Paragraph 1

Comment

Representation ID: 37455

Received: 01/08/2019

Respondent: Southend-on-Sea Borough Council

Thank you for the opportunity to comment on the above document.

The amendments on GDPR and Neighbourhood Planning are supported in principle. Southend Borough Council does not have any specific comments to make.

Comment

Representation ID: 37457

Received: 31/07/2019

Respondent: Chelmsford City Council

The Council notes the new section referencing to Neighbourhood Plans and support offered in preparing new neighbourhood plans.
This Council considers that proposed amendments are clear and comprehensive.
Chelmsford City Council will continue to actively engage with Rochford District Council on each other's respective Local Plans.

Object

Representation ID: 37458

Received: 08/08/2019

Respondent: Mr M Rennie

The Neighbourhood plan states allocate land for development, including new homes and employment. In the case of the Hullbridge development thee is no indication of new jobs being generated. I would suggest (1) that no further land should be allocated to build on and (2) the current development of 500 houses should be restricted to 125/250 so as to determine the impact on traffic congestion and the environment - likewise the London Road / Rawreth Lane development should be reduced.

Comment

Representation ID: 37463

Received: 21/08/2019

Respondent: Historic England

With regards to neighbourhood planning, we would welcome notification of proposed neighbourhood planning areas as well as consultation on draft plans. The regulations state that statutory bodies including Historic England should be consulted on draft plans where our interests are considered to be affected. This should be included in your amendment to paragraph 2.21. We have guidance on neighbourhood planning, which can be found at: <https://historicengland.org.uk/advice/planning/plan-making/improve-your-neighbourhood/>

Comment

Representation ID: 37467

Received: 27/08/2019

Respondent: Hullbridge Residents Association

Item 1 (page 1) This NP was introduced by the "Localism Act" in 2011 and gives local communities new powers to take decisions to help shape and drive the development that takes place in their area. Would you agree this can be done by proven professionally qualified groups, by example, such as the Hulbridge Residents Association (HRA) in the same way the District Council have accepted the Neighbourhood Forum of "Canewdon and Wallasea" as designated in the District (clause 9), and why Hullbridge have not been given the same opportunity, despite several requests to administer the Neighbourhood Planning Group (NPG) in accordance with the Neighbourhood Planning Regulations 2012, with the added advantage of seeking a Charitable status, with your approval, for funding purposes.

Neighbourhood Plan -

HRA were advised by Westminster Planning Department to apply to you, but we did not receive a reply.
Hullbridge Parish Council (HPC) conceded at a council meeting in 2016 (also attended by the Rural Community Council of Essex (RCCE)) that they were unable to administer projects due to lack of knowledge of large scale development planning matters. HRA 22-member committee were at this HPC meeting and we consider that HPC missed the opportunity to introduce HRA as a 'Professional Group' able to undertake the proposed Neighbourhood Planning Group. The HPC have had ample opportunity to discuss this and come to an agreement, but they have never tried. HRA have provided adequate proof of our 'professionalism' to administer a Neighbourhood Planning Group, under a charitable status to find funds to do this work, RDC and HPC were also copied into this correspondence, but our proposals have continually been rejected, despite us having a robust 'constitution' in accordance with the CPALC 10 point Guiding Principles, which is close to the Constitution observed by the RDC, along with professionally qualified and experienced committee members. HRA will abide by the 7 stages of the NP as set out in item 6, page 2.

Item 1 (cont). Neighbourhood Development Order
We have been in discussions with a Councillor about the possibilities of involvement with a Development Board, which we are happy to participate with, and we were hoping this would lead to some result, but to date we have had no progress.

Item 1 (cont). Community Right to build Order
This section is for the Parish Council, but the accent seems to be on the word "Community", which is in conflict with what we have been speaking about ie that HRA are well 'equipped' to prepare and administer this NP, as stated above, that HPC are unable to deal with large scale developments, but the community representative (HRA) are not provided the opportunity to participate in co-operation with the RDC and HPC in accordance with the rules and regulations set out in the Addendum C.

