Air Quality

I would like to object to the New Local Plan.

I have lived in Rayleigh my whole life and I feel so sad how what was once a lovely town has become so overdeveloped.

My Nan and Grandad have both passed on but they also lived in Rayleigh for most of their lives (My Grandad helped build the old Grove School swimming pool), they both moved to Suffolk in the latter part of their lives to get away from the traffic/pollution/ and the overdeveloped state that Rayleigh had become. I can see myself following in their footsteps and when my career is over I imagine I will want to get out of Rayleigh unless something is done to reduce traffic/pollution and over development.

I am 36 and work as a Tennis Coach, so more houses and more people could benefit me from a Business point of view, however after constantly sitting in traffic towards Rayleigh Weir almost daily and the traffic in general all around the Rochford District I am hugely against any more development that will add to these problems.

All the parents of kids moan about the traffic to and from the tennis club which is just off Rayleigh High Road. From speaking to parents and club members (We have over 100 Juniors and over 100 adults) almost everyone has commented on how frustrated they get with traffic and over development in and around Rayleigh. I fear that most people don't write in or make their views known because people have no confidence that their views will make any difference. To be honest that is probably why i have left my email so late before the deadline because the thought has crossed my mind - will i really make a difference? Anyway the point I am trying to make here is that for every person that does take the time to write/email and object you can be certain there are probably 10 times that amount of people that are fed up with how overdeveloped the Rayleigh and Rochford District area has become but haven't had their say.

The whole Rochford District area needs someone in the right position who is very strong and says NO MORE, even if that means telling the Government no. We need someone to be creative and address our problems and not add to them!

I propose we need to find creative ways to reduce Traffic congestion.

I would also kindly ask if someone could respond to me with the answers to the following questions:

1.What is a safe level of air pollution?

2.What is the current air pollution levels of Rayleigh High Street and Rayleigh Weir?

3.Was their once a device in Rayleigh High Street that measured air pollution? (I seem to recall their was)

4.If so why was this removed and who authorised its removal?

As someone who has lived in Rayleigh their whole life, worked in Rayleigh for many of them years please take notice of what the people of Rayleigh want, which is stop the overdevelopment now before the town is Ruined!
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I strongly object to the planning application for several reasons:

Firstly I would like to point out the Ministry of Housing, Communities and Local Government have issued new planning rules to deliver homes for everyone. The very first paragraph reinforces the need to maximise the use of land (i.e. affordable housing) and to strengthen the protection for Green Belt land. This came into place on 5.3.2018.

1. I object to the New Local Plan, particularly for all the green belt land that has been proposed, as this increased the amount of air pollution proposed in this plan, along with substantial overcrowding in areas of this District.

2. Your proposals, particularly CFS147, CFS146, CFS143, CFS170 and 171 (I acknowledge CFS167 has already been given permission on green belt land in spite of a high level of objections at the time) are all on green belt land and I ask that these proposals listed above be removed as per my first paragraph in the new planning rules in strengthening protection for green belt land.

3. In addition to this reason for the above said proposed new land an Essex County Council (ECC) 'Growth and Infrastructure Report 2016' states that to support current infrastructure costs are at £210million, in ECC's costings there is already a shortfall of £104 million. How will the New Local Plan infrastructure be funded? After all, I was at the meeting when RDC did agree that infrastructure will 'go in first'. I cannot see in any reports where this has been addressed, therefore I object to the New Local Plan until all necessary infrastructure is in place ( including the new A127/Fairglen interchange which is essential for the proposal numbers listed above as well as the general flow of traffic in and out of the RDC area.
No address has been made with regards to infrastructure for schools, doctors surgeries, our hospitals (if they remain as they are) are already overloaded, has RDC any guarantees of 'infrastructure first' for these to name a few essential services?

4. The risk of flooding in the West of Rayleigh has not been properly addressed either. No flood risk has been forthcoming in the New Local Plan, pretty pictures of landscaped 'parks' aka flood plains on land already given to development is not a flood risk assessment. I object strongly to the proposals listed above on the basis that the current green belt land also acts as its own flood plain, thereby keeping West Rayleigh safer from flooding. There is no evidence in the New Local Plan to suggest any alternative to flooding run-off areas.

5. The increasing number of Residents in RDC, particularly West of Rayleigh, yet in increase with the impending 500 additional homes will add to the current, already publicly shamed failure, with regard to air pollution within legal limits. With the proposed infrastructure 'improvements' at the A127/Fairglen interchange, the air pollution issue will increase along this corridor too - any further development will just accelerate this life threatening issue. I cannot believe any Council would proceed on this basis alone. I have to strongly object on the basis that clean air is a basic right that needs to be afforded to everyone. I cannot find any traffic flow/density assessments to address the above issues.

6. Consultation has not been carried out fully. Yes, sessions have been held with virtually no visual information. A few planning officers were left to 'field' the many people who had questions as there were no maps and one laptop available. The Housing Councillor was not present (yes, I attended two of them in Rayleigh). This was not a consultation, this was a box ticking exercise. You should re-run these properly and actually consult as opposed to leave your planning officers to deal with the hundreds of question which they were largely unable to answer as they did not have the information to hand. One laptop per meeting is woeful.

I have no confidence that the decisions about to be made by the Council members of the planning committee will be made in the best interests of the people of Rayleigh and surrounding areas. You did not take in account last time any matters objected to and since then you have held important meetings 'in cabinet' or as closed sessions, your lack of transparency is of great concern and I hope you prove me wring this time.

Thank you for taking the time to read this objection.

I object to both the scale and nature of the outlined proposal for the following reasons:

1. No matching funding for a supporting Infrastructure.
Our schools are already above capacity. I am aware of classes at local schools where there are already 35 children per class. There have been many threads on the local Rayleigh FaceBook pages from parents that have moved into our area who are unable to get their children into local schools. Many of these parents have had to place their children at schools out of the area that they live in or are still travelling long distances to their child's previous school. Enough new school places and schools must be guaranteed before more homes are built.
Our roads are frequently at a standstill even outside the rush hour. Before more houses are to be built, we need a better road system in place to stop our roads grinding to a halt. We are encouraged to use public transport, cycle or walk, but public transport in our area is not very good and expensive (I broke my arm last year and was unable to drive for 8 weeks so I can vouch for this!); cycle paths are virtually non existent in the district and many people feel that the roads are for too dangerous to use. ( I own a cycle but due to the lack of cycle paths [those that we do have don't really link up] and due to the amount of traffic on the road, I only use it when I go away on holiday!) Yes I do walk when I can, but I should be able to use my car sometimes!
2. No guarantees that Utilities can match extra demands.
3. No spare capacity within Health & Care Services.
At the moment, many people find it difficult to get a 'same day' appointment if they are ill as our Doctors Surgeries are at capacity. Our local hospitals are also struggling to cope with demand. Similarly, trying to get on an NHS dentists list in the district is very difficult, I know, I have tried! Those that I have tried in my locality have closed their books to new NHS patients. Our health and care services cannot cope with more people.
4. No let up in the sacrifice of the Green Belt & Air Quality.
RDC are already aware that the air quality in the High Street, Rayleigh and along stretches of the A127 are poor and above legal limits. How can you allow more homes to be built with the associated vehicles that come with them when you know that air quality and subsequently residents health is going to suffer?
5. No long-term LEGACY left for our future generations.

