Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?

Showing comments and forms 1 to 30 of 65

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 37634

Received: 03/08/2021

Respondent: Mr Ben Miller

Representation Summary:

While the technical evidence studies have no doubt been carried out well, I believe the Council should push back against central government who are making unreasonable demands in the first place. Tell central government to pick a new part of the UK to build news towns and cities, and while there at it, provide all the required infrastructure necessary for such an undertaking. Also, any new building plans for this area should only proceed AFTER the existing infrastructure is upgraded to support the new increase. Fair enough, I think?

Full text:

I don't doubt the Council have done their homework. In fact, I'm sure they've done a great job of preparing the plan. However, I believe, before anything else, the Council should be pushing back against central government for the unreasonable demands the central government are making. OK, I accept the UK population is growing and more housing is needed. However, it is not needed AND doesn't HAVE to be provided in THIS area. Truth is...we're already full. I believe the council should push back against the central government's plans and tell central government that if they want X thousand new homes by 2040, they scoop out another part of UK to build these new houses/towns/cities and, at the same time, provide the required infrastructure to support these new developments. At the very, very least, before any new plans are made by the council, the council should demand an 'infrastructure first' approach. Want us to build X thousand more houses? Sure. You provide the required infrastructure first and when it's complete, then, and only then, new dwellings can be built.

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 37663

Received: 04/08/2021

Respondent: Miss Marie McCarthy

Representation Summary:

Consider recreation - I think Rayleigh could do with a swimming pool.

Consider re-location of recycling centre in Castle Road. It needs moving to a larger location on outskirts of town.

Protect our remaining green spaces as Rayleigh does not have many left.

Full text:

Consider recreation - I think Rayleigh could do with a swimming pool.

Consider re-location of recycling centre in Castle Road. It needs moving to a larger location on outskirts of town.

Protect our remaining green spaces as Rayleigh does not have many left.

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 37736

Received: 07/08/2021

Respondent: Miss Donna Thresher

Representation Summary:

It is not possible to consider land before considering the infrastructure and current building program that is in progress. The current build program impacts the infrastructure more severely than the council is prepared to recognise and therefore an accurate assessment of infrastructure must be considered fist.

Full text:

It is not possible to consider land before considering the infrastructure and current building program that is in progress. The current build program impacts the infrastructure more severely than the council is prepared to recognise and therefore an accurate assessment of infrastructure must be considered fist.

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 37786

Received: 09/08/2021

Respondent: Ms Helen Wright

Representation Summary:

Since you are expecting a large increase in the elderly population and a decrease in those working to pay for them why are you not adjusting your plans to focus on::
Housing to suit the elderly,
Extra medical facilities for an elderly population

As the cost of housing is stated to be out of reach of the residents of Rochford who do work (10 times the average salary) where is your provision for those who need houses and already live here? Your plans to increase housing stock do not make provision for them.

Full text:

Since you are expecting a large increase in the elderly population and a decrease in those working to pay for them why are you not adjusting your plans to focus on::
Housing to suit the elderly,
Extra medical facilities for an elderly population

As the cost of housing is stated to be out of reach of the residents of Rochford who do work (10 times the average salary) where is your provision for those who need houses and already live here? Your plans to increase housing stock do not make provision for them.

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 37999

Received: 18/08/2021

Respondent: Mr Norman Bright

Representation Summary:

Poor choice of question in 'support, object or comment'
Objection:
There is no mention of the technical evidence study on the impact of developments on climate change which must be fundamental - emissions assessment prior to any developments
Flood reports - not just as flood zones are mapped now but forecast especially in light of the IPCC code red report on climate change. Both sea level and surface water.
assessment on wildlife and ecology
An assessment on the impact of housing numbers on crime

Full text:

Poor choice of question in 'support, object or comment'
Objection:
There is no mention of the technical evidence study on the impact of developments on climate change which must be fundamental - emissions assessment prior to any developments
Flood reports - not just as flood zones are mapped now but forecast especially in light of the IPCC code red report on climate change. Both sea level and surface water.
assessment on wildlife and ecology
An assessment on the impact of housing numbers on crime

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 38035

Received: 20/08/2021

Respondent: Philip Hitchman

Representation Summary:

It's funny how we're only allowed to use up to 100 words to comment whereas you've provided thousands upon thousand of lines of unreadable waffle! This whole consultation website needs to be summarised otherwise you are effectively excluding the bulk of the residents!

Full text:

It's funny how we're only allowed to use up to 100 words to comment whereas you've provided thousands upon thousand of lines of unreadable waffle! This whole consultation website needs to be summarised otherwise you are effectively excluding the bulk of the residents!

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 38226

Received: 26/08/2021

Respondent: Mr Stuart Greengrass

Representation Summary:

RDC future plan allows for greenfield sites to be considered for development when brown field and unused locations are exhausted - I do not believe that RDC has understood the future need of food production from vital, precious and finite farmland as climate change dictates diet changes away from meat production.
The implications for this change must be studied to ensure your review of greenfield use does not impact food production.

Full text:

RDC future plan allows for greenfield sites to be considered for development when brown field and unused locations are exhausted - I do not believe that RDC has understood the future need of food production from vital, precious and finite farmland as climate change dictates diet changes away from meat production.
The implications for this change must be studied to ensure your review of greenfield use does not impact food production.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 38430

Received: 02/09/2021

Respondent: Mr Kelvin White

Representation Summary:

The plan seems to focus on a 'need' for housing an older society. The plan does not appear to consider the needs of the immediate community either now or in the future. If the focus is on an older community then studies should be undertaken on what a community needs (i.e. more community spaces and facilities such as clubs/swimming/exercise etc). More houses means more people so the area will need better infrastructure (transport, schools, doctors, dentists, roads).

Full text:

The plan seems to focus on a 'need' for housing an older society. The plan does not appear to consider the needs of the immediate community either now or in the future. If the focus is on an older community then studies should be undertaken on what a community needs (i.e. more community spaces and facilities such as clubs/swimming/exercise etc). More houses means more people so the area will need better infrastructure (transport, schools, doctors, dentists, roads).

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 38447

Received: 03/09/2021

Respondent: Mr John Mason

Representation Summary:

Rochford District Council's Public Consultation on its New Local Plan asks residents to give feedback on the Council's ideas about Spatial Options but it omits the most important capacity data on Infrastructure making the choices made by residents far from "Infrastructure First" . The New Local Plan shows that the next Public Consultation in 2022 where The Council proposes to actually build under Preferred Options will have been made without any prior input on choices from residents taking into account infrastructure capacity; doctors, other health care, public transport, schools, population growth, highway congestion, pollution, climate change data, water, sewerage etc.,

Full text:

Defenders of The Rochford District is a Facebook Group with 300 Members.

It is acknowledged that in the past that Rochford District Council has only counted a Petition as one objection in a public consultation.

The E - Petition process in RDC requires the Approval of The Council and this was considered inappropriate in this instance so the Defenders of The Rochford District decided to use another Petition platform. "http://chng.it/XhLTSRRwdb"

Defenders of Rochford District Petition for Pushback on housing numbers (7200) by Rochford District Council to Save Green Belt

RDC Council Leader, Simon Wootton, is asked to write to local MP's and Robert Jenrick, Secretary of State on housing numbers to challenge the Rochford District's housing targets (known as the Objectively Assessed Need, or OAN), and press for an 'Infrastructure First' approach to housing delivery from The Government.

Challenges are already being made by Councils in both Southend and Basildon and it will be advantageous for RDC to also do so to work together on the same shared issues on the "peninsula" directly with The Government.

The latest Rochford District Council's Public Consultation on its New Local Plan asks residents to give feedback on the Council's ideas about Spatial Options but it omits the most important capacity data on Infrastructure making the choices made by residents far from "Infrastructure First" and more like "Infrastructure Last". The Council's Delivery Plan for its New Local Plan shows that the next Public Consultation in 2022 showing where The Council proposes to actually build under Preferred Options will have been made without any prior input on choices from residents taking into account infrastructure capacity; doctors, other health care, public transport, schools, population growth, highway congestion, pollution, climate change data, water, sewerage etc.,

RDC Council Leader, Simon Wootton, is also asked by this Petition to withdraw the present Public Consultation until this data can be provided to residents.

Rochford District Council has recently REFUSED a Planning Application in Rochford questioning highway congestion assessments on SER8 a site approved for development in the Old LocaL Plan.

Infrastructure was apparently NOT Put First in the Old Local Plan.

It may happen again if RDC Council Leader, Simon Wootton, does not listen to residents and act in accordance with their wishes under this Petition.

Defenders of Rochford District

This Petition has received 2287 signatures of support SO FAR and although RDC may not have regard for it at the very least Councillors and Officers should be aware of the wide objection to its public consultation and bear this in mind when going forward to Public Examination in due course.

As further support of the need for this Petition would you please take due note of the content of this email.

