
This is outside of the council's sphere of influence and so there is no point in worrying about it. Pubs and local shops will close if there is insufficient trade to keep them going, while in new developments business will spring up once there is sufficient demand provided planning restrictions do not get in the way. Options A and B.

Tell Us More SP3.1 Roads
Paragraph 8.1 "The equality of infrastructure in terms of services and facilities is challenging across the district given that we have such a large rural area to the east, which can mean that isolation becomes an issue." If you embrace my previous suggestion and with Southend and Castle Point persuade central government to fund the new road, the large area to the east will no longer be rural and isolated. In paragraph 8.10 "It also includes
the area to the south of the River Roach in proximity to Great Wakering." you identify exactly the problem that this would address.

Paragraph 8.12 mentions a requirement for a bypass around Rayleigh but there is nowhere to build such a bypass even if it could be justified and funded. Part of the problem in Rayleigh is that in the evening rush hour the A127 towards Southend is so congested that traffic turns off either at the Weir or Fairglen interchange and diverts through Rayleigh. Also, traffic coming down the A130 and heading for Southend finds it quicker to divert through London Road, Rayleigh town centre, and Eastwood Road than to queue for the Fairglen interchange and Progress Road. A bypass is needed not around Rayleigh but from the A130 to the eastern side of Southend.

Paragraph 8.17 "upgrades have been completed at the Rayleigh Weir junction". Is there any evidence that these 'upgrades' have made any difference whatsoever? Local people think not. If they have not been completed, do not say so.

Option C would be better than nothing. The others are only tinkering around the edges of the problem. What is really needed - although outside of RDC's control - is improvements to the strategic road network.

Paragraph 8.21. Option A is marginally better than doing nothing.

Tell Us More SP3.2: Sustainable travel
Paragraph 8.27. "Encouraging cycling within and through Rayleigh town centre are, in particular, supported to drive improvements to local air quality in this area, for example improved cycling storage." This is wishful thinking. Rayleigh is on top of a hill, of the four approaches, three involve cycling up hill in poor air quality. There are a few diehard cyclists (like my son) but normal people will not be influenced by improved cycle storage.

Paragraph 8.31. "study recommends several mitigation measures ..." These measures are just tinkering and are completely inadequate. More traffic lights are needed and some pedestrian crossings need to be moved or removed. I submitted a comprehensive plan for this previously and I shall submit it again as an appendix to this document.

Paragraph 8.34. "We could consider setting a more challenging mode share, for example 30/30/40 (public transport/walking and cycling/private vehicle)." This is wishful thinking. You can set what mode share you like but you cannot influence it.

Options A, C, and E are sensible. B will not help, D is impractical

Tell Us More SP3.3: Communications infrastructure Option B

Tell Us More SP3.4: Flood risk Options A and C

Tell Us More SP3.5: Renewable energy Option A

Tell Us More SP3.6: Planning Option A

Tell Me More SP4.1: Health Option D

Tell Me More SP4.2 Community facilities Option B

Tell Us More SP4.3: Education Option A and B

Tell Us More SP4.4: Childcare Option A and B

Tell Me More SP4.3: Open spaces and sports. [this number has been repeated]
These do not look like options. You seem to want to do all of them. What is there to choose?

Tell Me More SP4.4 Indoor sports and leisure [this number has been repeated] Option A

Tell Me More SP4.5: Young people Option A

Tell Me More SP4.6 Play spaces
Paragraph 9.57. "In order to reduce the amount of greenfield (undeveloped) land...." I do not entirely agree with this premise and think you should reconsider it. Most of the district is greenfield. Surely, building on some of that is better than trying to squash more and more development into the existing towns and villages. People in new houses can access their gardens every day, they possibly only 'go out east' to look at a field once or twice a year.
Option A

Paragraph 10.6 "A fundamental principle of the Green Belt is to keep a sense of openness between built up areas." Yes, that is what the green belt is for. However, most of the metropolitan green belt in Rochford District is maintaining a sense of openness between the built up areas to the west and the sea to the east.

Tell Us More SP5.1 Green belt vs homes Option B

Tell Us More SP5.2 Protecting habitats
Option A but leave it as it is; do not waste your time and our money worrying about climate change or wildlife corridors. There are plenty of wildlife pressure groups to do that. Also, implement options C, D, E, F, and H. Do not waste your time and our money with G.

Tell Us More SP5.3 Wallasea Island Options A and B

Tell Us More SP5.4 Landscape character
Paragraphs 10.35 to 10.45 - two and a half pages (!) written by someone who has gone overboard extolling the virtues of the countryside. I love the countryside and particularly the coastline and mudflats but this reads as though RDC councillors from the east have too much influence and want to protect their backyards (NIMBY) while pushing all the development to the west where, in fact, the majority of ratepayers actually live.
Options A and B

Tell Us More SP5.5 Heritage and culture Option A

Tell Us More SP5.6 Building design
I question whether there is any justification for doing this. Why not just follow the national guidelines, Essex Design Guide, and building regulations? Option A and K

Tell Us More SP5.7 Air quality
None of the actions proposed will make a significant difference to air quality. The biggest improvement will come from the gradual replacement of older vehicles with new ones built to a higher emissions standard and, ultimately, the introduction of hybrid and electric vehicles.

