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?

Updated assessments to include EDNA, Heritage, Transport and SHMA.
Parks and Green Spaces Assessment.

Updated assessments to include EDNA, Heritage, Transport and SHMA.
Parks and Green Spaces Assessment.

the business growth consultation be re done after covid as needs have changed

There is a major flaw in all of these plans in that the basic principal of the Governement being the agency to represent the will of the people has basically been inverted and ignored - Rochford is an unusual District Council/Historic Hundred in that over 50% of the land mass is unsuitable for any kind of heavy building and or housing and is a place that you have to want to visit as it isnt on the road to anywhere (as evidenced by the fact that the District has no major roads or infrastructure (Hospitals, Theatres, Major Sporting Venues). The whole input of this plan is being imposed by government targets rather than the economics of the area.

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?
I would expect to see reference to:
• The Infrastructure Delivery and Funding Plan
• Level 2 Strategic Flood Risk Assessment
• Local Cycling and Walking Infrastructure Plan
These plans are needed to assess the long-term sustainability of any proposed sites. Without these I find it difficult to make any comments.
Evaluation of the impact of current development on Hullbridge
I cannot comment on the suitability of the sites in the plan without the Infrastructure Delivery and Funding Plan which I have been told is being undertaken at present. In my opinion it is premature to consult without these.
I would expect it to see reference to
i) the main Roads and the principal junctions and exit points to Hullbridge on Lower Road, Watery Lane and Hullbridge Road as well as the junction with Rawreth Lane.
ii) Consultation with the schools in Hullbridge, Hockley and Rayleigh to accurately asses capacity, too often there are no places in specific school.
iii) Consultation with Doctors and Pharmacies as well the local Healthcare Trust, currently the Riverside Medical Centre are not moving forward with expansion proposals due to high costs.
iv) Air Quality Management - too many parts of the District have poor CO2/CO readings
Any such Plan would need agreement with Rochford District Council, Essex County Council, and Southend Borough Council as they are all affected.
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? [Please state reasoning]
Mostly. Although you have not included enough information on how you might achieve housing for the hidden homeless (sofa surfers) or those on low incomes, schemes to allow the elderly in large houses to be able to downsize or how you plan to provide suitable commercial units of varying sizes, to allow businesses to up or downsize into a suitably sized premises without them needing to relocate into another area. No provision for emergency housing.
Q3.
Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making? [Please state reasoning]
Yes, as each settlement has its own characteristics and needs.
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? [Please state reasoning]
No comments.
Q5.
Do you agree with the settlement hierarchy presented? If not, what changes do you think are required? [Please state reasoning]
Broadly yes. But it is important that the hierarchy is not changed through developments and cross boundary development must be carefully planned.
Q6.
Which of the identified strategy options do you consider should be taken forward in the Plan? [Please state reasoning]
Creating a new town would enable all the infrastructure to be put in place, allowing more scope for cycling routes and pedestrianised areas. This will stop the urban sprawl which is currently happening in the larger town (and proposed in option 1), creating traffic havoc and pollution. A single large urban development, possibly shared with Wickford could allow a more environmentally friendly development. A development that allows the infrastructure to be developed in advance of the housing.
Q7.
Are there any reasonable alternatives to these options that should be considered instead? [Please state reasoning]
Small development and windfall developments should be included in housing count.
Q8.
Are there any key spatial themes that you feel we have missed or that require greater emphasis? [Please state reasoning]
Yes: Cultural and Accessibility.
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? [Please state reasoning]
Yes. You must ensure the district has a suitable plan to protect not only the towns and village communities, houses, and businesses but also natural areas as well. The district needs good defences to limit flooding in all areas, protecting people and wildlife. Maybe these could be incorporated in the “natural” landscape theming. New developments not only need to address their carbon footprint but also the design of the housing they build so that they limit flood damage; raised floors, bunded gardens etc. All building should be carbon neutral.
Q10.
Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character? [Please state reasoning]
Yes. All coastal areas and areas of special interest, especially where there is a risk of flooding and harm to the environment need careful consideration.
The Ancient woodlands such as Kingley Woods, Hockley Woods and Rayleigh Grove Woods and all natural parks, not just the actual woodlands but also the surrounding areas and the proposed Regional Park to the West of Hullbridge.
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 low-carbon or renewable energy?
Yes.
New developments should be able to produce all energy requirements from zero carbon sources.
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? [Please state reasoning].
Yes. The World is suffering a climate crisis, without higher standards we will not be able to reduce carbon sufficiently to avoid the crisis.
Q13.
How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported? [Please state reasoning]
Solar and heat pumps in all new development as standard.
Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs; there are many flat roofed buildings all over the district that could accommodate solar panels without damaging the landscape. Explore tidal energy and seek out suitable locations in order to ascertain whether it is viable. Retrofitting existing housing and commercial buildings.
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? [Please state reasoning]
The district has some very distinct areas and a “one shoe fits all” would be detrimental to some smaller communities. The place-making charter should be bespoke, with each area being considered in its own right. The rules on building should be strict so as to enhance the areas of development and needs to consider the wider picture in respect of amenities, open spaces, retail, schools, services, pollution, character and accessibility (to name but a few). There should not be deviation of plans unless there are exceptional circumstances. Time and again, SPD2 documents are ignored and ugly extensions and dormers are built to the detriment of the area.
Q15.
Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included? [Please state reasoning]
Yes, but they must be kept to.
Q16.
a.
Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
Yes.
b.
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? [Please state reasoning]
You need different design guides as this district is both unique and diverse and the “one shoe fits all" would be detrimental to its character and charm.
c.
What do you think should be included in design guides/codes/masterplans at the scale you are suggesting? [Please state reasoning].
You need to ensure that the character and heritage of the settlements are adhered to whilst allowing for some growth, in order to rejuvenate the smaller settlements if needed.
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? [Please state reasoning]
By working closely with planners and developers, as well as different charities and communities, residents and businesses. You will then get a better understanding as to what you need and what will be achievable.
Q18.
With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas? [Please state reasoning]
The district has a large number of houses, existing and approved that have four or five bedrooms. The number of homes available with two or three bedrooms is small, which increases their price and availability. The smaller properties are the ones that need to be affordable for families. You must ensure that the “affordable“ properties are not all flats and that minimum or higher standards are met for gardens and recreational space. There are sure to be single, elderly residents that would like to downsize from their large family homes, into a smaller, more manageable one but do not wish to go into an assisted living, residential or retirement homes. They may want a one or two bedroomed property, maybe one storey, or low-rise apartment that they own freehold.
We should safeguard the number of smaller bungalows available and make sure that the existing stock is preserved and a suitable number are provided in the housing mix. You need to consider that some residents may need residential care and you should be looking at ways to cope with the rising number of elderly and provide accommodation for them also.
Consideration should be given to the provision of house for life, bungalows and other potential buildings for downsizing families .
The plan makes no reference to social housing quotas.
The district desperately needs to meet the needs of the hidden homeless. People like the adult children on low wages who have no hope of starting a life of their own away from their parents. By living in these conditions, even if the family unit is tight and loving, it will cause mental health issues, stress and anxiety. You also need accessible properties for the disabled members of our community, where they are assisted in order to fulfil a normal as possible life. All these issues, and perhaps many more, need be addressed.
Q19.
Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing? [Please state reasoning]
Housing for the hidden homeless – those “sofa surfing”, or adult children living at home with parents as they are on low wages or wages that would not allow them to move out to rent or buy somewhere on their own. Adapted homes for the disabled. Smaller, freehold properties for the older generation to enable them to downsize from large family homes. Emergency housing.
Q20.
With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller accommodation needs? [Please state reasoning]
You need to find a permanent site that has a little room to expand but not exponentially. The “Traveller” life has changed over the years and you should revisit the criteria for the traveller community to meet the legal requirements. Strong controls are needed to prevent illegal building work and to ensure the site populations do not exceed capacity.
Q21.
With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs? [Please state reasoning]
See answer to Q20
Q22.
What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites? [Please state reasoning]
See answer to Q20.
Q23.
With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan? [Please state reasoning]
The council should stop developing existing commercial land into housing. Too many sites have already been lost and many more are planned to go. Consider how the plan can help those businesses wanting to expand. Work with local schools and colleges, as well as businesses and the job centre, to see what sustainable employment is needed in the district. Incorporate ways to assist in schemes to train all ages get back into work or upskill. Developers should be encouraged to use local labour.
Q24.
With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the Green Belt? [Please state reasoning]
No. The current employment site allocations on Figure 30 do not provide enough space to meet the district’s employment needs through to 2040. There are eighty-seven thousand people in the district. There is no data on the form to suggest how many of these are in employment and how many are looking for work but the council need to reassess its future needs in order to future-proof our residents’ opportunities. The plan should only formally protect sites the that have a future and a potential to expand or continue effectively.
Q25.
With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?
Option 3 could deliver new opportunities for employment as it would be a new site completely. Industrial units of various sizes, with room for expansion plus retail, hospitality and other employment could be included in the criteria for the development.
Q26.
Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?
Environmental services - woodland conservation and management. Improve manufacturing base and revisit the JAAP to make the airport Business Park a technological park.
Q27.
Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g., skills or connectivity?
Other forms of sustainable transport (Tram), gigabit broadband and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training. No new roads.
Q28.
With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system? [Please state reasoning]
The airport brings little to the economy, It could be better used as an expanded technological park or for housing.
Q29.
Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
Yes. You should conform to and improve existing policies for protecting wildlife areas. Everyone should be doing all in their power to protect wildlife sites. All wildlife is important and has been neglected, sites have been slowly lost over the years. Wildlife now enters suburban areas as their own habitats have diminished and they can no longer fend for themselves adequately from nature. Badgers and hedgehogs as well as rabbits, frogs, newts, voles and shrews are declining and are seldom seen apart from dead at the roadside. Bat numbers are declining as their habitats are lost. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was.
Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. You mention that Doggett Pond no longer meets the standard but are there no steps to improve its status instead of dismissing it? It is obviously an important site for the wildlife in that area. To lose it would be to our detriment. You should be looking at creating new sites with every large housing development, and protecting them to improve our district and our own wellbeing. Private households should not be allowed to take over grass areas and verges or worse, concreting the verges over for parking and cost savings.
These areas, although small are still areas for wildlife. Bees and butterflies are also in decline, as are the bugs which feed our birds. The plan should create new wildlife meadows to encourage the pollinators in order to future proof our own existence. You should be exploring smaller sites that could be enhanced, managed and protected to give future generations a legacy to be proud of.
Q30.
Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
Yes. The plan must protect them for future generations and teach our children their history and importance so that they can continue to keep them safe.
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?
On site. You can then assess in real time and sort out any issues you would not have known about off site.
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? [Please state reasoning]
You need to retain what we already have by ensuring the necessary links are in place to join as many as possible, and ensuring that public rights of way are not blocked by land owners and are kept free from debris. You also need to assess some paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look into offering this in the larger spaces. For example, a small toilet block and hand washing facilities in the car park. Obtaining funding from new developments that can enhance existing areas as well as providing new spaces and facilities. The sites should be well-maintained.
Q33.
Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
They are a step in the right direction, but you need to assess periodically in order to be able to add further links to any new parkland that may be created in the future. The map is unclear as it does not show exact routes.
Q34.
With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure? [Please state reasoning]
Enhancing existing areas and ensuring developers include green space and recreational facilities within their developments. A new, separate development would be able to deliver this within their plan layout. Ensuring there are suitable links, access and footpaths. Making sure some of these footpaths are maintained and accessible for the disabled.
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? [Please state reasoning]
Assess the shortfall of facilities and networks before plans are approved so that adequate planning and funding can be secured before any building takes place.
Q36.
With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure? [Please state reasoning]
A new town would have this infrastructure built into its plans. Funding for improvements must otherwise come from developers if an area is already overpopulated.
Q37.
Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these? [Please state reasoning]
Most of the District feels overcrowded; the road network is no longer fit for purpose, some schools are near to capacity, it is difficult to obtain a GP or dental appointment. There is little to no disabled play areas or play equipment. There are often issues with waste collections, drain and road cleaning and verge trimming. The District Council does not have the staff to deal with all these issues. The council should either build another waste recycling site, or develop a better waste collection program which allows extra waste to be collected next to the bin. The current recycling site at Castle Road is no longer capable of expanding to meet the needs of an ever-growing population. The plan should also identify a site to accommodate commercial waste facilities to stop fly tipping.
Q38.
With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan? [Please state reasoning]
Improve what we already have. The tennis courts on Fairview Park needs improvement. Safeguard our open spaces to protect wildlife and recreation. Develop different types of sporting facilities. We need to offer free recreation.
Q39.
Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering? [Please state reasoning]
All-weather facilities should be considered.
Q40.
Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering? [Please state reasoning]
They look suitable. They will probably need funding.
Q41.
With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
A new development would be able to deliver this in their plans or fund improvements for existing facilities in line with national strategy and requirements.
Q42.
Are there particular open spaces that we should be protecting or improving? [Please note, you will have an opportunity to make specific comments on open spaces and local green spaces in the settlement profiles set out later in this report]
The sites will be specific in each parish. You must protect all of these recreational spaces and improve them, if necessary. Once lost to development, they can never come back. There are too few areas of accessible open space.
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? [Please state reasoning]
You should reassess the planning policies regarding alterations made to the buildings on the heritage list, especially those in conservation areas. There have been a few occasions where buildings of “interest” (or other) have been altered, and that places in conservation areas have been allowed canopies, shutters and internal illumination of signage without challenge. Any building work should be sympathetic to the area and you should require corrections to unauthorised changes, even if they have been in place for some time. Shop fronts are huge areas of uninteresting glass with garish colours. No objections are raised to signage and advertising that is out of character with a conservation area in a heritage town. Ensure statutory bodies are consulted and heeded.
You should take effective actions to manage the footways, ‘A’ boards and barriers are obstructions to those with impaired sight or mobility.
Q44.
Are there areas of the District we should be considering for conservation area status beyond those listed in this section? [Please state reasoning]
You should not take areas of precious woodland to make way for housing.
Q45.
Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets? [Please state reasoning]
Yes there are many sites of historic importance which should be included.
Q46.
With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state reasoning]
You can only have a vibrant town centre if there are shops to go to. If these units are subsequently changed to residential then our town centres will be fractured and uninviting. The new Use Class E will mean it will be even more important for the council to protect our retail outlets. You need to work actively with premises owners in order to assist in the re-letting of any empty shops. Maybe offer a reduced rent to new businesses as a start-up scheme. You could contain this as a “local” business only – allowing the entrepreneurs in the Rochford District a chance to showcase their businesses. You also need to be able to negotiate with the owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows, perhaps photos of the old towns or useful information, to make them more attractive. Explore business rates levies.
Any plan should be reviewed frequently; at least every 4 years
It is a well-documented fact that independent businesses have done better than large chains during Covid as they are able to diversify at short notice. RDC need to incentivise new small or micro businesses into our town centre, either through grant support or another mechanism. Occupied premises create employment, increase footfall and reduce vandalism. Landlords should be engaged with to ensure quick turn-arounds, or for more flexible lease agreements where for example a new business can take on a shorter lease to test the market.
Good public transport links are crucial for our villages, neighbourhoods and town centres.
Q47.
Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]
Yes.
Q48.
With reference to Figures 38-40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
Yes.
Q49.
Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]
Yes. A mix of retailers is essential as a lack of variety will eventually kill off the high streets. We need to have a balance of outlets that keep the area viable as you would lose the vibrancy you are hoping to achieve.
Q50.
With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]
Unfortunately, there has been a tendency to switch from commercial outlets to residential, where smaller retail areas have been sold off and housing development has been allowed. In a new development there would be scope to add a small, medium or large retail precinct, depending on the development size.
Retail parks, leisure areas and outlets are proving in many cases, the preferred option for consumers, normally as a result of having everything in one place, free on-site parking and maximum choice. We feel that some of the sites, whilst not suitable for large housing developments, may be suitable for something of this type. It would create much needed employment, opportunity and tourism for the area. Retail parks, leisure areas and outlets are proving in many cases the preferred option for consumers, normally as a result of having everything in one place, free on-site parking and maximum choice. I feel that some of the sites out forward in Rayleigh, whilst not suitable for large housing developments, may be suitable for something of this type. It would create much needed employment, opportunity and tourism for the area.
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? [Please state reasoning]
The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. The existing paths need updating and attention.
Q52.
Are there areas where improvements to transport connections are needed? What could be done to help improve connectivity in these areas?
More work needs to be done on the A127 and The Carpenters Arms roundabout. The feeder lanes proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions is now essential as this is a bottleneck. Hockley needs another access. Connecting the cycle ways into a proper cycle network as part of the plan. A tram system. No new roads should be built.
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.]
Better links to the Chelmsford perhaps through a tram system, new roads must not be built. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a complete review of sustainable transport.
Q54.
Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided? [Please note you may wish to comment on the use of specific areas of land in the next section]
This may be a suitable option for a retirement village that could be restricted to single storey dwellings only, and could include community facilities such as convenient store, community centre and so on.
Q55.
Are there any other ways that you feel the plan should be planning for the needs of rural communities? [Please stare reasoning]
Better public transport and sustainable transport links.
Q56.
a.
Do you agree with our vision for Rayleigh? Is there anything you feel is missing? [Please state reasoning]
No Comment
b.
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?
No Comment
c.
Are there areas in Rayleigh that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
No. Large scale residential development in Rayleigh should be resisted in the new Local Plan. So called windfall development should be incorporated in the overall development targets thereby reducing large scale development.
d.
Are there areas that require protecting from development? Why these areas? [Please state reasoning]
Conservation areas and green belt and sites subject to the exclusion criteria on the call for sites should be protected. Proposed sites within Rayleigh and on the Western side should not be considered for development. Only an infrastructure plan would provide evidence that the chosen sites are sustainable in the long term, and greenbelt and environmental policies should be adhered to in relation to open spaces on the edge or within the town.
e.
Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
All green spaces, no matter how small, hold some significance, especially to those who use them for recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets.
Q57.
a.
Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]
No Comment
b.
With reference to Figure 45 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 Rochford and Ashingdon?
c.
Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
d.
Are there areas that require protecting from development? Why these areas? [Please state reasoning]
Hockley Woods
Rayleigh Town Council. Spatial Plan Response 17 V 2.0 Published 13th September 2021
Q60.
a.
Do you agree with our vision for Hullbridge? Is there anything you feel is missing? [Please state reasoning]
No. This has been written by someone with no awareness of Hullbridge. I support the Parish Council Vision.
b.
With reference to Figure 48 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 Hullbridge?
The biggest issue with further development in Hullbridge is the distinct lack of infrastructure – whether that be roads, schools, transport and other general services – and so, without even mentioning the fact that many sites lay within the projected 2040 flood plains, the suggestion that further development can take place on any considerable scale is untenable. Any consideration of commercial or community infrastructure, such as youth services, care facilities, or local businesses would equally need to be subject to the same discussion and scrutiny.
Housing [market, affordable, specialist, traveller, other]
c.
Are there areas in Hullbridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
All of the areas lie within the green belt, and many will be within the projected 2040 flood plains, and so general appropriateness is not met with any; numerous promoted sites are outside walking distance of the majority of services and as such would increase residents using vehicles and increase reliance on our already stretched local infrastructure.
d.
Are there areas that require protecting from development? Why these areas? [Please state reasoning]
Significant portions of Hullbridge remain vital for local wildlife, its habitats, and the natural environment. As such, any and all developments along the River Crouch, the surrounding areas of Kendal Park and those that lie north of Lower Road should be protected from development.
e.
Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
All green spaces, no matter how small, hold some significance, especially to those who use them for recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets.

Please find below my response to the RDC Spatial Options Consultation.

Consultation Process -The volume of information contained in the consultation was difficult to access and view online. Some links did not work properly. RDC are not reaching residents who have no internet.

Spatial option 3b North of Southend is most feasible site.

Spatial Themes not included - Cultural and Accessibility.

Employment – District is lacking in Environmental services - woodland conservation and management.

Improve Long-term Economic growth - Better road networks, gigabit broadband and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training. The council should stop developing existing commercial land into housing.

Local generation of low-carbon and renewable energy - New developments should be able to source some or all of their energy from renewable sources. Solar in all new development as standard. Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs; there are many flat roofed buildings all over the district that could accommodate solar panels without damaging the landscape. Explore tidal energy and seek out suitable locations in order to ascertain whether it is viable. Retrofitting existing housing and commercial buildings.

Settlement Hierarchy: Rayleigh is the largest town in the district, but care needs to be taken to maintain the integrity of the existing settlements with respect to green boundary between Rayleigh and its neighbours.

Planned Forms of Housing: Mix of housing for “affordable“ properties with higher standards for gardens and recreational space. Consideration should be given to the provision of Lifetime Homes specifically adapted homes for the disabled and elderly, bungalows and other potential buildings for downsizing families. Housing for the hidden homeless – those “sofa surfing” & Emergency housing. The plan makes no reference to social housing quotas which should be included in all new developments. By working closely with planners and developers, as well as different charities and communities, residents and businesses. You will then get a better understanding as to what you need and what will be achievable.

From 1st August it was announced that empty buildings and brownfield sites should be converted rather than build new. This alternative should be evaluated first.
Many development proposals would also mean a further reduction in air quality, light pollution and the loss of trees, farming, and arable land at a time when food production and supply is becoming a cause for concern.
Enforcement on unauthorised development is not adequately managed.

Infrastructure - The Council cannot comment on the suitability of sites in the plan without completion of Infrastructure Delivery & Funding Plan, Level 2 Strategic Flood Risk Assessment and Local Cycling & Walking Infrastructure Plan.
This is a continuing concern to residents due to the volume of recent and proposed development causing additional pressure on roads, education, social services, health facilities and local employment opportunities all of which gives a sustainable balance for our communities. The Infrastructure Funding Statement states all financial and non-financial developer contributions relating to Section 106 conditions should be completed but this is not the case when larger sites are split up. If developers do not honour the conditions the money reverts to ECC and RDC who should use this to improve our existing facilities, especially on our roads and cycle paths which are in a pitiful state of repair and will only worsen with further development if funding is not used where it was intended.

Balancing access against increased congestion will be the issue for a lot of the sites in Rayleigh. If you keep adding small developments to the boundaries of the town, it will overcrowd existing houses and add to urban sprawl.
i. Rayleigh has taken the brunt of development without significant infrastructural improvement.
ii. Commercial development should be supported in town centres, secondary shopping facilities and on approved industrial estates (the latter should not become retail / entertainment locations and residential development should not encroach on them to avoid conflict). Community Improvement Districts should be established
iii. Community infrastructure should be preserved and extended. Access to town centres and secondary shopping by bicycle and foot should be made easier and safer.

Rayleigh like other towns that have suffered from overdevelopment in recent decades and should be protect from large scale private development during the forthcoming Plan Period. Only development or local needs should be permitted. Local facilities like Mill Hall would be saved and car parking retained and made cheaper to assist local town centre business to survive what will be a challenging period. Secondary shopping facilities in Rayleigh would be supported and encouraged with public finance where required. Sites within the existing Rayleigh Conversation Area should not be considered under any circumstances.
Public transport would be supported and encouragement, especially when given for children to reach school without parents’ vehicles. Renovation and refurbishment of historic buildings with modern green energy would be promoted over demolition and intensification. Public services would be encouraged to return/expand to Rayleigh, in existing buildings like Civic Suite, Police Station and Library etc. The town centre should be the heart of our community not just something you drive through to reach somewhere else. This could be our vision and our aim for the future.
Proposed sites within Rayleigh and on the Western side should not be considered for development. Only an infrastructure plan would provide evidence that the chosen sites are sustainable in the long term, and greenbelt and environmental policies should be adhered to in relation to open spaces on the edge or within the town.
Rayleigh is clearly already overcrowded; it has a road network no longer fit for purpose, some schools are at or near to capacity, it is difficult to obtain a GP or dental appointment. The majority of the town is inaccessible for wheelchair users. There is little to no disabled play areas or play equipment. There are always issues with waste collections, drain and road cleaning and verge trimming. The District Council does not have the staff to deal with all these issues. The council should either build another waste recycling site, or develop a better waste collection program which allows extra waste to be collected next to the bin. The current recycling site at Castle Road is no longer capable of expanding to meet the needs of an ever-growing population. The plan should also identify a site to accommodate commercial waste facilities to stop fly tipping.
Good public transport links are crucial for our villages, neighbourhoods and town centres. The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian, and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a complete review of sustainable transport.
Ensuring that public rights of way are not blocked by landowners and are kept free from debris. Assess paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look at offering this in the larger spaces. For example, a small toilet block and hand washing facilities in a car park.

Open Spaces - The value of our open spaces and the issues with climate change has become a priority. People will continue to reduce travel and split time working from home. Our open spaces are essential for wellbeing, exercise and relaxation. We are on an overpopulated peninsular surrounded by water with one way in and one way out and there is a proven risk of flooding. Open space is at a premium. All green spaces, no matter how small, hold some significance, especially to those who use them for recreation. They are of particular community value and should not be developed. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets.
All Conservation areas, green belt and sites subject to the exclusion criteria (i.e. Sites of Special Scientific Interest) on the call for sites must be protected from Development.

Local Wildlife Sites review: RDC policies for protecting wildlife areas need to be updated. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was. Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. The plan should create new wildlife meadows to encourage the pollinators to future proof our own existence.

Promoted Sites - Reasons against Development
CFS105 (Land North of Hambro Hill) would negatively impact the openness of the Green Belt between Rayleigh & Hockley. Rochford Green belt study states this parcel of greenbelt has a ‘Moderate’ rating for Purpose 1, and a ‘Strong’ rating for 2 & 3. It checks the unrestricted sprawl of large built-up areas, prevents Rayleigh & Hockley merging into one another, and assists in safeguarding the countryside from encroachment.

It was put forward by an Agent or Developer, not the Landowner. Legal constraints already identified. Landowner recently had planning application (20/00826/FUL) approved so extremely unlikely to support any development: Change of use of land from Commercial to combined Agricultural and Equine use. Site was originally used as part of a landfill tip by the former Rayleigh Urban District Council which ceased around 1960.

Grade 1 Agricultural Land Successfully farmed family business for over 50 years (wheat, barley & rape crops.) Fallow agricultural land, equestrian related grazing & woodland. Portion diversified for Equestrian Centre & agricultural barn for storage.

Infrastructure / Transport Overloaded road with a dangerous junction & poor visibility. Low bridge impact public transport – no double decker buses. No cycle paths or means to incorporate one. No pavements near the access road. Public right of way (PROW 298_48) poorly maintained at entrance to the site.

Heritage Assessment by Place Services ECC Minor Adverse / development of this site will cause harm to a heritage asset. The Historic Environment Record notes various finds from the pre-historic period.

Hockley Woods is the largest remaining wild woodland in the country RDC should be doing EVERYTHING it can to save it from development, either adjacent to or close by. RDC should also actively be adding to it by planting more trees to future proof its existence and status. RDC must protect any thoroughfares that access Hockley Wood.

Rayleigh Civic Suite & Mill Hall Arts & Events Centre
Dr Jess Tipper (Historic England)
Rayleigh Castle survives well both as earthwork and buried archaeological remains. It survives as a prominent earthwork in the centre of the town, with wide views across the landscape to the west. The inner bailey is located to the east of the motte and the outer edge of the inner bailey ditch forms the west boundary to the proposed development site.
The proposed development site is within the outer bailey of the castle, which is believed to have been constructed in the late 12th century AD. This is (currently) a non-designated heritage asset with high potential for below-ground archaeological remains; previous archaeological evaluation within the outer bailey had defined evidence of occupation dating between the 10th and 13th centuries, i.e. pre-dating the construction of the outer bailey. Bellingham Lane follows the outer edge of the outer bailey ditch.
The development has the potential to cause substantial harm to below-ground archaeological remains within the development site. The remains of occupation deposits in this area, functionally related to the castle, may be of schedulable quality. Buried artefacts and palaeoenvironmental remains will also have potential to increase our knowledge of the social and economic functioning of the castle and its relationships with the surrounding medieval town and landscape.
We have, therefore, recommended that the Council commissions an archaeological evaluation, to be undertaken by a specialist archaeological contractor, at the earliest opportunity to establish the significance of surviving archaeological remains in this area. Essex CC Place Services provide archaeological advice on behalf of the District Council on non-designated heritage assets and we would expect them to lead on the brief for this work.
The impact of any proposed development at this location on the setting and significance of the designated heritage assets, including the Grade II Listed windmill, will also require robust assessment - to assess the significance of heritage assets, their settings and the contribution their settings make to the significance, and to assess the impact of the proposals on the significance of the designated heritage assets.

Essex CC Place Services High-Level Heritage Assessment for Rochford District (Oct-2020)
The development of these sites will cause substantial harm to a heritage asset. There are likely no options for mitigation. Proposals causing this level of harm to the significance of a heritage asset should be avoided.
Built heritage - Lies within the Rayleigh Conservation Area and & medieval town extent. Civic Suite site contains GII Listed Barringtons [1168536]
Archaeological impact - The Civic Suite needs archaeological investigation & any development on the Mill Hall Site impacts the scheduled Monument of Motte and Bailey

The Mill Arts & Events Centre is situated within Rayleigh Mount Conservation Area, between main entrance to Rayleigh Mount (National Trust Scheduled Ancient Monument) & Rayleigh Windmill (Grade II Listed Building.)



It has been a hub of the community in Rayleigh Town for 50 years up until the time it was closed in March 2020 due to the COVID 19 pandemic Lockdown. This year is the Mill Halls’ Golden Jubilee, built in 1971, paid for by the Community.

RDC must approve nomination for the Mill Hall to be classed as an Asset of Community Value.