From: Cllr Lee Scott - Member CC <Cllr.Lee.Scott@essex.gov.uk>

I refer to your email regarding the Rochford Local Plan and the provision of current and potential future new infrastructure to support the provision of sustainable transport in the District. This is a very important issue to deal with, as plans for new housing are developed in the new Rochford Local Plan that is currently being prepared by the District, which will set the strategy for future development of Rochford beyond 2025. ECC is advising Rochford planners of aspects of both transport and land use issues.

With that in mind, and the fact that there are the same pressures across the whole of south Essex, a South Essex Plan is being developed that will set out an overall strategy for development across the whole area. Building on this partnership working approach, a South Essex 2050 Memorandum of Understanding was drawn up in January 2018 which was signed by all partner authorities, including both ECC and Rochford District Council, that sets a joint approach across South Essex to collectively support economic growth and importantly in the context of your email, puts sustainable development across the sub-region at the centre of respective plans. It will also be used to effectively respond to external pressures, such as the Thames Estuary 2050 Commission and the London Plan.

Being a largely rural district in nature its growing population is exerting more and more pressures on the local highway’s network and this will continue as the population grows. The population is expected to grow to 89,494 by 2025, up from 84,815 back in 2015, an increase of 5.5%. However due to the extent of Green Belt, the District is significantly constrained in how much and where new housing can be located. Therefore, there is a relatively limited amount of policy compliant developable land available in the Rochford area.

The Councils recognise that there are strong synergies between Rochford and the surrounding areas of Essex, including in relation to transport infrastructure and economic factors. It is likely that planned growth will have an impact on the transport infrastructure in Rochford, as well as beyond on wider ECC infrastructure. In response to this strong synergy, consultants have been commissioned to look into this and to produce fresh evidence in order to understand more deeply the existing transport infrastructure and future development, in line with the Duty to Co-operate requirement guiding Local Plan development. Contained in this work there has been an assessment of sustainable travel levels in the District and this is composed of three constituent areas; non-motorised users (walking and cycling), buses and rail services. Each site for potential housing development has been scored to ascertain the level of accessibility and unsurprisingly those sites with higher scores are predominantly within or proximate to settlements. The higher scoring sites are predominantly close by to a rail station or town centre where bus facilities are also nearby.

As well as the newly commissioned work, Rochford has invested in producing an Urban Capacity Study which seeks to assess the likely ability of Rochford District to accommodate additional residential development within existing residential areas and appropriate brownfield sites. The Urban Capacity Study builds upon the findings of the study carried out on behalf of Rochford District Council in 2000, using empirical evidence to review the accuracy of the previous study and make revised predictions for future residential development.

The Local Plan is evolving and there is much work still to be done. Therefore moving forward, further results will be published as the data and evidence is analysed and interpreted. All will be subject and be guided by both current ECC and Government transport and housing policies, with the promotion and development of sustainable transport at its core in order that new communities are built as sustainably as practical; supported by high quality sustainable transport infrastructure.

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 38456

Received: 03/09/2021

Respondent: Rochford District Residents

Representation Summary:

There is a failure to provide the necessary infrastructure capacity data, higher level strategy for South Essex and Essex and evidence of cooperation with other local Councils.

There is a failing deficient infrastructure of 10's of £ millions which was established by consultants engaged by ECC and referred to as GIF.

The Council has that evidence but has never discussed it in Council and apparently not included that evidence in The Evidence Base or Archive to this NEW Local Plan.

Residents have expressed disappointment that The Council has not publicly challenged the housing target for Green Belt.

Full text:

Rochford District Residents (RDR) is a Registered Political Party and has 6 District Councillors as well as a Councillor on Rayleigh Town Council.

RDR is a Stakeholder Organisation in this Public Consultation. I am Party Leader.

The Government announced changes to the National Planning Policy Framework (NPPF) on Tuesday 20 July. These changes have significant implications on the Rochford District NEW Local Plan.

Rochford District Council is now required to prepare a Local plan detailing 30-year vision. The current Spatial Options Public Consultation proposals (Vision?) are to guide development to only 2040 when it must now be 2055.

This Public Consultation is premature and flawed because the Council has acknowledged that it will not publish full Infrastructure Capacity Data until after this engagement even though each will be available in the short term.

Without correct and up to date information on provision of infrastructure and what that could look like no one can make an informed decision.

A South Essex Plan is being developed by ASELA (a quango comprising all Councils in South Essex) that will set out an overall strategy for development across the whole area. Building on this partnership working approach, a South Essex 2050 Memorandum of Understanding was drawn up in January 2018 which was signed by all partner authorities, including both ECC and Rochford District Council, that sets a joint approach across South Essex to collectively support economic growth and importantly in the context of The Rochford District NEW Local Plan, puts sustainable development across the sub-region at the centre of respective plans.

There is no Reference to GREATER ESSEX GROWTH AND INFRASTRUCTURE FRAMEWORK 2016-2036 (AECOM) and the multi million £ shortfall for Rochford District.

SO WHY HAS RDC PUT FORWARD A SPATIAL OPTIONS PUBLIC CONSULTATION ASKING RESIDENTS TO CHOOSE OR OBJECT TO SITES, VILLAGES AND TOWNS WITHOUT A PLAN FOR SOUTH ESSEX BEING AVAILABLE TO RESIDENTS?

RDC UNDERTOOK AN URBAN CAPACITY SURVEY (UCS) IN 2020 WHICH IDENTIFIES EXISTING SITES FOR AROUND 3000 HOMES BUT THIS IS NOT SPECIFICALLY DRAWN TO THE ATTENTION OF RESIDENTS SUCH THAT THE COUNCIL SHOULD ONLY BE LOOKING FOR NEW SITES AT AROUND 4200. THIS IS A MATERIAL INFORMATION DEFICIT IN THIS PUBLIC CONSULTATION..

Being a largely rural district in nature OUR growing population is exerting more and more pressures on the local highway’s network and this will continue as the population grows. The population is expected to grow to 89,494 by 2025, up from 84,815 back in 2015,an increase of 5.5%. However due to the extent of Green Belt, the District is significantly constrained in how much and where new housing can be located. Therefore, there is a relatively limited amount of policy compliant developable land available in the Rochford area.

SO INSTEAD OF PUTTING EVERY PIECE OF LAND THAT SOMEONE WANTS TO DEVELOP, WHY HASN'T RDC THINNED THIS DOWN TO WHAT IS SUSTAINABLE ON INFRASTRUCTURE AND IF THE TARGET IS NOT THEN CHALLENGE THE TARGET WITH THE GOVERNMENT LIKE SOUTHEND AND BASILDON HAVE DONE?

Residents already recognise that there are strong synergies between Rochford and the surrounding areas of Southend, Castle Point and Basildon, including in relation to transport infrastructure and economic factors. It is likely that planned growth will have an impact on the transport infrastructure in Rochford, as well as beyond on wider Essex infrastructure.

In response to this strong synergy, we understand that consultants have been commissioned by Essex County Council to look into this and to produce fresh evidence in order to understand more deeply the existing transport infrastructure and future development, in line with the Duty to Co-operate requirement guiding Local Plan development.

Contained in this work there will be an assessment of sustainable travel levels in Rochford District and this is composed of three constituent areas; non-motorised users (walking and cycling),buses and rail services.

SO WHY HAS RDC CONSULTED WITHOUT THE ECC EVIDENCE? IF THAT EVIDENCE WAS AVAILABLE THEN THE COUNCIL WOULD HAVE TO CONCLUDE THAT THE 7200 TARGET IS IMPOSSIBLE TO DELIVER WITHOUT CAUSING SIGNIFICANT DAMAGE TO THE DISTRICT.

Each site for potential housing development put forward to Rochford District Council by landowners and developers has been scored by RDC to ascertain the level of accessibility and unsurprisingly those sites with higher scores are predominantly within or proximate to settlements.

The higher scoring sites are predominantly close by to a rail station or town centre where bus facilities are also nearby.

WHY HAS ROCHFORD DISTRICT COUNCIL NOT RECOGNISED THIS IN ITS PUBLIC CONSULTATION ON SPATIAL OPTIONS AND COME UP WITH SOMETHING ELSE BECAUSE SURELY THE EXISTING INFRASTRUCTURE CANNOT COPE WITH THIS HOUSE BUILDING STRATEGY WITHOUT WRECKING OUR LIVES AND OUR BUSINESSES?

SOUTHEND BOROUGH COUNCIL (SBC) IS UNDERSTOOD TO BE PLANNING FOR A NEW SETTLEMENT IN THE FOSSETTS FARM AREA OF 7000 HOUSES. THIS HAS NOT BEEN DRAWN TO THE ATTENTION OF RESIDENTS. A SIGNIFICANT PROPORTION OF THE RESIDUAL 4200 HOMES (after UCS 3000) COULD ADDITIONALLY BE PLACED IN THE SAME AREA BY RDC ON CALL FOR SITES AVAILABILITY WITH A NEW ROAD PROPOSED BY SBC.

Please see the published RDC form for nominating sites which establishes criteria for approval of Nominations to Call for Sites.

Residents have brought to each other's attention that in respect two large sites, CSF045 (Belchamps) and CS194 (Rectory Road, Hawkwell) it is alleged that landowners do not wish to sell. In respect of CFS045 a Councillor has an email from Trustees.