CUT THE TARGET NUMBERS TO NATURAL GROWTH LEVEL.

I refer to the proposal for the possible building of 7,000 plus new homes in the local areas to Hullbridge, Rayleigh and surrounding areas.

A vast amount of homes in these areas will cause total havoc because of the resulting congestion as well pollution and loss of wildlife and green spaces (which you wont ever get back) and even more flooding than we are experiencing already.

On top of this there will be a lack of school places. doctors patient places and Heaven knows what will happen to hospital waiting times.
In short A complete reduction in ANY quality of life in these areas.

The 550 homes already going ahead in Hullbridge will dramatically alter life here as it is without building more and making it worse.

Hullbridge is a very special community. Dont ruin it .

I am writing to make my objection to the above mentioned New Local Plan for the following reasons;
Any additional housing development in the Rayleigh area, particularly to the west alongside the old A130, would make the already considerable traffic congestion all along the London Rd. untenable. Indeed throughout the routes in and out of Rayleigh, the
traffic congestion is so bad it is a constant topic of local complaint, the main roads in the area are not only at standstill at 'rush hour' times (which have become extended to include much of the weekday and weekend), buses have no chance of keeping to their shedules, people miss appointments, emergency services struggle to get through, air quality is suffering greatly due to the amount of vehicles standing still, the new 'intelligent' traffic lights at the Weir already cannot cope and have wasted taxpayers money, the schools in the area are full and new comers to the area are having their children refused entry and are therefore adding to the traffic by having to take them to outlying areas, the trains in the week are so packed there is never enough seats for the expensive commute, hospital services are stretched beyond capacity (we know this from 2 friends who are nurses), and as for the recent rumour that councillors have suggested a congestion charge for the A127 at peak times, I can only assume this to be a joke. Rate payers should be charging the councils for the congestion which is impacting on our daily lives and which has been allowed to get out of hand for decades by not addressing the contributing factors. South east Essex is grinding to a halt. There is not enough room left to build our way out of the mess we are already in let alone adding to the population.

RDC is still not able to access the impacts of current and approved future development, since a large amount has not been completed we are already noticing issues of gaining access to medical services and traffic congestion.

Development of the area should take in to account the unique geography being a peninsular.



I object to both the scale and nature of the outlined proposal ,as follows :

1. No matching funding for a supporting Infrastructure.

2. No guarantees that Utilities can match extra demands.

3. No spare capacity within Health & Care Services.

4. No let up in the sacrifice of the Green Belt & Air Quality.

5. No long-term LEGACY left for our future generations.

I find your Local Plan for extra housing in the Hullbridge, Essex area alarming and very worrying for the following reasons.

How will the infrastructure be delivered to support these new homes. New infrastructure such as schools, medical facilities,
shops, places of worship, recreational facilities, etc.

What is the plan for the many and different types of houses required.

Where are all the new roads to be for this housing and development plan. What is the plan for the upgrade of existing roads to
facilitate the influx of the extra vehicles which will accompany the vast amount of extra population. Who will pay for these new
and upgraded roads.
If a new major road structure is not planned for then this area will become gridlocked and people will be trapped within
the area of the development.

With the extra traffic due to the rise in population how will this affect the pollution that is now quite high.

How do we plan for open spaces, nature conservation, green areas for people to enjoy the countryside.

How do we plan for the extra local transport required.

Flooding is one great worry with a high percentage of the possible building land on flood plains and also very near to the River Crouch.
What thought has been given to the strengthening of the river bank and drainage of the land on lower levels.

Do you really think that your plan to build this amount of houses within such a small area with no plan or thought of how all
the infrastructure required is to be delivered is at all possible.

I am writing as part of Rochford District Council's public consultation in regard to the Issues and Options Document and the Sustainability Appraisal (SA) of the Rochford Local Plan (Interim SA Report).
NB: I have attached a copy of this email/letter as a Word document, should you need it.
I am particularly concerned about any housing developments that might be proposed in the Rochford, Ashingdon, Hawkwell and Hockley areas. These areas already have significant traffic congestion problems that would inevitably increase with any further building of new homes. It also seems that the Council is struggling to properly maintain the roads in these areas (I assume this is because of budgetary constraints). Furthermore, the GP practices in these areas are already oversubscribed and getting an appointment with a local GP is difficult enough and would be made more difficult with an expanding population. I believe that the schools that serve these areas are also fully subscribed.
Referring to Rochford District Council's - Strategic Housing and Employment Land Availability Assessment 2017 and it's Appendix B 'Find Your Site' and Area Maps I see that a large number of potential housing development sites within the Rochford, Ashingdon, Hawkwell and Hockley areas have been identified.
I object to any proposed developments in these areas based upon the problems identified above, particularly the SER8, CFS007, CFS013, CFS119, CFS129, CFS130, CFS131 (Map R) all east of Ashingdon Road, which would only exacerbate the current traffic congestion on the Ashingdon Road (where there have been a number of serious traffic accidents, some involving pedestrians and some fatal) and Bradley Way/Southend Road.
The additional traffic volume resulting from any further housing developments could result in total gridlock at busy times and would have a negative impact on residents' quality of life, local businesses ability to transport goods and receive deliveries and make the air quality even poorer than it already is. The extra strain on GP practices, schools etc. also cannot be ignored.
Similarly, the potential sites in Map I (CFS020 and CFS169 - South of Magnolia Road, CFS150, CFS093 - around Victor Gardens, CFS118, CFS036, CFS018, CFS132, CFS140 - around Rectory Road and Ironwell Lane) would result in the same problems and would eat up precious greenbelt land that currently provides a buffer between existing housing developments and is enjoyed by local residents walking on the many rural and semi-rural public footpaths.
I would also have the same concerns regarding traffic etc. from the sites identified around central Rochford on Map M, although I recognise that these sites are not as large as some of the other sites I have referred to.
Other sites in Map I (CFS02, CFS082, CFS081 - North of Hall Road opposite The Lawns) and Map J (CFS084) could also add to the problems noted above as well as making traffic congestion, air pollution etc. worse on the Southend Road towards Hawkwell and Hockley. The same would apply to CFS074 - North of Gusted Hall Lane and CFS045 - Belchamps.
I also note that the sites that I have referred to were in the Local Development Framework - Adopted 25 February 2014 - Allocations Plan, but were given different policy numbers as noted below.
Brownfield Residential Land Allocations (Page 17 onwards)
Policy BFR2 - Eldon Way/Foundry Industrial Estate, Hockley:
This would add to traffic congestion in Spa Road, Southend Road (B1013) and Aldermans Hill.
Policy BFR3 - Stambridge Mills, Rochford:
This would add to traffic congestion in Rochford Town Centre, Southend Road, Bradley Way and Ashingdon Road. This development also has flood risk problems.
Settlement Extension Residential Land Allocations (Page 35 onwards)
Policy SER2 - West Rochford/Policy SER3 - West Hockley/Policy SER4 - South Hawkwell/Policy SER5 - East Ashingdon/Policy SER7 - South Canewdon/Policy SER8 - South East Ashingdon:
The problems that I have laid out regarding the CFS sites also apply to these 'policies'.
Finally, I do recognise that RDC sometimes grants planning and development permissions based upon the provision of amenities by developers. However, I note that in the February 2014 Allocations Plan the already agreed and now being built SER2 of West Rochford (north of Hall Road development - 600 houses) the Allocation Plan states that there will be "New primary school with commensurate early years and childcare provision", yet I understand that this has now been dropped.
It also states that there will be "Local highway capacity and infrastructure improvements" but Bradley Way and Ashingdon Road will nevertheless get more congested due to the extra traffic created by the residents of this development as these roads cannot be widened to allow better traffic flow.
Please take into account the objections/issues that I have raised as part of your public consultation which runs until 5pm on 7th March 2018.