The Mill Hall showcases local Artworks within its Foyer, and has a permanent mosaic completed by children of our schools. From the first step within the building, visitors can immediately feel the sense of culture and creativity. A large noticeboard of all events, shows and clubs available is straight ahead, plus the ‘tourist board’ style information desks is immediately welcoming and accessible for all.
The Mill Hall is popular with residents and visitors to Rayleigh, with a coffee shop and facilities to use after a visit to the many Heritage sites within the Town Centre. This includes the Windmill (open for weddings & tours), Rayleigh Mount, The Dutch Cottage, Rayleigh Museum, and King George’s park when Fair arrives in Town.
The Mill Hall has the performance provision for staging Theatre, Musical Concerts, Comedy shows, Live Bands etc. The venues’ size is ideal for large scale events in the main hall including Professional Wrestling, Dances, Boxing, Children’s exercise classes (Jumping Beans). Upstairs, the smaller hall has capacity and versatility to cover social events including art exhibitions, Exercise Classes, craft fairs. The Mill Hall is frequently used for wedding receptions, birthday parties, funeral wakes, Charity social nights (including Rayleigh British Legion) and local school Proms.

It is utilised as a social meeting place by a significant number of community organisations, groups, clubs, and exercise classes. They make regular use of the Mill Hall throughout the day, as well as evenings and weekends. Consequences of the decision by the Council to keep the Mill Hall closed, some organisations have dis-banded and others have become less well supported.
The Mill Hall helps to put the town on the map as a tourist destination, improving the local economy and supporting other businesses including the many restaurants & pubs in the area prior or after an Event.


Rayleigh’s position within the District - and its proximity/travel links to Southend-on-Sea and Chelmsford - mean it is well placed to attract tourists and visitors who want to visit, eat out and then enjoy an event/show at the Mill Hall, without a long train journey home. The free parking after 1pm on Saturdays already brings in visitors to Rayleigh for shopping, so this would be ideal for evening shows/events at the Mill Hall.
The Mill Hall has excellent potential once renovated & refurbished. More focus/marketing placed on its Theatre staging ability. It could be a magnet for touring theatre groups and become part of the East of England theatre circuit, much like Chelmsford & Norwich.
Objections have been raised throughout the Asset Strategy Delivery Program by non-Administration District Councillors and residents with Rochford District Council over plans to demolish the Mill Hall and redevelop the site with housing. More than 4,000 people from the District have signed a petition opposing the demolition of the Mill Hall and building housing in the Rayleigh Conservation Area.
The Theatre’s Trust - the national advisory body for theatres and a statutory consultee within the planning system, has written to RDC in support of maintaining the Mill Hall performance venue.
Sustainable development as defined through the NPPF (2019) includes a social objective to support social and cultural wellbeing. Paragraph 92 seeks planning decisions to plan positively for facilities and to guard against unnecessary loss.
We do not consider there to be sufficient justification demonstrating the existing Mill venue and the live events it hosts are no longer required.

We would also suggest the economic impact on the town should be considered in terms of loss of audience spend in other businesses when attending shows and events. There will be significant harm to social and cultural wellbeing through the loss of existing events held at the Mill Hall.

Local Authorities are the biggest funder of arts and culture in England. They support cultural activity in their areas in order to provide their residents with a better quality of life, to promote tourism, stimulate the local economy, and build their area’s reputation – creating a unique sense of place. The Partnership Panel meeting earlier this year requested Officers research funding for the Mill Hall via Arts Council. Has this been completed and what opportunities are there to support this fantastic venue?

1.1. On behalf of our client Pigeon Investment Management Ltd, Savills (UK) Ltd has been instructed to prepare a response to the Rochford New Local Plan: Spatial Options Consultation Paper (July 2021).
1.2. Pigeon Investment Management Ltd are promoting Land north of Greensward Lane (also known as ‘Woodside Park’), Hockley, on behalf Pigeon (Hockley) Ltd; Graham Pattrick, Jill Newman and Jacqueline Strong; Ann Harris; and Chris Short (the ‘landowners’ of Woodside Park). The site is located to the north west of Hockley, and is bound by built development to the south, east and west and Beckney Wood to the north. Whilst the site is currently located in the Green Belt, it is well contained by its existing environment and it is considered its allocation will play an important role in meeting the District’s housing needs and importantly the affordability issues identified in Hockley.
1.3. The concept for Woodside Park is for a high-quality landscape-led sustainable scheme of approximately 100 new homes of a variety of different sizes, types and tenures, together with associated supporting infrastructure, amenity greenspace, and landscaping. The site is located within a highly sustainable location with access to key services and facilities including primary and secondary schools, a doctors surgery and the train station within walking distance of the site.
1.4. There are no significant landscape, ecological, heritage, utilities or drainage constraints that would prevent the scheme being delivered. The site would make a valuable, and sustainable, contribution to meeting housing needs, and could do so in the short-term.
1.5. The site, as shown on the submitted Location Plan, is formed of a number of sites submitted to the HELAA as follows:

• CFS023 (Land north and east of Malvern Road, Hockley)
• CFS197 (Land r/o 185 Greensward Lane, Hockley)
• CFS199 (Land r/o 155 Greensward Lane, Hockley)
• CFS201 (Land adjacent 41-45 Crouch View Crescent, Hockley)
• CFS204 (Greensward Lane, Hockley)
1.6. In addition to these, a parcel of land to the east of CFS023 is also included within the Woodside Park site, which has not previously been submitted to the HELAA Call for Sites.
1.7. We have responded to the following questions in the consultation, in the order that they are asked (we have sought to not be repetitive and thus cross-refer when a matter relates to more than one Question):
• Question 1: 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?
• Question 4: 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?
• Question 5: Do you agree with the settlement hierarchy presented?
• Question 6: Which of the identified strategy options do you consider should be taken forward in the Plan?
• Question 7: Are there any reasonable alternatives to these options that should be considered instead?
• Question 8 Are there any key spatial themes that you feel we have missed or that require greater emphasis?
• Question 14: 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?
• Question 17: 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
• Question 18: With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas?
• Question 58a: Do you agree with our vision for Hockley and Hawkwell?
• Question 58b: With reference to Figure 46 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
• Question 58c: Are there areas in Hockley and Hawkwell that development should generally be presumed appropriate?
1.8. In support of this submission, the following documents are enclosed:
• Site Location Plan

• Woodside Park Delivery Statement
This sets out our vision for the site including deliverability objectives, key constraints and opportunities and design objectives for the site.
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?

1.9. Yes. As discussed in our response to other Questions, we consider that further work is required in relation to the following:
1. The housing requirement, including to: i) understand the implications of the proposals contained within the emerging Southend-on-Sea Local Plan; ii) a suitable deliverability buffer; and iii) establish a housing requirement (see our response to Question 6).
2. An update to the Strategic Housing Market Assessment (SHMA). The South Essex SHMA was prepared in 2016 and updated in 2017. The SHMA is thus out of date with national policy, and does not factor in the impact of either Brexit, or the Covid-19 pandemic, and unless updated will become increasingly out-of-date as the preparation of the new Local Plan progresses.
Green Belt Study

1.10. The Green Belt Study Part 1 (2020) should be further updated to include a finer grained approach to key settlement edges. Some parcels (i.e. P19) are so large in scale it is not considered balanced and accurate conclusions can be drawn with the regards to the contribution the land makes to the Green Belt.
1.11. P19 extends to over 1,000 hectares from the north eastern edge of Hockley to the south western corner of Rayleigh (see Figure 1 below). It is difficult to comprehend how the Green Belt on the edge of Hockley can play the same role as land west of Rayleigh or south of the village of Hullbridge.
1.12. Figure 1: Extent of P19

1.13. Rayleigh and Hockley are identified as Tier 1 and 2 settlements in the settlement hierarchy respectively, and it is assumed both settlements could accommodate a significant proportion of required growth over the emerging plan period. Both settlements are tightly constrained by the Green Belt and thus it is considered inevitable that land will need to be released from the Green Belt adjacent to both settlements to help meet the District’s housing needs.
1.14. Whilst Stage 2 of the Assessment looks at specific areas on the edge of settlements in more detail, this simply draws on the conclusions of Phase 1 and if the contribution was high, then the harm was also considered high. These smaller edge of settlement areas (i.e. those that fall within parcel P.19) have not been appropriately assessed against the purposes of the Green Belt as advised by numerous planning inspectors as advised by Planning Inspectors (i.e. Welwyn and Hatfield, Cambridge and South Cambridgeshire).
1.15. Turning to the assessment of the area of land to the north east of Hockley (i.e. land north of Greensward Road), Stage 2 of the Green Belt Assessment concludes:
"The majority of the assessment area makes a strong High contribution to preventing encroachment into the countryside and a moderate contribution to checking sprawl from the large urban area and preventing the merging of towns. The north western corner of the assessment area which is more contained by the urban edge of Hockley and the woodland block makes a moderate contribution to all of the aforementioned purposes. Apart from a couple of isolated, detached dwellings which are not urbanising, the assessment area is open and undeveloped. With the exception of the north western corner the wooded Harrogate Drive along the south western edge of the area maintains distinction from the inset urban area, although its relationship with the wider countryside to the north is restricted by woodland. Release of the assessment area would impact adjacent Green Belt to the east due to the weaker boundary features at the edge of the assessment area and it would reduce the justification for retaining the existing washed over development in the Green Belt"

1.16. The assessment states that the area is open and undeveloped. The dwellings which front Greensward Road are within the parcel and given their number, it is incorrect to refer to them as being ‘isolated’.
1.17. Furthermore, the relationship with woodland to the north is the same for all these ‘high harm’ parcels as it is for P46 which was identified as having moderate harm. The woodland to the north and road to the south are narrowing on plan, providing more containment, and the boundary to the west edge of P198 is strong, defensible and permanent by virtue of the existing strong wooded vegetation. As a result the degree of containment becomes greater.
1.18. In conclusion, whilst it is appreciated that it is not the purpose of the Green Belt assessment to assess every site submitted for inclusion in the Local Plan, it is not considered that the conclusions drawn for the land within P19 can be used to determine which sites should be released from the Green Belt. Please see our response to Question 58b for an assessment of Woodside Park against the purposes of the Green Belt.

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?

1.19. Yes. See also our response to Question 6.

Q5. Do you agree with the settlement hierarchy presented?

1.20. Yes. We fully support the proposed settlement hierarchy. In particular, we support the identification of Hockley as a Tier 2 settlement.
1.21. Hockley is a wholly sustainable settlement with key services which include a train station, a secondary school, three primary schools, numerous employment sites and a town centre.
1.22. Its identification as a Tier 2 settlement reflects the important role it currently plays in servicing existing communities, including those in neighbouring villages, and the role it can play in supporting new growth. The distribution of a significant proportion of the proposed growth to Hockley will be essential to ensure the identified affordability issues can be addressed through the provision of new market and affordable homes. We discuss this matter and the quantum of housing in our response to Question 6.

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

1.23. Prior to discussing the four strategy options set out in the consultation, we have discussed the following matters, which provide important context to the options proposed:
• The Implications of the Emerging Southend-on-Sea Local Plan Consultation;
• Local Housing Need and the Housing Requirement;
• Housing Provision and the Spatial Distribution of Housing, and in relation to this:
• Implications of the Proposed Distribution of Growth for Hockley
The Implications of the Emerging Southend-on-Sea Local Plan Consultation
1.24. This representation is to the consultation on the emerging Rochford Local Plan only, and not to the Regulation 18 ‘Refining the Plan Options’ consultation on the emerging Southend-on-Sea Local Plan. However, given the content of the Southend-on-Sean consultation documentation, that consultation is very pertinent to the consultation on the Rochford Local Plan. In short, the Southend-on-Sea consultation concludes (Table 12) that, of the four strategy options considered, the only way that Southend-on-Sea can meet its identified housing needs is via the provision of 4,900 new homes to the north of the Borough, within Rochford.
1.25. The ‘proposed’ location of these 4,900 new homes (as an extension of the 7,200-home new neighbourhood within Southend-on-Sea), extending eastward from the immediate environs of the airport and southern point of Rochford town-centre has direct implications on what will be an appropriate and sustainable approach to the distribution of growth within Rochford itself.
1.26. Strategy Option 3 is stated as being:
“… to concentrate growth in one or more locations of 1,500+ dwellings. Option 3 has three sub-options based on locations where there is likely to be sufficient land being promoted to deliver this scale of growth in a co-ordinated way:
• Option 3a: Concentrated growth west of Rayleigh
• Option 3b: Concentrated growth north of Southend
• Option 3c: Concentrated growth east of Rochford”
1.27. Option 3b is essentially what is proposed within the current Southend-on-Sea Local Plan consultation, albeit that proposes a much higher level of growth in that location. With this location being proposed to accommodate growth from within Southend-on-Sea, it cannot also accommodate growth from within Rochford. Whilst the quantum of new homes within this area could be increased further to accommodate growth from within Rochford, with the Southend-on-Sea consultation already proposing 12,100 new homes in the area, it is considered that further increasing this number would be neither sustainable nor deliverable within the plan period. Option 3b is thus essentially negated as a viable option by the Southend-on-Sea proposals.
 
1.28. In this context, Option 3c would constitute further strategic development within just a few km of the Southend-on-Sea proposals. As above, it is considered that further increasing this number would be neither sustainable nor deliverable within the plan period. It would result in a more than significant impact on that part of the District and whilst larger-scale development does offer the ability to deliver more major infrastructure, it is considered that the social, economic and environmental impact of over 13,600 new homes, on that part of the District would be dramatic.
1.29. In addition, both Rochford and Southend-on-Sea fall within the same Housing Market Area (HMA). If the Rochford Local Plan were to focus the delivery of a major proportion of its housing needs within the same geographic area as the Southend-on-Sea Local Plan, this would undoubtedly result in a local imbalance between housing need and supply (noting the need for different sizes, types and tenures), and increase the risk of under-delivery resulting from the saturation of the local housing market. The emerging Rochford Local Plan notes at various points within the consideration of the Strategy Options that the risks of under-delivery can be mitigated by “… having a more diverse mix of sites and locations …”.
1.30. In summary, given the conclusions in the current Southend-on-Sea consultation, of the three sub-options to Strategy Option 3, only one – concentrated growth west of Rayleigh is thus considered to remain a viable, sustainable and deliverable possibility.
1.31. This not only has implications for Strategy Option 3, but also for Strategy Option 4, which is proposed as a ‘balanced combination’ “… making best use of urban capacity (Option 1), building one or two large growth areas (Option 3) and a number of smaller urban extensions (Option 2)”.
Local Housing Need and the Housing Requirement
1.32. The Spatial Options consultation explains (p. 12):
“Rochford is a district that is home to around 87,000 people across a mix of urban and rural settlements. Our population has grown around 4% over the last 10 years and is projected to grow by a further 12% over the next 20 years. This would make our population around 98,000 people by 2040.”
1.33. It proposes five ‘strategic priorities’, the first of which is (p. 21):
“Strategic Priority 1: Meeting the need for homes and jobs in the area”
under which it proposes six ‘strategic objectives’, the first two of which are:
“Strategic Objective 1: 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 prioritising the use of previously developed land first.
Strategic Objective 2: To plan for the mix of homes needed to support our current and future residents, in particular viably addressing affordability issues and supporting our ageing population, including the provision of private and social care schemes.”

1.34. The first of these objectives thus relates to the number of new homes to be provided, whilst the second relates to the mix (i.e. size, type and tenure) of homes.
1.35. The NPPF requires (para. 61) (our emphasis):
“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 – unless exceptional circumstances justify an alternative approach … . 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.
1.36. The PPG expands on this, explaining (ID: 2a-002-20190220) (our emphasis):
“What is the standard method for assessing local housing need?
... The standard method … identifies a minimum annual housing need figure. It does not produce a housing requirement figure.”
and (ID: 2a-010-20201216) (our emphasis):
“When might it be appropriate to plan for a higher housing need figure than the standard method indicates?
The government is committed to ensuring that more homes are built and supports ambitious authorities who want to plan for growth. The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.
This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground; …”
1.37. The consultation reflects this guidance, stating (p. 24):
“National policy … requires Local Plans to provide strategies that accommodate unmet need from neighbouring areas where it is practical to do so and is consistent with achieving sustainable development. Whilst the scale of unmet housing need from others’ plans, including those from elsewhere in South Essex and London, is not fully known, it is possible that building more than 360 homes per year, if sustainable to do so, could help to accommodate some of this need.”
1.38. In this context, the consultation discusses a range of growth scenarios, which are summarised in Figure 15 as:
1. Current Trajectory
“Approximately 4,500 new homes by 2040 can be delivered by maximising urban and brownfield capacity and windfalls. …”
2. Standard Methodology
“7,200 new homes by 2040 would meet the Council’s housing needs based on the current standard method …”
3. Standard Methodology + 50% Buffer
“10,800 new homes by 2040 would meet the Council’s housing needs based on the current standard method, with an additional 50% buffer which could help to drive local economic growth or address unmet need from elsewhere”
1.39. It should be noted that whilst the Standard Method Local Housing Need is approximately 360 homes per year (362.6 dpa based on the latest available figures), this is ‘capped’ – the cap being applied at a level of 40% above the projected increase in households. The uncapped housing need figure would be approximately 380 homes per year, which over the 20-year plan period would equate to a need for 7,600 new homes.
1.40. In addition, as we discuss later in this representation, it is evident that Southend-on-Sea cannot meet all of its housing need within its own boundary and is now proposing that the only way it can meet its need is to accommodate approximately 3,950 new homes within Rochford (over the period 2020 to 2040). Adding this to the (capped) minimum housing need for Rochford results in the need for the emerging Local Plan to provide for at least 11,150 new homes.
1.41. As such, we do not support the ‘Current Trajectory’ growth scenario, nor do we support the ‘standard methodology’ growth scenario unless Southend-on-Sea are able to demonstrate an alternative means of accommodating their need. We do support the ‘Standard Methodology + 50% Buffer’ growth scenario, albeit we consider that this should provide for at least 11,150 new homes, not 10,800. We also consider that the reference to a ‘buffer’ should be deleted as this is misleading given that the scenario would only meet Rochford’s own needs plus unmet needs from Southend-on-Sea; it would not meet any other unmet needs from elsewhere in South Essex or London (as the consultation moots), nor would it include any more housing than the minimum to ‘help drive local economic growth’.
1.42. In order that sufficient sites are identified to ensure that the minimum housing need is delivered, it is good practice to add a ‘buffer’ of 5 or 10% when establishing the amount of housing to be provided for in a Local Plan. Adding such a buffer to the minimum need identified above would result in the Rochford Local Plan having to identify sufficient sites for between 11,700 and 12,300 new homes (including that to be provided as part of the unmet need from Southend-on-Sea), or between 11,500 and 11,900 if the 5 to 10% deliverability buffer is only added to Rochford’s own minimum need.
1.43. Overall, we consider growth of between 7,500 and 7,950 new homes over the plan period would, assuming an average occupancy of 2.4 people, equate to an increase in the population of the District of between 18,000 and 19,000 people – approximately a 20% increase on the existing population of 87,000.
Housing Provision and the Spatial Distribution of Housing
1.44. The consultation explains (p. 24):
“Our Housing and Economic Land Availability Assessment (HELAA) 2020 identifies a supply of over 4,300 homes that are already planned for. This includes existing allocations, sites with planning permission and an allowance for windfall development of around 45 homes a year.”
1.45. The June 2020 HELAA is now over a year old but provides a helpful breakdown of the 4,300 figure, as it applies to the 20-year period 2019/20 to 2038/39 as follows:
1. Extant permissions: 2,397
2. HELAA sites (deliverable in accordance with existing policy): 239
3. Unimplemented allocations and other: 1,019
4. Windfall allowance: 765
Total: 4,320
1.46. The HELAA identifies that 285 homes were expected to be delivered during 2019/20. Whilst these homes should now be removed from the projected supply for the plan period (which commences with the year 2020/21), it is considered likely that a similar number of homes will have been permitted, meaning that the existing projected supply over the plan period probably remains at approximately 4,300 homes.
1.47. With reference to the ‘Current Trajectory’ growth scenario, the consultation notes (p. 25):
“Approximately 4,500 new homes by 2040 can be delivered by maximising urban and brownfield capacity and windfalls. …”
1.48. This would suggest that, in addition to the sites identified in the HELAA (including windfalls), there is the scope to accommodate just 200 additional dwellings through the maximisation of urban and brownfield capacity. However the HELAA identifies no supply in terms of additional ‘urban capacity’ thus it is assumed that the 4,500 figure referenced is either a rounding up of the 4,320 figure in the HELAA, and/or a rolling forward of this to account for more recent permissions. In either case it is considered reasonable to assume that the available, suitable and deliverable supply in Rochford at the time of writing is approximately 4,300 to 4,500 homes.
1.49. Given this, the ‘Standard Methodology’ and ‘Standard Methodology + 50% Buffer’ growth scenarios would require the identification of new sites sufficient to provide for between 2,700 and 6,300 new homes. However, as we have discussed above, a deliverability buffer should also be included such that new sites sufficient for between 3,000 and 3,450 new homes should be identified, plus the 3,950 proposed in the Southend-on-Sea Local Plan.
1.50. As we discuss above, we consider that Strategy Option 1 ‘Urban Intensification’, is unsound as it will not deliver the required quantum of housing. We also conclude that the proposals contained within the Southend-on-Sea consultation mean that only one of the potential locations identified in Strategy Option 3 ‘Concentrated Growth’, and thus also Strategy Option 4 ‘Balanced Combination’ (of Options 1, 2 and 3) – i.e. land west of Rayleigh, is considered to remain a viable, sustainable and deliverable possibility. Overall, it thus seems apparent that the only sound approach to accommodating Rochford’s housing need is to make best use of existing commitments and urban intensification to deliver approximately 4,500 new homes, and to identify additional small and medium sized sites across the District, with reference to the settlement hierarchy, potentially including the land west of Rayleigh .
1.51. The Strategy Options Topic Paper 2021 includes at Figure 1 a map showing the results of the ‘clustering’ exercise carried out with regard to the sites promoted for development. We consider this to have been a useful exercise to enable a better understanding of how the promoted sites ‘fit’ in the context of existing settlements and the context of other promoted sites. The clustering exercise identified 12 clusters, which we have ordered in Table SAV01 below as per the proposed settlement hierarchy (from Figure 14), insofar as this is possible. To this we have added the existing population (from Figure 7), and then converted this to establish approximately the number of existing homes in each area (utilising a conversion factor of 2.4 people per dwelling as per Figure 14 in the consultation).
1.52. We have then, extrapolated a 20% increase in the number of homes in each area. This approach, which is relatively simplistic, does not factor in the extent of land promoted for development, constraints or settlement / site specific factors, sustainability considerations, or extant commitments / windfall capacity, broadly reflects what is proposed in Strategy Option 2b ‘Urban extensions dispersed to settlements based on hierarchy’, albeit it applies an across-the-board percentage increase in housing.
1.53. We have then weighted aspects of this to more closely reflect an approach that is based on the settlement hierarchy, with a higher proportionate growth applied to settlements in the higher tiers – this also more closely reflects what is proposed in Strategy Option 2a ‘Urban extensions focused in the main towns’, which is considered likely to be a more sustainable approach.
1.54. In doing this we have also:
1. Included figures for the unmet need from Southend-on-Sea.
2. Given (1), reduced slightly rather than increased the proportionate growth at Rochford and Ashingdon (as discussed above).
3. Included for the potential of concentrated growth west of Rayleigh.
4. Given (3), not increased the proportionate growth at Rayleigh.
1.55. This approach results in a growth of 7,850 new homes (excluding the unmet need from Southend-on-Sea), well within the 7,500 to 7,950 range identified above.
1.56. If it is concluded that concentrated growth to the west of Rayleigh cannot be supported, then this approach would direct that growth to a combination of Rayleigh (e.g. increasing to c. 30% growth / 4,000 new homes) and Hockley (increasing slightly to nearly 2,000 new homes).
1.57. As noted, the above is relatively simplistic, does not factor in the extent of land promoted for development, constraints or settlement / site specific factors, sustainability considerations, or extant commitments / windfall capacity. Whilst a useful starting point, it will be for the Council to take all of these matters into account in identifying suitable sites for allocation and confirming the distribution of growth.
Implications of the Proposed Distribution of Growth for Hockley
1.58. As noted above, the June 2020 HELAA identifies existing housing supply, for the period from 2019/20, as follows:
1. Extant permissions: 2,397
2. HELAA sites (deliverable in accordance with existing policy): 239
3. Unimplemented allocations and other: 1,019
4. Windfall allowance: 765
Total: 4,320
1.59. The Council’s 2019/20 AMR identifies a similar, also for the period from 2019/20, supply as follows:
1. Extant permissions & resolutions to grant: 2,312
2. HELAA sites and other: 240
3. Unimplemented allocations: 900
4. Windfall allowance: 765
Total: 4,217
1.60. Of these sites, only sites for approximately 250 new homes are within Hockley and Hawkwell. On this basis it is considered that the emerging Local Plan should seek to make allocations at Hockley / Hawkwell sufficient for at least a further 1,550 new homes, and that these should be spatially balanced and include sites to the west, north and south-east of Hockley.
The Strategy Options
Option 1: Urban Intensification
1.61. As discussed above, this Option will not be able to meet the Councils growth needs. Option 1 is thus unsound, is contrary to national guidance, and should thus be discounted.
Option 2a: Urban extensions focused in the main towns
1.62. This option is supported, so long as a mix of sites and sizes are proposed. In accordance with the draft Settlement Hierarchy, Rayleigh, Rochford and Hockley are the most sustainable settlements in the District and thus the most sustainable locations for growth.
1.63. However, if such a strategy is proposed, it is essential that in addition to large scale urban extensions, a sufficiently high proportion of small to medium sized sites are identified. Such sites are more likely to be available in the shorter term, offer a suitable location for development in the shorter term, and be achievable with a realistic prospect that housing will be delivered on site in the short term. This is essential if the Council is to deliver a rolling five year housing land supply across the plan period.
1.64. In summary, Option 2a is considered sound. It would result in new homes being delivered consistently across the plan period in the most sustainable locations, close to existing services and facilities. New development on settlement edges (i.e. at Woodside Park on the north eastern edge of Hockley) will also provide the opportunity to enhance existing areas and communities and gateways into the towns.
Option 2b: Urban extensions dispersed to settlements based on hierarchy
1.65. As with Option 2a, this option is supported so long as a mix of sites are proposed including a high proportion of small to medium sized sites.
1.66. We welcome that this option would base the distribution of development based on settlement hierarchy. As discussed above, as the most sustainable settlements in the District, it is considered a higher proportion of growth should be distributed to the main towns of Rayleigh, Rochford and Hockley which are the most sustainable locations for development in the District.
1.67. In summary, Option 2b is considered sound. As with Option 2a, it would result in new homes being delivered consistently across the plan period in the most sustainable locations, such as at Woodside Park.
Options 3a, 3b & 3c: Concentrated Growth
1.68. We strongly oppose Strategy Option 3 for a number of reasons.
1.69. Firstly, there are significant challenges associated with the delivery or large scale sites which mean they are highly unlikely to come forward in the first five years of the plan. Such challenges include:
a) Large sites containing concentrated growth take a significant time to deliver due to their complex nature and long preparation, planning and overall lead-in times before development starts.
b) Such sites rely on a significant amount of upfront infrastructure. The upfront costs associated with sustainable urban extensions means they tend to make lower contributions to affordable housing, of which there is a significant shortage in Rochford.
c) If the new Local Plan were to be reliant on effective delivery of a small number of large schemes, and the failure of just one extension to deliver will result in a shortfall of housing throughout the Plan period.
1.70. Furthermore, this strategy would limit growth to Rayleigh and Rochford, such that the needs of other communities would not be met.
1.71. For example, pursuance of Option 3 will result in no planned growth at Hockley, a Tier 2 settlement which is wholly capable of accommodating new homes. As noted on page 77 of the consultation, housing availability and affordability is a key issue in this part of the District. Thus, in order to address this, a significant amount of new growth should be directed to Hockley, which would not occur with Option 3.
1.72. In summary, Options 3a, b and c are not considered sound, and should be discounted at this stage.
Option 4: Balanced Combination
1.73. This option is broadly supported, in principle, and noting the discussion above provided the Council are realistic when it comes to the distribution of growth. Development on brownfield sites and, as set out above, large scale urban extensions can take a long time to come forward and it is therefore essential small to medium sized sites are allocated to ensure a supply of homes across the plan period.
1.74. We would therefore support Option 4 providing a significant proportion of required growth is allocated to Hockley. Hockley is one of the least affordable areas in the District, and new growth is essential to address the worsening availability and affordability crisis.
Summary
1.75. Overall, we advocate a balanced, weighted distribution of growth, that takes into account the proposals in the emerging Southend-on-Sea Local Plan, similar to that set out above at Table SAV01.
Site Appraisal Paper (2021)
1.76. As noted above, Woodside Park (see site Location Plan) is formed of a number of sites submitted to the Call for Sites as follows:
• CFS023 (Land north and east of Malvern Road, Hockley)
• CFS197 (Land r/o 185 Greensward Lane, Hockley)
• CFS199 (Land r/o 155 Greensward Lane, Hockley)
• CFS201 (Land adjacent 41-45 Crouch View Crescent, Hockley)
• CFS204 (Greensward Lane, Hockley)

1.77. A parcel of land to the east of CFS023 is also included within the site boundary, which was not previously submitted to the HELAA Call for Sites.
1.78. In light of the above, it is requested that the sites are reassessed as a single site so that a full assessment of the site and suitability for development can be assessed. For the purposes of this response, however, we have reviewed the assessment of each of the above sites as contained in the Site Appraisal Topic Paper; our comments are set out at Appendix 1 to this response.

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

1.79. Further to our response to Question 6, it is considered that the Council should assess a fourth growth scenario that does include a buffer to ‘help drive local economic growth’ as a ‘reasonable alternative’. Failure to do so would mean that the growth scenario that is proposing to meet the highest quantum of growth is only providing for the minimum need, plus a small buffer to ensure deliverability. Not proactively considering a higher level of growth than this minimum could jeopardise the progress of the Plan.

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

1.80. See our response to Question 6.

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?

1.81. Yes. We consider that ‘place-making’ is crucial to the creation of well-designed and socially-inclusive communities. Whilst many of the same principles apply to all sites, any place-making charter should recognise that every site, and every solution, will be different.
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?
Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas?