Air quality now has increased importance. The EU is threatening to fine our government because its plans to improve air quality in a large number of cities and towns are inadequate. Just waiting and hoping that things get better will not do!

If you want to do anything in a faster time frame than that then steps must be taken to: reduce traffic congestion; avoid building new homes in areas that are already congested; build new homes in areas where the air quality is good.

I refer you again to the plan that I append to this document to significantly reduce congestion and improve air quality in Rayleigh town centre. This could be achieved in much less time than waiting for all the existing vehicles to be replaced.

You may as well stay with option A since options B and C will make no difference.

Tell Us More D.P1.1 Affordable homes Option F What happened to options A to E?

Tell Us More D.P1.2 Self build
You are making a mountain out of a molehill on this. No policy is needed. Anyone wishing to self build will have to find a plot of land first. They will then have to apply for planning permission and meet building regulations the same as anybody else would. All the council has to do is NOT to discriminate against such applications. From the self-builders point of view, negotiating the VAT maze is far more of a problem. New builds are zero rated but everything they buy will have VAT on it. The only way to claim back the VAT is to form a company and register it for VAT but that is difficult when it has no trading history and will only complete one project. This is all for central government to sort out, not local councils.
Option D

Tell Us More D.P1.3 Rural exception sites
Paragraph 11.16 "with the publication of the Housing White Paper in February 2017 the definition of what constitutes affordable homes could be amended" This is clearly out of date and needs updating. Was the paper published last year? Was the definition amended?

There is no point in wasting time and effort worrying about a situation that has not arisen yet and may not arise. Since there are so many possible variables in the circumstances any such policy would have to be extremely comprehensive. Wait until a planning application is made and then assess it on its merits. If there is no formal policy in place then this would have to be debated by the Development Committee. You could meet the NPPF requirement by putting a reference to rural exception sites on the council's website.
Option H

Tell Us More D.P1.4 Annexes and outbuildings
Option B which should say "...rely on case law", not "reply on case law".

Tell Us More D.P1.5 Basements
Option A

Tell Us More D.P1.6 Rebuilding in the green belt
Option B

Tell Us More D.P1.7 Agricultural occupational homes
Paragraph 11.42 ".... applications for the removal of agricultural occupancy conditions will not, therefore, be permitted except in the most exceptional circumstances." Are you sure this is sensible? If an agricultural home becomes empty would you rather let it remain empty and possibly become derelict than allow a non-agricultural worker to move into it? Option A

Tell Us More D.P1.8 Brownfield land in the green belt
Option B

Tell Us More D.P1.9 Extending gardens in the green belt
Option A

Tell Us More D.P1.10 Parking and traffic management
Options A and B

Tell Us More D.P1.11 Home businesses
A thriving home business could cause parking issues in the immediate area but it also provides local employment thereby reducing commuting out of the area. Also, noise and pollution issues have to be considered. This requires each case to be assessed on its own merits. Option A

Tell Us More D.P1.12 Altering businesses in the green belt
Option A

Tell Us More D.P1.13 Advertising and signage
Option A

Tell Us More D.P1.13 Light pollution [this number has been repeated]
Option B

Tell Us More D.P1.14 Contaminated land
Option A

The introduction is too verbose and will deter people from reading the whole document. A professional editor should have been employed to précis it down to a length that people will be willing to read. Some of the rest of the document is better but would still benefit from editing.

There are too many spelling, grammatical, and punctuation errors to make it worthwhile proof-reading this initial draft until it has been edited.



Interim Sustainability Appraisal

The first ten pages have been constructed by concatenating standard paragraphs, with minimal editing, in the same way than an accountant or surveyor prepares a report.

The rest of it consists of extracts from the Issues and Options document with meaningful, but not particularly incisive, comments.

Preparing this document was a legal requirement but it does not add much to the sum total of human knowledge.




Appendix

A proposal for the reduction of traffic congestion in central Rayleigh and consequent improvement of air quality

Air pollution is an acknowledged problem in central Rayleigh and just today the high court have ruled that the government must do more to reduce it, particularly NOx emissions from diesel vehicles. A major cause of air pollution in Rayleigh is traffic queuing on Crown Hill and creeping forward one vehicle at a time - engines continually running and repeated hill starts which are particularly bad for NOx emissions. Many recent cars and buses have automatic engine stop when stationary so that if traffic is held at a red light emissions will be significantly reduced. This feature will become commonplace over the next few years.

The pedestrian crossing at the top of Crown Hill and the mini roundabout at its junction with the High Street must be eliminated in order to cure this problem. This proposal achieves that and improves traffic flow in Websters Way as well as eliminating most traffic from the central part of the High Street.