On that basis neither should be under consideration unless RDC has nominated the sites itself as candidates for Compulsory Purchase. There is no evidence of the latter.

One wonders if there are any more sites that should not have been approved by RDC in accordance with its published criteria and policy.

A Conservative Councillor, a Member of The Planning Policy Committee has written in public about this public consultation " IF THERE IS NO LOCAL PLAN IT WOULD BE A FREE-FOR-ALL FOR DEVELOPERS TO BUY UP LAND WITHOUT HAVING TO GET PLANNING APPROVAL FROM THE LOCAL AUTHORITY."

That claim was also made throughout the Core Strategy.

Did that happen in Castle Point? Unarguably - NO.

Residents have expressed through a Petition their disappointment that The Council has not publicly challenged the housing target imposed by The Government and gained a reduction given that most of the target will be on green belt. Southend and Basildon Councils are challenging The Government. Castle Point Council has failed to deliver any local plan over the last 10 years or so but RDC has delivered several thousand homes against the background of a failing deficient infrastructure of 10's of £ millions which was established by consultants engaged by ECC and referred to as GIF. The Council has that evidence but has never discussed it in Council and apparently not included that evidence in The Evidence Base or Archive to this NEW Local Plan. This is unacceptable.

Residents are finding it very difficult to engage with this Public Consultation because it is unclear what they are asked to address; Strategy or Individual sites? The Volume of questions and the complexity of the online presentation was evidently not reviewed and tested by The Council before The Public Consultation was approved.

There is a failure to provide the necessary infrastructure capacity data, higher level strategy for South Essex and Essex and evidence of cooperation with other local Councils.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 38465

Received: 03/09/2021

Respondent: Dr Michael McDowall

Representation Summary:

I don't see how you can consider options for the placement of new housing in the area without a clearer idea of the traffic implications of the various options and an indication of what should be done to ease current problems and offset the effect of the new housing.. The current analysis is very thin. It's not enough to say, for example, that more concentrated housing will produce more funds for infrastructure without having an idea of what improvements are practical, what effect they would have and how much would they cost.

Full text:

I don't see how you can consider options for the placement of new housing in the area without a clearer idea of the traffic implications of the various options and an indication of what should be done to ease current problems and offset the effect of the new housing.. The current analysis is very thin. It's not enough to say, for example, that more concentrated housing will produce more funds for infrastructure without having an idea of what improvements are practical, what effect they would have and how much would they cost.

Support

New Local Plan: Spatial Options Document 2021

Representation ID: 38493

Received: 04/09/2021

Respondent: Mrs Marilyn Hopper

Representation Summary:

More evidence required for housing needs

Full text:

More evidence required for housing needs

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 38572

Received: 07/09/2021

Respondent: Mrs Gillian Wells

Representation Summary:

Given the amount of building that has been taking place in Rayleigh over the last few years,I feel that the Council should look into the current situation as to each of the elements graded in the document as to whether the number given to these actually represents the true picture on the ground. For example schools . What will be the impact to current standards and pupil welfare adding even more pupils to the current numbers attending these schools . Engage more closely with those responsible for these.

Full text:

Given the amount of building that has been taking place in Rayleigh over the last few years,I feel that the Council should look into the current situation as to each of the elements graded in the document as to whether the number given to these actually represents the true picture on the ground. For example schools . What will be the impact to current standards and pupil welfare adding even more pupils to the current numbers attending these schools . Engage more closely with those responsible for these.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 38641

Received: 08/09/2021

Respondent: Rochford District Residents

Representation Summary:

I feel that both MP's should invite The Rt Hon Robert Jenrick, Secretary of State to Rochford District to help The Council decide on whether The Government wishes The Council to build on Green Belt to meet The Government Target of 7200.

There is evidence from another area that The Government does not expect Green Belt to be lost if such a visit cannot be arranged.

https://www.getsurrey.co.uk/news/surrey-news/dont-want-homes-built-surreys-21468986.amp?fbclid=IwAR1Zar9c24XF4pnSVgguGnpEtcxjQ53in69u2WveFUtTfiIZRekorbeCSyE

Full text:

I feel that both MP's should invite The Rt Hon Robert Jenrick, Secretary of State to Rochford District to help The Council decide on whether The Government wishes The Council to build on Green Belt to meet The Government Target of 7200.

There is evidence from another area that The Government does not expect Green Belt to be lost if such a visit cannot be arranged.

https://www.getsurrey.co.uk/news/surrey-news/dont-want-homes-built-surreys-21468986.amp?fbclid=IwAR1Zar9c24XF4pnSVgguGnpEtcxjQ53in69u2WveFUtTfiIZRekorbeCSyE

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 38683

Received: 09/09/2021

Respondent: Stuart Watson

Representation Summary:

You should also survey residents. Many of these 'technical studies' seem to be heavily bias towards favouring further development. This has been observed recently around the SER8 traffic surverys. All technical studies must also be as up to date as possible - no older than 12 months and studies carried our over a representitive time period (e.g. not doing traffic surveys at quiet periods on the roads).

Full text:

You should also survey residents. Many of these 'technical studies' seem to be heavily bias towards favouring further development. This has been observed recently around the SER8 traffic surverys. All technical studies must also be as up to date as possible - no older than 12 months and studies carried our over a representitive time period (e.g. not doing traffic surveys at quiet periods on the roads).

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 38691

Received: 10/09/2021

Respondent: Ms Deborah Mercer

Representation Summary:

Evaluate the impact of the current developments, especially in Rayleigh and Hullbridge.

Full text:

Evaluate the impact of the current developments, especially in Rayleigh and Hullbridge.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 38754

Received: 13/09/2021

Respondent: Mr Jeff Higgs

Representation Summary:

Yes, to explore new concerns over air pollution in Rayleigh High Street linked to proposed housing development. The primary example being plot CFS077 along with other sites generating additional traffic congestion.
Air pollution N02 and particulates.
Previous ASR reporting has already mandated actions to mitigate current congestion levels.
See Section 2.2 Progress and Impact of Measures to address Air Quality in Rochford https://essexair.org.uk/Reports/Rochford2020ASR.pdf

From the report not all actions have been implemented. Therefore further action will be needed to address the current situation.
Under these circumstances I feel we should not be developing any further green belt areas in Rayleigh.

Full text:

Yes, to explore new concerns over air pollution in Rayleigh High Street linked to proposed housing development. The primary example being plot CFS077 along with other sites generating additional traffic congestion.
Air pollution N02 and particulates.
Previous ASR reporting has already mandated actions to mitigate current congestion levels.
See Section 2.2 Progress and Impact of Measures to address Air Quality in Rochford https://essexair.org.uk/Reports/Rochford2020ASR.pdf

From the report not all actions have been implemented. Therefore further action will be needed to address the current situation.
Under these circumstances I feel we should not be developing any further green belt areas in Rayleigh.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 38755

Received: 13/09/2021

Respondent: Mr Mark Thomson

Representation Summary:

Transport and infrastructure assessments

Full text:

Transport and infrastructure assessments

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 38796

Received: 14/09/2021

Respondent: Mr Jeff Higgs

Representation Summary:

Yes, explore new concerns over air pollution in Rayleigh High Street specifically linked to proposed housing development. A primary example being plot CFS077 along with other Rayleigh sites generating additional traffic congestion.
Air pollution N02 and particulates.
Previous ASR reporting has already mandated actions to mitigate current congestion levels.
See Section 2.2 Progress and Impact of Measures to address Air Quality in Rochford https://essexair.org.uk/Reports/Rochford2020ASR.pdf

From the report not all actions have been implemented. Therefore further action will probably be needed to address the current situation.
Under these circumstances we should not be developing any further green belt areas in Rayleigh.

Full text:

Yes, explore new concerns over air pollution in Rayleigh High Street specifically linked to proposed housing development. A primary example being plot CFS077 along with other Rayleigh sites generating additional traffic congestion.
Air pollution N02 and particulates.
Previous ASR reporting has already mandated actions to mitigate current congestion levels.
See Section 2.2 Progress and Impact of Measures to address Air Quality in Rochford https://essexair.org.uk/Reports/Rochford2020ASR.pdf

From the report not all actions have been implemented. Therefore further action will probably be needed to address the current situation.
Under these circumstances we should not be developing any further green belt areas in Rayleigh.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 39021

Received: 19/09/2021

Respondent: Chris Teeder

Representation Summary:

More emphasis needs to be given to maintaining existing wildlife habitat and biodiversity as it is becoming seriously under threat in this part of Essex by overdevelopment and building on greenbelt. Also building on areas where there is badger populations and foraging has an impact on surrounding properties when badgers start searching for alternative foraging and sett building sites due to their long established ones being disturbed or destroyed.

Full text:

More emphasis needs to be given to maintaining existing wildlife habitat and biodiversity as it is becoming seriously under threat in this part of Essex by overdevelopment and building on greenbelt. Also building on areas where there is badger populations and foraging has an impact on surrounding properties when badgers start searching for alternative foraging and sett building sites due to their long established ones being disturbed or destroyed.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 39141

Received: 20/09/2021

Respondent: Ms Claire Green

Representation Summary:

One element that must be considered as part of the consultation is local infrastructure, access to schools, local businesses, public transport but mainly access to roads.