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

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

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

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

Bungalows

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

Houseboats

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

Tourism and Rural Diversification

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

Highways Infrastructure

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

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

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

Education

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

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

Greenbelt

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

Wallasea Island

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

Outbuildings

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

Hullbridge Sewage Plant

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

Air Quality

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

Employment Land

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

Hospitals/Health Centres

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

Traveller Sites

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

To whom it may concern:

I am a Rayleigh resident and have lived in the area for 15 years. I now have a young family and have many concerns regarding the development of the area. I wish to say at this point I actually have no objection to new homes being built as I believe it is very important for people to have access to affordable housing. One of the proposed developments is adjacent to my own property and I will not be objecting to those homes being built ONCE FURTHER INFRASTRUCTURE IS IN PLACE.

As I live just off London Road, Rayleigh, I experience the large volumes of traffic on a daily basis.

I walk my daughter to school which is nearly 1 mile away. Myself and both my children are exposed to large amounts of pollution during this journey which seriously concerns me. I refuse to drive the journey as I will not contribute further to this and I want to teach my children healthy habits.

We have to cross London Road at some point during our journey. Should I chose to cross at the end of my road there are no viable crossing points. Some days I just give up altogether due to the volume of traffic. I can sometimes stand waiting with my children while 20 or 30 cars pass by on one side and I usually rely on a kind motorist waving us across. The two alternatives are either taking a very narrow path up to the nearest crossing point. This is also where the road narrows and where coaches and lorries pass down here they can get very close to the pavement. I do not chose this option. The other option I have is going a back route which adds a good 5 minutes to my journey.

Another issue I have with this road is the only access I have to public transport is by crossing London Road where there are no crossing points. I sometimes chose to take the bus to/from the town rather than drive. This is more expensive than parking and also I worry about crossing London Road with my children - why should I bother when it is easier, safer and cheaper to drive?

Finally on this point, my childminder lives the other side of London Road to me. When I have to collect my children in the evenings I drive a journey that would take me 2 minutes to walk as during the evening it is just to treacherous to cross the road due to the volume of traffic. To cross at a proper crossing would be a 15 minute walk each way with my children when it is late and they are tired.

Although the road is posted as a 30 mph limit the speeds of vehicles vary dramatically, making it harder to assess when trying to cross. There needs to be some serious consideration to speed control measures, better signage as you enter Rayleigh and without a doubt there needs to be some form of crossing at the bottom end of London Road. This road was historically a 40mph road and there were no houses past Pearsons Farm as you leave Rayleigh on the North side of London Road. This has changed dramatically over the last few years and the infrastructure needs to catch up before more homes are put in. I would love to see one or two crossings or at the very least a crossing point (an island in the middle) down the bottom end of London Road.

I will also add in relation to the congestion on London Road that I regularly cycle down the road - in the dark I always use lights on my bike. Most drivers are considerate of cyclists. Despite this I have had many close calls where motorists have passed too close. When I come to turn into my road, often the traffic is so heavy I wait to turn and have to rely on someone letting me through.

I feel really strongly that we should be encouraging cycling in the town. It is pretty poor for cyclists in so many ways. I do not know all the answers but surely some cycle lanes would be good start. I do not know that we have any at all in Rayleigh?

As far as I can see any further development in the area would have a huge detrimental affect to a town that already has serious traffic issues. I love the town, the people, and I would like to remain living here. I have such serious concerns about the pollution levels and volume of traffic that I would seriously consider moving away from the area as I do not think it is right to subject the existing (and future) residents of Rayleigh to this.

Kind regards,

Eleanor Carmichael

As discussed by phone with your planning department, I would like to make some comments/objections to proposed plots in the Strategic Housing & Employment Land Availability Assessment 2017 document.

The references are CFS 041 and CFS 042. These are farms with the potential for close on 200 houses to be built on Greenbelt. The following are the reasons why the building of this large number of homes is inappropriate for the location.

Lack of facilities: the location is 'poor' in your definitions as there are no shops, medical facilities, schools, etc within a reasonable distance. The now approved additional 500 houses being built in Hullbridge at the western end of Lower road and the many new houses recently constructed in Folly Lane will put a massive strain on local facilities even before additional houses are considered.

There is little public transport (approx. 1 bus each way a day) in Lower Road.

There is no mains sewerage and very poor mains drainage even before additional housing on such a large scale is considered. There is regular flooding of the road close to these farms due to the downhill nature of the surroundings with water coming down from fields. The sites are also not that far from the river with the future potential for flooding due to increases in sea levels and tidal surges.

Lower road has become, over the last 10 years, a major trunk route for fast moving lorries as well as commuters and farm traffic. It is now a 'dangerous' road for families with children. Air pollution due to these diesel lorries is already a major problem without the addition of up to 400 cars (2 cars per household is now the norm).

Farms will be more in demand as we need to become more self sufficient as a nation (particularly after Brexit) and the increase in numbers in South Essex would indicate more farm land rather than less.

If it is necessary to build further houses in Hullbridge then the brownfield site CFS 100 would be more appropriate rather than taking more greenbelt.

I am strongly opposing to the new local plans in Hullbridge to build another 750 homes.

We are about to have 500+ homes built on the Malyons Farm area. I believe this project needs to be completed before permission is granted for ANY MORE developments in the area whether small or large.
The impact of this new estate is going to be massive in terms of population, traffic, schools, pollution and health care. We must wait and see what changes to the current infrastructure is needed to accommodate such an influx of housing.

To currently free land for development for houses must be considered as an OVERDEVELOPMENT in such a small town.

I object to both the scale and nature of the outlined proposal ,as follows :

1. No matching funding for a supporting Infrastructure.
2. No guarantees that Utilities can match extra demands.
3. No spare capacity within Health & Care Services.
4. No let up in the sacrifice of the Green Belt & Air Quality.
5. No long-term LEGACY left for our future generations.
CUT THE TARGET NUMBERS TO NATURAL GROWTH LEVEL.