Housing Mix
1.82. The NPPF requires (para. 65):
“Within [the context of the overall identified housing need], the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to, those who require affordable housing, families with children, older people, students, people with disabilities, service families, travellers, people who rent their homes and people wishing to commission or build their own homes).”
Self / Custom Build
1.83. The 2016 Housing and Planning Act introduced the so-called ‘Right to Build’ requirement, requiring local authorities to grant sufficient permissions for self and custom build plots to meet local demand.
1.84. As noted in the Government’s self and custom build action plan (April 2021),
“The self and custom build sector is under-developed in the UK. In Europe and North America, the sector delivers a much higher proportion of housing output. Only 7% of homes in UK are built via self and custom build, delivering an estimated 13,000 units in 2018. Nonetheless, even at this underdeveloped scale, this level of output is enough to make the sector the equivalent of UK’s fourth largest housebuilder. There is capacity to expand and if we increased to levels similar to the Netherlands, we could see 30-40,000 self and custom build homes built annually.
The government is committed to increasing the number of self and custom build homes in this country and to establish it as a mainstream option for people to choose to get on the housing ladder or when moving home. The government has previously brought forward initiatives to tackle the barriers to the growth of the sector, and now we are bringing these initiatives and new ones together under one self and custom build action plan.”

and with regard to access to land:

“This legislation created a duty on local authorities to keep a register of demand for self and custom build in their area and permission serviced plots suitable to meet that demand within 3 years. Since April 2016, all local authorities have established a register.”
1.85. Demand is measured by the number of people registering on Right to Build registers. This legal requirement came into force after the publication of the 2016 SHMA and the matter was not addressed in the 2017 addendum. For data protection purposes, Rochford’s register is not publically available. However, as part of a new/updated SHMA, existing and future need for self and custom build homes would be assessed, providing evidence to determine future need in Rochford.
1.86. The Housing Topic Paper published alongside the consultation notes (para. 10.20):
“… Currently the Rochford District Custom and Self build register has 83 entries as of April 2021.”
1.87. However this is only a statement of current, existing, need, not an assessment of likely need over the plan period.
1.88. We are proposing that the Woodside Park site include approximately 12 to 15 self / custom build plots, alongside bungalows and other specialist accommodation.

 
Q58a. Do you agree with our vision for Hockley and Hawkwell?

1.89. The consultation proposes the following ‘vision statement’ for Hockley and Hawkwell:
“In 2050, Hockley and Hawkwell should be the District's gateway to the green lung of the Upper Roach Valley, making the most of its access to ancient woodland and a network of nature reserves. Its town and neighbourhood centres should be vibrant places with an emphasis on independent businesses and providing for a diverse range of jobs. Deprivation should continue to be largely absent from Hockley and Hawkwell however housing affordability should have been addressed to ensure that local first-time buyers can greater afford to live locally.”
1.90. We support the Council’s proposed vision for Hockley, and welcome the acknowledgement that access to the surrounding ancient woodland should be enhanced. Access to nature plays an essential role in promoting health and wellbeing, whilst well managed and planned trails can ensure appropriate use and management.
1.91. We also welcome the aspiration to address housing affordability which is identified as a key issue for Hockley. It is vitally important a mix of homes are provided to meet the needs of all. At Woodside Park, we are proposing a wide mix of homes including policy compliant affordable housing and self / custom-build plots.

 
Q58b. With reference to Figure 46 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?

1.92. We fully support the allocation of land to the north of Greensward Lane (see Site Location Plan), Hockley which comprises:
• CFS023 (Land north and east of Malvern Road, Hockley)
• CFS197 (Land r/o 185 Greensward Lane, Hockley)
• CFS199 (Land r/o 155 Greensward Lane, Hockley)
• CFS201 (Land adj 41-45 Crouch View Crescent, Hockley)
• CFS204 (Greensward Lane, Hockley)
And also land to the east of CFS023 which was not previously submitted to the Call for Sites.
1.93. This response is accompanied by a Delivery Statement which provides further details of the site, and demonstrates that the site is deliverable and there are no known technical constraints which could prevent the delivery in the first five years of the Plan.
Site Overview
1.94. Woodside Park would include a high-quality landscape and design-led sustainable scheme of new homes of a variety of different sizes, types and tenures, together with associated supporting infrastructure, amenity greenspace, and landscaping. The SHELAA sites all received positive assessments in the 2017 SHELAA assessment, which concluded the sites are available, suitable (subject to release from the Green Belt), and achievable to which we concur.
1.95. The land is located to the north east of Hockley, to the north of Greensward Lane and south of Beckney Wood. It is located within a highly sustainable location with access to key services and facilities with primary and secondary schools, doctors surgeries and the train station, amongst others, all within walking distance of the site, as can be seen from the Facilities Plan included in the Delivery Statement.
1.96. The concept for Woodside Park is for a high-quality landscape and design-led sustainable scheme of approximately 100 new homes of a variety of different sizes, types and tenures, including self/custom build homes and bungalows together with associated supporting infrastructure, amenity greenspace, and landscaping. It is envisaged the site could deliver:
• Family homes
• Policy compliant affordable homes
• Bungalows
• Self-build
• Custom-build
• Housing for older people
• Housing for those with specialist needs
1.97. The Delivery Statement accompanying this response demonstrates that Woodside Park could include provision for substantial new areas of:
• Amenity greenspace
• Play facilities
• Community orchard planting
• Wildflower meadow planting
• Ecological habitat
• Landscaping
• Woodland
together with street trees and extensive areas of new planting throughout.
1.98. Initial technical studies have concluded there are no landscape, ecological, heritage, utilities or drainage constraints that would prevent the scheme being delivered.
Green Belt
1.99. The site is currently located in Green Belt, however, it is considered to make a limited contribution as set out below.
1.100. The Rochford and Southend Green Belt Study is a two part study which identifies the site as falling within two parcels of land, P19 and P46. The results of the assessment show that the Council recognise that overall, the Site does not contribute very strongly to the Green Belt Purposes and is one of the weaker performing Sites.
1.101. A summary of the Council’s study in respect of Parcel P19 reveals the following:
[see document]

1.103. As noted in our response to Question 1, Part 1 of the Green Belt Study should be further updated to include a finer grained approach to key settlement edges. By way of an example, P19 extends to over 1,000 hectares stretching from north east Hockley to south west Rayleigh. Accordingly, an assessment relative to a small part of that larger parcel is very likely to result in a different outcome and the assessment of P19 should be treated with caution.
1.104. In this instance, the assessment relating to Purpose 3: Openness, is skewed by the huge scale of the parcel, such that when the very small part of the Site is considered in isolation, the Purpose 3 Openness score of ‘Strong’ is incorrect, and should be no greater than Moderate – the Site is influenced strongly by the built up area to the south and west, but is also contained by rising landform and woodland to the north, resulting in a reduced relationship with the wider countryside (than the wider parcel).
1.105. Similarly, it is considered in respect of the individual site that the score of ‘Moderate’ for both Purpose 1 (Sprawl) and Purpose 2 (Merging of Towns) are overstated. The Site is located on the north side of Hockley and does not lie in the area between Hockley, Rayleigh or Southend on Sea. Consequently, it can have no effect on the outward sprawl towards any of these towns, and it would also not result in any merging or coalescence of a settlement.
1.106. For the same reasons as P19, the P46 score of ‘Moderate’ for both Purpose 1 (Sprawl) and Purpose 2 (Merging of Towns) are overstated.
1.107. It is appreciated that the purpose of the Green Belt assessment is not to critique individual sites. Therefore, using the same methodology and criteria as outlined in the Green Belt Assessment (2020), we have undertaken our own assessment of the site as follows:

[see document]

Site Assessment
1.108. All five sites which comprise land north of Greensward Lane have been assessed in the Council’s Site Appraisal Paper 2021. It is noted at paragraph 3 of this document that this paper is not itself out for consultation, but as it forms part of the Councils current evidence base and will help inform the Council’s site selection process, it is essential any errors are corrected. We disagree with a number of conclusions drawn in respect of the five sites submitted and our assessment of these are contained at Appendix 1 to this response.
1.109. The purpose of the paper is to assess sites which have been submitted for allocation. Its purpose is not to assess parcels of land identified in, for example, the Green Belt Assessment or the Landscape Character, Sensitivity and Capacity Study. Thus when identifying the impact a site could have on the Green Belt or on the surrounding landscape, it is not enough to rely on the conclusions of these respective studies. The impact individual sites could have on their surroundings should be assessed on individual merit. Consequently as part of our comments on the site, we have sought to provide our own assessment Woodside Park could have on the Green Belt and landscape.
Preferred Spatial Option
1.110. As noted in our response to Question 6, it is considered that Options 2 and 4 are the only suitable options for the Council to take forward, in order to provide a sustainable strategy which meets the District’s needs.
1.111. In particular we support Options 2a and 2b as both will see a proportion of growth distributed to the Tier 2 settlement of Hockley. As acknowledged by the Council a key issue in Hockley is housing availability and affordability. The population is also slightly older than the local average. Thus, it is essential housing sites are allocated across the town to meet its local housing needs.
1.112. As can be seen from Figure 46 (Map of Hockley and Hawkwell), the majority of sites submitted to the Council’s Call for Sites are considered to be of small to medium scale (i.e. up to 250 dwellings). As set out in our response to Question 5, the allocation of small and medium scale sites will make an invaluable contribution to Rochford’s overall housing needs as such sites are more likely to be available in the shorter term, offer a suitable location for development in the shorter term, and be achievable with a realistic prospect that housing will be delivered on site in the shorter term.
Conclusion
1.113. Woodside Park has the potential to make a valuable, and sustainable, contribution to meeting housing needs, and could do so in the shorter-term. It is therefore considered that the site should be allocated in the forthcoming Rochford Local Plan.

Dear Sir / Madam,

Please find below my comments regarding the Spatial Options Consultation for your analysis.

Thank you in advance for your attention to this matter.

Kind Regards,
Jane

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?
I could not confirm what were the studies you conducted in order to determine the young people’s needs for leisure activities other than sports. In addition, could you please make available the studies conducted.
Q2. Do you agree with our draft vision for Rochford District?
In a matter of principle, yes, I agree, but there should be a greater highlight to creating new jobs through the establishment of business incubators and support to traditional and new outdoor markets to support local farmers.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
I don’t agree with the separate visions as it will divert the resources from a global vision for Rochford District in terms of number of houses and the respective infrastructure. As such I think it would be detrimental to have a narrower vision which can overlook the effects that the increase of population in one area will have on the remaining parts of the district.
Q4. Do you agree with the strategic priorities and objectives we have identified?
As principles, yes, but I have several objections in the way they are supposedly achieved.
Strategy Options
Q5. Do you agree with the settlement hierarchy presented?
Yes.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
It is my understanding that Option 4 would be preferable, but the more the building is concentrated into one area, the less green belt would have to be released. I will detail my concerns in Q17.
Q7. Are there any reasonable alternatives to these options that should be considered instead?
Please refer to Q6 and Q17.
Spatial Themes
Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis?
Yes, I was not able to verify what would be the dedicated areas for the construction / improvement of roads and other public transport infrastructure. In addition, I could not confirm where will the new waste management facilities (dumps or recycling centres) will be placed, the way the options are presented it does not allow the public to have a detailed understanding of it.
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?
Yes. No infrastructure or housing development should be authorised to be built in high floor risk areas or coastal change areas. As the plan is omits what would be the estimated costs in terms of the additional infrastructure that would be required for building in these areas, it doesn’t allow for a risk/benefit analysis of allowing to build in risk areas versus costs that would have to be paid in rates by the general public.
Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character?
Yes. In addition, Hockley Woods, Rayleigh Mount and Grove Woods should also be preserved from development.
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 low-carbon or renewable energy?
I agree, provided that the energy production equipment produces a relevant amount of energy.
There are plenty of opportunities to establish micro-production with community funding. I am not an expert, but please refer to the work done in Manchester in this regard http://www.gmcr.org.uk/ .
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?
I agree that energy efficiency should be an important consideration in any development, and they should be above the bear minimum, but I lack the technical knowledge to comment any further.
Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported?
The Council should encourage companies, charities and individuals to come up with projects and provide administrative and financial support whenever needed to help them see it through.
Considering the availability of surface water and rain in the UK but the lack of natural elevations in the Essex region, consideration should be given to hydro-electric micro-production facilities.
In addition, solar and wind energy should also be encouraged wherever possible.
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?
Yes. The principle should be applied by areas.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
Yes, 1) there is no point regarding public transport (bike lanes and walk paths alone are nowhere near the needs of the community) and 2) there is no point regarding the minimization of the impact that new roads will have in the fabric of the places they will go through.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
I do not understand the question, this seems to be a specialist subject I cannot provide input on.
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?
I do not understand the question, this seems to be a specialist subject I cannot provide input on.
Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?
I do not understand the question, this seems to be a specialist subject I cannot provide input on.
Housing for All
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?
I do not believe that in an area where young people have very few cheap options to buy a house, the option to primarily develop detached or semi-detached housing (80% of the planned houses) would be adequate as the house prices will still be too high, even with the affordable option.
In order to achieve the same number of houses in a significantly smaller development site, the option to increase the number of terraced houses and flats to 50% of the new builds would decrease the overall cost of providing these new houses, regardless of the affordable housing conditions.
In terms of the number of bedrooms, I agree with it, only the distribution between the house size seems too focused in large and expensive properties with a negligible discount that will not suffice to cover the current or future housing needs. A 20% discount on a £700,000 detached house for a family who can only afford a £250,000 terrace house is not an acceptable trade-off.
Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas?
In the specific case of Rayleigh where I reside, there is a significant shortage of terraced houses and flats which are by design cheaper than the other options, so in order to meet the new housing needs, development should focus on these rather than creating huge new areas of detached and semi-detached houses that will not meet current housing needs.
Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing?
I could not confirm in the plan what areas are being specifically allocated to house rough sleepers and other people in homeless situations.
Q20. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller accommodation needs?
Provided that they are willing to pay for their own accommodation and this does not implicate any increase on the council rates, I do not have any specific input in the solution.
Q21. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs?
Provided that they are willing to pay for their own accommodation and this does not implicate any increase on the council rates, I do not have any specific input in the solution.
Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites?
Provide that they pay for the land they spend their time on and the facilities and amenities provided by the council and this does not implicate any increase on the council rates through the clear-up of their sites, I do not have any specific input in the solution, although I would think that they would be better placed outside urban areas without sacrificing any green belt area.
Employment and Jobs
Q23. With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan?
I could not verify if the council is planning or willing to assist new businesses by providing any reduction in business rates for the first years. Considering the crisis that high-street local businesses are facing to establish themselves and thrive, this would be an incredible tool to employ. I am also not aware of any mention to the creation of new business hubs for creative industries, farmers markets and technology start-ups outside of the airport site. When considering the local importance of informal business sites, such as Battlesbridge Antiques Market, the creation of small business hubs would be extremely effective.
Q24. With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the Green Belt?
As a principle yes, but this has to have a case-by-case analysis of the impacts, namely in terms of polluting employment sites and the needs for infrastructure.
Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?
When establishing the new sites for development, there is an opportunity to require the property developer to establish a commercial presence proportional to the size of the site in order to create basic shopping amenities or go further if the site so justifies in order to attract more retail. For that purpose, the planning must include loading bays in order not to disturb residents and to supply the shops.
Q26. Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?
Considering that the two main villages in Rochford District are traditionally market towns, it is strange that there aren’t any plans to incentivise more street market initiatives, both seasonal and farmers markets.
Q27. Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g. skills or connectivity?
I think more public transport to formal and informal employment sites would greatly stimulate the growth or those sites.
Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system?
The current road infrastructure is already insufficient to move the traffic from the businesses and people going to and from the area adjacent to the airport. In order to increase the ability of the airport to be a major employment site, the roads must be able to allow the circulation of the increased traffic. It is already clear that the construction of an alternative to the A127 or the increase to a dual carriage capacity of an existing road is essential.
Biodiversity
Q29. Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?
Yes, it should include the whole of Hockley Woods.
Q30. Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
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?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Green and Blue Infrastructure
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?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q33. 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?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Community Infrastructure
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?
I could not verify where the schools are going to be built and what is going to be increased in terms of the public transport infrastructure.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?
Depends on the number of houses built and where they are built. I agree that there has to be an increase, but this seems to be a specialist subject I cannot provide input on.
Q37. Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these?
There is an absolute absence of any facilities for young teenagers that don’t involve organised sports or are not paid.
Regarding the schools and healthcare, the current infrastructure is stretched, and doctors are already struggling to keep up with their appointments as it is and this is a nationwide problem. With new houses being built, this should be addressed before the problem gets even worse, but this is a specialist subject I cannot provide further input on.
Open Spaces and Recreation
Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q39. Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q42. Are there particular open spaces that we should be protecting or improving?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Heritage
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?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q44. Are there areas of the District we should be considering for conservation area status beyond those listed in this section?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state
Ensure that new types of retail and other businesses are encouraged to establish themselves in the town centres, namely through the reduction or exemption of council rates to give them a chance to survive the initial period. Other than restaurants and beauty services, no new businesses have opened in Rayleigh High Street. This reduces the overall margin of the existing businesses, the attractiveness to the installation of new businesses and the ability to attract visitors to shop in Rayleigh.
Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]
I don’t have an issue with the hierarchy per se, but there should be some protection to the local centres and local parades to ensure that they don’t disappear.
Q48. With reference to Figures 38, 39 and 40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
Yes.
Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]
Yes. In the town centres the primary use must be commercial as the unchecked conversion to housing developments would create many problems with noise complaints and others where they didn’t exist before.
Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]
Yes, as I mentioned before, considering the market town pasts of Rayleigh and Rochford, it would greatly benefit local businesses to incentivise street market initiatives as it would not only provide a greater variety of goods to residents, but it would also provide local businesses the foot traffic.
Transport and Connectivity
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?
The plan has to have appropriate measures in place to secure those roads and railways are built ahead of the conclusion of the developments and not after they are concluded, as it is common sense that once the houses are built, any compulsory purchase of space to build infrastructure will be more expensive.
From what I could understand, any plans to increase the transportation network are left to chance or delegated to other entities.
The increase of the housing without transport will further exacerbate the problems that the road infrastructure is currently facing and there are no plans whatsoever to increase public transportation to places which are already lacking, such as Hullbridge which is almost entirely dependent on Rayleigh’s infrastructure.
It is strange that the Beaulieu Estates managed to have a new train line and the people of Rochford District can’t either get appropriate roads, let alone more train connections. I cannot understand how Chelmsford is able to plan these developments to have transport connectivity and Rochford cannot plan a road.
Q52. Are there areas where improvements to transport connections are needed?
Yes, the A127 needs increasing and there is a lack of an alternative route to this road going into Rochford and Southend.
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.]
Yes. All of the above, the increase in the demographics and the expected establishment of new businesses should account for an increase primarily focused on roads, rail and buses that serves as an alternative to the current routes that are massively overrun.
Green Belt and Rural Issues
Q54. Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Planning for Complete Communities
Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
No. I cannot see this translated in the detailed plan.
Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot understand the allocation between commercial and housing properties as well as infrastructure, as there are nowhere near enough roads or overpasses in the image provided.
Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate?
No, unless infrastructure is put in place. A simple example is the development in Daws Heath Road, where all these plots are meant to be made available for development, but the end of the road, approaching the A127, is not able to take two cars at the time.
Q56d. Are there areas that require protecting from development?
New developments in the Town Centre that either reduce green areas or affect the Mill Hall and any development that reduces the area of Hockley woods.
Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
The legend to Figure 44 does not allow for enough detail to understand the changes to the green spaces and the purpose of them.

Q57a. Do you agree with our vision for Rochford and Ashingdon?
I cannot provide meaningful input.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q57c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate?
I cannot provide meaningful input.
Q57d. Are there areas that require protecting from development?
I cannot provide meaningful input.
Q57e. Do you agree that the local green spaces shown on Figure 45 hold local significance?
I cannot provide meaningful input.
Q58a. Do you agree with our vision for Hockley and Hawkwell?
I cannot provide meaningful input.
Q58b. With reference to Figure 46 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q58c. Are there areas in Hockley and Hawkwell that development should generally be presumed appropriate?
I cannot provide meaningful input.
Q58d. Are there areas that require protecting from development?
I cannot provide meaningful input.
Q57e. Do you agree that the local green spaces shown on Figure 46 hold local significance? Are there any other open spaces that hold particular local significance?
I cannot provide meaningful input.
Q59a. Do you agree with our vision for the Wakerings and Barling? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q59b. With reference to Figure 47 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q59c. Are there areas in the Wakerings and Barling that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q59d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q59e. Do you agree that the local green spaces shown on Figure 47 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
I cannot provide meaningful input.
Q60a. Do you agree with our vision for Hullbridge?
I cannot provide meaningful input.
Q60b. With reference to Figure 48 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q59c. Are there areas in Hullbridge that development should generally be presumed appropriate?
I cannot provide meaningful input.
Q59d. Are there areas that require protecting from development?
I cannot provide meaningful input.
Q59e. Do you agree that the local green spaces shown on Figure 48 hold local significance?
I cannot provide meaningful input.
Q60a. Do you agree with our vision for Canewdon? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q61b. With reference to Figure 49 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses? How could that improve the completeness of Canewdon?
I cannot provide meaningful input.
Q61c. Are there areas in Canewdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q61d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q61e. Do you agree that the local green spaces shown on Figure 49 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
I cannot provide meaningful input.
Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q62b. With reference to Figure 50 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses? How could that improve the completeness of Great Stambridge?
I cannot provide meaningful input.
Q62c. Are there areas in Great Stambridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q62d. Are there areas in Great Stambridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q62e. Do you agree that the local green spaces shown on Figure 50 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
I cannot provide meaningful input.
Q63a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q63b. With reference to Figure 51 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q63c. Are there areas in Rawreth that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q63d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q63e. Do you agree that the local green spaces shown on Figure 51 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
I cannot provide meaningful input.
Q64a. Do you agree with our vision for Paglesham? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q64b. With reference to Figure 52 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q64c. Are there areas in Paglesham that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q64d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q64e. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q65a. Do you agree with our vision for Sutton and Stonebridge? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q65b. With reference to Figure 53 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot provide meaningful input.
Q65c. Are there areas in Sutton and Stonebridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q65d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
I cannot provide meaningful input.
Q65e. Do you agree that the local green spaces shown on Figure 53 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
I cannot provide meaningful input.
Q66. Do you agree that our rural communities do not require individual vision statements? Are there communities that you feel should have their own vision? [Please state reasoning]
I cannot provide meaningful input.
Q67. Do you agree with our vision for our rural communities? Is there anything you feel is missing? [Please state reasoning]
I cannot provide meaningful input.
Q68. Are there other courses of action the Council could take to improve the completeness of our rural communities?
I cannot provide meaningful input.

ECC Response to Rochford New Local Plan: Spatial Options Consultation July 2021

Thank you for consulting Essex County Council (ECC) on the Rochford New Local Plan: Spatial Options Consultation (SOC) published in July 2021. ECC has engaged with Rochford District Council (RDC) in the preparation of the new Local Plan, and our involvement to date has been proportionate at this early stage of plan preparation, building on the Issues and Options consultation in 2017/18. Once prepared, the new Local Plan will include the required strategies, policies and site proposals to guide future planning across the District, and will replace the current suite of adopted Development Plans up to 2040.

ECC welcomes the opportunity to review and comment on the emerging new Local Plan vision, strategic priorities and objectives, initial growth scenarios, spatial options, thematic themes and ‘Planning for Complete Communities’. As Plan preparation continues, ECC is committed to working with RDC through regular and on-going focussed collaborative discussions to prepare evidence that ensures the preferred spatial strategy, policies and site allocations are sound, viable and deliverable, where future development is aligned to the provision of required local and strategic infrastructure.

A Local Plan can provide a platform from which to secure a sustainable economic, social and environmental future to the benefit of residents, businesses and visitors. A robust long-term strategy will provide a reliable basis on which RDC, ECC and its partners may plan and provide the services and required infrastructure for which they are responsible. To this end, ECC will use its best endeavours to assist on strategic and cross-boundary matters under the duty to cooperate (Duty), including engagement and co-operation with other organisations for which those issues may have relevance.

It is acknowledged that RDC has engaged ECC under the Duty, during the past year, in addition to the joint and regular meetings established with the South Essex authorities, through specific South Essex strategic planning duty to co-operate groups for Members and Officers respectively to explore strategic and cross boundary matters.

ECC interest in the Rochford New Local Plan – spatial options consultation
ECC aims to ensure that local policies and related strategies provide the greatest benefit to deliver a buoyant economy for the existing and future population that lives, works, visits not only in Rochford District, but Essex as a whole. This includes a balance of land-uses to create great places for all communities, and businesses across all sectors; and that the developer funding for the required infrastructure is clear and explicit. As a result, ECC is keen to understand, inform, support and help refine the formulation of the development strategy and policies delivered by LPAs within and adjoining Essex. Involvement is necessary and beneficial because of ECC’s roles as:
a. the highway and transport authority, including responsibility for the delivery of the Essex Local Transport Plan; the lead authority for education including early years and childcare (EYCC), Special Education Needs and Disabilities, and Post 16 education; Minerals and Waste Planning Authority; Lead Local Flood Authority; lead advisors on public health;
and adult social care in relation to the securing the right housing mix which takes account of the housing needs of older people and adults with disabilities;
b. an infrastructure funding partner, that seeks to ensure that development proposed is realistic and does not place an unnecessary (or unacceptable) cost burden on the public purse, and specifically ECC’s Capital Programme;
c. major provider and commissioner of a wide range of local government services throughout the county (and where potential cross boundary impacts need to be considered);
d. Advocate of the Essex Climate Action Commissioner’s (ECAC) Report 2021 Net Zero – Making Essex Carbon Neutral providing advice and recommendations for action on climate change mitigation and adaption including setting planning policies which minimise carbon. This work has been tailored for use in the county of Essex; and
e. involvement through the Association of South Essex Local Authorities (ASELA) and Opportunity South Essex Partnership (OSE), promoting economic development, regeneration, infrastructure delivery and new development throughout the County.

In accordance with the Duty, ECC will contribute cooperatively to the preparation of a new Rochford Local Plan, particularly within the following broad subject areas,
• Evidence base. Guidance with assembly and interpretation of the evidence base both for strategic/cross-boundary projects, for example, education provision and transport studies and modelling, and wider work across South Essex as part of the joint strategic plan.
• ECC assets and services. Where relevant, advice on the current status of assets and services and the likely impact and implications of proposals in the emerging Local Plan for the future operation and delivery of ECC services.
• Sub-regional and broader context. Assistance with identification of relevant information and its fit with broader strategic initiatives, and assessments of how emerging proposals for the District may impact on areas beyond and vice-versa.
• Policy development. Contributions on the relationship of the evidence base with the structure and content of emerging policies and proposals.
• Inter-relationship between Local Plans. Including the Essex Minerals Local Plan (2014) and the Essex and Southend-on-Sea Waste Local Plan (2017).

To achieve this, ECC seeks a formal structure for regular and ongoing engagement with RDC through the next stage of Plan preparation. Of critical importance is the additional evidence required for the site assessment process at both the individual and cumulative level to refine and develop the spatial strategy, which will be informed by the provision of sustainable and deliverable infrastructure and services at the right scale, location and time, for the existing and future residents of Rochford. There are also challenges arising from COVID-19 and how these can be addressed through the Local Plan and the future growth ambitions for London Southend Airport.

Key issues and messages of the ECC response
The ECC requirements are set within the context of national policy and ECC’s organisation plan proposals within “Everyone’s Essex” and commitments for “Renewal, Ambition and Equality” based on ECC’s strategies, policies, objectives and evidence base. The ECC response therefore identifies where we support emerging options and proposals, and where we recommend further work and engagement with ECC in order to refine and inform the “Preferred Options”, the next iteration of the local plan preparation, scheduled for consultation in Spring 2022. The key messages in ECC’s response are summarised below.
1. ECC support RDC preparing a new Local Plan and will assist with the preparation of sound evidence and policies, that plan for long term sustainable infrastructure delivery.
2. It is still too early for ECC to provide detailed comments on the impacts, opportunities and requirements for the full range of ECC infrastructure and services, and additional evidence is required on a range of matters to inform the selection of a preferred strategy and sites, together with supporting policies. It is acknowledged that ECC has engaged with RDC on the preparation of the transport evidence base to date, which has been proportionate to this stage of plan preparation.
3. The preferred strategy and site allocations will need to ensure that the requirements of ECC infrastructure and services are met to secure their sound, viable and sustainable delivery at the right scale, location and time, that is commensurate with housing needs and growth aspirations.
4. This will include engagement with preparing additional evidence, that will include, but is not limited to,
o Transportation modelling (including sustainable transport) to develop a strategy to realise modal shift including analysis of existing active and sustainable travel infrastructure (including bus network and services). In collaboration with ECC, it is recommended that RDC prepare a Local Cycling and Walking Infrastructure Plan (LCWIP).
o Scenario testing for education provision including early years and childcare and the approach to Special Education Needs with Disabilities provision.
o Minerals and waste policy compliant assessments.
o Flood and water management assessments through revised Critical Drainage Areas (CDAs) and revisions to the South Essex Water Management Action Plan.
o Economic need and employment evidence including an up to date Economic Development Needs Assessment to refine the level of economic growth to be planned for.
o ECC will also contribute to the evidence in respect of skills, Adult Social Care, Public Health, climate change, and green and blue infrastructure to that can deliver safer, greener, healthier communities.
o There is also benefit in undertaking a Health Impact Assessment to ensure health and wellbeing is comprehensively considered and integrated into the Local Plan, including a strategic health and wellbeing policy, an area where ECC can advise and assist, and one successfully implemented and included in other plans across Essex.
5. RDC will need to engage and work closely with ECC to inform site selection and the range of preferred sites both individually and cumulatively, having regard to the evidence.
6. Spatial Growth Scenarios – the preferred scenario should meet national policy to deliver housing and other growth requirements; climate change resilience and adaptation; and environmental aspirations of RDC. As a minimum, the standard methodology should be met and any buffer to drive local economic growth or address unmet need from elsewhere is supported but will need to be based on sound evidence.
7. Spatial Strategy Options – the spatial strategy option to proportionately spread growth across the district would not deliver the necessary scale of growth to secure the viable and sustainable delivery of local or strategic infrastructure and services (most notably a secondary school) and would not be supported. Based on the information presented in the SOC, a preferable option is likely to see a combination of the options presented resulting in urban intensification, a focus on main towns, and concentrated growth in one or more locations (resulting in a new neighbourhood the size of a larger village or small town). The option will need to be informed by the evidence base and further site assessments.
8. ECC will need to be involved in any cross boundary development proposals. To this end, Option 3a would need to be delivered in the longer term given current constraints of the strategic road network (Fairglen Interchange) and have regard to emerging proposals and aspirations arising in Basildon and Castle Point Boroughs; and Option 3b will require close and formal working arrangements with Southend-on-Sea Borough Council.
9. It is noted that several of ECC’s comments and observations made in response to the Issues and Options consultation from 2017/18 continue to apply, given the early stages of Plan preparation. We therefore reiterate where important our previous comments and additional points where this is necessary to do so.