Comment

Representation ID: 37474

Received: 27/08/2019

Respondent: Hullbridge Residents Association

Community Infrastructure Levy (CIL) (Refer to the SCI 2016- page 10).

This CIL is in accordance with Regulation 2010 (As amended) in particular the Charging Schedule Clauses 2.17 and 2.18. HRA ask if the CIL is mentioned in the Core Strategy and the NPPF,
HRA are concerned with the insufficient consultation as to the "Evidence Base Preparation" and "Infrastructure Funding Gap Assessment" (Cl. 18), and the preliminary "Draft Charging Schedule" (Regulations 15 and 16) stated in the 'future tense'. HRA have not had the opportunity to engage on the "Timetable" for the preparation of the CIL as set out in the Local Development Scheme.

In consideration of the Malyons Lane development, now in construction, please provide us with the information as to how the CIL applies to the developer for incorporation of this Levy and what the sums of money are involved. We have not seen mention of this levy in the 'Contributions' of £4.5m by the developer. Please provide us with information on the Draft Charging Schedule to allow us an observation and comment opportunity. Will these charges be subject to consultation with the developer and what if these charges are insufficient to cope with the required contributions from the residents?

We are pleased to see that RDC have resurrected the Localism Act which gives local communities new powers to make decisions to help shape and drive the development/s in the area.
There is no definition on the words "Gives Communities the Power" or a clear meaning of 'communities'.
HRA have put forward many issues in respect of Malyons Lane , which, although not acknowledged, have been instrumental in amendments to the plans put forward by the developer, and we have had an impact by a 3 to 4 years delay in the construction works. We must remind RDC that HRA have been involved in all issues of developments since 2013 and demand the right to be consulted.

Many issues have not been resolved, specifically in relation to "Flood", existing "Drainage (foul and surface water", which has been neglected since 1968 and infrastructure.

Road improvements
There is no mention of 'road improvements' to Watery Lane, which has a direct impact on the road network in Hullbridge. Can RDC explain why the CPO has not been used to widen Watery lane ?
Several years ago HRA predicted that allocating two sites close together (Hullbridge and Rawreth) will cause chaos, and that has certainly come to pass. This means that the morning and evening 'rush hours' gridlock extends to the whole day and will continue for the next 10 to 15 years, or more if other developments are approved.

Section 6 - Contributions.

HRA wrote to RDC and the NHS requesting information on how the individual contributions were arrived at. A response from NHS presented a major calculation discrepancy and our calculations for the Medical services (£164k- in 2013) should be £384k (2016). We did not receive a response from NHS regards making good the shortfall, and you can understand our concerns for the future of our medical practioners. We spoke to BDW and they said simply that was what was agreed between all parties. If you take into consideration our 'expansion' figures below, we think the future contributions may be similarly calculated.

Expansion-Homes, Population and effect on Insurance.
New Homes Population
East Hullbridge 7 to 14 28 to 56
East Rawreth 1,773 to 3,545 7,092 to 14,180
West Hullbridge 926 to 1,350 3,704 to 5,400
North Hullbridge 537 to 1,074 2,152 to 4,304
South Hullbridge 134 to 268 536 to 1,072
Central Hullbridge 3,100 3,100 7,500 to 7,500 Existing.
Total 6,477 to 9,351 21,012 to 32,512

The total population may be some 21,000 to 32,500 in 10 to 15 years.
In consideration of what the Core Strategy and NPPF state, we say that Hullbridge can be classified as 'over-developed Town' with the unsatisfactory road network causing extreme congestion.
We estimate that the village has some 14,000 vehicles at present, likely to expand to some 33,000+. Common sense dictates that the existing infrastructure is totally inadequate and that the normal cycle of 5 year 'upgrading' has been neglected since 1968. The danger is of environmental, pollution and congestion issues having a substantial impact on Hullbridge, which is likely to be classified as a Town by 2021.