I also believe that a broad infrastructure needs study should be conducted by the council ahead of any planning permission decisions on new housing on the infrastructure required to support the appropriate number of houses required, paid for from the CIL generated from the housing proposed, and the appropriate permissions from planning and highways etc for the new schools, Drs surgeries, new roads, road improvements required to support the increase in demand for services is secured ahead of any development starting, so the infrastructure is built in tandem with the new housing required.

I have largely restricted this to housing and the environment.

Housing Needs
An additional 7000+ dwellings would almost certainly be unsustainable without severe damage to the environment and character of the district. According to the environmental capacity study 2015 only small scale expansion of existing settlements could be sustained.

As regards Hullbridge, further developments at Malyons Farm which currently has outline planning permission and was described by RDC as providing a (defensible green belt boundary) and numerous small developments, as an example of these smaller developments, in Ferry Rd, north of Riverside School 6 dwellings have been replaced by 40+.

Highways Infrastructure
I would be opposed to highway changes which could encourage even more traffic on Lower Road and Watery Lane.

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

Green Belt
The green belt to the east and west of Hullbridge village is important due to its proximity to the environmentally sensitive and protected River Crouch and to the south is needed to prevent any merging with Rayleigh & Hockley, as previously stated, the currently proposed Malyons Farm development was described by RDC as providing a (defensible green belt boundary).

Air Quality
Will only get worse with more cars & heavy transport. Rayleigh is already one of the worst air quality in the district.

Health and Well-Being
Our doctors and hospitals are already at critical levels and are only likely to get worse with a bigger housing developments.

Delivering Jobs
Hullbridge is a large village and is getting bigger. There is no industry or large commercial developments here, all workers have to leave and return to Hullbridge daily, adding to congestion of our roads and air quality readings.

In response to the proposed developments in the local Hockley, Hawkwell and Rochford area, I would like to make the following points:-

While I agree that there is a need for a sensible amount of new housing, as a long time resident of the Hockley and Hawkwell area, I would make the following observations:

* the road system is, at present, under great strain. One delivery van or lorry can snarl up the whole area, leading to missed appointments and real dangers in terms of getting to people who depend on we residents.
* the effect on children and vulnerable adults due to air pollution, from all the extra cars that a large amount of new housing would entail, would be very detrimental to the health of residents.
* the loss of green fields, farmland and woodland will further add to the detrimental effects on the environment, in terms of ecology, air quality and bio diversity.
* New school buildings would be needed with a substantial increase in pupil numbers. This would need to be planned and finished before any new families move in. As as a retired headteacher, I well understand the effect that a sudden influx of new pupils can have on a school community. These increases in roll need to be managed very carefully. Are skilled head teachers, teachers, assistants and support staff readily available when there are the current recruitment problems in teaching and school leadership? How is this being addressed in the planning for the district?
*new shops, leisure facilities and amenities would need to be put in place. The building of these would put further pressure on the present road systems.
* the health services in terms of GPs, clinics and hospitals, are already under great strain. There is a growing population who cannot find adequate treatment options already. Lots of new housing would substantially increase these pressures. I work as a volunteer at the hospital and I see these pressures first hand. There is a current recruitment problem with GPs, nurses and hospital staff. How is this being addressed in the planning for the district?
* the local ageing population cannot presently find adequate care facilities, whether from councils or privately. New developments would put further strain on this situation. How is this being addressed in the planning for the district?
* the police service is presently under pressure after funding cuts, what plans have been made to address this?
* the ambulance services are already under severe pressures and can take too long to respond to accidents. My 94 year old neighbour broke her femur and had to wait for over 2 hours for a paramedic. This isn't civilised. How is this being addressed in the planning for the district?

Our area is already under strain in terms of support services, resources, roads and environment. There is limited scope, using brown field rather than green field sites, for a huge increase in housing stock. I agree that first time buyers and local residents who need affordable rental property, are very much under strain. They should be a priority. However, there is only so much building, and the subsequent increase in population, that can be absorbed into our local area.

I understand that the situation is complex and needs very careful planning but I doubt that the pre-planning can be done in time for any proposed building. Houses spring up in our area at an alarming rate, ignoring the views of local residents. The need for central government building and housing targets to be met puts further pressure on the system.

I doubt if the carefully considered views of local residents, like myself, will really have any weight in your planning. I know that this is a consultation but will it really be a consideration?

However, I cannot sit idly by and fail to register my concerns.

I would welcome your response.

I would like to register my objection to the plan to build 7,500 new houses in the Rochford area on the grounds that we do not have the infrastructure to deal with the current population, so would not be able to contend with the population increase that these houses would bring. Also, I am at a loss to understand how the government has the right to demand this housing increase when, it has given I believe, £100,000 to Basildon and Rochford councils to monitor the nitric oxide levels on the A127 with a view to implement road charges to restrict the amount of traffic using it. 7,500 house could mean a possible increase in road vehicles to 11250 or more. I ask, if the A127 is restricted, and no other roads are built, where would all this extra traffic go?

I am not a nimbi, I do realise that we need more homes, however, common sense must prevail, we must not build at all costs and therefore ruin the quality of life for all.

My comments are as follows:

Page 38 , item 6.30
OPTIONS we must provide our own District housing quota. RDC has a significant green belt area, our neighbouring authorities are largely built up. If we opted to pool future development Rochford would inevitably lose open land other areas cannot provide.

Page 42, Table 5, also pages 44 and 45.
I strongly object to Rochford District Council's 'Settlement Heirarchy'. In my opinion this system is obsolete and inappropriate going forward. Past waves of development in the same areas have led to reduced living standards for residents in the more urban parts of the District. Negligible infrastructural improvements have been provided to offset this development.
If the level of development envisaged in SHMA addendum 2017 were agreed for the District as a whole (Page 33, Table 3), then I consider the development should be either:
A) Evenly distributed through all the parishes in the District creating about 25 homes per parish per annum.
or
B) The creation of a Locally Led Garden Village or Town as per government's recent policy guidance. Ideally this would be close to a pre-existing major artery A Road, such as the A1159. It should be noted that this area benefits from retail and leisure facilities, it also has easy access into Southend, which is asper page 10 Figure 2, is the destination for the largest number of residents leaving Rochford District every day for work (more than the number that go to inner and outer London combined).
The Rochford District area ( Fossetts Farm), close to the A1159 is I believe green belt. However the District will inevitably be obliged to release green belt land and we should not assume the boundaries of existing urban areas are the only green belt to be re-categorised. We must put the lives and wellbeing of our resident above our noble principles of preserving remote parts of the green belt.