The ECC response is set out in table from page 5 onwards and reflects the order of the SOC paper including responses to specific questions; the Integrated Impact Assessment; supporting Topic Papers; and Site Appraisal Paper.

[Due to tabular format of submission, please refer to attached documents for full submission]

Dear Sir/Madam
Rochford District New Local Plan: Spatial Options: Consultation Paper 2021
Thank you for providing the opportunity for Southend Borough Council (SBC) to comment on
the above consultation plan. Set out below are officer level comments that relate principally
to cross-boundary issues and potential strategic scale developments.
SBC and Rochford District Council (RDC) should continue to co-operate on cross-boundary
issues, including through the Rochford and Southend Member Working Group and via the
Association of South Essex Local Authorities (ASELA).
The effectiveness of joint working between the two authorities should continue to be
documented and as we continue to work together under the duty to co-operate, Statements
of Common Ground should be prepared and agreed in line with Government guidance.
General Approach
The Borough Council broadly welcomes the publication of the Consultation Paper and its
general approach to setting out the potential options for meeting Rochford District’s future
development needs, whilst delivering sustainable development and protecting the local
environment. Given Southend Borough’s acute challenge in finding sufficient land within the
Borough to meet its own development needs, it also particularly welcomes the recognition of
the importance of liaising with neighbouring local authorities to ensure wider cross-boundary
issues and development needs are fully addressed.
Coordination of Plans
SBC would wish to emphasise the crucial ongoing importance of coordinating the
preparation of the Rochford New Local Plan with the Southend New Local Plan, which has
reached a similar stage of consultation (the Southend New Local Plan also currently being
out to public consultation at a second Regulation 18 stage, ‘Refining the options’).
Progressing the plans in a collaborative, coordinated and timely manner will be essential to
the effective and sustainable planning for this part of south-east Essex.
As was identified in consultation paper, where it summarises feedback from the Rochford
New Local Plan Issues and Options Document (December 2017 – March 2018), ‘an
infrastructure-first approach to planning is required as there are existing issues with
infrastructure capacity’. (Rochford Local Plan Spatial Options Consultation Paper, page 102)
In seeking to meet future development needs for this part of south-east Essex, it will be
essential that infrastructure provision, particularly in relation to transport, is planned in such a
way to ensure that infrastructure improvements are clearly identified, are realistic and
achievable. In our view, this requires an effective coordinated, sub-regional and cross-
boundary approach, both through our inputs to ongoing ASELA work and through continued
duty of co-operate cross-boundary arrangements.
Question 1 (page 21): 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?
- Given the number of important strategic cross-boundary issues already recognized
between our two authorities (e.g. housing needs, employment needs, transport
infrastructure, environmental protection, strategic green infrastructure provision,
climate change mitigation/adaption, the future of London Southend Airport etc.), we
strongly advocate that both authorities must continue to work closely together on the
preparation of evidence studies and other technical work to support our plan making.
Draft Strategic Priorities and Objectives (pages 40 – 43)
Question 4: 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? – Inclusion of reference to a new Country Park facility north-east of
Southend should be considered and potentially included as part of Strategic
Objective 15.
It has long been an ambition to deliver a new Country Park facility to the north-east of
Southend, as identified in the adopted Southend Core Strategy. If enabled through our local
plans, it would complement similar facilities at Hadleigh Castle and Cherry Orchard and
provide a much needed addition to informal recreation opportunities for the residents of and
visitors to south east Essex.
It is therefore recommended that the words ‘including a new Country Park facility to the
north-east of Southend’ are inserted after the word ‘coastline’. The revised Strategic
Objective would then read as follows:
‘To protect and enhance leisure, sport, recreation and community facilities and to support the
delivery of a multi-functional green infrastructure network across our district and along the
coastline including a new Country Park facility to the north-east of Southend, connecting to
neighbouring areas in South Essex and beyond, to promote healthy and active lifestyles, and
improve physical and mental health and well-being into old age’.
Growth Scenarios (pages 46 – 50)
The ‘Southend New Local Plan - Refining the Options’ consultation document (2021) sets
out that Southend is unable to meet all identified housing needs, as calculated using the
Government’s Standard Methodology, up to 2040. Even if Southend’s remaining Green Belt
was developed there would be a calculated shortfall of around 4,000 new homes. This rises
to around 9,000 new homes if Green Belt land within Southend Borough is not developed.
It is therefore appropriate that Rochford District Council should continue to explore the
options within its area to accommodate a level of housing development which is higher than
necessary to meet its own housing needs (as calculated by Government’s Standard
Methodology), so it is able to consider the potential, and possibly address at least some of
the unmet housing need evident from plan preparation to date in Southend, in line with the
requirements of Government policy.
Spatial Strategy Options (pages 51 to 62)
Question 6: Which of the identified strategy options do you consider should be taken
forward in the Plan? - Strategy Option 4 Balanced Combination. (Strategy Options listed
in footnote 1 below)
It is our view that Strategy Option 4: Balanced Combination, appears to offer the most
appropriate strategic approach, balancing Strategy Option 1 and 3. This option appears to
provide the best opportunity to provide sustainable communities that afford the critical mass
needed to secure transformational new infrastructure whilst seeking to make the best
possible use of existing brownfield sites. It also allows for a continuous supply of
development land to come forward over the plan period.
In supporting this approach, it is recognized that as part of Strategy Option 4, Strategy
Option 1: Urban Intensification must take priority and every effort should be made to ensure
new economic and housing growth is being optimized where this would lead to sustainable
development within urban areas (i.e. the use of brownfield land) before looking at
development in the Green Belt.
Subject to Green Belt considerations, the Borough Council welcomes the identification of
Option 3a: concentrated growth west of Rayleigh and Option 3b: concentrated growth north
of Southend within the consultation as possible sites for comprehensive development noting
that may provide the potential critical mass for achieving infrastructure improvements.
It should be noted that land west of Rayleigh is well served by the strategic highway network
(A130 and A127) whilst land to the north of Southend is less so. The potential for this option
to come forward well served by the strategic highway network would be dependent therefore
on a coordinated and planned approach with land to the south in Southend Borough and the
provision of a new highway and sustainable transport link partly on land within Rochford
District.
The consultation document also omits to note that Option 3c, concentrated growth to the
east of Rochford, would also be strongly dependent on new highway provision to the east of
Rochford, the existing Ashingdon Road being of an inadequate capacity to cope with the
increase in transport movements.
In this respect Figure 23 (Sustainability Appraisal of Strategy Options (AECOM, 2021))
which identifies Options 3a, 3b, 3c and 4 as providing a positive return in terms of transport
and movement is misleading.
Rochford District Council and Southend Borough Council would need to co-operate
effectively to explore the potential opportunity of comprehensive development to the north of
Southend (Option 3b) if this option were to be considered further. This joint work can then
inform both Councils’ next stage of plan making.
Any growth in this location is well placed to meet some of Southend’s unmet housing need,
however, if it were to come forward it must deliver significant new infrastructure which
ensures it’s development is sustainable and delivers advantages to neighbouring
communities, including neighbourhoods in Southend, which could benefit for example from
the close proximity of new accessible parkland, education, community and leisure facilities
delivered as part of development in this locality. It is also crucial that any development
provides for the additional road, active travel and public transport capacity necessary to
serve the development and mitigate fully any impacts which might arise.
A comprehensive development in this area appears to include most of the land necessary to
deliver the new road links necessary to facilitate development within both authority areas
and provide relief to the existing network. Development of this scale also has greater
potential to deliver the level of development finance required to help provide for those links.
SBC would not support development to the east of Rochford or south of river Roach without
significant mitigation and transport improvements both within Rochford District and Southend
Borough. SBC has delivered a rolling program of junction improvements along the A127 over
the last 20 years, however further improvements to increase capacity at pinch points are
likely to be required to facilitate growth. There are however constraints in increasing capacity
along the A127 given its urban context. As such, both Councils, along with Essex County
Council should explore strategic transport opportunities and funding mechanisms, including
a potential new link road/ sustainable transport corridor to the north of Southend, the option
of a new transport hub at Southend Airport Railway Station with improved access and further
improvements along the A127.
Strategy Option 2: Urban Extensions is unlikely to deliver the required transport
improvements necessary to facilitate accommodate the growth in trips on the network within
this area.
Spatial Themes
Question 8: Are there any key spatial themes that you feel we have missed or that require
greater emphasis? – Yes. Transport and Connectivity.
As a general rule, all the themes listed are self-contained in that they relate to specific
sites/areas of land and uses of land. The exception is ‘Transport and Connectivity’.
Transport infrastructure provision has a wider impact that relates to a range of transport
modes and is cross-boundary and sub-regional in its impact. As such the theme is
considered to require greater emphasis in the Plan.
Climate Change and Resilient Environments (pages 65 – 68)
Questions 9, 11 and 12 relating to whether a sequential approach to flood risk should be
taken, for development to source a percentage of their energy from low carbon and
renewable sources, and the provision of higher energy efficiency standards are supported.
Question 10: Do you agree that the Coastal Protection Belt and Upper Roach Valley should
be protected from development that would be harmful to their landscape character? – Yes.
These areas also provide important areas for informal recreation for the residents of southeast Essex including Southend.
Place Making and Design (pages 69 – 72)
Question 16a: Do you consider that new design guides, codes or masterplans should be
created alongside the new local plan? – Yes.
Question 16b: 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? – To have design guides/masterplans for individual growth areas.
It will be essential that any identified concentrated growth sites (Options 3a and 3b) are
planned and designed individually so that the sites can be effectively planned in a
sustainable manner that takes into full account their setting and local environment and
provides for well-designed places and spaces.
Employment and Jobs (pages 84 – 90)
Question 25: With reference to your preferred Strategy Option, are there opportunities for
growth to deliver new employment facilities or improvements to existing employment
facilities? – Yes, land north of Temple Farm Industrial Estate.
Land north of the existing Temple Farm Industrial Estate provides the opportunity for an
extension of the estate to meet future employment needs as part of strategy option 3b:
concentrated growth north of Southend.
Future of London Southend Airport (pages 91 – 93)
Question 28: With reference to the options (listed as footnote 2 below), or your own options,
how do you feel we can best manage the Airport’s adaptations and growth through the
planning system?
SBC is currently consulting on options within its Local Plan ‘Refining the Plan Options’
document on how to continue to plan for London Southend Airport and would welcome
continued co-operation with RDC to ensure an effective policy framework remains up-to-date
to manage future development at the Airport, this could include consistent policies included
within respective Local Plans. It is crucial that any future growth that is facilitated, if that is
indeed the right course of action, should fully consider the environmental impacts of that
growth. It should also be noted that the existing planning permission allows a level of growth
beyond the level of operations being experienced pre-Covid, in 2019 and that level of
operation was in itself leading to local complaints associated with aircraft noise, airport
operations, on street car parking locally and night-flying in particular.
Green and Blue Infrastructure (pages 98 – 101)
Question 33: Do you agree that the central woodlands arc and island wetlands, shown on
Figure 32 are the most appropriate areas for new regional parklands? Are there any other
areas that should be considered or preferred? – Yes. See comments relating to question
34 below.
Question 34: With reference to your preferred Strategy Option, are there opportunities for
growth to help deliver new strategic green and blue infrastructure? – Yes. Option 3b:
concentrated growth north of Southend.
The identified option of seeking concentrated growth north of Southend offers clear
opportunities to deliver new accessible green space including the provision of a new subregional scale Country Park facility aligning with the River Roach and incorporating land
within flood Zone 2 (Figure 8). A new Country Park in this location would provide informal
countryside opportunities to the benefit of residents within the eastern peninsula of southeast Essex and would complement the facilities at Hadleigh Castle Country Park and Cherry
Orchard Jubilee Country Park and the broader South Essex Regional Park concept.
Community Infrastructure (pages 102 – 105)
Question 36: With reference to your preferred strategy option, are there opportunities for
growth to deliver new or improved community infrastructure? – Yes. Option 3b:
concentrated growth north of Southend.
The identified option of seeking concentrated growth north of Southend offers the potential
to provide for a range of community infrastructure, including new school, leisure and health
facilities.
Transport and Connectivity (pages 123 – 126)
Question 51: With reference to the options (listed as footnote 3 below), or your own options,
how do you feel we can best address our transport and connectivity needs through the plan?
All four options need to be pursued as part of an integrated approach in partnership
with South Essex Local Authorities, Essex County Council and the Government.
As stated in the Rochford Local Plan consultation document: ‘it is clear that a more
ambitious approach is required to connectivity if we are to keep growing.’ A step change in
improving connectivity and accessibility is needed to accommodate growth if the local
economy is to remain attractive to investors, and highway congestion and air quality issues
are to be addressed.
The plan needs to recognise that significant volumes of traffic that have their origin or
destination in Rochford District will utilise highways within Southend Borough, particularly the
A127. A coordinated partnership approach to infrastructure provision is therefore essential.
The Rochford Local Plan should seek to ensure that the approval of any large development
proposals are subject to infrastructure triggers where developments are not permitted to
proceed until such time as the necessary infrastructure is committed. Individual development
sites cannot continue to be treated in isolation, the cumulative impact of development
schemes has and will continue to have significant impacts on the existing highway
infrastructure, which has impacts beyond Rochford District.
Question 52: Are there any areas where improvements to transport connections are
needed? What could be done to help improve connectivity in these areas?
Yes. A comprehensive integrated partnership approach to improving transport
connections is required across the whole sub-region.
Question 53: 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?
Yes. Option 3b: concentrated growth north of Southend.
The identified option of seeking concentrated growth north of Southend appears to offer the
potential to provide for improved transport connectivity. Such a development scheme would
be dependent on the provision of a new link road from east Southend to the A127 via
Warners Bridge, utilising land within the administrative district of Rochford, as well as a new
transport hub at Southend Airport Train Station.
Any such link road should also give consideration to the potential for a Rochford bypass to
the east of the town particularly if Option 3c: concentrated growth to the east of Rochford
were to be taken forward. This could provide the first phase in a potential opportunity to
deliver an outer strategic highway route linking to the A130 between Rayleigh and
Hullbridge.
Planning for Complete Communities
• Rayleigh (pages 133 – 134)
Question 56b: 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 (housing,
commercial, community infrastructure)? Yes. Option 3a: concentrated growth west of
Rayleigh.
The identified option of seeking concentrated growth west of Rayleigh offers the potential to
meet a variety of housing needs, mixed use developments and community infrastructure.
• Rochford and Ashingdon (pages 136 – 137)
Question 57e: Do you agree that the local green spaces shown on Figure 45 hold local
significance? Are there any other open spaces that hold particular local significance? Yes.
Edwards Hall Park
Edwards Hall Park serves the informal recreational needs of residents of Eastwood in
Southend Borough and provides an important pedestrian/equestrian gateway into the Cherry
Orchard Jubilee Country Park.
Question 57d: Are there any areas that require protecting from development? Why these
areas? Yes.
In considering the identified option 3b: concentrated growth north of Southend any future
development scheme that may be justified as constituting exceptional circumstances and
sustainable development should be carefully planned so as to avoid the coalescence of the
Rochford with Southend.
Wakerings and Barling (pages 142 – 143)
Question 59b: With reference to Figure 47 and your preferred Strategy Option, do you think
any of the promoted sites should be made available for any of the following uses (housing,
commercial, community infrastructure)? Yes. Option 3b: concentrated growth north of
Southend.
The identified option of seeking concentrated growth north of Southend offers the potential
to provide for improved community infrastructure, transport and access improvements and
provision of public open green space.
Question 59d: Are there any areas that require protecting from development? Why these
areas? Yes. Preventing the direct coalescence of Great Wakering/Little Wakering with
Southend.
In considering the identified option 3b: concentrated growth north of Southend any future
development scheme that may be justified as constituting exceptional circumstances and
sustainable development should be carefully planned so as to avoid the direct coalescence
of the Great and Little Wakering with Southend.
Stonebridge and Sutton (pages 160 – 161)
Question 64b: With reference to Figure 53 and your preferred Strategy Option, do you think
any of the promoted sites should be made available for any of the following uses (housing,
commercial, community infrastructure)? Yes. Option 3b: concentrated growth north of
Southend.
The identified option of seeking concentrated growth north of Southend offers the potential
to provide for improved community infrastructure, transport and access improvements and
public open green space.
Other Minor Comments
There are one or two typing and cartographical errors in the consultation document as
follows:
- Page 65 last paragraph, the third sentence is incomplete.
- Page 98 Figure 32: Map of Key Green and Blue Infrastructure Assets includes
land within the Southend Borough south of Great and Little Wakering. This should be
deleted from the map.
- Page 135 Figure 45: Map of Rochford and Ashingdon
should read Figure 44: Map of Rayleigh. In addition, the blue horizontal lines
defined on the map are not interpreted in the key.
Kind Regards
Mark Sheppard
Team Leader Strategic Planning
Southend Borough Council
_________________________________________________________________
Footnotes
Footnote 1: Page 51 summarises the 4 strategy options as follows:
• Strategy Option 1: Urban Intensification
• Strategy Option 2: Urban Extensions
- » Option 2a: Focused on main towns
- » Option 2b: Dispersed to all settlements based on Settlement Hierarchy
• Strategy Option 3: Concentrated growth
- » Option 3a: Focused west of Rayleigh
- » Option 3b: Focused north of Southend
- » Option 3c: Focused east of Rochford
• Strategy Option 4: Balanced Combination
Footnote 2: Question 28 refers – Options for planning for the future of London Southend
Airport (page 93)
Given the ongoing uncertainty surrounding the impact of Covid-19 on the aviation industry, it is not
currently possible to identify precise land use requirements for the airport’s growth. Nevertheless,
there are considered to be a number of options available relating to planning for the future of London
Southend Airport. These are:
1. To work alongside Southend-on-Sea Borough Council to prepare a new joint Area Action Plan, or
masterplan, alongside each authority’s respective new Local Plan, that contains a consistent policy
approach to managing the Airport’s long-term growth ambitions
2. To work alongside Southend-on-Sea Borough Council to ensure that policies contained within both
authority’s respective Local Plans maintain a consistent policy approach, as far as is practicable, to
managing the Airport’s long-term growth ambitions
3. To prepare a new Area Action Plan, or masterplan, to manage the Airport’s long-term growth
ambitions, with suitable partner engagement but without the status of a statutory document
4. To continue to make decisions based on the existing JAAP for the time being, but to consider
developing a new Area Action Plan, or masterplan, after the new Local Plan is adopted or when the
need arises
Footnote 3: Question 51 refers – Options for addressing Transport and Connectivity (page 125)
Non-exclusive options for addressing transport and connectivity through the plan are to:
1. Embed a sustainable movement hierarchy into the plan to ensure sustainable modes of transport
are prioritised in favour of private vehicles
2. Prepare an Infrastructure Delivery Plan alongside the plan to ensure new development delivers
meaningful improvements to transport networks, including to cycling, walking, public transport and
road
3. Prepare a Local Walking and Cycling Infrastructure Plan or Cycling Delivery Plan alongside the
plan to identify and deliver specific improvements to our walking and cycling networks, including
costed schemes highlighted in the Rochford Cycling Action Plan
4. Work with Government, Highways England, Essex County Council and neighbouring local
authorities to deliver meaningful new transport options, such as rapid transit solutions and a long-term
solution to the A12

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?
We feel strongly that a local highways study needs to take place. The document only refers to a study of the main roads in the south Essex infrastructure position statement. This states in 4.2.4 that much of the main road network which leads to our district is operating at, or near, capacity in peak periods.
We cannot understand why Rochford District Council (RDC) would base its planning upon the 2025 flood risk area when developments could reasonably be expected to be in place for more than 100+ years. All evidence from the IPCC and other scientific institutions demonstrate that global sea level rise is a real and presently accelerating threat. In addition, the British Geological survey shows that the Eurasian tectonic plate is tilting along an axis between the Wash and the Bristol Channel, this means that Essex is sinking at a rate of 0.4 to 0.7mm per year (ref. research carried out at Durham University and published in the Journal ‘GSA Today’). These projections are not the worst-case scenario, and the sea level rise could be much worse if climate change continues raising temperatures beyond 1.5 degrees centigrade.
The map generated by Coastal Climate Central for 2050 shows that all of the promoted sites to the west of Hullbridge will be in the flood risk area, and that those to the North East of Hullbridge are also in the flood risk area. RDC needs to ensure that no site at risk of flooding by 2050 is developed.
The Coastal Climate Central 2050 map shows large part of Rochford including Hullbridge below flood levels:
https://coastal.climatecentral.org/map/15/0.6252/51.6246/?theme=sea_level_rise&map_ type=year&basemap=roadmap&contiguous=true&elevation_model=best_available&fo recast_year=2050&pathway=rcp45&percentile=p50&refresh=true&return_level=return_ level_1&slr_model=kopp_2014

Q2. Do you agree with our draft vision for Rochford District?


We believe that the vison should take into consideration the differences in towns and villages; for example, Rayleigh or Rochford may have a more business focus, whereas Hullbridge may be more of a rural community with a greater need to cater for its older population who do not need employment but do need more health services. In principle, the results of this consultation need to feed into it to make specific plans for each settlement.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?


We agree that there should be separate visions for each settlement, however, these should be determined by each Parish Council working with its own residents - this is the appropriate level of localisation. Whilst agreeing with the principle of the localisation approach, it is not visible in the document as a whole. As we have already covered, there should be separate visons for each settlement. In this way it will support planning decisions at a local and district level to ensure the unique character of each distinct settlement remains rather than developing into one indistinct mass.


Q4. Do you agree with the strategic priorities and objectives we have identified?


Strategic Option 2 fails to address the problem of the aging population within the district. This is in large part due to the failure to provide adequate low rent social housing to enable young people to remain in the district and to develop stable family units. The failure of Housing Associations to meet this need is well documented nationally, and locally the largest Housing Association (Sanctuary) has a poor record of maintaining properties and honouring contractual promises made when the RDC’s housing stock transferred. The strategy should provide council housing (preferably directly managed) with genuinely affordable rents and secure tenancies in small local exception sites. There also needs to be provision within these sites for social housing accommodation for elderly residents.
With regard to objective 12 we are concerned that Rayleigh tip has been put forward for development. If so there still needs to be a site for waste disposal close to Rayleigh. The restrictions on vans needs to be lifted to prevent fly tipping.
We believe that sufficient primary school places should be provided within local communities, and steps should be taken to minimise the use of cars to transport children to schools; we are concerned that this is currently not the case.
Strategy Options

Q5. Do you agree with the settlement hierarchy presented?


Yes, the hierarchy seems logical. We feel the strategy should take into account that many more people are working from home, reducing the need to commute to employment centres.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?


It seems that some elements of option 1 and 3 will be required but given the requirement to build more homes the least disruptive option preferred by us would be to go for option 3a. Option 3a has the advantage of being close to the existing road hubs (A127 and A130) and services. It would also be of a sufficient scale to attract section 106 funding for vital infrastructure. 3a would also be close to employment opportunities in Wickford and Basildon.

Option 3b would create considerable pressure on the existing road network and would erode the green belt separation of Southend and Rochford.

Option 3c would place development within the flood risk area and not be sustainable without the need for major road building that would open up the green belt to considerable development in the Crouch Valley.

The building of a major bypass road (as promoted by landowners in the past) to deal with congestion caused by 3b and 3c would destroy the green environment of Rochford and generate further development within the green belt. Development in the villages should be small scale and focussed on providing homes for young families and the elderly.

Small ‘exception’ housing developments added to the village settlements could provide council housing, sheltered housing and bungalows to meet the needs of low-income young families and the elderly. Such provision for the elderly could free up existing houses for younger residents and families to purchase.

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


Using option 3a as a starting point, other areas could be developed in future using option 1 when the infrastructure is planned and/or in place.
Restrict overdevelopment in rural and village communities to protect the character of village life.

Spatial Themes

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


We are concerned about the fact that access was denied to the topic papers, and wholeheartedly believe that the existing lifestyle of the area should be protected from overdevelopment.


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?
We agree that it is imperative that both flood risk and coastal change should be central to any development plans going forward; for us in Hullbridge, many of the proposed sites to the west of the existing settlement are projected to be deep within flooding territory by 2050, as are numerous ones in the east as well. With 2050 now less than three decades away, and no sign of any imminent alteration in the path of climate change, development in any of the areas identified to be in potential flood plains today and in the near future must not be considered.


Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character?


The main concern that we have about the Coastal Protection Belt is that it only extends up until 2025 – other areas would need to be included past this date because, as we have mentioned previously, the flood plains across the Rochford district will be vastly different by 2050. It is our view that any and all housing developments proposed in flood plains, current and near future, must not be approved and those that are approved should be given the assurance of protection from flooding over the coming decades. Closer to home, we believe that the river front in Hullbridge should equally be protected for its special landscape character. We would also like to make it known we are very supportive and enthusiastic about the Central Woodlands Arc and the Island Wetland proposals.


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 low-carbon or renewable energy?


Providing that the development is affordable and deliverable, and the cost is not lumped onto the buyer for many years to come then this is the right decision as the future rests in renewable energy. A solar farm in a place that will not impact its surroundings to solar panels ought to be considered and/or wind turbines on Foulness Island.


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?


Ideally BREEAM Very Good or Good, as long as the brunt of the cost is not rested on the shoulders of the buyer and that these homes are affordable.

Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported?


The installation of wind and solar power generators, in locations such as Foulness, would certainly assist in supporting the local generation of low-carbon and renewable energy which is a necessity in the modern day.

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?
Yes, these should be settlement specific, to allow for the maintenance of the integrity and specific characteristics of each area, sufficiently detailed to avoid confusion, and widely distributed.

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


Yes, provided individual settlements are consulted and these are adhered to.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
Yes, providing that each individual settlement is at the heart of it and considered as their own entities with their own individual characteristics. It is imperative that certain areas are protected completely, and that any future developers are aware of the identified characteristics of each area.

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?


Design guides should be area specific under one singular guide which is inclusive to the whole district – providing it remains flexible to local conditions.

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

As long as the character and aesthetic are maintained concurrently with necessary growth, nothing else needs to be included.

Housing for All

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?


Meet the need for different types, sizes and tenures of housing (including Affordable, Social, Council and Specialist Housing) by requiring a standard non-negotiable mix of housing to be provided on all housing developments.
New homes should meet the standards set out in Parts M4(2) or M4(3) of Building Regulations.

Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas?

There is too much focus currently across the district on the provision of 4/5 bedroom properties. This focus needs to shift towards 2/3 bedroom properties which would benefit more local residents/families in search of their first home. "Affordable" homes should not only be flats/apartments but other property types also.
1/2 bed bungalows (or similar) should be a priority, as with an ageing population, there will be increasing demand for such properties when elderly residents are looking to downsize. RDC should actively discourage bungalows being converted into larger properties. Additional provision for residential care is also a priority.
These can all be accommodated within Strategy Option 3a.

Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing?


Affordable homes and social housing to enable single persons or families buy or rent their own home.
Specialist homes for the disabled.
Smaller dedicated properties for the older generation, to enable them to downsize from larger properties, thereby freeing-up larger properties for younger families.

Q20. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller accommodation needs?


The failure to provide traveller sites has led to many unauthorised sites within the green belt being granted planning permission on appeal. With Michelin Farm no longer being an option, RDC needs to identify an alternative appropriate site(s) either from within its ownership or purchased specifically for the purpose. This site(s) should be located so that it (they) does not cause difficulties with established communities; fly-tipping and the impact on nearby residents being just one example. Perhaps, particular consideration of a contained site(s) within the Green Belt, so as to obviate the likelihood of unplanned, piecemeal and unauthorised sites fragmenting the green belt.
Consideration also needs to be given to the fact that there are different groups within the Traveller communities who do not want to be placed together and perhaps ways can be found to integrate these into everyday life and housing.

Q21. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs?


Some Traveller Groups tend to make their own arrangements to use owned land on a temporary basis. RDC needs to identify a site(s) either from within its ownership or purchased specifically for this purpose. It (they) would need to be sufficiently away from residences that they would not be disturbed or troubled by vehicles/caravans arriving or leaving. Perhaps a pre-payment/booking system could be introduced for this purpose and at the same time, reducing the likelihood of over-crowding.

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites?
Locate sites close to main roads to enable easy access for large vehicles, so that residential roads are not congested and nearby residents are not disturbed. Allow a little room for expansion and limit the likelihood encroachment onto neighbouring land.
Locate away from spaces of national, regional, local or community interest or recreation, so as not to spoil the visual amenity of the landscape.
The sites should not be closed and available to the whole Traveller community.

Employment and Jobs

Q23. With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan?


In addition to employment option 11 which states: Working with neighbouring authorities to identify land for higher or further education facilities where this would address current and future skills shortages, information should be collected and made available on where there are shortages or opportunities coming up. Offer advice to adults wishing to or needing to reskill. Provide local affordable adult education courses on the skills needed. Work with employers, education centres and Essex County Council.

With reference to employment option 4 that states: Meeting future needs by prioritising the delivery of new employment space alongside any new strategic housing developments. This should apply to the larger scale developments described in spatial strategy option 3. Employment option 4 goes on to specify live work units as an option. This would help with increasing numbers of people working from home. Also start up business centres and co-working spaces would be useful and there are many self-employed people and small businesses in this area. A sympathetic attitude is required towards people running a business from home provided that the impact on the surrounding area is minimal.