Insurance. HRA provided RDC with likely costs for the properties to be at 'flood' risk by Insurance Companies, with costs to householders likely to be double the normal price unless satisfactory assessments and evidence is provided to the contrary.

Boundary line between Hullbridge and rawreth

HRA stated in 2013 that the boundary line should be reviewed, but we were ignored. The above 'table' indicates quite clearly that the review now becomes even more important and discussions between RDC/HRA/HPC AND RAWRETH Parish Council becomes more imperative. HRA submitted to you substantial information, including our deliberations with the Boundary Commission, but RDC and both Parish Councils chose to ignore us, after we had provided them with the information, which they chose to emulate to you, without any acknowledgement of HRA past consultation with the Boundary Commission.

Assessments
A Planning Consultant invited HRA to visit an Environment Consultants in Bristol, and pending the final results, we are satisfied that the Consultants are a reputable Company, and will produce a Report on Environment in and around Hullbridge.
Purchasers' Condition Reports for the developers of the Malyons lane site indicated in their website that 79% of completed purchases had many faults or in a poor condition, it is not satisfactory for largest purchase of peoples' lives. HRA suggest a NPG can assist in consultation with prospective purchasers.
Inspection by the Local Authorities handing over responsibility to the developers has it's own consequences. Recently one of our MP's wrote an article about this very subject including the Housing Association in Partnership with the Local Authority, who offer an incentive to the Local Authority in return for approval of plans. RDC should consider the consequences.

A most recent TV programme (Britain's extreme Weather by Morland Sanders) suggested that the Government, Local Authorities and Environment/Highways and Drainage agencies are possessed with building homes irrespective of all the dangers present, a Town & Planning Officer made no excuses for why the antequated Planning Laws have lagged behind substantially to be modernised. The latest environment information is not being considered in the planning for more homes. Should this not happen, we consider that blame should be put on the Government, LA and all the planning agencies aforementioned, for putting housing development priorities at the expense of all the warnings being presented and possible lives being put at risk.
HRA are proud of all the amendments made in the approved Malyons Lane development.

HRA wrote to RDC on 11/5/14 in respect of HRA application. My Community Rights- Neighbourhood Planning (NP) & "Supporting Communities in NP submissions".

The information is extracted from the Statutory provisions S.61E-G of the Town and Country Planning Act 1990, s.38A of the Planning and Compensation Act 2004, the Localism Act 2011 chapter 20 and the neighbourhood Planning Act as included in part 6 chapter 1 clauses 109 to 113 and part 6, chapter 3 clauses 116 to 121 and part 6, chapter 4, clause 122 (amended).

Guidance notes for applicants, affective from 14 October 2013.
Subject clauses Question & Answers

Page Plans.
3 Through Neighbourhood Development Order (NDO): Apply for a development order.
Programmes provides support for neighbourhoods: Does £7k Grants apply to NPG.
Eligible
Form a working group of community reps & set up a Hullbridge Neighbourhood NP group have m
Neighbourhood Forum (NF) of 21 people to co-ordinate 21+ people in the group (Constitution)
as designated by the LA.
4 Officially Designated Neighbourhood or Designated Can we produce NP & Development Order.
Neighbourhood Forum (NF).
Complete Online Eligibility Form- Organisation details.
5 Are you able to support all groups to help them with their
final stages. Need to support NF (under-represented) Yes
Funding By setting up a charity.
Are you prepared to support NPF We are happy to conform to the rules.

11 COMPLETING APPLICATION
A) Stage reached in preparing plan. All information and funding will be assessed.
B) Nature of neighbourhood planning area. We will provide
C) Population size 7500 (present).
D) Level of growth anticipated As programme
E) Landscape and habitat characteristics. To provide
F) Level of expertise To provide
G) Volunteer time To provide.
H) Staff. To provide
I) Other resources of funding. To provide
J) Identify other support for the group such as: Funding, To provide. The group can be sustainable for
Volunteer Hours, in-kind support etc. duration of the development (12 years).