Page 78 Highway Infrastructure 8.3
Although, as stated, Rayleigh is close to a number of 'A' roads, those same highways create significant problems for Rayleigh and the western part of Rochford District.
The major multi lane A roads are all at the edge of the Rochford District or beyond its boundary. However most other A roads and main B roads within Rochford District are over 150 years old in modernised/upgraded form. Indeed most of the main roads in the western part of the District can be found on the 1875 County Series O.S. Map. It is truly astonishing that so much development has been added over the following 140 years with the same, if improved, roads. In essence we have a vastly expanded population funnelled down pre 20th century roads. This explains the traffic problems on roads in Rayleigh. Effectively no wholly new transport infrastructure has been added in 150 years to the western end of the District. This results in delays and difficult traffic movements throughout the week.
However one positive point we should not lose under any circumstances is the current traffic system in the centre of Rayleigh at least preserves the town centre. Were it returned to the former one way system, with it's race track effect, the District's most successful town centre would be greatly harmed and cease being a pleasant place to shop.
Traffic from all the adjoining communities Hockley, Hullbridge and Hawkwell flow through Rayleigh on the afore mentioned 200 hundred plus year old roads.
Another problem adversely effecting the traffic in Rayleigh and the western part of the District, is that congestion and frequent problems on the A127, which funnels many vehicles through the town in a west /east or reverse direction.
I submit that these road factors, which create delay and pollution in the western District, preclude further significant development in Rayleigh or Rawreth (above and beyond that already agreed).

Air Pollution
Tackling air pollution from road traffic should be at the heart of our new local plan. We are fortunate to have a good railway system running through the District. On a small scale cycling is rising in popularity and good for both the environment and also for the health and well being of residents, however cycling is poorly catered for in Rochford District. Adding cycle lanes in the overcrowded and somewhat dangerous main roads in our urban areas may be rather too challenging. However if RDC does opt for the 'Locally Led Garden Village or Town' option we should ensure safe cycle lanes are included in any scheme.

Historic Buildings , Conservation Areas and Local Lists
I am concerned that Local Lists have been somewhat down graded by Rochford District Council over recent decades. Whilst not giving the almost guaranteed protection of national Listing they do confer significant protection especially in Conservation Areas.
Conservation Areas / the Historic Core of Towns and villages are an efficient way of protecting historic and attractive areas of the District. I recommend that as part of the Local Plan process Conservation Area boundaries should be reviewed, with a view to extension, subject to local Public Consultation (not just County Council advice).

Accommodation for independent older age group residents in or close to town centres
In recognition of increasing older age group numbers within our District, we should a guidance note to allow town centre older age group units for independent mobile residents. These may come with shared garden / recreational areas. With the changing nature of our town centres and the erosion of some retail and public facilities such as Police Stations, the Council should encourage the conversion of historic buildings and the redevelopment of the more modern inappropriate and unappealing town centre buildings for elderly person accommodation. This is not to suggest that all modern buildings are bad and all old buildings good, however popular support for historic buildings in Conservation and adjacent areas should be given weight when considering planning applicatons. All development within Conservation Areas should meet the highest standard of architecture as in any historic towns in the country, furthermore elderly person units should be required to provide good sound proofing especially in town centre locations.

Page 39 6.31 Affordable housing
Developers do not want to include affordable housing within their schemes as it adversely affects their profit margins. A significant number of new residents have been coming from the London area where they are able to sell houses for extremely high values compared with the local housing stock, this has caused additional house inflation and has led to a greater demand for large housing units out of the reach of many local young people hoping to get a first foothold on the housing ladder. The new Local Plan should recognise and address this problem. Simple requirement for affordable housing within schemes may not be successful going forward. It would be good for RDC local policies to explore the possibility and practicality of requiring large scale developers to sell small parcels of land at reduced price to Housing Associations either for rental property or part rent part purchase schemes.

Page 41 6.36 Care Homes
Care Home finances are under severe financial pressures, which lead to problems for the NHS. Policy option B would be the best response in current circumstances of rising demand and limited supply.

OBJECTION to the RDC New Local Plan ( Issues & Options stage ):-

I object to both the scale and nature of the outlined proposal ,as follows :
1. No matching funding for a supporting Infrastructure.
2. No guarantees that Utilities can match extra demands.
3. No spare capacity within Health & Care Services.
4. No let up in the sacrifice of the Green Belt & Air Quality.
5. No long-term LAGACY left for our future generations.

I object to both the scale and nature of the outlined proposal ,as follows :

1. No matching funding for a supporting Infrastructure.

2. No guarantees that Utilities can match extra demands.

3. No spare capacity within Health & Care Services.

4. No let up in the sacrifice of the Green Belt & Air Quality.

5. No long-term LAGACY left for our future generations.

I am writing to you with respect to the planning applications around Hullbridge. I have seen a number of the documents describing the different housing developments.

I have a number of concerns on these various applications. While I appreciate we have to build new housing which I fully support, it is the vast number of house being planned around Hullbridge. There seems to be a significant lack of infrastructure planning. Before any significant housing is planned or built, the infrastructure must be addressed.

The roads into Hullbridge are currently not satisfactory to take increased traffic. Rawreth Lane is the dominate root, but Watery Lane is also a major root for people travelling from the Chelmsford direction. Watery Lane needs to be improved, not only for flooding; it also needs a width extension.

Rawreth Lane, itself coming into Hullbridge and Rayleigh at the mini roundabout struggles with traffic congestion during peak times. This supports some action in infrastructure is mandatory to maintain the current air quality. Increasing traffic jams, will have a negative effect on the environment and air quality. I have heard comments of increased traffic of 2 cars/hour, which given the extent of the development is not correct. I would like to review the figures of this study, and I sure I could help with the correct estimate. I have searched on the council site and can't find the actual figures anywhere, please could these be supplied.

One of the developments at the west of Hullbridge (in-between Hullbridge and Battlesbridge) is being planned on a flood plan, which poses a significant risk to any home owner in the future. In addition, a cost to flood defence agency (Government), these will need to be improved, and an analysis completed to understand what impacts this would have on the surrounding areas.

Currently there are a number of un-adopted roads, which have been built to facilitate light traffic, and will not support significant weight and magnitude of building traffic.

In summary I don't support the significant housing development plan around the Hullbridge area, and find it strange the council has not tried to old any meeting in Hullbridge to discus with residents, so can only assume this is not a serious proposal.

Map Ref CFS065

I am writing this letter with regards to a meeting that was held at Great Wakering Community Centre. This meeting took place on Thursday, 22 February it was about the proposed buying of land by the council to build more houses.