In all of this we need to be mindful of paragraph 83 of the NPPF which requires policies and decisions to accommodate local business needs in a way which is sensitive to the surroundings and prioritises the reuse of existing sites and buildings.

Q24. With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the green belt?


Consider any brownfield site for employment use these are currently mainly getting used for housing. There needs to be employment opportunities even in the smaller settlements if we are going to be greener and cut down on transport use. Employment option 6 states: Meeting future needs by prioritising the regularisation of informal employment sites such as those shown on figure 30. This would make employment accessible to people living in the rural communities especially if other farms able to do this could also be identified. Most of the sites are in the western half of the district it would be useful to identify a few more sites in the east to make this a policy that serves the whole district.

Any use that is not heavily disruptive to the surrounding area should be permitted. Planning officers should be able to permit reasonable adjustments requested by residents to make extensions and adaptations to their homes to accommodate working from home or running a business from home.

Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?


Our preferred spatial strategy option is 3a. Concentrated growth is required to bring the necessary infrastructure to make business and employment growth viable. There needs to be links to main roads to accommodate the commercial traffic required to service industry. Improvements to public transport to employment sites are needed.

Employment option 4 which states: Meeting future needs by prioritising the delivery of new employment space alongside any new strategic housing developments, could be delivered by strategy 3a.

Employment Strategy 6, which meets future needs by prioritising the regularisation of informal employment sites, would help deliver more businesses and employment. Employment option 3 refers to Saxon Business Park, Michelin Farm and Star Lane; we should continue to expand and improve these sites. However this needs to be done in conjunction with other options not as a stand-alone policy. These two strategies are needed and can be included in any of the spatial options.

Q26. Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?


Sites set aside for education and health uses in addition to the services they provide, they also provide good employment opportunities. Sites also for High and Low Technology. Foulness would be ideal for green industries.

Q27. Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g. skills or connectivity?


Provide appropriate schools and colleges to serve the increase in population due to high development, but locate with public transport links and accessibility by walking or cycling in mind. Also work with neighbouring authorities to identify land for higher or further education facilities where this would address current and future skills shortages as stated in employment option 11.

Work with bus companies and Essex County Council to make our existing employment sites as accessible as possible. Improve footpaths and cycle tracks using government funding applied for by Rochford District Council. Move away from planning employment sites in places that are designed to be accessed by car use. Some employment is going to have to be close to settlements. This of course would have to be take into account paragraph 83 of the NPPF which requires policies and decisions to accommodate local business needs in a way which is sensitive to the surroundings and prioritises the reuse of existing sites and buildings.

Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system?


Protect the airport and encourage airport linked transport adjacent or close to the airport eg, existing airport industrial park and Saxon Business Park. Both airport growth and industry will promote jobs.

The transport system both road network and public transport needs to be improved to make these growing opportunities accessible for all.

Biodiversity

Q29. Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?


YES

While Hockley Woods does not seem to be mentioned here, we would have thought this ancient woodland (and similar woodland), and its important wildlife habitat should be included as it provides for a number of rare species including lesser spotted woodpeckers and hawfinches.

The lower Crouch Valley, the River Crouch and its banks are important habitats for fauna including birds that are on the endangered species red list. This includes curlews, whimbrels, and other wading birds. The pasture land flanking the Crouch towards Battlesbridge is an important habitat for skylarks and other species; these areas should be protected.
Restrict development in all other green belt areas, in order to protect nature. Alongside this, provide protection for nature reserves, parkland and areas fronting rivers.

Q30. Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection


Yes, as we have already stated, many areas provide habitats for endangered or rare wildlife and therefore are more than worthy of protection.

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?

Onsite reduced developments in general will assist moving new developments to high unemployment areas.
We agree with the central woodlands arc and island wetlands proposals.

Green and Blue Infrastructure

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?


More investment is required in many areas of infrastructure, from roads to general services. It would be beneficial to green ideals to restrict or ban development in or near green belt sites and to keep development in the rural areas to a minimum.

Q33. 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?


By lobbying central government to allow revision of RDC plans to support a quality green and blue infrastructure.
Q34. With referene to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?


Concentrate on brownfield and town sites in order to protect rural communities and the green belt – as previously alluded, options 3 or 4 mean less development in rural areas and are therefore more accommodating to the needs of smaller rural areas like Hullbridge, hence our choice of option 3a.

Community Infrastructure

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?


Build property where there is existing infrastructure or where infrastructure can be expanded without encroaching on green belt etc.
A survey needs to be carried out on local roads to determine what is needed to be upgraded to achieve any sustainable way for traffic, both domestic and that which uses these as through roads.
With reference to Hullbridge much of it is unadopted roads and cannot support any development, let alone be able to accommodate the use of these roads as through roads for both building access and ultimate through road access to any development.

Provide schools for development areas and provide transport links to these schools. Local schools, both primary and secondary, are already struggling with the increase in pupil numbers coupled with limited capacity.

Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?


Funds were given via section 106 to expand Hullbridge Healthcare Centre and provide more school places - neither of these has happened. The section 106 money from the existing Malyons Farm development urgently needs to be made available to both the Hullbridge Healthcare Centre and the Hullbridge Primary School.
More development would make the situation untenable, particularly if further section 106 monies were withheld by RDC and not allocated to benefitting the local community where new developments are built.

Q37. Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these?

Even with section 106 grants, if made available, healthcare facilities in Hullbridge are severely restricted, especially since the pandemic due to doctor shortage. Further development in Hullbridge would worsen healthcare provision and, even with section 106 grants if released by RDC, will not improve the situation.
Whilst this is outside the control of RDC, developments would cause serious issues particularly as Hullbridge traditionally has an ageing population - one which is obviously more reliant on healthcare, alongside the inevitability of new patients from current and any new developments.
There are currently inadequate or no existent bus and footpath links to areas east of Hullbridge, such as the Dome Area. Any development to the east of Hullbridge would have transport difficulty and also the impact on Lower Road would be unacceptable; this would be the case even bus links were improved.
The same approach needs to be taken with schools and highways and new residents could be short- changed without easy access to schools, healthcare and employment.
Open Spaces and Recreation

Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?


With reference to open spaces and recreation option 5, we should improve and maintain what we already have, using section 106 money for improvements. We should ensure that any section 106 money does get spent how and where it was intended. No section 106 money should end up being unused.

We should improve bus links to existing facilities in the district, for example Clements Hall where buses used to run in the past (at least in the school holiday periods). There should be an aim to provide permanent all year-round bus services to our main leisure sites.

The Hockley ‘Park Run’ is very popular. Should the proposed Central Woodlands Arc come into being it would be ideal for a park run. Orienteering could be an interesting additional activity; local scouting groups, and schooling groups too, would certainly benefit from this.

Q39. Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering?


We should ensure that any proposal for a 3G pitch has the backing of local residents. For reference, in 2016 a 3G pitch was applied for planning permission by The Fitzwimarc School but turned down by Rochford District Council due the objections of local residents.
The Hullbridge Recreation Ground would be ideal for a new 3G pitch.

Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering?


Primary Schools should also be considered along with any site that could host a hockey or a 5 a side pitch.

Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?


Our preferred spatial strategy option is 3a. The section 106 money that comes with the larger developments has more chance of providing good sustainable new facilities.
A bus service needs to be run to facilities like Clements Hall, at least during half term and school holidays, to enable young people to access it from areas where it is currently difficult to access by public transport; this has been done in the past to access sports and in particularly swimming facilities which are not available in Hullbridge or Rawreth.
Swimming facilities were excluded from the Rawreth Lane sport facility.

Q42. Are there particular open spaces that we should be protecting or improving?


Hullbridge Recreation Ground. Our nature reserves, parks and woodlands to promote walking and other appropriate exercising activities.

Heritage

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?


Protect village and rural areas from over or inappropriate development through careful planning considerations.

Compose a list of sites with local consultation. Then look maintain them with local residents and organisations.


Q44. Are there areas of the District we should be considering for conservation area status beyond those listed in this section?


Villages fronting riversides: Hullbridge, Paglesham, Canewdon, South Fambridge.

Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets?


As with protected sites a consultation needs to be done for each locality. With reference to Hullbridge, in addition to the old school, Shell Cottage and River Cottage are already listed. We would add the school house next to the school, Brick Cottages, Tap's Cottage and the Anchor Cottages if they are not already listed/locally listed buildings.

Town Centres and Retail

Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state]


Market forces are moving purchases online so town centres need to be more accessible and convenient to encourage day shopping, and also increase night time business where appropriate to take up capacity lost from retail.

Improve transport links to town shopping and amenities. There is no transport link from the Dome that would take their residents into nearby Hockley for example. There are no easy transport links from Hullbridge to Hockley or Rochford.

Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]


Protecting businesses generally will not work as commercially if they are not profitable, they will close and we will have empty shops. Rochford District Council needs to encourage business with free parking and reduced business rates.

Businesses should be encouraged to work together with a co-operative nature, or a number of shops all open a little later one night of the week to make it worth shoppers coming out in the early evening. Local eateries could offer special deals on those nights.

Community events that encourage shops and businesses to join in – fairs, celebrations, etc.

Q48. With reference to Figures 38, 39 and 40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]


Keep streets clean and tidy, and repair and repaint street furniture regularly. Conserve the character of the town centres by avoiding high rise development and buildings that are at odds with the street scene.

Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]


Some existing ok but links to, e.g., Clements Hall from Hullbridge non-existent.

Businesses cannot be forced into staying unless benefits outlined in Q47 are adhered to which may encourage some business opportunities and current business to remain.

Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]


Spatial strategy 3a will give the most opportunity to expand retail both in terms of including retail space and bringing customers into the town centres nearest to the new developments. The document mentions a cinema. The best site for this would be Saxon Business Park. A bowling alley would work well with this alongside some eateries.

Transport and Connectivity

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?


Certainly, prepare an Infrastructure Delivery Plan that would deliver meaningful improvement to transport networks, including but not exclusively, cycle routes, walking pathways, public transport and roads. However, all these modes are currently completely stretched; modernisation and improvements to all need to happen before future housing developments are built. It should be noted that following the last developments in the Core Strategy, as far as Hullbridge is concerned (and almost certainly elsewhere also), the promised improvements have either not materialised, been completed or proven to be inadequate.
The plan needs to deliver improvements to public transport by working with bus companies to re-establish bus routes to isolated communities that have been either been terminated or severely curtailed. For example, ‘The Dome’ has a bus service twice a week. Residents regularly complain that they are isolated from everywhere else. It is also claimed that Hullbridge has its own bus service that runs 4 - 7 times a day. This is not the experience of Hullbridge residents and it only needs the slightest issue along Hullbridge Road for the service to either be even further curtailed or suspended entirely.
RDC need to continue to work with Government, Highways England, Essex CC etc to deliver meaningful road improvements to both the main road arteries and to the local road network. However, any large-scale bypass scheme such as the "Southend Outer Bypass" scheme needs to be opposed. Not only would it cut directly through the Green Belt but it would increase development along its course, which in turn would have enormous negative impact on the Green Belt itself, natural habitats and the environment generally.

Q52. Are there areas where improvements to transport connections are needed?


Whilst some improvements are shortly to commence at the Fairglen Interchange and A130, further improvements are needed to the Junction of Rawreth Lane and the A1245. Perhaps also the A127 could be widened along its length from four lanes to six lanes.
Additionally, the bus service between Hullbridge and Rayleigh can be cut with the slightest issue along Hullbridge Road and this needs to be addressed urgently. When this happens it consequently results in more vehicles using Hullbridge road, which in turn exacerbates traffic congestion and leads to other problems such as pollution.
A bus service between Rochford and Rayleigh via Hullbridge and Hockley and Rayleigh via Hullbridge would serve to reduce traffic congestion along Lower Road, especially at "rush" hours. This would benefit residents of the Dome as well as properties along the length of Lower Road. It would also serve to provide access for Hullbridge students to access the Greensward Academy that does not exist currently.

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.]
Improvements to existing road networks. Large scale bypass schemes, such as the “Southend Outer” bypass would be unacceptable because of the hugely detrimental impact on the Green Belt and its physical and natural environment.
Small low top busses to link smaller communities with larger ones. Trams not a viable option for the more rural areas as roads are too narrow and winding; additionally, would increase congestion on existing roads.
Improvements to the cycle path network, extending and linking the network as and where appropriate and safe.

Green Belt and Rural Issues

Q54. Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided?


Yes, but not within the Green Belt and Rural and Village life must be safeguarded.
Any such sites must be small scale and have developments that prioritise genuinely "Affordable" homes and/or Social Housing that would benefit local residents/families most.

Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities?
Support changes that would require developers of 10 units or less to pay something akin to s.106/CIL monies, that would go towards infrastructure improvements, particularly those affecting rural communities.

Planning for Complete Communities

Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?


N/A


Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate?


N/A


Q56d. Are there areas that require protecting from development?


N/A


Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?


N/A

Q57a. Do you agree with our vision for Rochford and Ashingdon?



N/A

Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


N/A


Q57c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate?


N/A


Q57d. Are there areas that require protecting from development?


N/A



Q57e. Do you agree that the local green spaces shown on Figure 45 hold local significance?

N/A

Q58a. Do you agree with our vision for Hockley and Hawkwell?

N/A

Q58b. With reference to Figure 46 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?

N/A

Q58c. Are there areas in Hockley and Hawkwell that development should generally be presumed appropriate?


N/A

Q58d. Are there areas that require protecting from development?


N/A



Q57e. Do you agree that the local green spaces shown on Figure 46 hold local significance? Are there any other open spaces that hold particular local significance?


N/A


Q59a. Do you agree with our vision for the Wakerings and Barling? Is there anything you feel is missing? [Please state reasoning]

N/A

Q59b. With reference to Figure 47 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


N/A




Q59c. Are there areas in the Wakerings and Barling that development should generally be presumed appropriate? Why these areas? [Please state reasoning]


N/A





Q59d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]


N/A


Q59e. Do you agree that the local green spaces shown on Figure 47 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]


N/A


Q60a. Do you agree with our vision for Hullbridge?


We do not agree with the wording or the aims of the provided vision statement for Hullbridge and have instead drafted our own (see below). We were sceptical about the suggestion that the river could be used for transport without consideration on the viability or environmental impact of this proposal.

Hullbridge will have expanded on its already self-reliant nature, boasting impressive local businesses and amenities – providing a perfect space for those who wish to enjoy their retirement as well as those with young families. Through small, localised and respectable developments, the thriving community and riverside aesthetic of the village remains as strong as ever; all of this has been achieved through the transparency and openness of different local authorities, residents, businesses and developers on any and all developments going forward.

Q60b. With reference to Figure 48 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


The biggest issue with further development in Hullbridge is the distinct lack of infrastructure – whether that be roads, schools, transport and other general services – and so, without even mentioning the fact that many sites lay within the projected 2050 flood plains, the suggestion that further development can take place on any considerable scale is untenable. Any consideration of commercial or community infrastructure, such as youth services, care facilities, or local businesses would equally need to be subject to the same discussion and scrutiny.

Q60c. With reference to Figure 48 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


All of the areas lie within the green belt, and many will be within the projected 2050 flood plains, and so general appropriateness is not met with any; numerous promoted sites are outside walking distance of the majority of services and as such would increase residents using vehicles and increase reliance on our already stretched local infrastructure.

Q60d. Are there areas in Hullbridge that development should generally be presumed appropriate?


Significant portions of Hullbridge remain vital for local wildlife, its habitats, and the natural environment. As such, any and all developments along the River Crouch, the surrounding areas of Kendal Park and those that lie north of Lower Road should be protected from development.

Q60e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there areas that require protecting from development?


Yes, all of those identified as such in Figure 48 are definitely areas of local significance and are correct to be identified as such. Other areas that should be outlined include the Rose Garden, the banks of the River Crouch and the upcoming green space and Memorial Gardens provided as part of the recent Malyons Farm development.

Q61a. Do you agree with our vision for Canewdon? Is there anything you feel is missing? [Please state reasoning]


N/A


Q61b. With reference to Figure 49 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses? How could that improve the completeness of Canewdon?


N/A


Q61c. Are there areas in Canewdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]


N/A


Q61d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]

N/A

Q61e. Do you agree that the local green spaces shown on Figure 49 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]

N/A



Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing? [Please state reasoning]


N/A


Q62b. With reference to Figure 50 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses? How could that improve the completeness of Great Stambridge?


N/A


Q62c. Are there areas in Great Stambridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]

N/A



Q62d. Do you agree that the local green spaces shown on Figure 50 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]

N/A



Q63a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state reasoning]


N/A





Q63b. With reference to Figure 51 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


N/A


Q63c. Are there areas in Rawreth that development should generally be presumed appropriate? Why these areas? [Please state reasoning]


N/A


Q63d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]


N/A


Q63e. Do you agree that the local green spaces shown on Figure 51 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]


N/A


Q64a. Do you agree with our vision for Paglesham? Is there anything you feel is missing? [Please state reasoning]


N/A


Q64b. With reference to Figure 52 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


N/A


Q64c. Are there areas in Paglesham that development should generally be presumed appropriate? Why these areas? [Please state reasoning]


N/A

Q64d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]


N/A


Q65a. Do you agree with our vision for Sutton and Stonebridge? Is there anything you feel is missing? [Please state reasoning]


N/A


Q65b. With reference to Figure 53 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?


N/A


Q65c. Are there areas in Sutton and Stonebridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]


N/A


Q65d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]


N/A


Q65e. Do you agree that the local green spaces shown on Figure 53 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]


N/A






Q66. Do you agree that our rural communities do not require individual vision statements? Are there communities that you feel should have their own vision? [Please state reasoning]


No - All communities should have their own individual, locally determined vision statements, especially the more rural ones. Each settlement has its own distinct character and the vision statement would serve to aid the planning process in safeguarding their individual character.

Q67. Do you agree with our vision for our rural communities? Is there anything you feel is missing? [Please state reasoning]


Yes in the broadest terms. We would want it to re-iterate that the individual character and seeming uniqueness of our rural communities needs to be, and will be, safeguarded. By extension, we would like to see more activity in this regard from all tiers of Government.

Q68. Are there other courses of action the Council could take to improve the completeness of our rural communities?


Respect the green belt that surrounds our rural communities and our higher tier settlements; thereby ensuring a buffer ("defensible boundary") that would actively prevent communities merging into one conglomeration.

Create a Country Park to the west of Hullbridge.

Improve village roads, transport, educational and utility infrastructure. All of which are already in desperate need of improvement and renovation. For example, it is questionable whether the sewerage system in Hullbridge could cope with any further development without expansion and upgrading.

Consultation Process -The volume of information contained in the consultation was difficult to access and view online. Some links did not work properly. RDC are not reaching residents who have no internet.
Spatial option 3b North of Southend is most feasible site.
Spatial Themes not included - Cultural and Accessibility.
Employment – District is lacking in Environmental services - woodland conservation and management.
Improve Long-term Economic growth - Better road networks, gigabit broadband and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training. The council should stop developing existing commercial land into housing.
Local generation of low-carbon and renewable energy - New developments should be able to source some or all of their energy from renewable sources. Solar in all new development as standard. Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs; there are many flat roofed buildings all over the district that could accommodate solar panels without damaging the landscape. Explore tidal energy and seek out suitable locations in order to ascertain whether it is viable. Retrofitting existing housing and commercial buildings.
Settlement Hierarchy: Rayleigh is the largest town in the district, but care needs to be taken to maintain the integrity of the existing settlements with respect to green boundary between Rayleigh and its neighbours.
Planned Forms of Housing: Mix of housing for “affordable“ properties with higher standards for gardens and recreational space. Consideration should be given to the provision of house for life, Adapted homes for the disabled, bungalows and other potential buildings for downsizing families. Housing for the hidden homeless – those “sofa surfing” & Emergency housing. The plan makes no reference to social housing quotas which should be included in all new developments. By working closely with planners and developers, as well as different charities and communities, residents and businesses. You will then get a better understanding as to what you need and what will be achievable.
From 1st August it was announced that empty buildings and brownfield sites should be converted rather than build new. This alternative should be evaluated first.
Many development proposals would also mean a further reduction in air quality, light pollution and the loss of trees, farming, and arable land at a time when food production and supply is becoming a cause for concern.
Enforcement on unauthorised development is not adequately managed.
Infrastructure - The Council cannot comment on the suitability of sites in the plan without completion of Infrastructure Delivery & Funding Plan, Level 2 Strategic Flood Risk Assessment and Local Cycling & Walking Infrastructure Plan.
This is a continuing concern to residents due to the volume of recent and proposed development causing additional pressure on roads, education, social services, health facilities and local employment opportunities all of which gives a sustainable balance for our communities. The Infrastructure Funding Statement states all financial and non-financial developer contributions relating to Section 106 conditions should be completed but this is not the case when larger sites are split up. If developers do not honour the conditions the money reverts to ECC and RDC who should use this to improve our existing facilities, especially on our roads and cycle paths which are in a pitiful state of repair and will only worsen with further development if funding is not used where it was intended.

Balancing access against increased congestion will be the issue for a lot of the sites in Rayleigh. If you keep adding small developments to the boundaries of the town, it will overcrowd existing houses and add to urban sprawl.
i. Rayleigh has taken the brunt of development without significant infrastructural improvement.
ii. Commercial development should be supported in town centres, secondary shopping facilities and on approved industrial estates (the latter should not become retail / entertainment locations and residential development should not encroach on them to avoid conflict). Community Improvement Districts should be established
iii. Community infrastructure should be preserved and extended. Access to town centres and secondary shopping by bicycle and foot should be made easier and safer.

Rayleigh like other towns that have suffered from overdevelopment in recent decades and should be protect from large scale private development during the forthcoming Plan Period. Only development or local needs should be permitted. Local facilities like Mill Hall would be saved and car parking retained and made cheaper to assist local town centre business to survive what will be a challenging period. Secondary shopping facilities in Rayleigh would be supported and encouraged with public finance where required. Sites within the existing Rayleigh Conversation Area should not be considered.
Public transport would be supported and encouragement, especially when given for children to reach school without parents’ vehicles. Renovation and refurbishment of historic buildings with modern green energy would be promoted over demolition and intensification. Public services would be encouraged to return/expand to Rayleigh, in existing buildings like Civic Suite, Police Station and Library etc. The town centre should be the heart of our community not just something you drive through to reach somewhere else. This could be our vision and our aim for the future.
Proposed sites within Rayleigh and on the Western side should not be considered for development. Only an infrastructure plan would provide evidence that the chosen sites are sustainable in the long term, and greenbelt and environmental policies should be adhered to in relation to open spaces on the edge or within the town.
Rayleigh is overcrowded; it has a road network no longer fit for purpose, some schools are near to capacity, it is difficult to obtain a GP or dental appointment. There is little to no disabled play areas or play equipment. There are always issues with waste collections, drain and road cleaning and verge trimming. The District Council does not have the staff to deal with all these issues. The council should either build another waste recycling site, or develop a better waste collection program which allows extra waste to be collected next to the bin. The current recycling site at Castle Road is no longer capable of expanding to meet the needs of an ever-growing population. The plan should also identify a site to accommodate commercial waste facilities to stop fly tipping.
Good public transport links are crucial for our villages, neighbourhoods and town centres. The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian, and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a complete review of sustainable transport.
Ensuring that public rights of way are not blocked by landowners and are kept free from debris. Assess paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look at offering this in the larger spaces. For example, a small toilet block and hand washing facilities in a car park.
Open Spaces - The value of our open spaces and the issues with climate change has become a priority. People will continue to reduce travel and split time working from home. Our open spaces are essential for wellbeing, exercise and relaxation. We are on an overpopulated peninsular surrounded by water with one way in and one way out and there is a proven risk of flooding. Open space is at a premium. All green spaces, no matter how small, hold some significance, especially to those who use them for recreation. They are of particular community value and should not be developed. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets.
All Conservation areas, green belt and sites subject to the exclusion criteria (i.e. Sites of Special Scientific Interest) on the call for sites must be protected from Development.
Local Wildlife Sites review: RDC policies for protecting wildlife areas need to be updated. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was. Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. The plan should create new wildlife meadows to encourage the pollinators to future proof our own existence.
Promoted Sites - Reasons against Development
CFS105 (Land North of Hambro Hill) would negatively impact the openness of the Green Belt between Rayleigh & Hockley. Rochford Green belt study states this parcel of greenbelt has a ‘Moderate’ rating for Purpose 1, and a ‘Strong’ rating for 2 & 3. It checks the unrestricted sprawl of large built-up areas, prevents Rayleigh & Hockley merging into one another, and assists in safeguarding the countryside from encroachment.


It was put forward by an Agent or Developer, not the Landowner. Legal constraints already identified. Landowner recently had planning application (20/00826/FUL) approved so extremely unlikely to support any development: Change of use of land from Commercial to combined Agricultural and Equine use. Site was originally used as part of a landfill tip by the former Rayleigh Urban District Council which ceased around 1960.


Grade 1 Agricultural Land Successfully farmed family business for over 50 years (wheat, barley & rape crops.) Fallow agricultural land, equestrian related grazing & woodland. Portion diversified for Equestrian Centre & agricultural barn for storage.

Infrastructure / Transport Overloaded road with a dangerous junction & poor visibility. Low bridge impact public transport – no double decker buses. No cycle paths or means to incorporate one. No pavements near the access road. Public right of way (PROW 298_48) poorly maintained at entrance to the site.

Heritage Assessment by Place Services ECC Minor Adverse / development of this site will cause harm to a heritage asset. The Historic Environment Record notes various finds from the pre-historic period.

Hockley Woods is the largest remaining wild woodland in the country RDC should be doing EVERYTHING it can to save it from development, either adjacent to or close by. RDC should also actively be adding to it by planting more trees to future proof its existence and status. RDC must protect any thoroughfares that access Hockley Wood.

Rayleigh Civic Suite & Mill Hall Arts & Events Centre
Dr Jess Tipper (Historic England)
Rayleigh Castle survives well both as earthwork and buried archaeological remains. It survives as a prominent earthwork in the centre of the town, with wide views across the landscape to the west. The inner bailey is located to the east of the motte and the outer edge of the inner bailey ditch forms the west boundary to the proposed development site.
The proposed development site is within the outer bailey of the castle, which is believed to have been constructed in the late 12th century AD. This is (currently) a non-designated heritage asset with high potential for below-ground archaeological remains; previous archaeological evaluation within the outer bailey had defined evidence of occupation dating between the 10th and 13th centuries, i.e. pre-dating the construction of the outer bailey. Bellingham Lane follows the outer edge of the outer bailey ditch.
The development has the potential to cause substantial harm to below-ground archaeological remains within the development site. The remains of occupation deposits in this area, functionally related to the castle, may be of schedulable quality. Buried artefacts and palaeoenvironmental remains will also have potential to increase our knowledge of the social and economic functioning of the castle and its relationships with the surrounding medieval town and landscape.
We have, therefore, recommended that the Council commissions an archaeological evaluation, to be undertaken by a specialist archaeological contractor, at the earliest opportunity to establish the significance of surviving archaeological remains in this area. Essex CC Place Services provide archaeological advice on behalf of the District Council on non-designated heritage assets and we would expect them to lead on the brief for this work.
The impact of any proposed development at this location on the setting and significance of the designated heritage assets, including the Grade II Listed windmill, will also require robust assessment - to assess the significance of heritage assets, their settings and the contribution their settings make to the significance, and to assess the impact of the proposals on the significance of the designated heritage assets.

Essex CC Place Services High-Level Heritage Assessment for Rochford District (Oct-2020)
The development of these sites will cause substantial harm to a heritage asset. There are likely no options for mitigation. Proposals causing this level of harm to the significance of a heritage asset should be avoided.
Built heritage - Lies within the Rayleigh Conservation Area and & medieval town extent. Civic Suite site contains GII Listed Barringtons [1168536]
Archaeological impact - The Civic Suite needs archaeological investigation & any development on the Mill Hall Site impacts the scheduled Monument of Motte and Bailey

The Mill Arts & Events Centre is situated within Rayleigh Mount Conservation Area, between main entrance to Rayleigh Mount (National Trust Scheduled Ancient Monument) & Rayleigh Windmill (Grade II Listed Building.)

It has been a hub of the community in Rayleigh Town for 50 years up until the time it was closed in March 2020 due to the COVID 19 pandemic Lockdown. This year is the Mill Halls’ Golden Jubilee, built in 1971, paid for by the Community.

RDC must approve nomination for the Mill Hall to be classed as an Asset of Community Value.
The Mill Hall showcases local Artworks within its Foyer, and has a permanent mosaic completed by children of our schools. From the first step within the building, visitors can immediately feel the sense of culture and creativity. A large noticeboard of all events, shows and clubs available is straight ahead, plus the ‘tourist board’ style information desks is immediately welcoming and accessible for all.
The Mill Hall is popular with residents and visitors to Rayleigh, with a coffee shop and facilities to use after a visit to the many Heritage sites within the Town Centre. This includes the Windmill (open for weddings & tours), Rayleigh Mount, The Dutch Cottage, Rayleigh Museum, and King George’s park when Fair arrives in Town.
The Mill Hall has the performance provision for staging Theatre, Musical Concerts, Comedy shows, Live Bands etc. The venues’ size is ideal for large scale events in the main hall including Professional Wrestling, Dances, Boxing, Children’s exercise classes (Jumping Beans). Upstairs, the smaller hall has capacity and versatility to cover social events including art exhibitions, Exercise Classes, craft fairs. The Mill Hall is frequently used for wedding receptions, birthday parties, funeral wakes, Charity social nights (including Rayleigh British Legion) and local school Proms.
It is utilised as a social meeting place by a significant number of community organisations, groups, clubs, and exercise classes. They make regular use of the Mill Hall throughout the day, as well as evenings and weekends. Consequences of the decision by the Council to keep the Mill Hall closed, some organisations have dis-banded and others have become less well supported.
The Mill Hall helps to put the town on the map as a tourist destination, improving the local economy and supporting other businesses including the many restaurants & pubs in the area prior or after an Event.
Rayleigh’s position within the District - and its proximity/travel links to Southend-on-Sea and Chelmsford - mean it is well placed to attract tourists and visitors who want to visit, eat out and then enjoy an event/show at the Mill Hall, without a long train journey home. The free parking after 1pm on Saturdays already brings in visitors to Rayleigh for shopping, so this would be ideal for evening shows/events at the Mill Hall.
The Mill Hall has excellent potential once renovated & refurbished. More focus/marketing placed on its Theatre staging ability. It could be a magnet for touring theatre groups and become part of the East of England theatre circuit, much like Chelmsford & Norwich.
Objections have been raised throughout the Asset Strategy Delivery Program by non-Administration District Councillors and residents with Rochford District Council over plans to demolish the Mill Hall and redevelop the site with housing. More than 4,000 people from the District have signed a petition opposing the demolition of the Mill Hall and building housing in the Rayleigh Conservation Area.
The Theatre’s Trust - the national advisory body for theatres and a statutory consultee within the planning system, has written to RDC in support of maintaining the Mill Hall performance venue.
Sustainable development as defined through the NPPF (2019) includes a social objective to support social and cultural wellbeing. Paragraph 92 seeks planning decisions to plan positively for facilities and to guard against unnecessary loss.
We do not consider there to be sufficient justification demonstrating the existing Mill venue and the live events it hosts are no longer required.