Living in Great Wakering, a small village with few road access routes, traffic, congestions and road usability is already challenging. We already have severe congestion down Little Wakering Road and that is without the impact of the development already under construction down Barrow Hall Road.

I would suggest an in depth investigation into the impact new housing with have on the roads into and out of the village.

Full text:

One element that must be considered as part of the consultation is local infrastructure, access to schools, local businesses, public transport but mainly access to roads.

Living in Great Wakering, a small village with few road access routes, traffic, congestions and road usability is already challenging. We already have severe congestion down Little Wakering Road and that is without the impact of the development already under construction down Barrow Hall Road.

I would suggest an in depth investigation into the impact new housing with have on the roads into and out of the village.

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 39149

Received: 20/09/2021

Respondent: Mr Mike Webb

Representation Summary:

Greater awareness of the traffic issues on the Ashingdon Road is needed as the road is not able to take any more traffic.

Full text:

Greater awareness of the traffic issues on the Ashingdon Road is needed as the road is not able to take any more traffic.

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 39218

Received: 20/09/2021

Respondent: Mrs Olivia Reeve

Representation Summary:

The local community and facilities (schools, doctors etc) cannot cope with the amount of housing we have now.

Full text:

The local community and facilities (schools, doctors etc) cannot cope with the amount of housing we have now.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 39281

Received: 21/09/2021

Respondent: Mr ian mears

Representation Summary:

Shouldnt the environmentasl impact study of 2015 also be included? Especially as it raised significant doubt that the area could support 1400 houses, let alone the proposed 4500 odd.
Also shouldn't the new government legal commitment to 'net zero' by 2050 be a significant driver to the overall policy and approach? Constant growth is not compatible with this legal goal unless implemented in very specific ways.

Full text:

Shouldnt the environmentasl impact study of 2015 also be included? Especially as it raised significant doubt that the area could support 1400 houses, let alone the proposed 4500 odd.
Also shouldn't the new government legal commitment to 'net zero' by 2050 be a significant driver to the overall policy and approach? Constant growth is not compatible with this legal goal unless implemented in very specific ways.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 39297

Received: 21/09/2021

Respondent: Mr Colin Murdoch

Representation Summary:

Study of social and cultural needs of the community and their provision

Full text:

Study of social and cultural needs of the community and their provision

Support

New Local Plan: Spatial Options Document 2021

Representation ID: 39316

Received: 21/09/2021

Respondent: Canewdon Parish Council

Representation Summary:

Technical evidence considered satisfactory

Full text:

Technical evidence considered satisfactory

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 39397

Received: 21/09/2021

Respondent: Mr oliver Bagnall

Representation Summary:

The local area is struggling with recent additional housing, on many levels and a thorough investigation into the local resources required for additional housing needs to be done ,but most importantly the natural areas in Stambridge and surrounding , the incredible biodiversity of the countryside and the essential efffect this large area of
Natural resource has on our local
Environment and the planet as a whole is a vital necessity in our current climate emergency.

Full text:

The local area is struggling with recent additional housing, on many levels and a thorough investigation into the local resources required for additional housing needs to be done ,but most importantly the natural areas in Stambridge and surrounding , the incredible biodiversity of the countryside and the essential efffect this large area of
Natural resource has on our local
Environment and the planet as a whole is a vital necessity in our current climate emergency.

Support

New Local Plan: Spatial Options Document 2021

Representation ID: 39463

Received: 22/09/2021

Respondent: Thurrock Borough Council

Representation Summary:

Thurrock Council notes the range of technical studies that have been prepared and those that are proposed to be updated as part of the evidence base for the New Rochford Local Plan.

Thurrock Council also supports the continued collaboration and involvement of Rochford Council in the preparation of other technical work being prepared or proposed to be commissioned by the ASELA authorities to support local plans and the South Essex Strategic Framework.

Full text:

Thurrock Council notes the range of technical studies that have been prepared and those that are proposed to be updated as part of the evidence base for the New Rochford Local Plan. Thurrock Council supports the proposals to provide updated evidence in particular the Economic Development and Needs Assessment (EDNA) and Strategic Housing Market Assessment (SHMA), the latter being produced in collaboration with the other local authorities in the Association of South Essex Local Authorities (ASELA).

Furthermore the range of evidence to be commissioned in the future to provide additional evidence for the Rochford New Local plan is also considered appropriate.

Thurrock Council also supports the continued collaboration and involvement of Rochford Council in the preparation of other technical work being prepared or proposed to be commissioned by the ASELA authorities to support local plans and the South Essex Strategic Framework. This additional evidence includes updates to retail evidence and role of town centres together with the possibility of commissioning a South Essex Strategic Green Belt Review. Rochford Council should consider how this future evidence work will inform the preparation of its New Local Plan.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 39472

Received: 22/09/2021

Respondent: Persimmon Homes Essex

Representation Summary:

Agree with the list of evidence based documents being prepared; some sections however appear vague and would require more detailed assessments to be prepared in order to fully understand and appreciate each topic.

The technical evidence that Rochford is preparing is comprehensive, though we would suggest the following additional evidence (which may be included within the evidence base documents listed) will also be required to inform the new Local Plan:

Heritage
An ‘initial Heritage Assessment’ is listed, which is vague, which is not sufficiently detailed or robust to properly consider the relationship of heritage assets and emerging site allocations. Persimmon Homes
is, in particular, concerned that it identifies site CFS087 as having a ‘moderate-adverse’ impact on the Grade II listed Weir Farmhouse, despite this asset being located some distance from site CFS087 and screened from view (as would have been evidence if Place Services had undertaken site visits) by existing mature vegetation and twentieth century housing developments. The heritage asset listed within Place Services report therefore has no relationship with our allocated site, and cannot be seen
from the site.
It is recommended therefore that the Council’s Heritage Evidence Base will need to be properly updated to include, at a minimum, some or all of the following:

 A Heritage Asset Review, to assess the significance of heritage assets and the contribution they make to their environment;
 Lists of Buildings of Local Architectural or Historic Interest;
 Conservation Area Character Appraisals Programme – noting that these were last reviewed in 2008 and therefore these need updating so that the Council have up to date evidence and therefore able to properly consider applications affecting these assets;
 Historic Environment Characterisation Studies; and
 Heritage Impact Assessments, and Archaeological Evaluation Reports, where relevant, on each allocated site. We would strongly recommend that these are prepared in accordance with each site developer and will need to involve site visits, rather than relying on a simple mapping
exercise.

Highways

An ‘initial Transport Assessment’ is listed as being provided, which is a vague description and does not specify the required level of detail to support the Plan. It is recommended that this will need to include, at a minimum, some or all of the following:

• Transport evidence for the new Local Plan;
• Transport evidence mitigation;
• Sustainable Modes of Travel Strategy;
• Cycling Action Plan/Local Walking and Cycling Infrastructure Plan/Cycling Delivery Plan;
• Transport modelling of key strategic routes/junctions – the Spatial Options Document goes on to highlight the congestion affecting the road network, and identifies the improvements already planned for the A127 and Fairglen Interchange; and
• Infrastructure Delivery Plan.

Housing

Alongside the HELAA and SHMA, we would recommend the following:

• Self-Build Custom Build Housebuilding Register;
• Housing Implementation Strategy;
• Settlement Capacity Studies;
• Brownfield Land Registers;
• Schedule of Brownfield Sites and Extant Permissions; and
• Housing Trajectories.

Full text:

Persimmon Homes is a FTSE 100 housebuilder with a national presence. In 2020 the Group delivered 13,575 new homes, down from 15,855 in 2019 (largely in part due to the impact from Covid-19 on operations), although the selling price increased by about seven per cent.
Persimmon Homes has a strong presence in Rochford, having an option to deliver site CFS087: Land between Western Road and Weir Farm Road Rayleigh, and are actively seeking additional sites in Rochford to deliver much needed housing and regeneration in the Borough. Persimmon Homes welcomes the opportunity to comment on the New Local Plan Spatial Options Consultation Paper 2021.

In the short term, Persimmon Homes is aware that Rochford’s existing Local Plan is now out of date, as per the tests of the NPPF. Ensuring that an adequate supply of housing is provided is a key policy requirement of the NPPF. The Rochford District Core Strategy, which was adopted in December 2011, fails to meet the requirements of the NPPF. Therefore, it is imperative that the draft Local Plan continue to be progressed to allow it to be adopted as soon as possible so that the District can continue to plan effectively to meet the District’s ongoing needs.

Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?

The technical evidence that Rochford is preparing is comprehensive, though we would suggest the following additional evidence (which may be included within the evidence base documents listed) will also be required to inform the new Local Plan:

Heritage

An ‘initial Heritage Assessment’ is listed, which is vague, which is not sufficiently detailed or robust to properly consider the relationship of heritage assets and emerging site allocations. Persimmon Homes is, in particular, concerned that it identifies site CFS087 as having a ‘moderate-adverse’ impact on the Grade II listed Weir Farmhouse, despite this asset being located some distance from site CFS087 and screened from view (as would have been evidence if Place Services had undertaken site visits) by existing mature vegetation and twentieth century housing developments. The heritage asset listed within Place Services report therefore has no relationship with our allocated site, and cannot be seen from the site.