We oppose the amount that is being allowed to be built as this is classified as a village and is fast becoming part of Shoeburyness due to the amount that ha already been allowed to be built. Look at Alexandra Road. This should have been only 38 homes there is in excess of 140 on many days it would be hard to get Emergency services down there due to insurficent parking, and people parking on the pavement which results in broken pavements thus resulting in claims against the Council.

a. The land at the back of Shoebury Road where I live is arm greenbelt land, this was one of the factor that made use buy this property plus the estuary views, this reflected in the price that was paid, and should this land be sold and built on it would devalue all of our properties that surround this area, therefore we will be seeking compensation for our losses.

b. There is also other facts like infurstructure, when every we have heavy rainfull the drains cannot cope where Shoebury Rd meets New Rd it always floods plus other area along the High St.

c. The bus service is most of the time unreliable, if they turn up many are cancelled for the return journey. This is not suitable for people who have had treatment for cancer, this leaves the patient tired, and does not want the added stress of a bad public service.

d. Pollution recently this has been above the legal requirement of the W A O Pollution contributes to 46000 premature deaths per year, traffic is a big factor in pollution.

e. There is an argument stating these new homes will provide jobs, these are only temp. Or we need affordable homes, a majority of homes being built are second homes that's put up for rent, keeping house prices high.

f. Schools, Doctors, Hospitals, cannot cope now let alone with the extra volume of people flooding into the area.

g. There is in excess of 380,000 empty properties across Essex, this is 38yrs of our allocated build. Therefore once you allow building on greenbelt land to take place our future generations will suffer as there will not be fresh Veg, Fruit, meat. This will affect the economy as we will have to import. Also many cancers are caused through proceesed food.

h. It is a fact that Wakering cannot cope with parking as many of these properties are over 100yrs old. The council are paying out £millions on claims due to broken pavements due to cars parking on them, plus the amount it cost with litter this cost the country £146 million per year.

i. What about the amount of houseowners/rented that dont pay council tax for what ever reason.

j. It can take up to 45 mins to get to cuckcoo corner, therefore if an ambulance was needed? How many lives will be lost through this.

k. Most of this land that the council are trying to buy and sell off for building is farm/greenbelt, therefore this government stated would not be used.

l. As for flood plains, surely the more concreate that's put down the more floods will be a result of this, thus making many properties uninsureable.

Map Ref. CFS065

I am writing this letter with regards to a meeting that was held at Great Wakering Community Centre. This meeting took place on Thursday 22 February it was about the proposed buying of land by the council to build more houses.

In my opinion and many others that live here, we oppose the amount that is being allowed to be built as this was a village and is fact becoming part of Shoeburyness, my reasons are laid out as follows.

a. The land at the back of Shoebury Road where I live is farm land, and this was one of the factors that made me buy this property and the estuary views, this reflected in the price that was paid, and should this land be sold and built on it would devalue all of our properties that surround this area, therefore, we will be seeking compensation for our losses.

b. There is also other facts like infurstructure, when every we have heavy rainfall the drains cannot cope where Shoebury Rd meets New Rd it always floods plus other area along the High St.

c. The bus service is most of the time unreliable, if they turn up many are cancelled for the return journey. This is not suitable when you have had treatment for cance, you feel very tired and just want to get home.

d. Pollution recently this has been above the legal requirement of the W.O.A. Pollution contributes to 46000 premature deaths per year, traffic is a big factor in pollution.

e. There is an argument stating these new homes will provide jobs, these are only temp. Or we need affordable homes, a majority of homes being built are second homes that's put up for rent, keeping house prices high.

f. Schools, Doctors, Hospitals cannot cope now let along with the extra volume of people flooding into the area.

g. There is in excess of 380,000 empty properties across Essex, this is 38 yrs of our allocated build. Therefore once you allow building on greenbelt land to take place our future generations will suffer as there will not be fresh Veg, Fruit, meat. This will affect the economy as we will have to import. Also many cancers are caused through processed food.

h. It is a fact that Wakering cannot cope now with parking as many of these properties are over 100 yrs old. The council are paying out £millions on claims due to broken pavements due to cars parking on them, plus the amount it cost with litter this cost the country £146 million per year.

i. What about the amount of houseowners/rented that don't pay council tax for what ever reason.

j. It can take up to 45 mins to get to cuckoo corner, therefore if an ambulance was needed? How many lives will be lost through this.

On the enclosed Comments form, I have not completed the Section, Option and Paragraph Section of the form.

As I am an elderly person (age 79), I tried to telephone your Planning Department in order to be sure I put the correct details on the relevant sections.

I tried on three occasions today to speak to someone but each time I received the reply - "All our Customer Service officers are busy with other calls at present and your call will be answered as soon as possible".

I have, therefore, left these sections blank and perhaps you would kindly complete them for me.

I thank you in anticipation for your kind consideration of my objections.

Yours faithfully

K Randall





Meeting at Hockley Fire Station - 16 January 2018

ROCHFORD LOCAL PLAN 2017-2037

OBJECTION

My general objections and concerns to build a further 7,500 homes in the Second Local Development Plan which are in addition to the over 10,000 homes in the First Local Plan 2011-2025 are as follows:-

* INFRASTRUCTURE - Will there be increased funding so that infrastructure can match the proposed growth. Currently, under funding seems to apply. This new Plan would only increase problems on a failing infrastructure.

* FLOODING - Flood risk sites that would need a Sustainable Urban Drainage System are a poor choice due to costs.

* CIVIL AMENITIES - With the current crisis in Health and Care provision, emergency services and Education how is it feasible to impose this level of development. Mr. Hunt, the Health Minister, recently stated that there will be a million more people over the age of 75 in the coming years so how can Health and Care provision be sustained alongside this level of development.

* ENVIRONMENT - Pollution is a major problem. On the BBC News on 2nd March 2018 Professor Dame Sally Davies, the Chief Medical Officer, stated that Air, Light, Noise and Chemical pollution was having a serious impact on health. Air pollution levels are very bad for asthma sufferers. Her report stated that there must be an emission and plastic reduction. On same bulletin, the British Lung Foundation stated that action must be taken on air pollution. Surely this Second Local Plan will only increase air pollution to even more dangerous levels.

Whilst I appreciate the need for housing, may I respectfully suggest that you review your Plan and consider cutting the number of homes by at least 50 per cent. I believe this action should be considered by all authorities in the County of Essex as over development appears rampant and unsustainable.

Comments: New Development Plan 2017-2037
We are writing to register our OBJECTION to the planned extra 7,500 homes proposed in the Second New Development Plan. We feel this is far too many. The full effect of the extra 2,600 homes to be built under the First Development Plan has not been felt yet.

We are concerned that:

1. There is no match FUNDING for a supporting Infrastructure. We live in a peninsular, if you enter our area you need to return the same way. The roads are already clogged, especially at rush hour. Travelling through Hockley between 4.00 and 6.30 p.m. is impossible, with huge tailbacks through the village. Pollution should be monitored.

2. There are no guarantees that UTILITIES can match extra demands.

3. There is no spare capacity within the HEALTH & CARE SERVICES. A personal friend of mine recently tried twice in a week to get a Doctors appointment at Greensward Surgery, only to be told they were not even accepting child emergencies that day.

4. There is no let up in the sacrifice of the GREEN BELT & AIR QUALITY. Greenbelt is there to protect the countryside from urban sprall. Some of the proposed sites would virtually join Hockley to Rayleigh.

5. No long-term LEGACY left for future generations. What quality of life will future generations have if we don't plan appropriately.

Resolutions:
1. Infrastructure to be considered first before extra housing planned.

2. Build Quality Bungalows/complexes for elderly people. Many elderly people are still living in their family home with unused space and high running costs as they have nothing else suitable to move into. Much needed family housing could then be released.

3. Housing for LOCAL people. Many people migrate from London to take advantage of the lower prices in comparison. There should be a percentage of new build properties set aside for purchasing by LOCAL people ONLY.