CONTEXT FOR THE AREA

Estimate of whole demographic population. Can provide
SUPPORT NEEDED In accordance with the Regulations.

13. Preparation of evidence base
A) Community engagement To provide
B) Identify issues and setting aims To provide
C) Writing policies and the plan Yes
D) Pre-submission consultation. HRA are reasdy to be involved.
E) Updating the plan in the light of consultation. Our team is capable

SUPPORTING DOCUMENTS Important documents
which add background to application. To provide

FOR GRANT SUPPORT We will identify what is needed in terms of Length of time & cost.

HRA suggest open consultation with RDC and HPC to clarify and agree on the way forward to make Hullbridge a better place to live. Past & present experience identifies a lack of trust and transparency, we ask how this situation can be resolved.

We could have achieved the Guinness Book of Records for the largest support of residents, but the Parish Council and local councillors could not find a way to support us.

HRA look forward to robust discussions on all issues concerning the above.

Object

Representation ID: 37475

Received: 29/08/2019

Respondent: Mrs Wendy Nixon

Any further planning for new housing has to stop. Our small town cannot cope anymore. We havnt the inforstructer of facilities to support more people. Roads are like car parks coming in and out of Rayleigh. This also puts added strain on our health survice.schools ect. You need to stop thinking of money and support the local community. And all the time our council tax is going up and we are suffering.

Comment

Representation ID: 37476

Received: 29/08/2019

Respondent: MR Adrian Walker

There is no definition on the words "Gives Communities the Power" or a clear meaning of 'communities'.

Clearly, these "powers" amount to nothing as our concerns have been totally ignored and you have continued to allow these developments to continue unabated, with flagrant disregard for infrastructure.

Comment

Representation ID: 37484

Received: 28/07/2019

Respondent: Mr J Cripps

In keeping with your recent invitation we submit comments On behalf of Action Groups Resisting Overdevelopment :-

1. PUBLIC PERCEPTIONS -
Decades of Urban Sprawl ( on 'exempt' Green Belt )
has made a mockery of Public Consultation which
is now perceived as a 'tick the box' compliance tool.
This is the primary reason why the public response
is historically minimal (sic: ' there is no point...').
2. THE REALITY -
The central Government aspirations on new housing
targets ( via user friendly Councils ) is not matched
by Strategic Planning ( Infrastructure ) funding. This
poses those same Councils with an impossible task
because they are under-funded & under resourced;
and anyway the Primary Consultee (ECC) dictate the
key issues (Health/Education/Highways/Flooding....).
3. THE PRIMARY PROBLEM -
The Government's NPPF Policy is designed to drive
Council Planning in a set direction ( Call for Sites is
the only source of 'free' land supply ). Inevitably, in
the predominantly Green Belt Rochford Peninsular,
this means the very essence of GB Law is breached.
4. THE SECONDARY PROBLEM -
With limited resource, funding, deference to ECC and
Party loyalties the Rochford District Council have no
choice but to elect isolated random plots as a so-
called Preferred Option. The current Local Plan is a
prime example and , by using the same formulae, the
"New" Local Plan will yield more of the same (errors).
5. THE TERTIARY PROBLEM -
Decades of 'efficiencies / capping / cuts and Austerity'
have eroded both County and Local Council capability
for so long that a prevailing climate of make do & mend
precludes any vision. This acceptance extends to the
Essex MP's who are noticeable by their absence in even
recognising their Governments flawed Planning policy.
6. WHAT WE NEED -
The ( now overdue ) Joint Strategic Plan for the South
corridor of Essex must not be repeating the standard
approach again - the scale of housing is too large now.
This critical document must give a clear new direction
on planning the subsequent " New" Local Plans in a
new, modern, long-term ( sustainable ) manner. This
must include assessments of strategic Infrastructure
funding levels required to support Government housing
targets - not blind acceptance.

This cannot be solved by Public Consultation, the Crisis
in Planning needs to be addressed by those responsible
for it at both RDC and ECC - now.