It is recommended therefore that the Council’s Heritage Evidence Base will need to be properly updated to include, at a minimum, some or all of the following:

• A Heritage Asset Review, to assess the significance of heritage assets and the contribution they make to their environment;
• Lists of Buildings of Local Architectural or Historic Interest;
• Conservation Area Character Appraisals Programme – noting that these were last reviewed in 2008 and therefore these need updating so that the Council have up to date evidence and therefore able to properly consider applications affecting these assets;
• Historic Environment Characterisation Studies; and
• Heritage Impact Assessments, and Archaeological Evaluation Reports, where relevant, on each allocated site. We would strongly recommend that these are prepared in accordance with each site developer and will need to involve site visits, rather than relying on a simple mapping exercise.

Highways

An ‘initial Transport Assessment’ is listed as being provided, which is a vague description and does not specify the required level of detail to support the Plan. It is recommended that this will need to include, at a minimum, some or all of the following:

• Transport evidence for the new Local Plan;
• Transport evidence mitigation;
• Sustainable Modes of Travel Strategy;
• Cycling Action Plan/Local Walking and Cycling Infrastructure Plan/Cycling Delivery Plan;
• Transport modelling of key strategic routes/junctions – the Spatial Options Document goes on to highlight the congestion affecting the road network, and identifies the improvements already planned for the A127 and Fairglen Interchange; and
• Infrastructure Delivery Plan.

Housing

Alongside the HELAA and SHMA, we would recommend the following:

• Self-Build Custom Build Housebuilding Register;
• Housing Implementation Strategy;
• Settlement Capacity Studies;
• Brownfield Land Registers;
• Schedule of Brownfield Sites and Extant Permissions; and
• Housing Trajectories.

Q2. Do you agree with our draft vision for Rochford District? Is there anything missing from the vision that you feel needs to be included?

The draft vision at present appears to be too vague and lacks a real vision. It is clear that the two big challenges facing the country in the next 20-30 years are a lack of homes, particularly for both young and elderly, along with the impending threat of climate change and its attendant impacts. Therefore, both of these need to be reflected in the vision. Rochford should strive, in its local plan, to not only meet its housing supply but to plan beyond, as well as to meet the threat of climate change by encouraging
all developments to be ‘green’, to exceed climate change targets and to seek alternatives to the private car to transform how Rochford residents travel.
For example, the ‘Our Society’ vision needs to have a greater vision for the delivery of new housing and
supporting infrastructure. Rochford should welcome the challenge of building at least 360 homes per year, by choosing to focus on high quality developments and the attendant benefits of planning for the delivery of these homes.
Similarly, the ‘Our Environment’ vision does not refer to climate change, which is a missed opportunity, given the pressing need facing the Country in addressing Climate Change impacts and its repeated messages within the NPPF, particularly as detailed within Chapter 14, and at paragraph 153 which states that, “Plans should take a proactive approach to mitigating and adapting to climate change…”.
Alongside this, the Covid-19 pandemic has transformed how people work, with more people now choosing to work from home, more often. This needs to be reflected in the ‘Our Economy’ vision – can Rochford provide the employment hubs and flexible working conditions to meet the new ‘normal’ for example.

Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?

Persimmon Homes would agree that separate visions for each settlement would help guide decision making and notes, for example, the wide character as detailed within the settlement profiles from page 71 onwards of the Spatial Options paper. This confirms that Rochford ranges from Tier 1 Settlements such as Rayleigh with 34,000 residents, to isolated hamlets such as Paglesham and Stonebridge of only 250 residents. Clearly, the type and level of development is going to differ and a set of visions for each settlement would provide clarity to developers on the type, and level, of development that would be appropriate. Such vision statements could usefully be informed by the following:
 Historic Environment Characterisation Studies;
 Heritage Impact Assessments;
 Settlement Capacity Studies;
 Transport Studies and Strategies;
 Green Belt Studies;
 Strategic Land Availability Assessment;
 Flood Risk Assessments;
 Design and Development Briefs; and
 Masterplanning Studies

Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?

The Spatial Options Paper lists 23 Strategic Options and Persimmon Homes broadly agrees with these, though we would have the following observations to make:
 Strategic Objective 1 – Persimmon Homes understands the Council’s reasons for looking to prioritise previously developed land first. However, the Paper goes onto confirm at page 29 that previously developed land will not be able to meet the Council’s housing targets in full; therefore there is no justification in prioritising previously developed land first. In many cases, greenfield sites are able to be brought forward quicker than previously developed land, particularly in the case of previously developed land having existing uses that need to be relocated first, or contaminated land that requires remediation. Accordingly, this objective could be reworded as follows:
“To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs, through working with our neighbours in South Essex and encouraging the redevelopment of previously developed land alongside suitably located greenfield sites to ensure the plan requirements are met in full.”
 Strategic Objectives 4 and 5 – these objectives could usefully reference the change in remote working patterns and confirm that Rochford will promote the use of flexible working practices to meet the needs of the ‘new normal’ arising from Covid-19, as well as offering flexible work
spaces to meet the needs of the 21st Century Office;
 Strategic Objective 6 – we would disagree with the phrasing ‘highest attainable quality’ as this is vague and imprecise; design is, to a large degree, subjective (particularly moreso where Local Authorities lack design codes and guides to guide the design of built form). We would therefore recommend the following revised wording:
“To ensure that all new homes and commercial premises are built to a high quality design and sustainability standard with a good level of access to green space and the countryside.”
 Strategic Objective 13 – this objective could usefully highlight Governments’ requirement to direct development to Flood Zone 1 (i.e. areas at the lowest risk of flooding);
 Strategic Objective 23 – the sole objective relating to climate change could usefully reflect Governments’ Future Homes’ requirement (being introduced in 2025).

Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
Persimmon Homes would agree with the settlement hierarchy presented, which demonstrates that growth should be predominantly located at Rayleigh, Hockley and Rochford. As Rayleigh is the sole ‘Tier 1’ settlement, it is logical that as the Plan progresses, that Rayleigh takes a larger proportion of development than other settlements.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?

The NPPF makes it clear at para 61 that Local Planning Authorities should be looking to use the Standard Method to determine how many homes are required, stating, “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance…”.
Accordingly, it is confusing at Figure 15 that it includes a ‘current trajectory’ scenario of only 4,500 homes when this scenario will not deliver the Standard Method requirement of a minimum of 7,200 homes. The Council could, therefore, be clearer in this regard and confirm that this Scenario cannot be taken forward in isolation.
The Plan presents four options; Persimmon Homes would support a combination of Options 1 and 2.
Our comments of which are as follows:
 Strategic Option 1 – The Paper itself acknowledges that this Option will not be able to fully meet the Standard Method requirement, as well as acknowledging that it will not be able to deliver the brand new infrastructure that is required alongside new homes.
It is also identified within the Integrated Impact Assessment that the lower growth options will not deliver the required levels of growth, stating on page 25 that:
“The lower growth option will not meet the needs of all people in the district during the plan period. The medium and higher growth options will meet the needs of all people in the district and improve accessibility to housing, employment, training, health, and leisure opportunities.
The higher growth option is more likely to meet the needs of not only people in the district but beyond, as well and encourage the integration and interaction of cross-boundary communities through the delivery of large-scale developments. The medium and higher growth options are also considered for their overall potential to deliver a wider range of housing types, tenures and
sizes, particularly catering for the needs of groups with protected characteristics, such as specialist housing for the elderly and disabled.”
Furthermore, the Integrated Impact Assessment states that: “…smaller scale development proposals bring less opportunity for strategic infrastructure improvements, and may place increased pressure on local road networks.”
The Paper also identifies that said option to increase densities in urban areas are unlikely to be compatible with historic centres and local character, as confirmed within the Integrated Impact Assessment, which states:
“…it is recognised that the lower growth option will focus development in existing urban areas, with a higher potential in this respect to impact on historic centres.”
It also goes on to confirm
"Option 1 would not deliver sufficient housing to meet local needs over the Plan period, in this respect it is also likely to deliver less affordable housing and long-term negative effects can be anticipated.”
Again, we would request that the Council undertake updated Conservation Area Appraisals and Settlement Surveys so that the Council has the required evidence base to consider if increased densities, taller buildings etc. would be appropriate in the historic centres and urban areas, as this would help inform the actual number of dwellings available under this option.
We would also question that this Option uses sites that have retained site allocations from the 2011 Core Strategy, and would question why these sites have not been developed by now – are these sites developable and deliverable as per the tests of the NPPF. This is something that the District Council should review.
Accordingly, this option cannot be taken forward within the next stage of the Local Plan on its own, though it is acknowledged that some level of urban intensification on appropriate sites may be suitable to help meet the Standard Method.
 Strategic Option 2 – Option 2a proposes Urban Extensions focused in the main towns; as Rayleigh is the Districts sole Tier 1 settlement, it is logical and sensible that urban extensions should be focused in Rayleigh. Furthermore, it benefits from not being restricted by any flood zones, being sequentially preferable to many other settlements in the District.
The Spatial Options document identifies that this option would be able to deliver new infrastructure; meet local housing needs; and deliver quickly; all of which Persimmon Homes endorses.
This Option would also deliver the required level of growth required for employment needs, as confirmed within the Integrated Impact Assessment:
“The medium and higher growth options are more likely to have a significant positive effect on this IIA theme through the delivery of new employment land and retail floorspace. These options are also likely to deliver more new infrastructure upgrades and sustainable transport routes to attract further inward investment. Further to this, the higher growth options could contribute to the delivery of sub-regional improvements to green and blue infrastructure, which could have a positive effect on the tourism economy. Whilst positive effects are considered likely under all options, the lower growth option is considered less likely to lead to positive effects of
significance.”
It goes on to state:
“Urban extensions under Options 2a and 2b provide large scale development opportunities that can deliver new infrastructure provisions to support both existing (particularly those in edge of settlement locations) and future residents.”