4. More help for the young in the area. Special schemes negotiated to enable local people's children to be able to stay in their own area.

5. Is it possible to negotiate with other Districts in Essex who have the infrastructure to be able to expand, and offer some of our allocated housing numbers from Government?

6. We would also like to see more suitable complex's/flats to enable people with disabilities to live independently.

TARGET NUMBERS NEED TO BE CUT TO AT LEAST NATURAL GROWTH LEVELS.

Objections to the development of land to the rear of Malvern Road and Harrogate Drive plus the 'play area'. Rochford District Council Plan 2037 - CFS023 and COL38 refers.
Option:
Paragraph:
Comments: Objections to the Development of land at the rear of Malvern Road and Harrogate Drive - RDC reference CFS023
The land to the north of Malvern Road CFS023 and the land described as COL38 at the top of Malvern Road is not suitable for inclusion in the Rochford District Development Plan for 2037.

The land adjacent to Mount Bovers Lane and the land behind the 'Cock Inn' Public House and adjacent to the roundabout at the northern end of Cherry Orchard Lane would be better for development. Both sites are flat expanses of land, are connected to Hall Road and better linked to the A127. Also, they are in close proximity to the development of industrial units adjacent to Cherry Orchard Lane and the planned expansion of business at Southend Airport making the location good for employees. The residents could also enjoy the benefits and use of Cherry Orchard Country Park.

We object to the development of land at the rear of Malvern Road (your ref CFS023) as set out below.

1. Steep gradient of land - privacy

Any development would require deep piling and foundations to take into account the gradient of the land. In addition the excessive gradient sits on clay. It is likely that areas of blue clay exists. When Malvern Road was developed 42 years ago work was interrupted and it is believed that an area of blue clay was investigated. This will make development expensive.

Any development of the field would also result in loss of privacy. The existing properties that back onto the field have small rear gardens. As the land is elevated substantially the associated excessive gradient would mean that any new houses would overlook every aspect of existing properties creating a complete loss of privacy on both ground and upper floors and gardens.

2. Surface Water Flooding History

Any development will significantly increase the risk of flooding to existing gardens and properties backing onto the field. We already have excessive water on our gardens caused by the increase in the water table levels of the field behind Malvern Road after heavy rainfall. As a consequence a spring appears on the south west boundary of the field. We understand it is fed by the rise in the level of the water table beneath the field. The stratum it creates follows the contour of the land and floods existing gardens.

We are very concerned that building on top of the water table would adversely effect the natural ability for the water to be absorbed into the soil quickly enough and will increase further the danger of surface water flooding to our property.

With the evidence of climate change due to global warming now accepted by Government we are right to assume that seasonal weather conditions are no longer a given. We are likely to have heavier rainfall in the future and any development of the field at the rear of Malvern Road will have a significant and unacceptable increased risk of flooding to existing properties caused by the inability of natural and engineered drainage to cope with extreme volumes of water. The contamination from Foul Water breaches from development is also a major concern and one which should be considered.

Water Pressure

Water pressure is a concern to residents. Houses no. 50, 52, 54, 56, 58 already have water pressure reduction at certain times. The existing system of pipe work and pumps are insufficient to support further development adjacent to the Malvern Road area.

Access

The land at the junction of Harrogate Drive and Greensward Lane is not wide enough to create a safe and hazard free turn for road users. Any development of the field behind or adjacent to Malvern Road will result a huge increase in traffic using Harrogate Drive and significantly increase the chances of accidents due to drivers having to wing their vehicles wide out of or into Harrogate Drive - Greensward Lane. In addition Harrogate Drive is too narrow at the undeveloped end to accommodate 2 way traffic and suitable safe pavements for pedestrians. Also hedgerows will have to be removed and loss of natural habitat for wild life gone forever.

Impact and Amenity Loss

The proposed development will have a negative impact on the quiet peaceful character of the neighbourhood. The increased traffic will create more CO2, NO and particulate matter pollution. Together with slower vehicle speeds this will have a devastating effect on the air quality and noise levels which will have a severe and detrimental effect on the Ancient Woodland of Beckney Woods with the glorious fauna and flora that exists there.

The field itself which has not been infected with offensive sprays and heavy machinery for 50 years or more offers habitat to a diverse array of creatures including Bats that are seen flying at dusk, adders, slow worms, grass snakes, badgers, foxes, muntjac deer and a variety of rodents. Amphibians including the crested newt have been seen. We also have a full array of British birds including the blackbird (quite rare), thrush (even rarer), herons, 2 species of woodpecker, several species from the tit family including the long tailed, robins and the joyous wren. The buzzard and sparrow hawk are also arrivals in recent years.

These are just a few examples of the diversity the woodland and field attract and the need to protect this environment from destruction is apparent. It is an amenity to be enjoyed by many and appreciated by residents at this end of Hockley and beyond.

The small plot of land at the top of Malvern Road 'Play Area' REDC reference CO38

Designated Children's Play Area

This is a designated children's play area. Families living in Malvern Road and surrounding area exercise their right to access and have enjoyment of this piece of land.

Three years ago the land was inspected by Rochford District Council and its use as a children's play area was upheld after a proposal to change of use to a bridleway was rejected.

This area of land is used every day by many walkers to access Beckney Woods. The inspector, Mr Martin Elliot, published his report on 1 December 2014 where he recognised the route used by pedestrians across the children's play area over a period of time and ruled it to be a public right of way. He also recorded the significant concern expressed by objectors for the need to protect the public open space from development.

Access for vehicles via Malvern Road

Estimated at about a 15% steep gradient and having a narrow access between 2 properties the proposed development between Malvern Road and the children's play area would make this a very dangerous junction for both motorists and pedestrians especially in winters just experienced.

Flash flooding

We also have serious concern, that in extreme weather conditions as is expected in the years ahead, this development will be prone to cause flash flooding in Malvern Road as the drainage, natural and engineered will be unable to cope.

The prospect of building a possible unconstrained additional 7500 dwellings is not sustainable. The primary reasons are summarised briefly below. Throughout this email I will be referring to the evidence of funding contained on page 126 of the "Greater Essex Growth and Infrastructure Framework 2016 - 2036" (GEGIF) produced February 2017.

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 and that can truly be afforded by local residents. The housing must be appropriate to the needs of the all members of the community. Many developments have larger houses when there is actually more demand from older residents to downsize once their families have moved out. This group are looking for smaller but high quality homes - not affordable starter homes. Therefore we should be looking to ensure that these smaller, high quality properties are built to free up existing larger properties in the district and avoid the need to build more larger properties.

The natural growth of the district can be met by 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 viable places to live and work. All these measures will prevent the proposed maximum attack on our greenbelt and valuable farmland.

Traffic and Road network

The western part of the district including Rayleigh and Hullbridge suffers from 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 and are all regularly at a standstill. 7500 extra dwellings will result in at least 15,000 more vehicles. The local plan has no credible improvements to public transport. Page 126 of GEGIF shows that there is only £15million of secured funding out of a total of an estimated need of almost £30million.