1. Close the High Street to traffic between the Crown and Half Moon/ Church. Allow access for taxis to the existing taxi lagoon only. Allow access for delivery vehicles but perhaps only at specified times. This will be a shared space and so 10 MPH speed limit.
2. Block off access from Bellingham Lane and Church Street to the High Street.
3. Replace the mini roundabout at the Crown Hill / High Street junction with a swept bend with limited access to and from the High Street (see 1) with give way lines on the outside of the bend.
4. Replace mini roundabouts at the High Street / Eastwood Road and Eastwood Road/ Websters Way junctions with traffic lights.
5. Replace the zebra crossing at the top of Crown Hill with a light controlled pedestrian crossing.
6. Remove the pedestrian crossing outside the Spread Eagle. This is no longer needed as people can cross from The Crown to the taxi lagoon.
7. Replace the zebra crossing across Eastwood Road outside Marks and Spencer with a light controlled pedestrian crossing.
8. Replace the zebra crossing across Websters Way near to Eastwood Road with a light controlled pedestrian crossing.
9. Arrange for coordinated control of the two new sets of traffic lights, and the four light controlled pedestrian crossings (Crown Hill, Websters Way, and two in Eastwood Road). *
10. Remove the pedestrian crossing in the centre of the High Street as it is no longer needed.
11. Remove the traffic lights at the Junction of Websters Way and High Street and the pedestrian crossing across the High Street as they are no longer needed. Retain the pedestrian crossing across Websters Way. This junction becomes a swept bend and will be free flowing for traffic except when pedestrians are crossing.
12. Access for wedding cars and hearses to the church will be unaffected except that they will have to use London Hill instead of Bellingham Lane to/from Church Street.
13. Access to the Mill Hall and its car parks will be via London Hill and Bellingham Lane. A new exit will be required from the windmill car park to London Hill adjacent to Simpsons solicitors. **
14. Provide parking for disabled people in Bellingham Lane between the Mill hall and its previous junction with the High Street. Create a small turning circle where the junction used to be.
15. Create a layby in Websters Way for buses heading for Hockley or Bull Lane.
16. The loading bay outside Wimpy will become the bus stop for the No 9 bus.
17. The No 1 bus is a problem as it will no longer be able to stop in the High Street or Websters Way and the first stop in the High Road is too far from the town centre. A new bus layby will be needed outside Pizza Express. ***
18. Install traffic lights at the junction of Downhall Road and London Road, incorporating the existing light controlled pedestrian crossing.
19. Install traffic lights at the junction of London Hill and London Road / Station Road. Traffic lights will not be needed at the junction of The Approach and London Road if the lights either side of this junction are phased correctly.

* There are potentially some problems which arise because there will be traffic lights at junctions where the limited space available prohibits the use of a right turn lane or a left filter lane and there are pedestrian crossings nearby. The traffic lights at High Street / Eastwood Road and Eastwood Road / Websters Way will each need to have a phase when traffic from all three directions is stopped and both the adjacent pedestrian crossings are open for pedestrians. This phase will only need to occur when a pedestrian has requested it at either of the adjacent crossings. When there is a lot of pedestrian traffic it will be necessary to synchronise both junctions so that the "all traffic stopped" phase occurs at both junctions at the same time.

** Some drivers will complain that in order to get to the Mill Hall they have to go down Crown Hill and up London Hill, although they could park in Websters Way car park or the market car park and walk. However, people approaching Rayleigh along the London Road will have easier access to the Mill Hall car parks and will not enter the town centre at all, reducing congestion and pollution.

*** Considering traffic coming up Crown Hill, it will be advantageous to arrange that when the pedestrian crossing on Crown Hill goes red to stop traffic there is a delay of several seconds before the light at the High Street/ Eastwood Road junction and the Eastwood Road pedestrian crossing turn red. This should empty this section of road and allow a bus in the layby to pull out without disrupting the traffic flow up Crown Hill.

The Local Authority's current position is that of significant development pressure in addressing historic poor delivery of housing numbers, which is reflected in the other authorities in South Essex. Option B is clearly the only suitable approach to adopt, as the status quo has not delivered the required need within the district and has therefore applied pressure onto the authority which otherwise could have been avoided if past under-delivery was addressed. Option B can be only the avenue for exploration by the LPA to ensure that maximum delivery can be assured by way of seeking brownfield sites to their exhaustion as well as the most appropriate sites to be released from the Green Belt.