We would also suggest the economic impact on the town should be considered in terms of loss of audience spend in other businesses when attending shows and events. There will be significant harm to social and cultural wellbeing through the loss of existing events held at the Mill Hall.
Local Authorities are the biggest funder of arts and culture in England. They support cultural activity in their areas in order to provide their residents with a better quality of life, to promote tourism, stimulate the local economy, and build their area’s reputation – creating a unique sense of place. The Partnership Panel meeting earlier this year requested Officers research funding for the Mill Hall via Arts Council. Has this been completed and what opportunities are there to support this fantastic venue?

Ref Spatial Options Paper
Rochford District Local Plan response / comments
Question numbers followed by comment
Q1 I believe that RDC should conduct a study to check the validity of the government’s target of 7,200 to 10,800 homes with the Rochford District. The study should check whether facilities and infrastructure have kept pace with development over the last 5 decades (not whether the infrastructure can be stretched further to cope but has it increased in line with development in the past).
Q1 RDC must take a proactive role in studying traffic increase when developing the Local Plan, not simply rely on Essex County Council advice.
If the government’s requirement, which could easily increase the District’s population by 30%, were found to be at odds with the infrastructural and facility capacities of the district then RDC should vigorously challenge government targets and seek a reduced more appropriate level of development during the plan period.
Q1 RDC should study opportunities to impose solar panels and other environmental features on all new developments. Recent and current development show no sign of adopting such measures therefore we cannot rely of a voluntary code. This must become an RDC Planning Policy with conditions imposed on all new approved applications. If support from central government required then they should be approached as a matter of some urgency.
Q1 RDC should conduct an air quality study throughout the district, not just at a very limited selected locations (all main roads and junctions in particular).
Q2 Draft Vision is far too optimistic and does not address the realities of current situation and challenges of the future.
Our vision should include respect for residents views – especially when consulted (which should be frequent).
Our Vision should include more infrastructure and facilities for existing communities which have already grown to a capacity population eg Rayleigh during recent waves of development. This infrastructure must be in place before new development is permitted
Rochford District vision should aim maintain green boundaries of individual communities - no merging of towns and villages at the boundary.
Our vision should include a desire for no further substantial boundary developments in and around Rayleigh and Rawreth, no more urban extension. The logic is that the old main roads (B roads etc.), that support the town are overburdened and cannot cope with additional traffic.
Our vision for the Plan period should be that if additional development is proved to be necessary within the Local Plan, then it should be sited in a separate ‘Garden Village’ development away from existing communities (separate from towns, villages and hamlets), with new infrastructure and roads connecting to existing main roads such as Eastern Avenue with its nearby facilities and retail opportunities.

Q5 Rayleigh is the biggest town in population and is currently undergoing yet another round of significant additional residential development in the form of urban expansion. It is therefore of deep concern that public facilities such as Mill Hall and Council Chamber are proposed to be removed from Rayleigh. It is suggested that the Council Debating Chamber be relocated to a town lower down in the hierarchy list. This is against overwhelming public opposition expressed in the Public Consultation (Engagement). Therefore the Local Plan review should consider whether hierarchy refers to population the Council serves or some other measurement which dictates where public facilities should go.

Q6 in view of public concern in most of the communities in the district, a new Garden Village Development in the east of the district, away from existing communities, should become policy, even if it regrettably it encroaches on greenbelt/agricultural land (most development will be on agricultural land anyway unless sufficient existing brownfield sites can be identified. Sites within the District that should be considered for a Garden Village new settlement are CFS155, CFS260Z, CFS260AE, CFS260AE, CFS260H, CFS260AK, CFS071, CFS071, CFS260G.
Urban extension of our existing communities is no longer acceptable in the RDC area.
Q10 Answer is NO, I do not agree. We are obliged to consider all areas if we are forced to accept new development by government. No such policy should be approved.
Q11, Q12 + Q13 RDC should demand solar panels and other environmental additions for all new housing schemes and industrial and commercial developments. The large ‘sheds’ in industrial / commercial areas would be excellent location for solar energy collection. However RDC need to do something positive about it and uphold robust planning policy on the subject not merely refer to it in the minor text of reports.
Where solar farms and wind farms are approved on agricultural land. The developers must be legally obliged to re-instate as agricultural land when their solar or wind farm etc. use is withdrawn / removed / not commenced. It should be a policy of RDC to demand legal guarantees regarding the same.
Q16 in particular item b, design guidelines should be just that – guidelines. It is not appropriate to have neo Georgian or pastiche Victorian dormers imposed on a 1960’s or mid 20th century properties. 50,60 and 70 year old property will be the heritage properties of the near future. Although not a strict rule this also applies to our town centres, shops and conservation areas.

Q18 modest starter homes for local people required, including some social housing. This is contrary to developer’s normal practice of building high value / high profit homes. RDC should challenge national government about this if they have a problem with adopting this as policy.
RDC should avoid flats especially in our crowded town centres and should generally stop all residential development in town centres, in particular Rayleigh Conservation Area, other than already accepted policy of change of use for rooms above shops as per current Local Plan.
Q20 it is important to have a well regulated Travellers Site approved, away from our communities, in order to avoid uncontrollable development of other land (as seen in recent times).
Q21 previously identified site close to A1245 / A127 junction (west side)
Q22 Travellers sites should be well regulated with clear unbreachable green boundaries.
Q23 Town centre and commercial land should not be used for housing.
Q25 the recent move to home working from former city based office working in London etc, should be carefully considered when predicting future work patterns. The change will inevitably lead to new commercial opportunities within the district that will require flexibility and commercial opportunities in our town centres and industrial estates. These sites should not be used for housing.
Q29 open/agricultural land on the edge towns and villages is very important to conserve. However the strict protection of remote agricultural land at the expense of open land close to our communities should be opposed. We have for too long sacrificed our communities on the altar of green belt protection in remote areas.
Q30 a few special sites should be protected (SSI’s etc), but the current boundaries of our towns must also be protected. They too preserve wildlife and precious environmental assets. Town and village boundary green spaces give opportunities for our population to enjoy recreation without resorting to driving to distant green locations.
Q34 A Garden Village in the east of the district away from existing communities is the best option for any essential future development. Reasoning: we have already had too much urban extension, time to do something different for future decades of growth.
Q35 & Q36 new Garden Village with new infrastructure paid for by developer.
Q37 There is very little additional capacity Rayleigh in particular, also in all other towns and villages generally in the RDC area. The burden of traffic on centuries old roads causes delay and further air pollution problems. Leaving Rayleigh at many busy times can often take as much time as a 20 mile journey after leaving the town.
Q44 It is vital that Rayleigh’s existing Conservation area be protected from housing development, views of the listed Windmill and Mount must be protected. The Civic Suite our link with local democracy with it’s historic Council Chamber should preserved and used. It is the top town in the hierarchy as stated in the draft Local Plan, with the biggest population. Therefore it is illogical to remove these facilities from the town. The beautiful gardens to the rear of Barringtons / Civic Suite – a significant part of the Rayleigh Conservation Area – should be protected.
Rayleigh’s Conservation Area should also be extended to the south as far as Rayleigh Weir under the Local Plan review. Although there are a small number of less attractive shops and restaurants close to the Police Station (buildings of their time), which could be designated an improvement area, this quickly changes to grand historic buildings of significance; the Library, Salvation Army chapel, Love Lane School, the old Post Office, former Elephant and Castle pub on the corner of Castle Road, the Baptist Chapel from the late 18th century, the Paul Pry which is not listed, the grand Rayleigh House and cottages opposite (none listed), right down to the Beautiful Weir Farm. It is not just the buildings that make a conservation area, fine trees and vegetation, in abundance at these locations, also make an important contribution in this area. . We should value High Road - the entry into Rayleigh – to a much greater extent. It should be incorporated into an enlarged Rayleigh Conservation Area. There has been survey evidence of resident approval of an extension to the Conservation Area (I can provide details if required).

Q45 Additional buildings local list buildings in Rayleigh Mill Hall, Civic Suite with Council Chamber, Rayleigh Library,( Paul Pry pub, Rayleigh House and old Post Office if not already on the List). The principle of adding to the list is a good one and should be considered during the Local Plan process with public input.
Q46 keep all parking spaces, make them easily accessible and affordable, maintain town centre facilities and shops. Do not allow residential development in Rayleigh Conservation Area which will lead to downgrading of shopping facilities and the loss of community assets like Mill Hall and Civic Suite.
Q47 the natural hierarchy of Rayleigh is threatened by proposed housing development of COL07 and COL20.
Q50 we must protect Rayleigh with it’s vibrant town centre with shopping and other facilities. The biggest threat to Rayleigh Town Centre and Conservation Area is the District Council’s own plan to demolish and promote residential development on sites COL07 AND COL20. RDC has a vested interest in these development sites. This must not sway their impartial creation of a Local Plan.
Q51 RDC must retain all its Rayleigh town centre car parking.The Rayleigh car parks are unusually attractive and do not receive adequate recognition of their contribution to the town’s Conservation Area, views of historic buildings, parks and gardens. They add significantly to the the town centre vitality. Building on any part of them should be forbidden.
Q53 safe cycle routes requires more attention and support in the new RDC Local Plan.

Q56 Vision statement ignores major traffic problems in Rayleigh. I would challenge the optimistic words about walking distances. Rayleigh has grown to such an extent that walking to the town centre is impractical for many of the new developments. There must be no further urban extension developments in / around Rayleigh / Rawreth.
All potential development areas around Rayleigh and Rawreth should be excluded from development sites in the new Local Plan. This is important in view of the enormous amount of urban expansion during past decades and lack of infrastructure and facilities. I strongly object to site COL07 (Mill Hall, car park and green) and also site COL20 Civic Suite with landscaped gardens to the rear being included in the Local Plan as future residential development sites.

Under Section 71 of the Planning (listed Buildings & Conservation Areas) Act 1990 and other legislation Rochford District Council has a duty to preserve and enhance the Rayleigh Conservation Area. Both sites are surrounded by listed buildings and a Scheduled Ancient Monument in the case of Mill Hall, neither should not be developed for housing. The setting of the listed buildings are also greatly enhanced by the gardens and the landscaped car parks which make a significant contribution to the conservation area, these would be lost if developed for residential use.

Under S.39 Planning & Compulsory Purchase Act 2004, the Planning & Compulsory Purchase Act 2004 and other legislation and guidance, Rochford has a duty to contribute towards achieving sustainable development.
It is widely acknowledged that the greenest building is the one already there. The carbon footprint of demolishing existing buildings on these sites will significantly increase the carbon footprint of the whole district. In is important therefore to invest in the present buildings and make them more sustainable (Mill Hall would appear to offer significant opportunities.).

Under S.40 of the Natural Environment & Rural Communities Act 2006, the local planning authority has a duty, when exercising its functions, to conserve biodiversity. The green areas and trees on both sites greatly contribute to the biodiversity of the area. In particular in this conservation area, which is not only valued for its buildings but for the mature trees and open space owned by the public. The loss of this biodiversity would be unacceptable if these sites were changed to residential use in the next local plan.

The contribution of car parking to the vitality of the town centre is significant and loss of public car parking within COL07 and COL20 would be detrimental to the Rayleigh Town Centre.

The above are borne out by Rochford Council's own plans and policy documents

Q63 Greater Rawreth has also sustained huge amount of development and has significant flood issues. Rawreth has no facilities. No further development should be permitted in in the Rawreth parish area.

Q65 C. Sutton and Stonebridge. I would not support additional development as extensions of these existing communities. However, the Sutton Parish does hold potential for a Garden Village site which could join onto main access roads and facilities nearby. Included in this is the opportunity of access to nearby retail and other facilities in Southend.
Sites within Sutton Parish that should be considered are CFS155, CFS260Z, CFS260AE, CFS260AE, CFS260H, CFS260AK, CFS071,CFS071, CFS260G.

Local Plan Spatial Options Consultation
Please find below the comments from Hockley parish Council regarding the Spatial Options consultation.
The need for housing is understood but many of the proposals in the Local Plan Consultation and the impact of over-development in Hockley are a major cause for concern, especially without evidence of supporting infrastructure. This initial consultation informs residents of landowners who have put forward sites for future development so there is a personal gain aspect here. Rochford District Council has a duty to actively support residents needs in all communities and influence
Government policies.
Consultation Process -The volume of information contained in the consultation was difficult to access and view online. Some links did not work properly. RDC are not reaching residents who have no internet.
Spatial Themes not included - Cultural and Accessibility.
Vibrant Town Centres: Work actively with premises owners to assist in the re-letting of any empty shops. Maybe offer a reduced rent to new businesses as a start-up scheme for “local” business only – allowing the entrepreneurs in the Rochford District a chance to showcase their businesses. Discuss with owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows, perhaps photos of the old towns or useful information, to make them more attractive.
Employment – District is lacking in Environmental services - woodland conservation and management. Work with local schools and colleges, as well as businesses and the job centre, to see what sustainable employment is needed in the district. Incorporate ways to assist in schemes/apprenticeships to train all ages get back into work or upskill (with jobs at the end of training.) Developers should be encouraged to use local labour. The current employment site allocations on Figure 30 do not provide enough space to meet the district’s employment needs through to 2040. There are eighty-seven thousand people in the district. There is no data on the form to suggest how many of these are in employment and how many are looking for work, but the
council need to reassess its future needs to future-proof our residents’ opportunities Improve Long-term Economic growth - Better road networks, gigabit broadband and Wi-Fi. The council should stop developing existing commercial land into housing.
Planned Forms of Housing: Young people/couples do indeed find it difficult to purchase property in Hockley. It is hoped that the new developments proposed will cater for their needs with more semi-detached properties than is now the case. The growing elderly population requiring
specialist/suitable accommodation need assistance. Many elderly single people are living in familysized homes when they would prefer more suitable accommodation such as bungalows or purpose-built flats. Mix of housing for “affordable“ properties with higher standards for gardens and recreational space. Consideration should be given to the provision of house for life, Adapted homes for the disabled, bungalows and other potential buildings for downsizing families. Housing
for the hidden homeless – those “sofa surfing” & Emergency housing. The plan makes no reference
to social housing quotas which should be included in all new developments. By working closely with planners and developers, as well as different charities and communities, residents, and businesses. You will then get a better understanding as to what you need and what will be achievable.
From 1st August it was announced that empty buildings and brownfield sites should be converted rather than build new. This alternative should be evaluated first.
Many development proposals would also mean a further reduction in air quality, light pollution and the loss of trees, farming, and arable land at a time when food production and supply is becoming a cause for concern.
Care needs to be taken to maintain the integrity of the existing settlements with respect to green boundary between Hockley and its neighbours. Essential green belt is being allowed to erode further (suggested land at north of Merryfields Avenue, Turret Farm, Church Road, land north east of Folly Lane, a number of sites on Greensward Lane, Lower Road and High Road) which will be impossible to replace.
Enforcement on unauthorised development is not adequately managed.
Local generation of low-carbon and renewable energy – It is encouraging to learn of Rochford
District Council’s intention to provide housing to meet the needs of both young and old that are
carbon neutral and energy efficient. New developments should be able to source some or all their energy from renewable sources. Solar in all new development as standard. Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs; there are many flat roofed buildings all over the district
that could accommodate solar panels without damaging the landscape. Explore tidal energy and seek out suitable locations to ascertain whether it is viable. Retrofitting existing housing and commercial buildings.
Infrastructure - The Council cannot comment on the suitability of sites in the plan without completion of Infrastructure Delivery & Funding Plan, Level 2 Strategic Flood Risk Assessment and Local Cycling & Walking Infrastructure Plan. This is a continuing concern to residents due to the volume of recent and proposed development causing additional pressure on roads, education, social services, health facilities and local
employment opportunities all of which gives a sustainable balance for our communities. The Infrastructure Funding Statement states all financial and non-financial developer contributions relating to Section 106 conditions should be completed but this is not the case when larger sites
are split up. If developers do not honour the conditions the money reverts to ECC and RDC who should use this to improve our existing facilities, especially on our roads and cycle paths which are in a pitiful state of repair and will only worsen with further development if funding is not used where was intended. The volume of traffic has increased to an unacceptable level on the B1013
causing noise, air pollution and disturbance; Is the traffic survey up to date?. The main access to Hockley and on to Southend is via the B1013; one of the busiest ‘B’ roads in the country. It is difficult to understand how this already congested road could cope with the vehicles from another 1,000 houses in Hockley, let alone those from adjacent villages and towns. Rochford District is on
a peninsular: traffic can go no further than Southend especially with limited access to the north of the county via Battlesbridge. It is suggested the Council undertake a road traffic survey before continuing with the District Plan.
Good public transport links are crucial for our villages, neighbourhoods, and town centres. Hockley
benefits from being on the main Southend Victoria/Liverpool Street train line. Unfortunately its bus
service is not so efficient with the nos 7 and 8 services passing through the village from Southend to Rayleigh and vice versa twice an hour. Services to other parts of the district/county have to be accessed from these two termini. The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian, and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a complete review of sustainable transport. Cycling infrastructure and other sustainable transport methods should be prioritised over a car-centric highway use.
Balancing access against increased congestion will be the issue for a lot of the promoted sites in Hockley. If RDC keep adding small developments to the boundaries of the town, it will overcrowd existing houses and add to urban sprawl.
Ensuring that public rights of way are not blocked by landowners and are kept free from debris. Assess paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look at offering this in the larger spaces. For example, a small toilet block and hand washing facilities in a car park.
Community infrastructure - Community infrastructure should be preserved and extended.
Access to town centres and secondary shopping by bicycle and foot should be made easier and safer. Hockley has a road network no longer fit for purpose, some schools are near to capacity, it is difficult to obtain a GP or dental appointment. Hockley is served by two GP practices, as has been the case for 50 years or more. Hockley’s health clinic closed in the last few years and
young mothers and the elderly have to travel to Rayleigh for medical attention. What are the plans for additional health services in line with the vastly increased population should the plan be enforced?. There is little to no disabled play areas or play equipment. There are always issues with waste collections, drain and road cleaning and verge trimming. The District Council does not have the staff to deal with all these issues. The current recycling site at Castle Road, Rayleigh is
no longer capable of expanding to meet the needs of an ever-growing population. The plan should also identify a site to accommodate commercial waste facilities to stop fly tipping.
Open Spaces - The value of our open spaces and the issues with climate change has become a priority. People will continue to reduce travel and split time working from home. Our open spaces are essential for wellbeing, exercise and relaxation. We are on an overpopulated peninsular surrounded by water with one way in and one way out and there is a proven risk of flooding. Open
space is at a premium. Unfortunately for the youth of Hockley, there is no sports field they can use in the village. The District Plan does mention the use of the Greensward Playfield and it is to be hoped this will be progressed. The District Plan places great emphasis on health and wellbeing. Fortunately Hockley is well served with a network of footpaths. It is important that they
are maintained and not encroached upon by development All green spaces, no matter how small, hold some significance, especially to those who use them
for recreation. They are of community value and should not be developed. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets. RDC must protect all recreational spaces
and improve them, where necessary.
Conservation areas, Green Belt & sites subject to the exclusion criteria (i.e. Sites of Special Scientific Interest) on the call for sites must be protected from Development.
Local Wildlife Sites review: RDC policies for protecting wildlife areas need to be updated. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was. Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. The plan should create new wildlife meadows to encourage the pollinators to future proof our own existence.
RDC to focus on concerns and consideration to wildlife, birds, animals, and insects. Alongside plants and endangered species. Surrounded by Green Belt, Hockley is lucky in having access to a number of open spaces. It is noted that the Marylands Nature Reserve is included in The District Plan but not Plumberow Mount Open Space or St Peter’s Road Open Space – all maintained by the Parish Council. Marylands Woods, Plumberow Woods, Crabtree Woods, Hockley Hall Woods and nearby
Beckney Woods are all ancient woodland but in private hands. It would be of great benefit to the community if they were included in the Local Plan and protected for the future. Betts Wood and, of course, Hockley Woods are in the care of the RDC. With so much development, it is obvious that flora and fauna will suffer. Consideration should be given to identifying further green spaces (not just play areas) for public use. Efforts should be
made to ensure wild-life corridors are incorporated into developments near to woods and open countryside.
Heritage
The District Plan contains a list of conservation areas. It is disappointing to note that St Peter and Pauls’ Church, Church Road and adjacent buildings (the old school house, Hockley Hall, Mill House and the former rectory) does not appear. In the surrounding green belt, it is constantly under threat and it would be a tremendous loss to the community should this historic part of the
village be developed.
Plumberow Mount (a Romano/British tumulus) does not appear in the document as an ancient monument.
Promoted Sites (Hockley)
The plan proposes around 1000 additional houses in Hockley with other developments on land bordering the parish. This density will have a major detrimental impact on the quality of life for the settlements.
• CFS105 (Land North of Hambro Hill) would negatively impact the openness of the Green Belt between Rayleigh & Hockley. Rochford Green belt study states this parcel of greenbelt has a ‘Moderate’ rating for Purpose 1, and a ‘Strong’ rating for 2 & 3. It checks the unrestricted sprawl of large built-up areas, prevents Rayleigh & Hockley merging into one another, and assists in safeguarding the countryside from encroachment.
• The Merryfields Avenue (green belt) proposal has been previously rejected by residents due to access issues as the land borders on the Nature Reserve and footpath 13. Consideration should be given to incorporating it into the Reserve rather than releasing it for development. The owner of the tract of land has made a few unsuccessful planning applications in the past on account of the threat to local wildlife, impact on ancient woodland, lack of access, the danger of flooding from the nearby stream and run off from the road. The cost effectiveness of providing access and services could prove to be exorbitant along with any damage incurred on the nearby
Nature Reserve, better that the land become part of the Reserve.
• Proposals for Folly Chase and Church Road will increase density and give further traffic problems on a busy county access road which has light industry and equestrian centres but does not have footways for pedestrian safety; vehicles are also subject to dangerous line of sight restrictions. The Folly Chase proposal was previously rejected by residents and supposedly dismissed by RDC but still appears in the Local Plan for development. The land to the north east of Folly Chase is adjacent to ancient woodland with protected trees (Betts Wood).
To the west of the site there is a green lane bordered with ancient trees which should be protected if development takes place. There is no public access to the site and there is concern that the adjacent community centre could be sacrificed for this purpose. What are the plans for the Community Centre and public footpaths which must be retained?
• Sheltered accommodation is in danger of being lost at Lime Court and Poplar Court.
• The proposal for development on land at Belchamps is particularly contentious due to the lack of open space for activities available to youngsters and community groups in the Rochford District. Any considered development would be a detrimental impact to the Historical
woodlands. This site has been a very valuable well used resource and it is important this is retained for our future generations.
• As Hockley Woods is the largest remaining wild woodland in the country RDC should be doing EVERYTHING it can to save it from development, either adjacent to or close by. RDC should also actively be adding to it by planting more trees to future proof its existence and status. RDC must protect any thoroughfares that access Hockley Wood.
These comments will be publicised on the Parish Council website, I would be grateful if you could do the same on the Rochford District Council website.

1. INTRODUCTION
1.1 These representations have been prepared by Pegasus Group on behalf of Penland Estates Limited in respect of their land interests in Rochford District Council (RDC).
1.2 These representations are submitted in response to the current Rochford Local Plan Regulation 18 ‘Spatial Options' consultation, which sets out the different growth
strategy options that could be pursued by the Council in the emerging Local Plan. The evidence base accompanying the Spatial Options document includes a Site Appraisal Paper which identifies the suitability of potential sites for allocation, including Penland Estate Limited's interests at:
• Site Reference CFS190: Land South of Pooles Lane, Hullbridge
1.3 The purpose of these representations is primarily to respond to the questions raised by the consultation to ensure there is a sound basis for emerging policies, as well as to support the most sustainable growth options of those set out in the consultation. These representations also confirm the deliverability of the above site and the exceptional circumstances in support of a minor revision to the Green Belt alongside the provision of a site-specific policy that allocates Land South of Pooles Lane, Hullbridge, for residential development in the emerging Local Plan. The representations are supported by high-level technical assessments and an indicative Framework Plan.
1.4 These representations should be read in conjunction with the enclosed high-level technical assessments and an Illustrative Framework Plan, which explain further
the opportunities available to create a high-quality and sustainable residential development with the ability to contribute positively towards the District’s significant housing needs.