Proposed 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.

The provision of cycle paths to suitable destinations is patchy and given the terrain in most of the western side of the district, cycling (however desirable) is unlikely to be taken up on a large scale.

Walking

Due to the distances involved and the gradients in the district it is unrealistic to expect residents to walk for most of their daily requirements. As an example the elderly and families will not be able to walk from Hullbridge to Rayleigh and carry necessary groceries, a distance of 3 miles plus along undulating terrain. It is simply not practical and to suggest otherwise is simply unrealistic and disingenuous.

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.

Air Quality

Rayleigh town centre, as acknowledged in the report, has 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.

The gap in funding for adult social care is not addressed in this proposed plan.


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'.

Farmland

With the UK imminently leaving the EU there is a need for national food supply security. We should therefore look to maintaining farming capacity during the next decade and beyond due to uncertainty of market conditions.

Water supply

Additional properties in the RDC and wider south east Essex area will put unsustainable demands on the water supply and sewage networks. The region is the driest in the UK and it is not sustainable to continually deplete the natural aquifers.

1. INTRODUCTION

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

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

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

2. ECC Interest in the Issues and Options Consultation

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

3. DUTY TO CO-OPERATE

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

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

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

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

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

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

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

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

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

4A Summary

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

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

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

4B ECC Detailed Response to the Issues and Options Consultation

INTRODUCTION (SECTION 1)

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

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

TELL US YOUR VIEWS (SECTION 2)

Next Steps

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

OUR CHARACTERISTICS (SECTION 3)

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

Our Economy

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

Our Communities

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

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

National Picture

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

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

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

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

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

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

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

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

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

OUR VISION AND OBJECTIVES (SECTION 5)

Draft Vision

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

Strategic priorities

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

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

Strategic Objectives

SP1 The homes and jobs needed in the area

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

SP 2 Provision of retail, leisure and other commercial development

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

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

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

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

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

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

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

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

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

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

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

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

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

SP5 Climate Change and Environmental protection and mitigation

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

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

DELIVERING HOMES & JOBS (SECTION 6)

ECC General Comments

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

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

SP1.1 Need for Market, Affordable and Specialist Homes

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

ECC Comments

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

Affordable Homes

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

ECC Comments

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

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

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

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

ECC Comments

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

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

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

Homes for Older People and Adults with Disabilities

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

ECC Comments

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

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

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

SP1.2 Care Homes

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

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

ECC Comments

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

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

SP1.3. Delivering our Need for Homes

ECC General Comment

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

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

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

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

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

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

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

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

Paragraph 6.48 Options to provide a realistic strategy for delivering new homes:
A. Increase density within the existing residential area - which would require an amendment to our current density policy
B. Increase density on allocated residential sites
C. Several small extensions to the existing residential area
D. A number of fewer larger extensions to the existing residential area
E. A new settlement

ECC Comments

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

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

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

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

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

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

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

SP1.4 Good Mix of Homes

Paragraph 6.58 Options identified in relation to the broad approach for considering the type and size of new homes:
A. Retain the current policy on types of homes, which takes a flexible, market-driven approach to types
B. Include specific reference to the size and types of homes referred to the South Essex SHMA
C. Continue to require new homes to meet the National Technical Housing Standards - nationally described space standards
D. Do not adopt specific policy on the mix of homes

ECC Comments

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

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

SP1.5 Gypsy, Travellers and Travelling Showpeople

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

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

SP1.6 Houseboats and Liveaboards

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

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

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

ECC Comments

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

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

SP1.7 Meeting Business Needs;

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

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

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

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

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

ECC Comments

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

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

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

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

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

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

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

SP1.8 Need for Jobs;

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

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

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

ECC Comments

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

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

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

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

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

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

ECC Comments

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

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

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

SP1.10 Supporting Tourism and Rural Diversification

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

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

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

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

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

Paragraph 6.128 Options for tourism and rural diversification:

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

ECC Comments

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

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

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

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

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

SP2.1 Retail, Leisure and Town Centres

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

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

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

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

SP3.1Highways Infrastructure

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

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

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

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

Paragraph 8.20 Options for the Local Highway Network:

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

ECC Comments

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

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

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

Strategic Highways Network Transport

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

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

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

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

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

SP3.2 Sustainable Travel

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

ECC Comments

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

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

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

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

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

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

SP3.3 Communications Infrastructure,

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

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

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

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

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

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

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

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

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

SP3.4 Water and Flood Management,

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

ECC Comments

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

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

SP3.5 Renewable Energy Generation

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

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

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

ECC Comments

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

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

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

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

SP3.6 Planning Obligations and Standard Charges;

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

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

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

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

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

ECC Comments

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

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

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

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

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

SUPPORTING HEALTH, COMMUNITY AND CULTURE (SECTION 9)

SP4.1 Health and Well-being;

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

ECC Comments

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

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

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

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

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

SP4.2 Community Facilities;

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

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

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

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

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

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

SP4.3 Education and Skills;

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

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

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

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

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

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

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

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

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

ECC Comments

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

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

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

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

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

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

SP4.4 Early Years and Childcare Provision;

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

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

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

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

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

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

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

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

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

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

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

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

SP4.5 Open Space and Outdoor Sports and Recreation

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

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

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

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

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

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

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

SP4.6 Indoor Sports and Leisure Centres

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

ECC Comments

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

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

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

SP4.7 Facilities for Young People;

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

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

SP4.8 Play Space Facilities;

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

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

PROTECTING AND ENHANCING OUR ENVIRONMENT (SECTION 10)

Paragraph 10.1 Overall ECC welcomes the Strategic Priority SP5

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

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

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

SP5.1 Green Belt

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

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

Paragraph 10.16 Options in relation to the Green Belt:

A. Retain the existing policy on broad Green Belt principles in the Core Strategy
B. Amend the current Green Belt policy in the Core Strategy
C. Do not have a policy on the Green Belt

ECC Comments

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

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

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

SP5.2 Biodiversity, Geology and Green Infrastructure

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

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

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

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

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

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

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

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

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

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

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

ECC Comments

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

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

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

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

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

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

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

SP5.3 Wallasea Island and the RSPB Wild Coast Project

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

ECC Comments

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

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

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

SP5.4 Landscape Character;

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

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

ECC Comments

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

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

SP5.5 Protecting and Enhancing Heritage and Culture

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

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

SP5.6 Good Design and Building Efficiency

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

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

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

ECC Comments

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

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

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

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

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

ECC Comments

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

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

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

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

SP5.7 Air Quality

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

Paragraph 10.72. Options in relation to Air Quality:

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

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

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

DETAILED POLICY CONSIDERATIONS (SECTION 11)

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

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

D.P1.1 Mix of Affordable Housing

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

ECC Comments

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

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

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

ECC Comments

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

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

DP1.10 Parking standards and Traffic Management

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

ECC Comments

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

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

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

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

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

D.P1.11 Home Businesses

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

ECC Comments

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

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

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

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

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

DRAFT SUSTAINABILITY APPRAISAL

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

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

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

*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