Thank you for the opportunity to comment on the Regulation 18 version of the Rochford
Local Plan. These representations are submitted on behalf of Rydon Homes which has an
interest in land south of Wellington Road, Rayleigh (site CFS053 in the 2017 SHELAA).
Attached to this representation is a schedule which sets out Rydon's views on the options
presented in the document. Hopefully, this will assist your analysis. However, such a point
by point response can also obscure the Respondent's overall views on the plan and its main
issues. In view of this, this letter brings together the various themes of the Rydon response.
The main points are :
1. The Vision and Strategic Objectives should make it clearer that the plan should seek
to meet local housing needs in full. Many other Local Authorities with high levels of
Green Belt (eg St Albans) have concluded that their housing needs have to be met and
have commissioned a Green Belt Review to identify which land parcels serve the least
Green Belt purposes.
2. The Green Belt Review should be progressed in parallel with an assessment of which
sites would best promote a more sustainable pattern of development and minimise the
use of the car.
3. The plan recognises that Rayleigh is the largest settlement in Rochford District and
has the greatest range of facilities and services, plus public transport. As a
consequence, new housing allocations within and on the edge of Rayleigh have the
greatest chance of minimising the need to use the car in favour of walking, cycling
Sellwood
Planning
Chartered Town Planners
Chartered Surveyors
Stoughton Cross House, Stoughton Cross, Wedmore, Somerset, BS28 4QP
Tel: 01934 712041 Fax: 01934 712118 Mobile: 07801 321162 Email: bob@sellwoodplanning.com
2
and public transport. Whilst it is accepted that the centre of Rayleigh is currently an
Air Quality Management Area, your 2015 Environmental Capacity Study (para 8.2)
recognises that a package of mitigation measures is available.
4. Whilst it is a matter of concern that your Environmental Capacity Study only focusses
on the environmental facet of sustainable development and largely ignores the social
and economic aspects, it is noted that it concludes (para 8.27) that the greatest
capacity for further development lies within and on the edge of the urban areas in the
north and west of the District. When this conclusion is combined with the sustainable
credentials of Rayleigh, it is clear that the evidence base provides the justification for
smaller housing allocations on the periphery of Rayleigh.
5. The Rydon land south of Wellington Road, Rayleigh (CFS053 - see attached plan) is
a strong candidate for allocation since
* It is within walking distance of Rayleigh Town Centre
* It has an existing access on to Wellington Road
* It is close to schools, open space and community facilities
* It is not constrained by environmental or heritage issues
* It is outside the boundary of the Upper Roach Valley (see Figure 07 of the
Environmental Capacity Study)
* The site could be released from the Green Belt with only limited impacts on
the purposes of the Green Belt
* An indicative master plan is attached (No. 2575-A-1004 A) which shows how
the site can be planned to provide up to 80 homes. This master plan forms
part of the 'Site Appraisal and Promotion Document' provided to you on the
18th May 2017. If you would like this resubmitted, please let me know.
Should you feel that a meeting would be useful to discuss this site, perhaps you could suggest
some dates.

Rochford Local Plan Regulation 18 Consultation
Representations on behalf of Rydon Homes
submitted by Sellwood Planning
1. Vision (para. 5.9) : The Vision should include the objective of fully meeting housing
needs within the Rochford District.
2. Vision (para 5.10) : The 'Our Society' Vision should contain the objective of fully
meeting housing needs with Rochford District.
3. Strategic Objective (para 5.11) : The objective should make it clear that 'sufficient
homes' equates to Objectively Assessed Housing Needs, or such housing figure that
emerges from the 'Right Homes' consultation by DCLG. It is unclear what
'prioritising the use of previously developed land first' means. Given the scale of
housing needs, it is likely that both previously developed land and Green Belt releases
will be needed throughout the plan period.
4. Strategic Priority 1 (para 5.11) : There should be an objective to locate new housing
where it can best deliver the most sustainable pattern of development.
5. Strategic Priority 1 (p38) : The plan should pursue Option A to seek to provide as
much housing as possible within Rochford District.
6. Affordable Housing Threshold (para. 6.31) : Option A should be selected to
maximise the delivery of affordable homes from a wider range of sites.
7. Affordable Housing Percentage (para 6.31) : In order to ensure delivery and viability
the percentage of affordable housing should be retained at 35%.
8. Settlement Hierarchy (p42, Table 5) : The settlement hierarchy is supported as logical
and evidence based.
9. (para 6.45) : Since housing need is likely to require the release of Green Belt land,
the Council should commission a Green Belt Review to assess which sites contribute
least to Green Belt purposes.
10. (para. 6.46) : Greater weight should be given to locations for new housing which
offer the opportunity to use non car based modes of travel.
11. (para. 6.48) : The most appropriate option is one which combines A, B and C.
Options D and E (larger new allocations or a new settlement) conflict with the
conclusion of the Environmental Capacity Study that the preferred options would
entail smaller allocations within and on the edge of the urban areas in the north and
west of the District.
12. Housing Mix (p46, Table 6) : The table should be disaggregated to provide separate
mixes for market and affordable housing. Option A on page 48 is the most
appropriate option.
13. Local Highways (p83) : Given the acknowledged current problems of air quality in
Rayleigh Town Centre, priority should be given to Option C to investigate the
upgrading of Rawreth Lane or Watering Lane to take traffic away from the centre of
Rayleigh.
14. Planning Obligations (p99) : The existing Policy should be retained (Option A).
15. (para. 10.15) : The conclusions of the Environmental Capacity Study that the greatest
potential for development lies within and on the edge of settlements to the north and
west of the District are supported. Given the size of Rayleigh and its range of
services, facilities and public transport, it should be the logical first choice for
sustainable housing allocations. Since recent development in the town has been to the
west, this Local Plan should seek to 'rebalance' the spatial form of Rayleigh by the
allocation of land to the east, such as the land south of Wellington Road.
16. Green Belt (para. 10.16) : It is considered that a Green Belt Review (Option B) will
have to form an essential part of the evidence base for the new Local Plan. This
should be commissioned as soon as possible.

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

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

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

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

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

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

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

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

Issues and Options Document

In paragraph 3.3 "The area home to around 3,320 businesses...." the verb "is" is missing.

Paragraph 3.5 "The workplace and resident earnings in the district are below average compared to Essex and the UK." This is not true. It is true for workplace earnings but not for resident weekly earnings which at 670.9 are higher than Essex (594.0) and UK (539). The statement is also inconsistent with the first sentence of the next paragraph "The area is a generally prosperous part of the country,"

Paragraph 3.14 "'green part' of the South Essex". The word "the" is superfluous.