2. SPATIAL OPTIONS DOCUMENT
2.1 This section responds to questions posed by the Spatial Options consultation that are relevant to Penland Estate Limited's interests in Rochford.
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?
2.2 The technical evidence that has been prepared and is yet to be prepared by the Council is supported as being required to inform the production of a sound Local
Plan in accordance with the provisions of the National Planning Policy Framework (NPPF 2021).
Q2. Do you agree with our draft vision for Rochford District?
2.3 Penland Estates Limited considers that the Draft Vision for Rochford District Council provides a sound basis for preparing a spatial strategy. Land to South of Pooles Lane, Hullbridge, will deliver upon the draft vision of Rochford District by providing a high-quality, well-designed development in a sustainable location with good
access to services and facilities which will foster vibrant and healthy communities.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
2.4 Penland Estates Limited broadly agree with the importance of adopting a range of separate visions for each of the District's settlements to help apply the district-wide vision and objectives at more localised settings. Nevertheless, there is likely to be considerable cross-over between the specific visions for individual settlement, and
as such, the benefits of this approach might not be fully realised.
2.5 Furthermore, this is likely to be quite a time-consuming exercise for the Council's Planning Policy Team to create separate visions for each of the District's
settlements. The Draft Local Development Scheme (2021-23) anticipates that the Local Plan could be submitted to the Secretary of State for independent
examination by Spring 2023, thus providing a short timescale to prepare and submit the emerging Local Plan. Therefore, it is considered that the resource of the
Planning Policy team is likely to be better deployed in other more pressing aspects of the emerging Local Plan process.
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?
2.6 The Spatial Options document identifies five ‘Strategic Priorities.' Strategic Priorities one (meeting the need for homes and jobs in the area) and five (making suitable and sufficient provision for climate change mitigation and adaptation, conservation, and enhancement of the natural and historic environment, including landscape) are of particular interest to our client's site.
2.7 Our client is promoting Land South of Pooles Lane, Hullbridge, for the allocation of residential development through the emerging Rochford District Council Local Plan (RDCLP). It is estimated that the site is capable of delivering up to 226 new homes towards meeting the housing need target for the RDCLP. In addition to delivering much-needed market and affordable housing, the site will deliver upon the draft strategic priorities of the RDCLP as follows:
2.8 Meeting the need for homes (Strategic Priority 1 and 2) – Penland Estates Limited prides itself on working with developers that deliver well-designed, highquality, and sustainable homes for all to enjoy. Any scheme delivered on the site would provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include affordable housing provision which would be tenure blind in terms of design and well-integrated into the scheme to enhance social cohesion and generate community spirit. It is agreed that the
delivery of new homes sufficient to meet local housing need should be assigned great importance.
2.9 Climate change (Strategic Priority 5) – Any scheme would provide modern high-quality living with housing that meets the latest Building Regulation requirements in respect of energy and water consumption. In addition, the site is located in a highly sustainable settlement, within walking distance of a range of shops, services and pre and primary schools. The site’s location and proximity to
the local service provision in Hullbridge would assist in reducing travel by car and thus assist in reducing carbon emissions.
2.10 Natural environment (Strategic Priority 5) – Any scheme brought forward would aim to achieve a net gain in biodiversity through the retention, protection and enhancement of any on-site habitats, provision of extensive new public open space and high-quality landscaped areas. Existing vegetation at the site would be retained and enhanced through new planting to enhance the potential for habitat creation. In addition, drainage attenuation basins, required as part of the surface water drainage strategy, offer further potential to boost on-site biodiversity.
2.11 Furthermore, whilst the site is currently located in the Green Belt, the evidence provided in our representations and accompanying Green Belt Appraisal demonstrate that the site performs poorly against the five purposes of Green Belt as set out in the NPPF and is capable of coming forward for development without unduly damaging the integrity of the Green Belt. The evidence gathered by the Council clearly illustrates that the District's housing need cannot be sufficiently met
through urban and previously developed land only. Some release of Green Belt land in appropriate locations should be recognised as being necessary where 70% of the
District is designated as Green Belt. The release of Green Belt sites such as Land South of Pooles Lane, Hullbridge, will allow the continued sustainable growth of existing settlements, and would be consistent with the NPPF.
2.12 Historic environment (Strategic Priority 5) – The evidence provided in our representations, the accompanying Heritage Appraisal (see attached at Appendix A) and the Council's Initial Heritage Assessment of Submitted Sites (October 2020)
demonstrates that the site does not adversely impact any nearby heritage assets either directly or indirectly.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
2.13 The Options Spatial Paper includes a draft settlement hierarchy based on the 2021'Settlement Role and Hierarchy Study,' which uses various factors (including population size, availability and range of services and transport accessibility) to assess the relative sustainability of the District's multiple settlements.
2.14 The Adopted Core Strategy (2011) categorises Hullbridge (and Great Wakering) as a second-tier (out of four) settlement, where there is considered to be a more
limited range of services and access to public transport is judged to be relatively poor. The Spatial Options paper shifts Hullbridge into tier three (out of four) of its
draft settlement hierarchy. This appears to be due to the sub-division of Tier 1 of the Adopted Core Strategy into Tier 1 and 2 of the draft settlement hierarchy, with
Rayleigh remaining in Tier 1 and Rochford (including Ashingdon) and Hockley (including Hawkwell) shifting down into Tier 2 2.15 In addition to Hullbridge, the new proposed Tier 3 includes Great Wakering and
Canewdon. Penland Estates Limited, as outlined below, considers that Hullbridge is better related to the Tier 2 settlement of Hockley in terms of access to services,
population, geographical size, and transport accessibility, compared to the Tier 3 village Canewdon:
2.16 Population – according to the Parish Council website, Hullbridge's population is approximately 7,300, which is markedly greater than that of Canewdon (Tier 3) at circa 1,100. The other Tier 3 settlement of Great Wakering (including Little Wakering and Barling) has a similar population to Hullbridge at circa 7,200.
However, it is recognised that Hullbridge has a growing population, particularly through strategic allocations, such as the 500 unit Lower Road development in southwest Hullbridge (adopted Policy SER6 – South West Hullbridge). It is also anticipated that Hullbridge's population will continue to grow through strategic
allocations in the emerging Local Plan, given the sustainability of the settlement and its ability to support continued growth. This means that the population of
Hullbridge is anticipated to move closer to the suggested Tier 2 population threshold of 10,000.
2.17 Access to public transport – Hullbridge is serviced by the frequent no. 20 bus route operated by Frist Group (every 30 minutes between 7.00 to 21.00 Monday
to Saturday) to Southend via Rayleigh, where wider connectivity into London via the Greater Anglia train service is available. Great Wakering is similarly wellconnected as Hullbridge to public transport links; however, Canewdon is only serviced every two hours by the 60 bus route to Southend via Rochford. It is
recognised that neither Hullbridge nor Great Wakering includes rail links, as available in the Tier 2 settlements. Nevertheless, the frequent bus journeys to these rail station destinations from Hullbridge (and Great Wakering) provide accessible sustainable transport options for residents of these settlements.
2.18 Range of services and facilities – the village of Hullbridge has a good range of services and community facilities capable of meeting the everyday needs of
residents. These include three convenience stores, a dentist, GP surgery, library, pharmacy, a pre-school and primary school and public houses, fast food outlets
and restaurants. In comparison, Canewdon does not possess any such range of services facilities, with only a primary school, a convenience store, and a public
house. Great Wakering has a few more facilities, including a primary school, medical centre, and pharmacy and two public houses, albeit not to the extent found
in Hullbridge.
2.19 It is recognised that Hullbridge does not include a secondary school. Nevertheless, the no. 20 bus route provides a regular service (every 30 minutes) to the
settlements of Rayleigh and Hockley, which contain secondary schools as well as higher order retail services.
2.20 Access to jobs – several small-scale businesses are positioned around Hullbridge and at the various facilities and services mentioned above, which could
accommodate some local employment opportunities. It is considered that such employment opportunities would not be available at the Tier 3 settlement of Canewdon.
2.21 On the above basis, it is considered that the range of existing services and facilities available in Hullbridge mean that the village is better related to Tier 2 of the
settlement hierarchy than Tier 3. It is important that the Council has due consideration of the sustainability of Hullbridge when determining what level of growth is appropriate. The designation of Hullbridge as a Tier 3 settlement should not in itself be taken as a reason for allocating a certain level of growth. This is especially important as the Spatial Options document recognises that Hullbridge (and Great Wakering) are larger settlements than Canewdon; the scale of new
growth that would be appropriate for the settlements would therefore differ.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
2.22 Penland Estates Limited strongly agree with the identification of a housing requirement of 7,200 homes based on the standard method, which is in accordance
with paragraph 61 of the NPPF. The acknowledgement that this housing requirement forms the minimum housing needs for the District is also strongly agreed with; the Council must explore all opportunities available to accommodate additional growth above the minimum requirement and take on unmet need from neighbouring authorities that are constrained in the level of housing growth they are able to deliver.
2.23 The Spatial Options Document recognises that there is potential for Rochford District to accommodate unmet need from neighbouring authorities. The District's
neighbours are burdened with constraints to identifying sufficient land for housing, such as significant areas of Green Belt land which envelops existing urban areas
and areas of high flood risk. The authorities located within the same housing market area as Rochford have also struggled with maintaining sufficient levels of housing
delivery, further highlighting the importance of this matter. We therefore consider it to be highly likely that there will be unmet need arising from neighbouring authorities. In particular, early evidence issued for the Southend-on-Sea Local Plan preparation has indicated that Southend will require some of their housing requirement to be delivered in Rochford District (Issues and Options consultation,
April 2019). It is therefore vitally important that Rochford District pursues a growth strategy that includes a buffer in excess of the minimum housing required to meet local needs.
2.24 On the basis of the above, Growth Option 1 should be discounted as the strategy would not secure the level of housing required to meet the identified minimum
housing requirement. A sound Local Plan could not therefore be produced following this strategy.
2.25 Of the remaining options which would deliver sufficient housing growth, Penland Estates Limited is strongly supportive of Option 2 (Urban Extensions), particularly Option 2b 'Urban extensions dispersed to settlements based on hierarchy.'
2.26 Firstly, it is recognised that Rochford District Council have had a historic record of housing under-delivery, which in 2020 resulted in the Council having to publish a
Housing Delivery Test Action Plan as their 2019 Housing Delivery Test (HDT) was calculated at 77%. The 2020 Action Plan noted that the delayed delivery of several
strategic sites was a key factor. In particular, this was due to prolonged landowner and developer negotiations, delays at the planning application stage, and the time
taken to discharge pre-commencement conditions. The growth strategy for the Local Plan should therefore limit any over-reliance on large-scale strategic urban
extensions for delivering the required amount of housing.
2.27 Consequently, our client considers that the Council should identify available and deliverable small and medium-sized sites (10 and 1,500 homes) dispersed to
settlements based on hierarchy. This approach would be consistent with Paragraph 69 of the NPPF (2021), which states that "small and medium sized sites can make
an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly." The delivery of sites at this scale also helps to
ensure sustainable growth can take place across the District in a dispersed manner that allows all settlements to grow organically. 2.28 The NPPF allows for revisions to be made to the Green Belt boundary through the
Local Plan process where there are exceptional circumstances. As explained earlier, release of Green Belt land is required if the Local Plan is to deliver sufficient housing to meet the local housing needs for the District. This forms the exceptional circumstances required for the release of land from the Green Belt in appropriate locations. The delivery of small and medium-scale sites released from the Green Belt, such as Land South of Pooles Lane, will also play an important role in the Council meeting their five-year housing land supply as required by paragraph 68 of the NPPF.
2.29 Land South of Pooles Lane, Hullbridge, is available and deliverable within the Local
Plan period and should be considered further by the Council. Secondly, Option 2b will support existing services by directing further growth to villages like Hullbridge to support the vitality of local services. This approach is consistent with NPPF 79 of the NPPF (2021), which outlines that "planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services."
Consequently, sites in sustainable locations with good access to a range of services and facilities (generally Tier 2 and 3 settlements) should be selected to ensure the
sustainable and effective growth of settlements across the District.
2.30 The Council's Settlement Role and Hierarchy Study assesses the relative sustainability of individual settlements by considering its 'completeness'. The
theory is that the more services a place has, and the easier to access those services are, the more complete that place is. The 'completeness' assessment is shown in
the form of a heatmap, and for Hullbridge, this is shown on Page 82 of the Spatial Options Paper. Land to the South of Pooles Lane adjoins the north-eastern
settlement boundary of Hullbridge, which benefits from a 'walking completeness score' of between 11 and 13, which is the highest score in Hullbridge and is in the
second-highest category overall.
2.31 This is because the north-eastern section of Hullbridge includes Hullbridge preschool and Riverside Primary School, Hullbridge Community Centre, and a bus stop providing a frequent bus service to Southend and Rayleigh (one bus every 30 minutes). These services and facilities are less than a five-minute walk from Land
to the South of Pooles Lane. Additional services and facilities, including convenience stores, a dentist, GP surgery, library, pharmacy, and other fast food outlets and
restaurants, are within a 10-minute walk from the site. By affording sustainable levels of growth to sites such as these, it will assist in safeguarding existing services, public transport links and infrastructure which local people currently rely upon and support vibrant rural communities.
2.32 For the reasons set out above, Penland Estates Limited strongly supports the pursuance of Growth Option 2b, with concentrated growth dispersed to settlements based on hierarchy. This includes allocating growth in high performing and sustainable Tier 3 settlements, such as Hullbridge.
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 low-carbon or renewable energy?
2.33 Penland Estates Limited supports the Council's ambition of ensuring future growth takes place in a manner that is aligned with the national objective of transitioning towards a zero-carbon economy. Penland Estates Limited intends to work with developers that will create high-quality, energy-efficient buildings, which could
incorporate energy generation and conservation technologies, in line with the Council's strategy to reduce carbon emissions.
2.34 Notwithstanding this, there needs to be a balancing act in order to meet this target against the need to deliver a viable scheme. It is clear that further consideration is
required regarding the expected capital uplifts in the emerging Local Plan to ensure that energy efficiency is considered alongside viability. In doing so, the guidance
should consider the Government's figures in their Draft Future Homes Standard which will be in place by the time homes allocated by the new Local Plan are likely to be built. Any policy brought forward on this matter should therefore be supported by appropriate evidence that has investigated potential impacts on viability. The policy itself should include wording to reflect the importance of considering the overall viability of a scheme when determining the application of energy efficiency
initiatives over and above that required by Building Regulations
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?
2.35 The Council should be consistent with the Government's Draft Future Homes Standard that proposes to remove the ability of local planning authorities to set higher energy efficiency standards than those in the Building Regulations. This is because the Government considers the situation confusing, particularly as the application of energy efficiency standards across local authority boundary lines often means that homes need to be built to different technical specifications. This inconsistency creates inefficiencies in supply chains, labour and potentially the quality of outcomes.
2.36 Nevertheless, Future Homes Standard outlines that changes to the Building Regulations are expected to mean that between 75- 80% fewer carbon emissions
are released into the atmosphere from new development compared to ones built to the 2013 Part L requirement. Requiring new developments to achieve energy
standards higher than the proposed changes to the Building Regulations would need robust evidence identifying the need for such a requirement.
13. How do you feel the plan can help to support the local generation of lowcarbon and renewable energy? Are there locations where you feel energy generation should be supported?
2.37 The Council should promote the idea of the Local Plan supporting renewable energy developments by designating appropriate locations within the District for lowcarbon and renewable energy generation projects. The Council could consider a
'call for sites' process for potential low carbon and renewable sites submitted by landowners, site promoters or developers. The Council could then assess the suitability of submitted sites using relevant criteria.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
2.38 Penland Estates Limited broadly supports the principles contained in the draft place-making charter, which sets out a number of key principles for how new
development is expected to be delivered in a way that contributes positively to their setting and wider environment. In taking this charter forward however, it should be made clear what weight will apply to the principles contained in the charter at the development management stage, as well as how the charter will interface with development management policies.
2.39 Penland Estates Limited prides itself on working with developers that deliver welldesigned, high-quality and liveable schemes for all to enjoy. Place-making and
creating a sense of identity is at the heart of the scheme design shown on the enclosed Development Framework Plan (see attached at Appendix B), with a
consideration of the opportunities and constraints of the site (see plan attached at Appendix C). New dwellings would be modern but sensitively designed to complement the character of the local area, and public open space would be delivered to a high standard to stimulate on-site recreation and interaction between residents. The development would be a positive and environmentally friendly place to live, work and play.
Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
2.40 The production of new design guides, codes or masterplans alongside the new Local Plan could provide applicants with clarity about design expectations at an early stage. However, there are two important considerations to take into account.
Firstly, site-specific design guidance is likely to be useful only in cases where the development proposed is at a strategic scale or there are unique constraints which
design guidance would help to overcome. For the majority of small and mediumscale development, development management policies relevant to urban design and placemaking are sufficient in securing a high-quality design.
2.41 Additionally, the production of design guidance requires time and staffing resources. The Council should consider the level of detail required in a design code
and the possible impacts of delays due to detailed discussions and negotiations between applicants regarding a scheme's compliance with a design code. Given the Council's historic under-delivery of strategic housing sites, which has in part been attributed to delays at the planning application stage, it is considered that with the preparation of design guides and masterplans is likely to slow housing delivery rates further if required for all sites.
2.42 The suggestion that design guidance is produced alongside the Local Plan preparation would also potentially delay the Local Plan process; which would mean further delaying the delivery of much-needed homes, given the delays experienced in the Local Plan process thus far. It would also require developers to invest in upfront work with no certainty that their particular site would be allocated in due course.
2.43 As such, Penland Estates Limited considers the preparation of design codes, guides or masterplans should be limited to large-scale strategic sites or sites with particularly complex delivery strategies only. All other developments can be brought forward appropriately without specific design guidance, as development
management policies related to design will ensure the correct design principles are followed.
4 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?
2.45 Penland Estates Limited recognises the importance of providing a mix of homes to meet the identified local housing needs. Option 2 is supported as providing a logical and flexible approach to ensuring that each new development provides a mix of housing that is appropriate to its location, taking into account all relevant sitespecific factors. This would ensure schemes can provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include an element of affordable housing provision which would be tenure blind in terms of design and be well integrated into the scheme to enhance social cohesion and generate community spirit.
Q31. Do you consider net gains for biodiversity are best delivered on-site or offsite? Are there specific locations or projects where net gain projects could be delivered?
2.46 National guidance outlines that biodiversity net gain can be achieved on-site, offsite or through a combination of on-site and off-site measures. Schemes should come forward with the aim of achieving a net gain in biodiversity through the retention, protection and enhancement of any on-site habitats, provision of extensive new public open space and high-quality landscaped areas wherever
possible. However, the option of achieving net gain through off-site contributions or habitat creation should not be discounted, as there may be site constraints such
as viability which limit a site's ability to provide net gain on-site.
2.47 Existing vegetation at Land South of Pooles Lane site would be retained and enhanced through woodland belt planting to enhance the potential for habitat creation, as shown on the illustrative Development Framework Plan (Appendix B). In addition, surface water detention basins, required as part of the surface water drainage strategy, offer further potential to boost on-site biodiversity. All opportunities will therefore be taken to enhance the biodiversity of the site.
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?
2.48 National policy outlines that strategic plans should take a strategic approach to green and blue infrastructure to help promote active and healthy lifestyles, combat climate change and alleviate air quality issues. Well-designed green infrastructure can provide a sustainable alternative to car use through a connected network of
public rights of way and greenways. Proposed option 3 is supported, as the delivery of new and enhanced green infrastructure on new development sites will assist in
creating an improved network of green infrastructure throughout the District.
2.49 In reference to Option 2b ('Urban extensions dispersed to settlements based on hierarchy'), the Council should select sites that are in close proximity to the existing and proposed green and blue infrastructure networks to ensure that future residents have a sustainable alternative to car use. Land to the South of Pooles Lane is located within the Option 2b strategic area, and there is an existing 'secondary greenway' (ref PROW 287_6) approximately 300m to the east of the
site, running in a north-south direction as indicated on Figure 32 of the Spatial Options Document. To the north, this greenway connects to a network of existing and proposed coast paths along the River Crouch, which is less than a 5-minute walk from the site. To the south, this 'secondary greenway' connects to a network of primary greenways circulating Hockley.
2.50 The Land South of Pooles Lane, Hullbridge, promoted by our client Penland Estates Limited, is well placed to encourage a shift away from the private car. As shown by the submitted Framework Plan, any development at the Pooles Lane site will integrate into the existing highway network by providing vehicular, pedestrian and cycle access points. The Council's Site Appraisal (2021) recognises the accessibility of the site to existing walking and cycling infrastructure, as Land South of Pooles Lane (ref CFS03) is scored at level 5 (highest category), as the site is within 400m of an existing cycle or footway.
2.51 In contrast however, the Site Appraisal (2021) scores the site at level 2 for accessibility to public rights of way (the second-lowest category), as there are
adjudged to be no PROWs with 400m. However, a PRoW (ref 287_12) does indeed run along part of the site's eastern boundary, as indicated on the submitted Framework Plan and connects to the 'secondary greenway' (ref PROW 287_6), further to the south. Future residents of the site will significantly benefit from the existing and proposed green and blue infrastructure, which is directly connectable from the site. This inaccuracy within the Council's site assessment should be rectified to correctly reflect the sites accessibility in all ways, including to the PRoW network.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?
2.52 There is the potential for new development to contribute towards the upgrade and maintenance of existing facilities. Penland Estates Limited would welcome the opportunity to engage with the Council and local stakeholders in Hullbridge to understand local community needs.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
2.53 In reference to Strategy Option 2b ('Urban extensions dispersed to settlements based on hierarchy'), the Council should support sites that can help improve open space or sports facility accessibility or provision. This would be in line with proposed option 4 for meeting open space needs through the Local Plan, which proposes requiring new developments to provide on-site open space or contribute towards improving existing recreational facilities.
2.54 Land South of Pooles Lane is located in the Option 2b settlement of Hullbridge. As identified in the 2009 Rochford District Council Open Space Study, Hullbridge has deficits against the local minimum standards of natural and semi-natural greenspaces (-2.05ha), amenity green space (-0.11ha) and children's play space (-0.01ha). Incidentally, Hullbridge has the second-highest deficit in the District for the provision of natural and semi-natural greenspaces. The provision of sports facilities is 0.53ha above the local minimum standards. It is recognised that the Open Space Study informing the evidence base is slightly dated. Nevertheless, it is
expected that the settlement's deficits (or low provision levels) of semi-natural greenspace and amenity green space, and children's play space are likely to still
exist in the village.
2.55 Taking this information into account, Land South of Pooles Lane has the potential to provide around 3ha of open space throughout the site, serving a range of
different purposes. Open space will be landscaped with a variety of natural and semi-natural areas, such as new woodland belt planting and mixed grassland areas
to promote biodiversity. Circular walking routes are provided, integrated into the wider network of public rights of way in the area. A centrally located locally equipped area for play (LEAPS) can also be provided. The open space would be delivered to a high standard to stimulate on-site recreation and interaction between residents. The development would be a positive and environmentally friendly place to live, work and play.
2.56 Land South of Pooles Lane achieves the highest score for access to public open space in the Council's Site Appraisal (2021) paper, given that Hullbridge Playing
Field is located directly opposite the site. Hullbridge Playing Field contains various existing sports facilities, including a BMX track, skate park, basketball court, sports pitch, as well as play equipment. Furthermore, Hullbridge Yacht Club, located on the River Crouch, is less than a five-minute walk, providing future residents with a wider range of sports and leisure facilities. The Council should consider allocating sites, such as Land South of Pooles Lane, in the emerging Local Plan that are well placed to provide accessible open space and sports facilities, either on-site or within
close walking distances.
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?
2.57 Paragraph 104 of the National Planning Policy Framework (NPPF) identifies that transport issues should be considered from the earliest stages of plan-making,
which includes opportunities to promote walking, cycling and public transport. The importance of encouraging a shift towards more sustainable modes of transport is
recognised as this will assist in reducing climate change and congestion levels on roads.
2.58 The four options set out in the Spatial Option document are considered to be logical approaches to take in addressing transport and connectivity issues. The Rochford Local Plan should also promote sustainable forms of transport by allocating housing sites in sustainable locations in established settlements which possesses good quality public transport links, including; bus services, footways and cycleways. The preparation of an Infrastructure Delivery Plan or Cycling Delivery Plan would provide clear evidence of the infrastructure improvements that may be required to further support and achieve sustainable development.
2.59 The Land South of Pooles Lane, Hullbridge, is exceptionally well placed to encourage the shift away from the private car. As shown by the submitted
Framework Plan (Appendix B), any development at the Land South of Pooles Lane site will integrate into the existing highway and pedestrian infrastructure by
providing vehicular, pedestrian and cycle access points in appropriate locations. 2.60 By utilising the proposed access points, residents of the scheme will have
convenient and sustainable access (via walking or cycling) to education, a range of shops, and services capable of serving their day-to-day needs. The public transport links available to residents of a scheme at Land South of Pooles Lane are summarised in the schedule below. Access to these services could be further
improved through new development resulting in an increased level of users.
Public Transport Links
Bus stops outside Riverside School, Ferry Road:
No 20 bus service from Hullbridge to Southendon-Sea via Rayleigh:
Monday to Saturday- every 30 minutes
between 7.00 to 21.00, and hourly between
22.15 and 23.15
Sundays- every 30 minutes between 9.00 to
21.30
(0.3km – to bus stop, 3-10 minute walk)
Hockley train station,
Station Approach Hockley SS5 4BG
(6.2 km, 19 minute cycle, 10 minute car)
Rayleigh train station, 1 Castle Dr, Rayleigh, SS6 7HT
5.1 km
(18 minute cycle, 9 minute car,15 minute bus)
Q60a. Do you agree with our vision for Hullbridge?
2.61 Penland Estates Limited broadly support the draft vision of Hullbridge becoming self-sufficient and accessible by sustainable means and to make the most of its location by opening up its coastline as a more attractive and usable space for both residents and visitors. Any development should respond to meeting the housing needs of local residents, and it should be acknowledged that the aims of meeting housing needs and Hullbridge becoming self-sufficient are interlinked. The growth of service provision would be supported by new housing and new customers, which would encourage new businesses as well as support the vitality of existing
businesses.
2.62 The vision currently references the need to provide suitable housing for the elderly, which our client supports. However, the vision should be expanded to incorporate
the needs of young families and parishioners seeking local and affordable housing to ensure a diverse and sustainable settlement can be maintained.
2.63 Land South of Pooles Lane would seek to provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include
a provision of affordable housing which would be tenure blind in terms of design and be well integrated into the scheme to enhance social cohesion and generate
community spirit.
Q60b. With reference to Figure 48 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
Housing [market, affordable, specialist, traveller, other]
Commercial [offices, industrial, retail, other]
Community infrastructure [open space, education, healthcare, allotments, other]
Other
2.64 As mentioned in answer to question 6 above, Penland Estates Limited supports Growth Strategy Option 2b. This strategy would provide new development in
sustainable locations across the settlement hierarchy, of a scale that is suitable to the services provision in the relevant settlement. Land South of Pooles Lane (ref
CFS190), promoted by Penland Estates Limited to provide a medium-sized housing scheme, is exceptionally well placed in this regard. It would adjoin the north-western boundary of Hullbridge and lead to the natural extension of this sustainable settlement. The site is incredibly well related to existing services as illustrated on
the walking completeness score replicated below. Development of the site offers the potential to increase permeability within this part of the village, improving
access for existing residents located north of Pooles Lane. 2.65 This accessibility has been reflected in the Council's Site Appraisal Paper (2021), which aims to provide an indication of the relative sustainability and suitability of potential housing sites. For example, the site scores in the highest accessibility (category five) for access to a primary school (less than 400m), a bus (more than 10 bus services provided per hour within 400m), and walking and cycling infrastructure (less than 400m from existing footway and cycle paths). This assessment is strongly supported as reflecting the location of the site in relation to services and facilities, as illustrated in the summary table below.
[see document for table]
2.66 However, the site scores poorly in the following categories: green belt impact (level two), agricultural land classification (level one), access to a train station (level one), access to a secondary school (level one), town centre (level one) and employment site (level one). Additional information is outlined below to provide a more robust assessment of the site's credentials against its poorly performing categories from the Site Appraisal Paper and demonstrate the deliverability of the site.
Green Belt
2.67 Given the extent of the Green Belt across the District and drawn tightly around sustainable settlements such as Hullbridge, it is vital that specific parcels of Green
Belt land adjacent to settlement boundaries are subject to a detailed Green Belt review process. Notwithstanding its Green Belt designation, this land will often provide a sustainable location for growth by virtue of its proximity to the local service provision and public transport links. We consider that this is the case of Hullbridge, where our client is promoting Land South of Pooles Lane, Hullbridge.
Indeed, this is recognised in the Rochford District and Southend-on-Sea Borough Joint Green Belt Study (February 2020) undertaken by the Council, which at paragraph 3.9 states that the most sustainable sites for allocation may be located in areas that make a strong contribution to Green Belt purposes.
2.68 As explained earlier in these representations, the exceptional circumstances required to justify the release of land from the Green Belt are considered to exist
by virtue of the evidence base demonstrating there is insufficient non-Green Belt land available to accommodate the growth required during the Local Plan period. Paragraph 130 of the NPPF readily acknowledges that the plan making process can incorporate the review of existing Green Belt boundaries in exceptional
circumstances. Penland Estates Limited believe that exceptional circumstances exist to warrant such a review and consider that a modification is required in order
to deliver economic and housing growth which is recognised by the Government to be of national and potentially international importance.
2.69 Central to this review should be an assessment of specific parcels of land with development potential against the five purposes of Green Belt as set out in the
NPPF. Sustainable sites for housing growth which are found to not contribute to the five purposes of the Green Belt should be released and subsequently allocated for
development. It is strongly contested that this is the case for the Land South of Pooles Lane. The evidenced and justified release of this land from the Green Belt will allow development to come forward which will meet the objectives of achieving sustainable development as set out in paragraph 8 of the NPPF and assist in
delivering growth of regional and national importance.
2.70 In respect of Land South of Pooles Lane, an independent Green Belt Assessment of the site has been commissioned. The Assessment, produced by Pegasus Group, is appended to these representations (Appendix D). The Green Belt Assessment draws on the recently published Green Belt Study (February 2020) but applies a
finer-grain assessment in order to provide a comprehensive and robust, yet concise
assessment. The conclusions in respect of Land South of Pooles Lane contribution to the Green Belt purposes, is outlined below:
• Purpose 1: To check the unrestricted sprawl of large built-up areas. Site Contribution is assessed as Low/weak.
• Purpose 2: To prevent neighbouring towns merging into one another. Site Contribution is assessed as Low/Weak.
• Purpose 3: To assist in safeguarding the countryside from encroachment. Site Contribution is assessed as Moderate.
• Purpose 4: To preserve the setting and special character of historic towns. Site Contribution is assessed as Low/Weak.
• Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Site Contribution is assessed as n/a.
2.71 The detail underpinning the above listed conclusions is evidenced in the Pegasus Group report. In light of the specific assessment against each Green Belt purpose,
the Green Belt Appraisal provides an overarching conclusion which confirms that Land South of Pooles Lane provides a low contribution to the NPPF Green Belt
purposes. In respect of bringing forward development at the site, the Appraisal concludes that:
2.72 “the Council agree that there are exceptional circumstances to justify the release of land from the Green Belt to accommodate development needs, then the Green Belt land immediately around Hullbridge – the site, would be suitable for such release.”
2.73 It is strongly recommended that the Council review the Green Belt Assessment alongside the other submitted evidence from their Site Appraisal Paper and Green
Belt Review study. The results of the Green Belt Assessment have strongly influenced the formulation
of the Framework Plan, in particular with regard to the incorporation of landscape mitigation measures. These take the form of a substantial landscape buffer along
the length of the eastern boundary, which will comprise new woodland planting and will integrate with and enhance existing vegetation. The landscaping strategy for
the site will aid in creating a strong defensible Green Belt boundary, as well as create a scheme that responds sensitively to the countryside character, with a soft
transition from built development to rural countryside.
Agricultural Land Classification
2.74 The Site Appraisal Paper (2021) scores Land South of Pooles Lane (ref CFS190) level one (the lowest category), as the majority of the site is adjudged to contain Grade 1-3 agricultural land (best most versatile or BMV). The other sites in Hullbridge also mostly score level 1, with a few scoring level 2 (i.e. any part of the site contains Grade 1-3 agricultural land). The assessment is based on Natural England Agricultural Land Classification mapping. However, the Natural England maps' scale is intended for strategic use and is not sufficiently accurate for the assessment of individual fields. Given that the site is currently used for arable grazing, it is unlikely that the land will be classified as BMV agricultural land.
Nevertheless, it is clear that the loss of some agricultural land will be necessary if Hullbridge is to continue growing in a sustainable manner. The sites available for
development in this area are of a similar agricultural value, and it is considered the benefits of sustainable development would be sufficient to outweigh the loss of
agricultural land.
Drainage
2.75 The site is located within Flood Zone 1 (lowest risk) as defined by the Environment Agency. The site is therefore considered sequentially preferable for residential development in flood risk terms.
2.76 The score of level two for 'critical drainage risk' appears to have been informed by a high-level review of the surface water flood risk for the site. Mapping on the
Environment Agency long term flood risk website illustrates that the majority of the site is in an area of low or very low surface water flood risk. There are small,
localised areas of medium and high surface water flood risk, associated with low spots within the site or near watercourses. 2.77 This is a matter that can be suitably addressed through any future planning application, which would be supported by a surface water drainage strategy
incorporating Sustainable Urban Drainage Systems (SuDS). The Framework Plan which has been produced has been informed by a high-level Flood Risk and
Drainage Constraints Plan (Appendix E) which illustrates how surface water flood risk can be appropriately mitigated through the inclusion of detention basins in
appropriate locations. The location and design of the basins will be subject to further detailed drainage assessment, however it is considered that a scheme can
be designed that effectively mitigates the risk of surface water flooding.
Access to a train station
2.78 The nearest train station to Land South of Pooles Lane (ref CFS190) is located in Rayleigh approximately 5.2km, which is just over the 5km threshold for a level one score. However, the assessment should take into account where opportunities exist for linked trips via other sustainable modes of transport such as by cycle or public
bus. Land South of Pooles Lane is located less than two minutes' walk from the nearest bus stop, where there is a frequent bus service (every 30 minutes) to Rayleigh railway station, with the journey taking approximately 15 minutes (including walking to the bus stop). This provides a very sustainable option for future residents of this site, and the Council should consider this factor when
assessing the site's sustainability.
Access to secondary school
2.79 It is recognised that Hullbridge does not include a secondary school, and as a result, the site scores level one in the Site Appraisal Paper. However, as mentioned above, the frequent no. 20 bus route (every 30 minutes between 7.00 to 21.00 Monday to Saturday) between Hullbridge and FitzWimarc School, in Rayleigh takes
approximately 15-20 minutes. This is considered to be an acceptable distance for secondary-aged pupils who often travel by bus, bike or even train to get to school.
The Council should therefore consider the accessibility of secondary schools by modes of public transport when assessing the relative sustainability of a site.
Access to a town centre
2.80 The nearest town centre of Rayleigh is around 6.2km from Land South of Pooles
Lane (ref CFS190), which is therefore within level one threshold, as the site is more than 2.3km from the town centre. However, it should be recognised that Hullbridge
contains a range of services, which could be found on a high street, with three convenience stores, medical centre, a pharmacy and other facilities. These services
are therefore capable of supporting the day-to-day needs of residents within Hullbridge, limiting the need to travel beyond the village on a frequent basis.
2.81 The site is also less than two minutes' walk from the nearest bus stop, where there are frequent bus services (every 30 minutes) to Rayleigh town centre, with the
journey taking approximately 15 minutes. This provides a very sustainable option for future residents of this site. Furthermore, due to the impacts of the COVID-19
pandemic, there has been a greater focus on online retail shopping; thus, it is considered that the 2.3km threshold is unjustified adopted by the Site Appraisal Paper, particularly where residents of Land South of Pooles Lane could either access retail facilities by public transport or online.
Employment site
2.82 The nearest designated employment (Imperial Park) area is 4km from Land South of Pooles Lane in Rayleigh, which is just over the level one threshold of 2.3km.
However, this employment site can be accessed by frequent bus service (every 30 minutes), with the journey taking approximately 20 minutes, providing a
sustainable option for future residents of this site. The Council should also consider the impact of the COVID-19 pandemic with increased levels of working from home
practices when considering the relevant proximity of employment sites.
Conclusion
2.83 Penland Estates Limited consider that Land South of Pooles Lane, is suitable, available and achievable for development, taking into account the evidence that it
has prepared to support the site’s promotion so far. The site should be allocated in order to achieve a sustainable and deliverable development strategy for Hullbridge,
consistent with the Local Plan strategy as a whole.