It concludes:
“Significant positive effects are considered likely under Options 2a, 2b and 4.”
The delivery of sites under the medium and higher levels of growth would also allow for the delivery of climate change measures that are required and discussed later in the Spatial Options Document. The delivery of these measures may not be possible through reusing
existing buildings (Strategic Option 1) as confirmed within the Integrated Impact Assessment:
“…the delivery of large-scale growth that is more likely to come forward under the medium and high growth options present more opportunities for the delivery of low carbon infrastructure through economies of scale compared to the lower growth option.”
On the same theme, the medium and higher levels of growth options are much more likely to be able to deliver the biodiversity and green infrastructure improvements and contributions required, than on existing brownfield sites, as also confirmed within the Integrated Impact
Assessment:
“The medium and higher growth options are also noted for their potential to support the delivery of strategic green infrastructure provisions and associated biodiversity net gain. This includes improvements being explored in the green infrastructure network across the sub-region through the South Essex Green and Blue Infrastructure Study (2020), such as the Regional Parkland.
The Regional Parkland has the potential to act as alternative greenspace targeted at reducing recreational pressures at designated biodiversity sites. These options thus provide a greater contribution to the principles of the Essex Coast Recreational disturbance Avoidance &
Mitigation Strategy (RAMS).
The lower level of growth will mainly result in the delivery of new homes on urban and brownfield sites so has greater potential to avoid designated sites and support urban greening to some extent. The urban focus however is less likely to bring forward strategic mitigation, such as the Regional Parkland to mitigate the recreational pressures on designated biodiversity resulting from a growing population. As a result, the medium and higher growth options are considered more likely to perform better overall in relation to this IIA theme; however, the potential for a significant effect is uncertain as will be dependent on the location of growth.”
It continues:
“…the potential for larger-scale development under Options 2a and 2b is recognised for the potential for greater net gains in biodiversity.”
The site that Persimmon Homes is promoting – site CFS087 – would be capable of being delivered under this Option.
 Strategic Option 3 – The Spatial Options document identifies a number of significant ‘Cons’ which would impact upon the delivery of this option (and thus threaten the delivery of the plan as a whole), all of which we would agree with and would therefore recommend that this option is not progresses as:
o The plan identifies that this option involves complex land ownership issues which is likely to be difficult to resolve and address;
o Significant redrawing of the Green Belt boundaries, including proposing development in more sensitive Green Belt locations than other strategic options;
o Focussing development in a single location/settlement would deprive other settlements of being able to accommodate development, and thus potential infrastructure improvements.
On Environmental impacts, the Integrated Impact Assessment identifies that harm that this option would have on Environmental Quality, stating that:
“…extensive countryside development proposed through the concentrated growth options (Options 3a, 3b and 3c); which is considered highly likely to lead to negative effects of significance in this respect. Options 3a and 3b are also likely to intersect the flood plains of the Crouch and Roach tributaries, and development will need to ensure appropriate mitigation to avoid impacts on water quality…Negative effects of significance are considered more likely under Options 3a, 3b, 3c and 4 given the extent of concentrated growth development locations
in the countryside.”
 Strategic Option 4 – This option proposes a ‘balanced combination’ of all three; we would recommend a balanced combination of Options 1 and 2 represents the most suitable Spatial Strategy going forwards for the reasons given above and indeed as detailed within the Spatial Options document, and the Integrated Impact Assessment, which concludes:
“Option 4 is noted for its potential to perform better against a wider range of the IIA themes than the remaining options. This predominantly relates to the flexibility provided in a tailored approach, essentially combining the best performing aspects of each individual approach (urban intensification, urban extensions and concentrated growth).”

Q7. Are there any reasonable alternatives to these options that should be considered instead?

Southend are currently consulting on its ‘Local Plan - Refining the Plan Options’, with the Consultation running through until 26 October 2021. The NPPF is clear that Local Authorities should also plan to meet housing needs that cannot be met within neighbouring authority areas (para.61), stating that, “In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for”.
In this regard, it is noted that within their Plan proposes a ‘Development Opportunity D’ of c.10,000 homes, of which 4,900 homes lies within Rochford.
It is imperative, therefore, that Rochford works alongside Southend to understand if it needs to plan for these 4,900 new homes alongside its own minimum of 7,200 homes, which would need to be reflected within the next stage of the Rochford District Local Plan.

Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis?

Persimmon Homes would request that further spatial themes topic papers are required, or updated, for:
 Place Making and Urban Design – further questions within the Spatial Options paper deal with design (Q14 – Q16), but as yet a corresponding topic paper has not been published to consider this issue. The NPPF places an increasingly strong emphasis on design, with the recent 2021 revision further emphasising the Governments’ commitment to building ‘beautiful’ homes and places, to be underpinned by Design Codes and guidance. Understanding how Rochford District Council intends to interpret this requirement will be key for Developers as the plan progresses and beyond.
 Flood Risk and Drainage – Briefly discussed within the Climate Change topic paper, but this issue needs to be sufficiently evidenced as the plan progresses.
 Landscape and Visual Impacts – As above.
 Heritage – The Heritage Topic Paper confirms that existing Conservation Area Appraisals date back to 2007 (if they exist at all) and that these, along with the ‘Local List’ may be updated as the Local Plan progresses. Persimmon Homes would strongly support this evidence being undertaken as understanding heritage impacts is often key, which cannot be understood without up to date evidence.
 Duty to Co-Operate and Strategy Options – As identified at Q7, these topic papers do not address the potential for Rochford needing to meet Southend’s housing needs, as is currently presented as a potential option within their new Local Plan ‘Refining the Plan Options’ consultation.

Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

Persimmon Homes strongly recommends that Rochford take the sequential approach to Flood Risk as required by paragraphs 161-162, confirming that new development should be directed to areas with the
lowest risk of flooding from any source.
The flood map at Climate Change and Resilient Environments Topic Paper identifies that the four
settlements least impacted by Flood Zones are Rayleigh, Hullbridge, Hockley and Ashingdon, and therefore these settlements are sequentially preferable for residential development to meet the Local Plan needs than those settlements that lie within Flood Zones 2 or 3 (such as Great Wakering).
We would also take this opportunity to identify to the Council that the site that Persimmon Homes is
promoting (Site CFS087: Land between Western Road and Weir Farm Road, Rayleigh) lies within Flood Zone 1 and is therefore sequentially more preferable than those sites being promoted that lie within Flood Zones 2 and 3.

Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply lowcarbon or renewable energy?

Climate change is a principal risk for Persimmon Homes and a significant issue, with more extreme weather events such as heatwaves, rising sea levels and flooding being experienced and resulting in impacts of both global and local significance. Society is more environmentally conscious with the international community and Government taking a leading role to reduce greenhouse gas emissions by setting and legislating ambitious targets for all to achieve.
As one of the UK’s leading house builders we acknowledge our role in supporting these common aims.
We understand the risks and challenges that climate change presents to our business and the wider industry. We are proactively working with all stakeholders to more effectively integrate climate change issues within our operations and ensure that sustainable improvements are managed in a pragmatic and robust manner.
We recognise that we have a key role to play in minimising our contribution to climate change, through
our own operations, our supply chain and by striving to ensure that the homes and communities we build are sustainable, inherently energy efficient and encourage our customers to live in a way that minimises any impact to climate change. We are committed to working alongside all stakeholders to achieve this.
Working with the Carbon Trust, a global climate change and sustainability consultancy providing specialist support to assist businesses to reduce their greenhouse gas emissions, Persimmon has set ambitious targets to be net zero carbon in our homes in use by 2030 and in our operations by 2040.These targets are supported by interim science based carbon reduction targets to reduce greenhouse gas emissions from our own operations by 46.2% (2019 baseline) and our indirect operations (i.e. those from our homes in use and our supply chain) by at least 22% per m2 completed floor area by 2030 (2019 baseline).
Referring back to the Spatial Strategy Options, the delivery of sites under the medium and higher levels
(Strategy Options 2 & 3) of growth would allow for the delivery of climate change measures that are required. The delivery of these measures may not be possible through reusing existing buildings (Strategic Option 1) as confirmed within the Integrated Impact Assessment:
“…the delivery of large-scale growth that is more likely to come forward under the medium and high growth options present more opportunities for the delivery of low carbon infrastructure through economies of scale compared to the lower growth option.”

Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?

Persimmon Homes would support new homes being built to meet the new Future Homes Standard (being introduced from 2025), which proposes an ambitious uplift in the energy efficiency of new homes through changes to Part L (Conservation of fuel and power) of the Building Regulations. This will ensure that new homes produce 75-80% less carbon emissions than homes delivered under current regulations.

Q14. Do you consider that the plan should include a place-making charter that informs relevant policies?
Should the same principles apply everywhere in the District, or should different principles apply to different areas?

As the Spatial Options document identifies, Rayleigh is diverse area with a mix of character and vernacular. Accordingly, a ‘Place-Making Charter’ would be welcomed as an overarching theme to guide all new development in the area during the plan period. Persimmon Homes welcomes the Government’s increasingly strong emphasis on design and place making, noting and agreeing with the Government’s statement at paragraph 126 of the NPPF that, “high quality, beautiful and sustainable buildings and places is fundamental to what the planning and development process should achieve.”
Accordingly, the more guidance on this that Rochford can produce (noting that design is often, subjective and without suitable guidance, decisions can be delayed), would only assist developers in understanding the Council’s aspirations in this regard. This would be supported by paragraph 126 of the NPPF, which states that, “being clear about design expectations, and how these will be tested, is essential for achieving this.”
It would also assist decision making in local residents and members are involving in the creation of
place-making charters and other design guidance; to ensure that design is properly considered by members and local residents at an early stage in the process and to ensure their views on design and place making are heard early; rather than such views being made during the application process (such as at Committee) which will delay decision making.
This would also identify if the same principles should apply throughout the District, or if certain settlements have specific principles and design, requirements that only apply to their settlement for example. Such an approach would be supported by paragraph 127 of the NPPF (“Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics.”)
As above, the more guidance that can be produced, and the more involvement and agreement with local residents/members, can only guide and aid the decision making process.
Of the principles identified within Spatial Options paper, the majority of these would apply everywhere in the District, albeit on some sites certain principles may not apply (impacts on the historic environment for example).
On Design Codes, the NPPF confirms at paragraph 128 that, “all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences. Design guides and codes provide a local framework for creating beautiful and distinctive places with a consistent and high quality standard of design. Their geographic coverage, level of detail and degree of prescription should be tailored to the circumstances and scale of change in each place, and should allow a suitable degree of variety.” Persimmon Homes would support Rochford District Council in the preparation of
Design Codes in the District.

Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?

Persimmon Homes would broadly support the draft Place-Making Principles, as they would provide a
broad framework for future Design guidance and policy produced by the Local Authority. We note however that there is not a principle relating to Biodiversity; given the Government’s commitment to ensure that development pursue opportunity for net gains to Biodiversity, it may be appropriate to reflect this within the place-making charter.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?

Persimmon would welcome the use of design guides, codes or masterplans, which would be supported by the NPPF:
“Being clear about design expectations, and how these will be tested, is essential…” (para. 126)
“Plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable.” (para. 127)
“To provide maximum clarity about design expectations at an early stage, all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences.” (para.128)

Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?

Persimmon Homes would refer to paragraph 129 of the NPPF:
“Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale, and to carry weight in decision-making should be produced either as part of a plan or as supplementary planning documents. Landowners and developers may contribute to these exercises, but may also choose to prepare design codes in support of a planning application for sites they wish to develop.
Whoever prepares them, all guides and codes should be based on effective community engagement and reflect local aspirations for the development of their area, taking into account the guidance contained in the National Design Guide and the National Model Design Code. These national documents should be used to guide decisions on applications in the absence of locally produced design guides or design codes.”
However, given the variety of settlements and styles within Rochford, we would suggest that separate
Design Codes be created for each settlement.

Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?

The National Model Design Code, published July 2021, confirms that the preparation of a Local Design Code should follow seven steps:
1. Analysis.
1A - Scoping: Agreeing on the geographical area to be covered by the code and the policy areas that it will address.
1B – Baseline: Bringing together the analysis that will underpin the code and inform its contents.
2. Vision.
2A – Design Vision: Dividing the area covered by the code into a set of typical ‘area types’ and deciding on a vision for each of these area types.
2B – Coding Plan: Preparing a plan that maps out each of the area types and also identifies large development sites from allocations in the local plan.
2C – Masterplanning: On larger sites working with land owners and developers to agree a masterplan for each of the development sites establishing the key parameters and area types.
3. Code.
3A – Guidance for Area Types: Developing guidance for each area type by adjusting a set of design parameters.
3B – Code Wide Guidance: Agree on a set of policies that will apply equally across all area types.
We would advise the District Council to use the Model Design Guide as the basis for the production of
all Design Codes in the District.

Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing?

Of the options listed, Persimmon Homes would support:
 Option 2 – requiring a suitable or negotiable mix of housing that is response to the type or location of development;
 Option 5 – all homes to meet NDSS;
 Option 6 – all homes to meet M4(2); and
 Option 7 – a proportion of homes to meet M4 (3).
Option 1 listed proposes a non-negotiable mix to be provided on all housing developments. Clearly, this
option is unworkable in practice as certain sites are unable to deliver certain types of housing. For example, Brownfield sites in the urban areas are unlikely to be able to deliver suitable proportions of larger dwellings; likewise, heritage constraints in certain areas may influence the size of dwellings that a site could deliver to satisfy historic environment consultees. It is therefore more appropriate to require housing mix to be agreed during pre-application discussions, having regard to site and location characteristics, with the latest SHMA evidence used as a broad guide to inform those pre-application discussions.

Similarly, option 3, which proposes to allocation specific sites for certain types of housing, such as affordable homes, would have the potential to result in ‘ghettos’ and not created mixed inclusive communities (as required by paragraph 92 and 130 of the NPPF; good place-making would be achieved by requiring all developments to deliver policy compliant levels of affordable or specialist housing (subject to viability etc.) and to ensure that housing is of the same build quality/appearance as the
market housing.

Q31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?

Guidance confirms that net gains should normally be delivered on site. However, where achieving biodiversity net gain is not possible on site whilst still delivering a viable project; developers have the option to contribute at a local or regional scale to off-site Offsetting or Compensation. This approach can often successfully result in greater gains for biodiversity than could be provided within a constrained development site. It supports delivery of Local Nature Recovery Strategies and is consistent with the central conclusion of the 2010 report ‘Making space for nature’, that we need more, bigger, better and joined up habitats.
Referring back to the Spatial Strategy Options, the medium and higher levels of growth options are much more likely to be able to deliver the biodiversity and green infrastructure improvements and contributions required, than on existing brownfield sites, as confirmed within the Integrated Impact Assessment:
“The medium and higher growth options are also noted for their potential to support the delivery of strategic green infrastructure provisions and associated biodiversity net gain. This includes improvements being explored in the green infrastructure network across the sub-region through the South Essex Green and Blue Infrastructure Study (2020), such as the Regional Parkland. The Regional Parkland has the potential to act as alternative greenspace targeted at reducing recreational pressures at designated biodiversity sites. These options thus provide a greater contribution to the principles of the Essex Coast Recreational disturbance Avoidance & Mitigation Strategy (RAMS).
The lower level of growth will mainly result in the delivery of new homes on urban and brownfield sites so has greater potential to avoid designated sites and support urban greening to some extent. The urban focus however is less likely to bring forward strategic mitigation, such as the Regional Parkland to mitigate the recreational pressures on designated biodiversity resulting from a growing population.
As a result, the medium and higher growth options are considered more likely to perform better overall in relation to this IIA theme; however, the potential for a significant effect is uncertain as will be dependent on the location of growth.”
It continues:
“…the potential for larger-scale development under Options 2a and 2b is recognised for the potential
for greater net gains in biodiversity.”

Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?

Persimmon Homes would support a combination of option 1 and 3 listed on page 55 of the Spatial Options document to address green and blue infrastructure through the Local Plan:
 Option 1 – Allocating specific areas of land for strategic infrastructure appears a sensible and logical strategic objective to deliver tangible green and blue infrastructure through the course of the Local Plan. Strategic policies to the enhancement and protection of these areas would
be required to provide a policy framework for these specific areas (the coastal path project and South Essex Estuary Park for example), and contributions towards funding these projects could be secured, where required/relevant etc., through S106 contributions or CIL;
 Option 3 – Development sites of a certain scale (particularly edge of settlement, greenfield sites) are typically capable of being able to deliver on-site green and blue infrastructure; of providing connections to green and blue infrastructure through their site; or of securing financial contributions to improving green and blue infrastructure in the local area. With reference to our
site at Western Road, Rayleigh, the site benefits from an existing public right of way running through the centre of the site, and informal footpaths running along the southern boundary along the woodland edge. These informal paths have to be managed yearly in order to maintain these paths for the use of existing residents; without this regular maintenance these footpaths
would not be usable. The development of the site therefore look to retain these links and provide permanent, sustainable connections and to enhance these where possible, providing improved footpaths and links to the surrounding area, including to Kingley Woods to the west of the site. Access to the wider countryside can also be promoted through the development as
existing footpaths can be improved and maintained. There is scope to enhance the Green Infrastructure Network in the locality by providing more formalised and accessible links through the green spaces.