Figure 5: Ecological Map of the District. I think this is a bit out of date. Should not the whole of the eastern side of Wallasea island be shown as a local wildlife site? Also metropolitan green belt and sites of special scientific interest are shaded in the same colour.

The summary of statistics in paragraph 3.20 is muddled. "The proportion of residents aged 20 to 64 is expected to remain relatively stable over the next 20 years." is inconsistent with "An increase in the older proportion of residents compared to the rest of the population has the potential to lead to a smaller workforce and higher dependency needs."

Paragraph 4.3. "Through the Growth Deal, SELEP can direct Government monies towards specific projects across the LEP area - including schemes to deliver new homes, jobs and infrastructure - which can competitively demonstrate a growth return for the investment." My comment is that the criterium 'can competitively demonstrate' pushes investment towards homes and jobs at the expense of infrastructure, as it is easier to demonstrate growth from the former than the latter. But, adequate infrastructure is a necessary enabler of growth. If you use an unsuitable analysis method, you get the wrong answer.

Paragraph 4.5. The words "we must not over-burden investment in business." are meaningless and make the whole sentence incomprehensible. Delete these and the first word "Whilst" and the sentence makes sense.

Paragraph 4.13. The word "however" occurs twice in one sentence, which is incorrect.

Paragraphs 4.13 and 4.15. If Castle Point and Southend really are unable to meet their housing obligations then perhaps RDC could offer them some land in the extreme south east of the district, which is reasonably near Shoebury rail station, provided that central government funds the much needed relief road from the A130 to Shoebury, crossing the Crouch somewhere between Hullbridge and Fambridge and crossing the Roach. Southend and Castle Point would pay for the necessary flood defences for the new homes.

Twenty two Strategic Objectives is far too many! The document would be more convincing if you called the five Strategic Priorities the five Strategic Objectives and put the other points under them as numbered bullet points. Many of these are not strategic and they are not objectives; they are job descriptions of what the council is expected to do.

Putting homes and jobs first might be what central government want but it is not what the existing residents want. These two are interdependent - build more homes and you have to create jobs for the people to work in; create more jobs and then you cannot fill the jobs until you have built homes for the workers. The first priority should be what you have at number three: transport, waste management, and flood risk. You can forget about telecoms, water supply, wastewater and the provision of minerals and energy as these will all be provided by the private sector.

Paragraph 6.12. "Affordability can be measured by comparing the lowest 25% of earnings to the lowest 25% of house prices, which gives an affordability ratio." This is written the wrong way round and would give a ratio of 0.103. It should be written "Affordability can be measured by comparing the lowest 25% of house prices to the lowest 25% of earnings, which gives an affordability ratio."

Tell Us More SP1.1: Affordable homes and ageing population.
Surely the district council's responsibility is restricted to ensuring that sufficient land is available for development and that there are no unreasonable planning hurdles put in the way of developers. The net completions graph shows that the actual number of houses built depends on the overall state of the economy and the economics of the housing market. The district council has no control over either of these. Central government has only minor influence, even if they think otherwise.

6.30 Option: A Option C sounds like a good idea but will not work. If you are thinking of the children of existing residents then in many cases those children who would like to buy a home here will not currently be residents here. They may be renting elsewhere (in my case in South Woodham Ferrers and the Isle of Man). You would have to come up with a definition of something like a "right to residence" rather than "resident". The whole concept is fraught with difficulties.

6.21 Option: C Market forces will sort out what gets built and options D and E are then irrelevant.

6.33 Option: A

If there is a particular requirement for providing additional assistance for certain sectors of the population then try persuading central government to allow you to increase the rates paid by everybody already in the district and put that money away, securely, in a fund earmarked for that purpose.

Tell Us More SP1.2: Care homes Option: A

Paragraph 6.45. I do not agree with this statement: "We need to demonstrate that we have considered all the options before considering the Green Belt."

The original idea of the Green Belt has become distorted over time. The idea was that existing towns and cities would be surrounded by a belt of green land to prevent urban sprawl. (It is usually cheaper to build on greenfield instead of brownfield sites and so without this "belt" developments will always expand outwards, leaving a neglected and eventually derelict inner core, as in many USA cities.) In Rochford District we have a lot of Green Belt land which is not a belt around anything - it is just a vast expanse of undeveloped land.

Instead of infilling within existing developments and nibbling away at what really is the green belt immediately adjacent to them, something a lot more radical is needed and if central government are going to keep handing down housing targets then they must be prepared to provide the necessary infrastructure. It is this:
Build the relief road previously mentioned from the A130 to Shoebury, crossing the Crouch somewhere between Hullbridge and Fambridge and crossing the Roach. It needs to be a high capacity dual carriageway feeding directly onto the A130 and not at Rettendon Turnpike. The Fairglen interchange needs to be substantially improved (not the current inadequate proposals) to handle the extra traffic between the A130 and the A127 in both directions. The new road needs direct exits to both Battlesbridge and Shoebury stations and 2 or more exits to allow new developments to be built on this huge area of green land which is not green belt at all. A bus service will provide transport from the new developments to both stations. Obviously, schools, health, drainage, and power infrastructure will be needed as well but it will be cheaper to provide it out here than adding to existing conurbations. Flooding is an issue but the existing villages have to be protected against flooding anyway.

Tell Us More SP1.3: New homes ...
Option: E All of the other options are just short-term tinkering.

Tell Us More SP1.4: Good mix of homes
Option: A (The policy on affordable housing in conjunction with market forces takes care of this.) Option E is also worth considering but will only be viable if option E has been chosen in SP1.3.

I do not agree with the statement "This approach would therefore not be appropriate." in Option I. What justifies the "therefore"? It would be sensible to adopt option I and not have a specific policy. If you want to build bungalows you will probably have to accept a lower density than the current minimum, if you want to have an area of affordable housing then a good way to keep the costs down is to go for a higher density. Not to have a specific policy does not mean that there is no policy at all. Why constrain yourselves unnecessarily?

Paragraph 6.70 "There is no need has been identified..." remove "There is"

Tell Us More SP1.5: Gypsys and Travellers Option B

Tell Us More SP1.6: Houseboats Option B

Tell Us More SP1.7: Business needs Options B, C, and E

Tell Us More SP1.8: New Jobs Options B, D, E, F

Tell Us More SP1.9: Southend airport Implement all options A, B, C, D

Paragraph 6.127 "The availability of broadband in more rural areas is a constraint to the development of tourism in the district; nowadays visitors need access to promotional and other material electronically to help them navigate around (although paper copies are still
important)." This is just not true. Do you mean broadband or do you mean 3G/4G phone coverage? Local businesses need broadband, tourists do not.

Tell Me More SP1.10: Tourism and rural diversification Option B

Tell Us More SP2.1: Retail and leisure Options A, B, C, D If it ain't broke, don't fix it!

Tell Us More SP2.2 Local facilities
This is outside of the council's sphere of influence and so there is no point in worrying about it. Pubs and local shops will close if there is insufficient trade to keep them going, while in new developments business will spring up once there is sufficient demand provided planning restrictions do not get in the way. Options A and B.

Tell Us More SP3.1 Roads
Paragraph 8.1 "The equality of infrastructure in terms of services and facilities is challenging across the district given that we have such a large rural area to the east, which can mean that isolation becomes an issue." If you embrace my previous suggestion and with Southend and Castle Point persuade central government to fund the new road, the large area to the east will no longer be rural and isolated. In paragraph 8.10 "It also includes
the area to the south of the River Roach in proximity to Great Wakering." you identify exactly the problem that this would address.

Paragraph 8.12 mentions a requirement for a bypass around Rayleigh but there is nowhere to build such a bypass even if it could be justified and funded. Part of the problem in Rayleigh is that in the evening rush hour the A127 towards Southend is so congested that traffic turns off either at the Weir or Fairglen interchange and diverts through Rayleigh. Also, traffic coming down the A130 and heading for Southend finds it quicker to divert through London Road, Rayleigh town centre, and Eastwood Road than to queue for the Fairglen interchange and Progress Road. A bypass is needed not around Rayleigh but from the A130 to the eastern side of Southend.

Paragraph 8.17 "upgrades have been completed at the Rayleigh Weir junction". Is there any evidence that these 'upgrades' have made any difference whatsoever? Local people think not. If they have not been completed, do not say so.

Option C would be better than nothing. The others are only tinkering around the edges of the problem. What is really needed - although outside of RDC's control - is improvements to the strategic road network.

Paragraph 8.21. Option A is marginally better than doing nothing.

Tell Us More SP3.2: Sustainable travel
Paragraph 8.27. "Encouraging cycling within and through Rayleigh town centre are, in particular, supported to drive improvements to local air quality in this area, for example improved cycling storage." This is wishful thinking. Rayleigh is on top of a hill, of the four approaches, three involve cycling up hill in poor air quality. There are a few diehard cyclists (like my son) but normal people will not be influenced by improved cycle storage.

Paragraph 8.31. "study recommends several mitigation measures ..." These measures are just tinkering and are completely inadequate. More traffic lights are needed and some pedestrian crossings need to be moved or removed. I submitted a comprehensive plan for this previously and I shall submit it again as an appendix to this document.

Paragraph 8.34. "We could consider setting a more challenging mode share, for example 30/30/40 (public transport/walking and cycling/private vehicle)." This is wishful thinking. You can set what mode share you like but you cannot influence it.

Options A, C, and E are sensible. B will not help, D is impractical

Tell Us More SP3.3: Communications infrastructure Option B

Tell Us More SP3.4: Flood risk Options A and C

Tell Us More SP3.5: Renewable energy Option A

Tell Us More SP3.6: Planning Option A

Tell Me More SP4.1: Health Option D

Tell Me More SP4.2 Community facilities Option B

Tell Us More SP4.3: Education Option A and B

Tell Us More SP4.4: Childcare Option A and B

Tell Me More SP4.3: Open spaces and sports. [this number has been repeated]
These do not look like options. You seem to want to do all of them. What is there to choose?