Q35. With reference to the options above, or your own options, how can we address the need for sufficient and accessible community infrastructure through the plan?

With reference to the four options, we would comment as follows:
 Option 1 – support the protection of existing school and healthcare facilities through specific allocations.
 Option two – support the allocation of specific sites for the creation of new community infrastructure (providing that site is being allocated for that use or would not conflict with other site promotions).
 Option 3 – Broadly support requiring new developments to deliver new community infrastructure on site, though would caution that this would only apply to sites of a certain scale.
For example, the Essex County Council Developers’ Guide to Infrastructure Contributions highlights that developments with an individual or cumulative size of 1,400 homes are likely to be required to deliver a new two-form entry primary school, whilst developments with an individual or cumulative size of 4,500 homes or more will need to provide a new two-form entry secondary school. It would be simpler for the LPA to identify new sites for community infrastructure (new schools/extensions to existing schools, new surgeries/extension to existing surgeries etc.), and require developments to contribute towards those new facilities (with reference to para.34 of the NPPF requiring that Local Plans should clarify the level of contributions expected from new developments).
With reference to the Spatial Strategy Options, the Integrated Impact Assessment states:
“The medium and higher growth options are more likely to have a significant positive effect on this IIA theme through the delivery of new employment land and retail floorspace. These options are also likely to deliver more new infrastructure upgrades and sustainable transport routes to attract further inward investment. Further to this, the higher growth options could contribute to the delivery of sub-regional improvements to green and blue infrastructure, which could have a positive effect on the tourism economy. Whilst positive effects are considered likely under all options, the lower growth option is
considered less likely to lead to positive effects of significance.
We would also question whether the Council intends to progress with a Community Infrastructure Levy, to fund the development of new infrastructure in Rochford, as no reference is currently found on the Council’s website (and no reference is made to CiL within the Spatial Options Document). CIL is seen by many as creating a more transparent contributions system, whereby developer contributions can be calculated upfront (which assists developers with viability calculations, as well providing clarity to local residents/interests groups on the level of funding provided by new development and where that funding is directed towards).
Persimmon Homes would support Rochford District Council in the development of a Community Infrastructure Levy.

Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan?

Persimmon Homes would request that the Conservation Area Appraisals be updated as part of the emerging Local Plan process; these were last produced in 2007 so by the time the plan is adopted, these will be over 15 years old. The Local Authority are aware that settlements and areas change over time, and as such, it would assist greatly for these documents to be regularly reviewed.
Persimmon Homes are also concerned that our site at Western Road, Rayleigh (ref. CFS087) is marked poorly in the accompanying Site Appraisal Paper due to impacts on Built Heritage. This appears to have been assessed purely on the basis that there is a listed building – the Grade II listed Weir Farmhouse (List UID: 1322351) – but that this assessment has seemed to be have been undertaken purely as a mapping exercise and without any consideration to the sites relationship to this asset on the ground. The listed building is located a considerable distance from our site, and is screened from view not only by existing twentieth century development but also by considerable mature trees (which would be retained as part of any development proposals); therefore development of our site (ref. CFS087) would have no impacts on the setting of this listed building, as is fully confirmed within the Heritage Statement that accompanies these representations.
With reference to the Spatial Strategy Options, the Spatial Options Paper identifies that said option to
increase densities in urban areas are unlikely to be compatible with historic centres and local character,
as confirmed within the Integrated Impact Assessment, which states:
“…it is recognised that the lower growth option will focus development in existing urban areas, with a higher potential in this respect to impact on historic centres.”
We would therefore recommend that all assessments of built heritage impacts be fully assessed by up to date evidence, noting that the Council’s Conservation Area Appraisals haven’t been updated since 2007 and therefore may not accurately reflect existing site conditions.

Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
Persimmon Homes would support the four options listed to address transport and connectivity through the plan.

Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [walking, cycling, rail, bus, road etc.]

With reference to, our site at Western Road, Rayleigh (ref. CFS087), and the site is within a very sustainable location being walking distance to local amenities including schools (0.6 miles) and a train station (1.1 miles). A main bus route also runs in very close proximity to the site. The wider main road network is also easily accessible.
The development will provide betterment to existing footpaths, creating enhanced foot and cycle links to services and employment areas for new and existing residents. The existing PROW could be upgraded into a cycle link and a formal path that can connect to an east/west foot/cycle link that runs from Western Road to Weir Farm Road. This will allow a good connection to High Road and therefore services/employment/further transport networks. As previously stated, existing footpaths running through the site are informal and could be upgraded as part of the redevelopment proposals for the site to provide permanent, sustainable connections for existing and new residents.
Access to the wider countryside can also be promoted through the development as existing footpaths can be improved and maintained.

Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
Persimmon Homes agrees with the vision for Rayleigh. As the District’s only Tier 1 settlement, it is correct that it should take large proportion of the District’s Plan Requirements during the Plan Period.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other

Persimmon Homes is promoting site CFS087 for residential development. This 10-acre site is located
north of the A127 by Rayleigh Weir. The site is contained between the current residential area defined by the southernmost extent of Western Road and Eastern Road with the A127.
The majority of the site comprises rough grassland, which has no beneficial use. There is a Public Right
of Way (No25) running south from Eastern Road. The development offers the opportunity to formalise footpath links from Western Road. It would also offer the opportunity to create recreational routes through to Weir Farm Road. The allocation has the potential to enhance the Green Infrastructure Network in the local area.
The site benefits from being closely related to the existing built up area of Rayleigh, its town centre, train station, bus routes and key services. The Vision is that the site will add to the growth of Rayleigh, providing homes in a sustainable location close to existing services, transport links and accessible green space.
The site is located immediately south of the Main Settlement of Rayleigh and north of the A127.
Rayleigh Town Centre is within a 10-minute walking distance and the Train Station, with a direct link into London, is only 1.1 miles walking distance. A main bus route linking the town centre/train station, Southend, Basildon and Canvey Island runs through High Road. This is in close proximity of the site. The site has good access to the wider main road network.
The site is within walking distance to the nearest Primary and Secondary School (0.6 miles and 1.1 miles respectively).
The development of the site would provide beneficial enhancements to the public open space provisions
and improved walking/cycling links across the site to encourage new and existing residents to use
sustainable modes of transport.
The site does not serve the five purposes of Green Belt (as confirmed within the Council’s evidence base) and would benefit from housing development to allow for improved biodiversity creation and management. Development of the site would also provide an enhanced settlement boundary to the A127 and provide an improved setting for Ancient Woodland and Local Wildlife Site.
Development of the site will allow for delivery of required housing in a sustainable location.
Persimmon Homes are currently preparing an updated Promotional Document to support the allocation of the site for residential development, which will be submitted shortly.

Conclusion
The adoption of the new Local Plan (2023) remains, optimistically, 2 years away. The Council does not
have a published strategy for bolstering housing land supply in the period up to the adoption of the new Local Plan. The Council need to identify a strategy to boost significantly the supply of housing in the period up to the adoption of the development plan, such measures should include the early identification of suitable new sites and seeking to pro-actively work with landowners and developers to bring such sites forward.
The Council must ensure that a new development plan is taken forward without further delay. The continued lack of an up to date development plan is significantly hampering delivery and the regeneration imperative.
Persimmon Homes have an interest in site CFS087: Land between Western Road and Weir Farm Road
Rayleigh, which the Site Appraisal Paper confirms suitable, deliverable and available for residential
development, and are actively seeking additional sites in Rochford to deliver much needed housing and
regeneration in the Borough. Further details of this site, along with plans, are submitted as part of this submission to support its allocation within the Local Plan for development.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 39473

Received: 22/09/2021

Respondent: Mr Danny McCarthy

Representation Summary:

Consideration of climate and human impact needs to be considered.
This applies to rain, breaches of coastal defences, the provision of flood plains, climate warming, increase in sea levels and flooding.
Additionally, evidence on how the traffic polution is affecting young children especially where there are schools on busy roads and set against where the policy is to reduce traffic going past schools

Full text:

The plans as envisaged both seem to break Equality laws and basic rights.
There is emphasis in national and county on air quality, the impact on children's health and the provision of education making reductions in traffic past schools and increase air quality is a priority in areas outside RDC. Yet in RDC this is not considered. If it is a human right in areas other than RDC to attend a school with good air quality then those in RDc are facing lietime health problems, disability and poor education through living in the wrong district.
Air quality data from road traffic, consideration of road usage and alternative routes need to be sought especially on with the Ashingdon road schools.
Further evidence needs to be sought oneducation provision and arrangements for schools.
Further data is needed on the flood plains and potential breaches of the coastal defences.