Tell Me More SP4.4 Indoor sports and leisure [this number has been repeated] Option A

Tell Me More SP4.5: Young people Option A

Tell Me More SP4.6 Play spaces
Paragraph 9.57. "In order to reduce the amount of greenfield (undeveloped) land...." I do not entirely agree with this premise and think you should reconsider it. Most of the district is greenfield. Surely, building on some of that is better than trying to squash more and more development into the existing towns and villages. People in new houses can access their gardens every day, they possibly only 'go out east' to look at a field once or twice a year.
Option A

Paragraph 10.6 "A fundamental principle of the Green Belt is to keep a sense of openness between built up areas." Yes, that is what the green belt is for. However, most of the metropolitan green belt in Rochford District is maintaining a sense of openness between the built up areas to the west and the sea to the east.

Tell Us More SP5.1 Green belt vs homes Option B

Tell Us More SP5.2 Protecting habitats
Option A but leave it as it is; do not waste your time and our money worrying about climate change or wildlife corridors. There are plenty of wildlife pressure groups to do that. Also, implement options C, D, E, F, and H. Do not waste your time and our money with G.

Tell Us More SP5.3 Wallasea Island Options A and B

Tell Us More SP5.4 Landscape character
Paragraphs 10.35 to 10.45 - two and a half pages (!) written by someone who has gone overboard extolling the virtues of the countryside. I love the countryside and particularly the coastline and mudflats but this reads as though RDC councillors from the east have too much influence and want to protect their backyards (NIMBY) while pushing all the development to the west where, in fact, the majority of ratepayers actually live.
Options A and B

Tell Us More SP5.5 Heritage and culture Option A

Tell Us More SP5.6 Building design
I question whether there is any justification for doing this. Why not just follow the national guidelines, Essex Design Guide, and building regulations? Option A and K

Tell Us More SP5.7 Air quality
None of the actions proposed will make a significant difference to air quality. The biggest improvement will come from the gradual replacement of older vehicles with new ones built to a higher emissions standard and, ultimately, the introduction of hybrid and electric vehicles.

Air quality now has increased importance. The EU is threatening to fine our government because its plans to improve air quality in a large number of cities and towns are inadequate. Just waiting and hoping that things get better will not do!

If you want to do anything in a faster time frame than that then steps must be taken to: reduce traffic congestion; avoid building new homes in areas that are already congested; build new homes in areas where the air quality is good.

I refer you again to the plan that I append to this document to significantly reduce congestion and improve air quality in Rayleigh town centre. This could be achieved in much less time than waiting for all the existing vehicles to be replaced.

You may as well stay with option A since options B and C will make no difference.

Tell Us More D.P1.1 Affordable homes Option F What happened to options A to E?

Tell Us More D.P1.2 Self build
You are making a mountain out of a molehill on this. No policy is needed. Anyone wishing to self build will have to find a plot of land first. They will then have to apply for planning permission and meet building regulations the same as anybody else would. All the council has to do is NOT to discriminate against such applications. From the self-builders point of view, negotiating the VAT maze is far more of a problem. New builds are zero rated but everything they buy will have VAT on it. The only way to claim back the VAT is to form a company and register it for VAT but that is difficult when it has no trading history and will only complete one project. This is all for central government to sort out, not local councils.
Option D

Tell Us More D.P1.3 Rural exception sites
Paragraph 11.16 "with the publication of the Housing White Paper in February 2017 the definition of what constitutes affordable homes could be amended" This is clearly out of date and needs updating. Was the paper published last year? Was the definition amended?

There is no point in wasting time and effort worrying about a situation that has not arisen yet and may not arise. Since there are so many possible variables in the circumstances any such policy would have to be extremely comprehensive. Wait until a planning application is made and then assess it on its merits. If there is no formal policy in place then this would have to be debated by the Development Committee. You could meet the NPPF requirement by putting a reference to rural exception sites on the council's website.
Option H

Tell Us More D.P1.4 Annexes and outbuildings
Option B which should say "...rely on case law", not "reply on case law".

Tell Us More D.P1.5 Basements
Option A

Tell Us More D.P1.6 Rebuilding in the green belt
Option B

Tell Us More D.P1.7 Agricultural occupational homes
Paragraph 11.42 ".... applications for the removal of agricultural occupancy conditions will not, therefore, be permitted except in the most exceptional circumstances." Are you sure this is sensible? If an agricultural home becomes empty would you rather let it remain empty and possibly become derelict than allow a non-agricultural worker to move into it? Option A

Tell Us More D.P1.8 Brownfield land in the green belt
Option B

Tell Us More D.P1.9 Extending gardens in the green belt
Option A

Tell Us More D.P1.10 Parking and traffic management
Options A and B

Tell Us More D.P1.11 Home businesses
A thriving home business could cause parking issues in the immediate area but it also provides local employment thereby reducing commuting out of the area. Also, noise and pollution issues have to be considered. This requires each case to be assessed on its own merits. Option A

Tell Us More D.P1.12 Altering businesses in the green belt
Option A

Tell Us More D.P1.13 Advertising and signage
Option A

Tell Us More D.P1.13 Light pollution [this number has been repeated]
Option B

Tell Us More D.P1.14 Contaminated land
Option A

The introduction is too verbose and will deter people from reading the whole document. A professional editor should have been employed to précis it down to a length that people will be willing to read. Some of the rest of the document is better but would still benefit from editing.

There are too many spelling, grammatical, and punctuation errors to make it worthwhile proof-reading this initial draft until it has been edited.



Interim Sustainability Appraisal

The first ten pages have been constructed by concatenating standard paragraphs, with minimal editing, in the same way than an accountant or surveyor prepares a report.

The rest of it consists of extracts from the Issues and Options document with meaningful, but not particularly incisive, comments.

Preparing this document was a legal requirement but it does not add much to the sum total of human knowledge.




Appendix

A proposal for the reduction of traffic congestion in central Rayleigh and consequent improvement of air quality

Air pollution is an acknowledged problem in central Rayleigh and just today the high court have ruled that the government must do more to reduce it, particularly NOx emissions from diesel vehicles. A major cause of air pollution in Rayleigh is traffic queuing on Crown Hill and creeping forward one vehicle at a time - engines continually running and repeated hill starts which are particularly bad for NOx emissions. Many recent cars and buses have automatic engine stop when stationary so that if traffic is held at a red light emissions will be significantly reduced. This feature will become commonplace over the next few years.

The pedestrian crossing at the top of Crown Hill and the mini roundabout at its junction with the High Street must be eliminated in order to cure this problem. This proposal achieves that and improves traffic flow in Websters Way as well as eliminating most traffic from the central part of the High Street.

1. Close the High Street to traffic between the Crown and Half Moon/ Church. Allow access for taxis to the existing taxi lagoon only. Allow access for delivery vehicles but perhaps only at specified times. This will be a shared space and so 10 MPH speed limit.
2. Block off access from Bellingham Lane and Church Street to the High Street.
3. Replace the mini roundabout at the Crown Hill / High Street junction with a swept bend with limited access to and from the High Street (see 1) with give way lines on the outside of the bend.
4. Replace mini roundabouts at the High Street / Eastwood Road and Eastwood Road/ Websters Way junctions with traffic lights.
5. Replace the zebra crossing at the top of Crown Hill with a light controlled pedestrian crossing.
6. Remove the pedestrian crossing outside the Spread Eagle. This is no longer needed as people can cross from The Crown to the taxi lagoon.
7. Replace the zebra crossing across Eastwood Road outside Marks and Spencer with a light controlled pedestrian crossing.
8. Replace the zebra crossing across Websters Way near to Eastwood Road with a light controlled pedestrian crossing.
9. Arrange for coordinated control of the two new sets of traffic lights, and the four light controlled pedestrian crossings (Crown Hill, Websters Way, and two in Eastwood Road). *
10. Remove the pedestrian crossing in the centre of the High Street as it is no longer needed.
11. Remove the traffic lights at the Junction of Websters Way and High Street and the pedestrian crossing across the High Street as they are no longer needed. Retain the pedestrian crossing across Websters Way. This junction becomes a swept bend and will be free flowing for traffic except when pedestrians are crossing.
12. Access for wedding cars and hearses to the church will be unaffected except that they will have to use London Hill instead of Bellingham Lane to/from Church Street.
13. Access to the Mill Hall and its car parks will be via London Hill and Bellingham Lane. A new exit will be required from the windmill car park to London Hill adjacent to Simpsons solicitors. **
14. Provide parking for disabled people in Bellingham Lane between the Mill hall and its previous junction with the High Street. Create a small turning circle where the junction used to be.
15. Create a layby in Websters Way for buses heading for Hockley or Bull Lane.
16. The loading bay outside Wimpy will become the bus stop for the No 9 bus.
17. The No 1 bus is a problem as it will no longer be able to stop in the High Street or Websters Way and the first stop in the High Road is too far from the town centre. A new bus layby will be needed outside Pizza Express. ***
18. Install traffic lights at the junction of Downhall Road and London Road, incorporating the existing light controlled pedestrian crossing.
19. Install traffic lights at the junction of London Hill and London Road / Station Road. Traffic lights will not be needed at the junction of The Approach and London Road if the lights either side of this junction are phased correctly.

* There are potentially some problems which arise because there will be traffic lights at junctions where the limited space available prohibits the use of a right turn lane or a left filter lane and there are pedestrian crossings nearby. The traffic lights at High Street / Eastwood Road and Eastwood Road / Websters Way will each need to have a phase when traffic from all three directions is stopped and both the adjacent pedestrian crossings are open for pedestrians. This phase will only need to occur when a pedestrian has requested it at either of the adjacent crossings. When there is a lot of pedestrian traffic it will be necessary to synchronise both junctions so that the "all traffic stopped" phase occurs at both junctions at the same time.

** Some drivers will complain that in order to get to the Mill Hall they have to go down Crown Hill and up London Hill, although they could park in Websters Way car park or the market car park and walk. However, people approaching Rayleigh along the London Road will have easier access to the Mill Hall car parks and will not enter the town centre at all, reducing congestion and pollution.

*** Considering traffic coming up Crown Hill, it will be advantageous to arrange that when the pedestrian crossing on Crown Hill goes red to stop traffic there is a delay of several seconds before the light at the High Street/ Eastwood Road junction and the Eastwood Road pedestrian crossing turn red. This should empty this section of road and allow a bus in the layby to pull out without disrupting the traffic flow up Crown Hill.