RDC have launched their Spatial Options Consultation to the residents of Rochford District for comment on proposed sites to be brought forward for housing development to meet proposed numbers of new housing to be built .


The question must be asked WHY this is happening prior to ECC Highways Study being commenced and a report compiled. Is this not against Government guidelines? Highways are a major consideration and huge concern to most residents in the district. RDC should not or cannot make any kind of plan or recommendation to its officers until capacity of the local road network has been reviewed. Any possible proposed extension or changes to the network must have guaranteed Central Government Funding in place before any further consideration for further building is planned.

Local infrastructure is not fit for use.

The current road network is already under severe strain with current car movements. Recently RDC made a decision to refuse the proposed Bloor development in Ashingdon. “In the absence of a definition of severe it is for the local authority to determine whether a severe impact would result and in this case it considered that the development would result in severe impact on the local highway network”

By definition RDC has acknowledged that the road network throughout the area does not have capacity to take on increased capacity through mass development.

Of particular concern to us is site Field CFS064. This site is constrained by existing housing. The only possible access being through woodland in Manor Road or Folly Chase, a private road which is a public footpath. The site is also boarded by a public footpath. Loss of amenity to the local community would be catastrophic. The site would feed out on the B1013 already running at well over capacity.

Rochford district is constrained by its location. Located on a peninsula it is bordered by the River Crouch, areas of SSI, ancient woodland, Green belt and the proximity of the coast. Railway bridges built up to 120 years ago constrain movement on roads in at least five locations on the network. All, but one, have height restrictions. None allow easy movement of two opposing cars passing, one is one way only.

The road system running through the district is ancient in many places. Indeed the Ashingdon Road having been laid out and originally built by The Romans. Maps dating from the 18th century show most major roads, e.g. the B1013, having a layout which still exists in 2021. Housing, shops and businesses have been built along their borders allowing
no capacity for expansion. We no longer see the stagecoach bound for Southend, two donkeys, a haycart and the odd child on a bicycle moving along these roads each day compared to the number of vehicle movements now seen.

Lower Road and Watery Lane are used as major or main routes in and out of the district into and out of Southend, Chelmsford and beyond.

The following areas are also of significant concern to me as a resident all being at or close to saturation point with demand from the current population.

An aging and vulnerable services system. Water, drains, sewage, (one recent development was actually completed without sewage systems being in place) gas, electricity and communication networks. E.g., Recent catastrophic water main collapse in The Hullbridge Road due to aged pipes.

Roads which are no longer fit for purpose. Many and multiply needs for repair, maintenance upgrade and extension causing broken surfaces and most significantly constant road closure or restrictions. County Highways seems to deem the district way down on its list for repairs and maintenance.

The severe risk to life and property should any major, or minor, emergence occur necessitating
the need for multiple emergency services, fire, ambulance, police to attend at peak times where roads are blocked or at capacity. On street parking is also a huge issue in many areas. Grid lock throughout the district ensues almost immediately any accident occurs or road work(s) are in place.

Existing Schools are at capacity with most being in locations where it would be difficult or impossible to increase their footprint. E.g. Rochford Primary. None of the proposed developments come with any plan for new schools, or any room to build them. Current approved development has necessitated the movement of children to school in adjoining villages due to lack of planning or capacity locally, resulting in increased car movements at peak times and pollution issues.

Doctors’ surgeries are at capacity and placed under further strain by the difficulty of recruiting GP’s

Local Hospital capacity is at breaking point

Environmental issues are not mentioned or considered. Building on flood plain, lost green belt areas, loss of habitat. Existing roads or areas already exceeding approved pollution levels. This I believe must also be the case for most main roads in the area, if not all, especially during rush hours due to standing traffic.

For ALL the above reasons no additional housing should be considered until a full and comprehensive environmental study is carried out and analysed.

RDC have launched their Spatial Options Consultation to the residents of Rochford District for comment on proposed sites to be brought forward for housing development to meet proposed numbers of new housing to be built .


The question must be asked WHY this is happening prior to ECC Highways Study being commenced and a report compiled. Is this not against Government guidelines? Highways are a major consideration and huge concern to most residents in the district. RDC should not or cannot make any kind of plan or recommendation to its officers until capacity of the local road network has been reviewed. Any possible proposed extension or changes to the network must have guaranteed Central Government Funding in place before any further consideration for further building is planned.

Local infrastructure is not fit for use.

The current road network is already under severe strain with current car movements. Recently RDC made a decision to refuse the proposed Bloor development in Ashingdon. “In the absence of a definition of severe it is for the local authority to determine whether a severe impact would result and in this case it considered that the development would result in severe impact on the local highway network”

By definition RDC has acknowledged that the road network throughout the area does not have capacity to take on increased capacity through mass development.

Of particular concern to us is site Field CFS064. This site is constrained by existing housing. The only possible access being through woodland in Manor Road or Folly Chase, a private road which is a public footpath. The site is also boarded by a public footpath. Loss of amenity to the local community would be catastrophic. The site would feed out on the B1013 already running at well over capacity.

Rochford district is constrained by its location. Located on a peninsula it is bordered by the River Crouch, areas of SSI, ancient woodland, Green belt and the proximity of the coast. Railway bridges built up to 120 years ago constrain movement on roads in at least five locations on the network. All, but one, have height restrictions. None allow easy movement of two opposing cars passing, one is one way only.

The road system running through the district is ancient in many places. Indeed the Ashingdon Road having been laid out and originally built by The Romans. Maps dating from the 18th century show most major roads, e.g. the B1013, having a layout which still exists in 2021. Housing, shops and businesses have been built along their borders allowing
no capacity for expansion. We no longer see the stagecoach bound for Southend, two donkeys, a haycart and the odd child on a bicycle moving along these roads each day compared to the number of vehicle movements now seen.

Lower Road and Watery Lane are used as major or main routes in and out of the district into and out of Southend, Chelmsford and beyond.

The following areas are also of significant concern to me as a resident all being at or close to saturation point with demand from the current population.

An aging and vulnerable services system. Water, drains, sewage, (one recent development was actually completed without sewage systems being in place) gas, electricity and communication networks. E.g. Recent catastrophic water main collapse in The Hullbridge Road due to aged pipes.

Roads which are no longer fit for purpose. Many and multiply needs for repair, maintenance upgrade and extension causing broken surfaces and most significantly constant road closure or restrictions. County Highways seems to deem the district way down on its list for repairs and maintenance.

The severe risk to life and property should any major, or minor, emergence occur necessitating
the need for multiple emergency services, fire, ambulance, police to attend at peak times where roads are blocked or at capacity. On street parking is also a huge issue in many areas. Grid lock throughout the district ensues almost immediately any accident occurs or road work(s) are in place.

Existing Schools are at capacity with most being in locations where it would be difficult or impossible to increase their footprint. E.g. Rochford Primary. None of the proposed developments come with any plan for new schools, or any room to build them. Current approved development has necessitated the movement of children to school in adjoining villages due to lack of planning or capacity locally, resulting in increased car movements at peak times and pollution issues.

Doctors surgeries are at capacity and placed under further strain by the difficulty of recruiting GP’s

Local Hospital capacity is at breaking point

Environmental issues are not mentioned or considered. Building on flood plain, lost green belt areas, loss of habitat. Existing roads or areas already exceeding approved pollution levels. This I believe must also be the case for most main roads in the area, if not all, especially during rush hours due to standing traffic.

For ALL the above reasons no additional housing should be considered until a full and comprehensive environmental study is carried out and analysed.

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 Council would expect to see specific reference to:
• The Infrastructure Delivery and Funding Plan
• Level 2 Strategic Flood Risk Assessment
• Local Cycling and Walking Infrastructure Plan
These plans are vital to the long-term sustainability assessment of any proposed sites. Without these
we are unable to comment
Evaluation of the impact of current development on the town of Rayleigh
Rochford District Council should produce its own estimate of Housing need with which to Challenge the figures imposed by Westminster, it is known that the nearest neighbours have all done this.
The Town Council cannot comment on the suitability of the sites in the plan without completion of an
Infrastructure Delivery and Funding Plan which is being undertaken at present, why has this consultation been undertaken before this is available. RDC, ECC, and SBC,
I would expect it to see specific reference to
i) the main Roads and the principal junctions and exit points to Rayleigh, there is potential in this
plan is to build on London Road, Eastwood Road, Hockley Road and Hullbridge Road simultaneously.
ii) Consultation with the actual schools in Rayleigh as to capacity, too often there are no places in
specific school.
iii) Consultation with Doctors and Pharmacies as well the local Healthcare Trust, again there is
evidence of no capacity in certain parts of Rayleigh.
iv) Next level HealthCare such as Hospitals, need consulting, as they are overstretched.
v) Air Quality Management - too many parts of Rayleigh have poor CO2/CO readings
Any such Plan would need agreement with Rochford District Council, Essex County Council, and
Southend Borough Council as they are all affected

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? [Please state
reasoning]
Mostly. Although you have not included enough information on how you might achieve housing for
the hidden homeless or those on low incomes, schemes to allow the elderly in large houses to be able
to downsize or how you plan to provide suitable commercial units of varying sizes, to allow businesses
to up or downsize into a suitably sized premises without them needing to relocate into another area.
No provision for emergency housing.

Q3. Do you agree that we should develop a range of
separate visions for each of our settlements to help
guide decision-making? [Please state reasoning]
Yes, as each settlement has its own characteristics and needs.

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? [Please state
reasoning]
No comments.

Q5. Do you agree with the settlement hierarchy
presented? If not, what changes do you think are
required? [Please state reasoning]
Yes. Rayleigh is the largest town in the district but care needs to be taken to maintain the integrity of
the existing settlements with respect to green boundary between Rayleigh and its neighbours.

Q6. Which of the identified strategy options do you
consider should be taken forward in the Plan? [Please
state reasoning]
Creating a new town would enable all the infrastructure to be put in place, allowing more scope for
cycling routes and pedestrianised areas. This will stop the urban sprawl which is currently happening
in the larger town (and proposed in option 1), creating traffic havoc and pollution. A single large
"garden" village, possibly shared with Southend could allow a more environmentally friendly
development. A development that allows the infrastructure to be developed in advance of the
housing.

Q7. Are there any reasonable alternatives to these options that should be considered instead? [Please state
reasoning]
Small development and windfall developments should be included in housing count.

Q8. Are there any key spatial themes that you feel we
have missed or that require greater emphasis? [Please
state reasoning]
Yes: Cultural and Accessibility.

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? [Please state reasoning]
Yes. You must ensure the district has a suitable plan to protect not only the towns and village communities, their houses and businesses but also the natural areas as well. The district needs adequate defences to limit flooding in all areas, protecting people and wildlife. Maybe these could be incorporated in the “natural” landscape theming so as to deflect any water away from these areas.
New developments not only need to address their carbon footprint but also the design of the housing they build so that they limit flood damage; raised floors, bunded gardens etc.
The plan must include or identify a flood plane that is protected from development.

Q10. Do you agree that the Coastal Protection Belt and
Upper Roach Valley should be protected from
development that would be harmful to their
landscape character? Are there other areas that you
feel should be protected for their special landscape
character? [Please state reasoning]
All the coastal areas and areas of special interest, especially where there is a significant risk of
flooding and harm to the environment need careful consideration.
The Ancient woodlands such as Kingley Woods, Hockley Woods and Rayleigh Grove Woods and all
natural parks, not just the actual woodlands but also the surrounding areas

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 low-carbon or renewable
energy?
Yes.
New developments should be able to source some or all of their energy from renewable sources.

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? [Please state reasoning].
Yes. The Town Council believes that you should aim to achieve a higher standard if possible and
encourage developers to put forward new ways of achieving this. You must plan for future generations and should not be stuck in the past. Why go for minimum standards? Always aim higher! Keep the technology under review to capitalise on new development.

Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation
should be supported? [Please state reasoning]
Solar in all new development as standard. Incentives to encourage existing developments to install
solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs;
there are many flat roofed buildings all over the district that could accommodate solar panels without
damaging the landscape. Explore tidal energy and seek out suitable locations in order to ascertain
whether it is viable. Retrofitting existing housing and commercial buildings

Q14. Do you consider that the plan should include a placemaking charter that informs relevant policies? Should the same principles apply everywhere in the district, or should different principles apply to different areas? [Please state reasoning]
The district has some very distinct areas and a “one shoe fits all” would be detrimental to some smaller communities. The place-making charter should be bespoke, with each area being considered
in its own right. The rules on building should be strict so as to enhance the areas of development and needs to consider the wider picture in respect of amenities, open spaces, retail, schools, services, pollution, character and accessibility (to name but a few). There should not be deviation of plans unless there are exceptional circumstances. Time and again, SPD2 documents are ignored and ugly extensions and dormers are built to the detriment of the area.

Q15. Are the principles set out in the draft place-making
charter the right ones? Are there other principles that
should be included? [Please state reasoning]
They are, as long as they are adhered to.

Q16.
a. Do you consider that new design guides, codes or
masterplans should be created alongside the new
Local Plan?
Yes.
b. 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? [Please state reasoning]
You need different design guides as this district is both unique and diverse and the “one shoe fits all"
would be detrimental to its character and charm.
c. What do you think should be included in design
guides/codes/masterplans at the scale you are
suggesting? [Please state reasoning].
You need to ensure that the character and heritage of the settlements are adhered to whilst allowing for some growth, in order to rejuvenate the smaller settlements if needed.

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? [Please state reasoning]
By working closely with planners and developers, as well as different charities and communities,
residents and businesses. You will then get a better understanding as to what you need and what will
be achievable.

Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure?
What is required to meet housing needs in these
areas? [Please state reasoning]
The district has a large number of houses, existing and approved that have four or five bedrooms. The number of homes available with two or three bedrooms is minimal, which increases their price and availability. The smaller properties are the ones that need to be affordable for families. You must ensure that the “affordable“ properties are not all flats and that minimum or higher standards are
met for gardens and recreational space. There are sure to be single, elderly residents that would like to downsize from their large family homes, into a smaller, more manageable one but do not wish to go into an assisted living, residential or retirement homes. They may want a one or two bedroomed property, maybe one storey, or low-rise apartment that they own freehold. The Council would like to safeguard the number of smaller bungalows available and make sure that the existing stock is preserved and a suitable number are provided in the housing mix. You need to consider that some residents may need residential care and you should be looking at ways to cope with the rising number of elderly and provide accommodation for them also.
Consideration should be given to the provision of house for life, bungalows and other potential buildings for downsizing families.
The plan makes no reference to social housing quotas.
The district desperately needs to meet the needs of the hidden homeless. People like the adult children on low wages who have no hope of starting a life of their own away from their parents. By living in these conditions, even if the family unit is tight and loving, it will cause mental health issues, stress and anxiety. You also need accessible properties for the disabled members of our community, where they are assisted in order to fulfil a normal as possible life. All these issues, and perhaps many more, need be addressed.

Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing? [Please state
reasoning]
Housing for the hidden homeless – those “sofa surfing”, or adult children living at home with parents as they are on low wages or wages that would not allow them to move out to rent or buy somewhere on their own. Adapted homes for the disabled. Smaller, freehold properties for the older generation to enable them to downsize from large family homes. Emergency housing.

Q20. With reference to the options listed, or your own
options, what do you think is the most appropriate
way of meeting our permanent Gypsy and Traveller
accommodation needs? [Please state reasoning]
You need to find a permanent site that has a little room to expand but not exponentially. The “Traveller” life has changed over the years and you should revisit the criteria for the traveller community to meet the legal requirements. Strong controls are needed to prevent illegal building work and to ensure the site populations do not exceed capacity.

Q21. With reference to the options listed, or your own
options, what do you think is the most appropriate
way of meeting our temporary Gypsy and Traveller
accommodation needs? [Please state reasoning]
See answer to Q20

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations
for new Gypsy and Traveller sites? [Please state
reasoning]
See answer to Q20.

Q23. With reference to the options listed above, or your
own options, how do you feel we can best ensure that
we meet our employment and skills needs through
the plan? [Please state reasoning]
The council should stop developing existing commercial land into housing. Too many sites have already been lost and many more are planned to go. Consider how the plan can help those businesses wanting to expand. Work with local schools and colleges, as well as businesses and the job centre, to see what sustainable employment is needed in the district. Incorporate ways to assist in schemes to train all ages get back into work or upskill. Developers should be encouraged to use local labour

Q24. With reference to Figure 30, do you consider the
current employment site allocations to provide
enough space to meet the District’s employment
needs through to 2040? Should we seek to formally
protect any informal employment sites for commercial
uses, including those in the Green Belt? [Please state
reasoning]
No. The current employment site allocations on Figure 30 do not provide enough space to meet the district’s employment needs through to 2040. There are eighty-seven thousand people in the district. There is no data on the form to suggest how many of these are in employment and how many are looking for work but the council need to reassess its future needs in order to future-proof our residents’ opportunities. The plan should only formally protect sites the that have a future and a
potential to expand or continue effectively.

Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new
employment facilities or improvements to existing
employment facilities?
Option 3 could deliver new opportunities for employment as it would be a new site completely. Industrial units of various sizes, with room for expansion plus retail, hospitality and other employment could be included in the criteria for the development.
Q26. Are there any particular types of employment site or
business accommodation that you consider Rochford
District is lacking, or would benefit from?
Environmental services - woodland conservation and management. (We need to find funding for this
as it is important!) HGV training school and modern transport training. Improve manufacturing base.
Q27. Are there other measures we can take through the
plan to lay the foundations for long-term economic
growth, e.g., skills or connectivity?
Better road networks, gigabit broadband and Wi-Fi. Apprenticeships or training for all ages with jobs
at the end of training. CCTV where appropriate.
Q28. With reference to the options listed above, or your
own options, how do you feel we can best manage the
Airport’s adaptations and growth through the
planning system? [Please state reasoning]
No comments.
Q29. Do you agree that the plan should designate and
protect areas of land of locally important wildlife
value as a local wildlife site, having regard to the Local
Wildlife Sites review? Are there any other sites that
you feel are worthy of protection? [Please state
reasoning]
Yes. You should conform to and improve existing RDC policies for protecting wildlife areas. Everyone should be doing all in their power to protect wildlife sites. All wildlife is important and has been neglected, sites have been slowly lost over the years. Wildlife now enters suburban areas as their own habitats have diminished and they can no longer fend for themselves adequately from nature. Badgers and hedgehogs as well as rabbits, frogs, newts, voles and shrews are declining and are seldom seen apart from dead at the roadside. Bat numbers are declining as their habitats are lost. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was.
Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. You mention that Doggett Pond no longer meets the standard but are there no steps to improve its status instead of dismissing it? It is obviously an important site for the wildlife in that area. To lose it would be to our detriment. You should be looking at creating new sites with every large housing
development, and protecting them to improve our district and our own wellbeing. Private households should not be allowed to take over grass areas and verges or worse, concreting the verges over for parking and cost savings. These areas, although small are still areas for wildlife. Bees and butterflies are also in decline, as are
the bugs which feed our birds. The plan should create new wildlife meadows to encourage the pollinators in order to future proof our own existence. You should be exploring smaller sites that could be enhanced, managed and protected to give future generations a legacy to be proud of.
Q30. Do you agree that the plan should designate and
protect areas of land of locally important geological
value as a local geological site, having regard to the
Local Wildlife Sites review? Are there any other sites
that you feel are worthy of protection? [Please state
reasoning]
Yes. The plan must protect them for future generations and teach our children their history and importance so that they can continue to keep them safe.
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?
On site. You can then assess in real time and sort out any issues you would not have known about off
site.
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? [Please state reasoning]
You need to retain what we already have by ensuring the necessary links are in place to join as many as possible, and ensuring that public rights of way are not blocked by land owners and are kept free from debris. You also need to assess some paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look into offering this in the larger spaces. For example, a small toilet block and hand washing facilities in the car park. Obtaining funding from new developments that can enhance existing areas as
well as providing new spaces and facilities. The sites should be well-maintained.
Q33. Do you agree that the central woodlands arc and
island wetlands, shown on Figure 32 are the most
appropriate areas for new regional parklands? Are
there any other areas that should be considered or
preferred? [Please state reasoning]
They are a step in the right direction, but you need to assess periodically in order to be able to add further links to any new parkland that may be created in the future. The map is unclear as it does not show exact routes. There is a large open space to the South West of Rayleigh (on the border), South of Bardfield Way and The Grange/Wheatley Wood, which could be enhanced. Existing sites must be retained
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new
strategic green and blue infrastructure? [Please state
reasoning]
Enhancing existing areas and ensuring developers include green space and recreational facilities
within their developments. A new, separate development would be able to deliver this within their plan layout. Ensuring there are suitable links, access and footpaths. Making sure some of these footpaths are maintained and accessible for the disabled.
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? [Please state reasoning]
Assess the shortfall of facilities and networks before plans are approved so that adequate planning
and funding can be secured before any building takes place.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or
improved community infrastructure? [Please state
reasoning]
A new town would have this infrastructure built into its plans. Funding for improvements must otherwise come from developers if an area is already overpopulated.
Q37. Are there areas in the District that you feel have
particularly severe capacity or access issues relating to
community infrastructure, including schools,
healthcare facilities or community facilities? How can
we best address these? [Please state reasoning]
Rayleigh is overcrowded; it has a road network no longer fit for purpose, some schools are near to capacity, it is difficult to obtain a GP or dental appointment. There is little to no disabled play areas or play equipment. There are always issues with waste collections, drain and road cleaning and verge trimming. The District Council does not have the staff to deal with all these issues. The council should either build another waste recycling site, or develop a better waste collection program which allows extra waste to be collected next to the bin. The current recycling site at Castle Road is no longer
capable of expanding to meet the needs of an ever-growing population. The plan should also identify
a site to accommodate commercial waste facilities to stop fly tipping.
Q38. With reference to the options above, or your own
options, how do you feel we can best meet our open
space and sport facility needs through the plan?
[Please state reasoning]
Improve what we already have. The tennis courts on Fairview Park needs improvement. Safeguard our open spaces to protect wildlife and recreation. Develop different types of sporting facilities. We need to offer free recreation.
Q39. Are the potential locations for 3G pitch investment
the right ones? Are there other locations that we
should be considering? [Please state reasoning]
All-weather facilities should be considered
Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should
be considering? [Please state reasoning]
They look suitable. They will probably need funding.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver
improvements to open space or sport facility accessibility or provision?
A new development would be able to deliver this in their plans or fund improvements for existing facilities in line with national strategy and requirements.
Q42. Are there particular open spaces that we should be
protecting or improving? [Please note, you will have
an opportunity to make specific comments on open
spaces and local green spaces in the settlement
profiles set out later in this report]
The sites will be specific in each parish. You must protect all of these recreational spaces and improve them, if necessary. Once lost to development, they can never come back.
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? [Please
state reasoning]
You should reassess the planning policies regarding alterations made to the buildings on the heritage
list, especially those in conservation areas. There have been a few occasions where buildings of “interest” (or other) have been altered, and that places in conservation areas have been allowed canopies, shutters and internal illumination of signage without challenge. Any building work should be sympathetic to the area and you should require corrections to unauthorised changes, even if they
have been in place for some time. Shop fronts are huge areas of uninteresting glass with garish colours. No objections are raised to signage and advertising that is out of character with a conservation area in a heritage town. Ensure statutory bodies are consulted and heeded.
You should take effective actions to manage the footways, ‘A’ boards and barriers are obstructions to
those with impaired sight or mobility.
Q44. Are there areas of the District we should be
considering for conservation area status beyond those
listed in this section? [Please state reasoning]
You should not take areas of precious woodland to make way for housing. Sites within the existing Rayleigh Conversation Area should not be considered

Q45. Are there any buildings, spaces or structures that
should be protected for their historic, cultural or
architectural significance? Should these be considered
for inclusion on the Local List of non-designated
assets? [Please state reasoning]
Yes there are many sites of historic importance which should be included.
Q46. With reference to the options listed above, or your
own options, how do you think we can best plan for
vibrant town centres in Rochford, Rayleigh and
Hockley? How can we also ensure our village and
neighbourhood centres remain vibrant? [Please state
reasoning]
You can only have a vibrant town centre if there are shops to go to. If these units are subsequently changed to residential then our town centres will be fractured and uninviting. The new Use Class E will mean it will be even more important for the council to protect our retail outlets. You need to work actively with premises owners in order to assist in the re-letting of any empty shops. Maybe
offer a reduced rent to new businesses as a start-up scheme. You could contain this as a “local”
business only – allowing the entrepreneurs in the Rochford District a chance to showcase their
businesses. You also need to be able to negotiate with the owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows, perhaps photos of the old towns or useful information, to make them more attractive. Explore business rates levies. Any plan should be reviewed frequently; at least every 5 years
It is a well-documented fact that independent businesses have done better than large chains during Covid as they are able to diversify at short notice. RDC need to incentivise new small or micro businesses into our town centre, either through grant support or another mechanism. Occupied premises create employment, increase footfall and reduce vandalism. Landlords should be engaged with to ensure quick turn-arounds, or for more flexible lease agreements where for example a new
business can take on a shorter lease to test the market.
Good public transport links are crucial for our villages, neighbourhoods and town centres.
Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make?
[Please state reasoning]
Yes
Q48. With reference to Figures 38-40, do you agree with
existing town centre boundaries and extent of
primary and secondary shopping frontages in
Rayleigh, Rochford and Hockley? If not, what
changes would you make? [Please state reasoning]
Yes.
Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary
shopping frontages within those centres? If yes, what
uses should be restricted? [Please state reasoning]
Yes. A mix of retailers is essential as a lack of variety will eventually kill off the high streets. We need to have a balance of outlets that keep the area viable as you would lose the vibrancy you are hoping to achieve.
Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved
retail and leisure services in the District? [Please state
reasoning]
Unfortunately, there has been a tendency to switch from commercial outlets to residential, where smaller retail areas have been sold off and housing development has been allowed. In a new development there would be scope to add a small, medium or large retail precinct, depending on the development size. Retail parks, leisure areas and outlets are proving in many cases, the preferred option for consumers, normally as a result of having everything in one place, free on-site parking and maximum choice. We feel that some of the sites, whilst not suitable for large housing developments, may be suitable for something of this type. It would create much needed employment, opportunity and tourism for the
area.
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?
[Please state reasoning]
The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. The existing paths need updating and attention
Q52. Are there areas where improvements to transport
connections are needed? What could be done to help
improve connectivity in these areas?
More work needs to be done on the A127 and The Carpenters Arms roundabout. The feeder lanes
proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions is
now essential as this is a bottleneck. Hockley needs another access. Connecting the cycle ways into a
cycle network as part of 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.]
As the preferred strategy option is 3b, this could create opportunities for improved links to Southend. You should also consider more and smaller buses to link the towns and villages. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a
complete review of sustainable transport.
Q54. Do you feel that the plan should identify rural
exception sites? If so, where should these be located
and what forms of housing or employment do you feel
need to be provided? [Please note you may wish to
comment on the use of specific areas of land in the
next section]
This may be a suitable option for a retirement village that could be restricted to single storey dwellings only, and could include community facilities such as convenient store, community centre and so on.
Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities?
[Please stare reasoning]
Better public transport and sustainable transport links.
Q56.
a. Do you agree with our vision for Rayleigh? Is there
anything you feel is missing? [Please state reasoning]
The plan is adequate so far is it goes, but you have more work to do. You must plan for a reduced volume of traffic and air pollution. More attention is needed to initiatives that design-out crime and fear of crime, and this needs to be functional, sustainable and viable. The Draft Vision Statement ignores the over-development, the lack of infrastructure and facilities we already suffer. Indeed, Rochford District Council’s stated aim within their Asset Strategy and the plans of other Public Service providers is to reduce facilities in the Town further. This is at the same time as demand is growing from a sharply increasing population. This is particularly relevant for the growing elderly population. This will make the next 25 years very challenging.
1/ Cycling infrastructure and other sustainable transport methods should be prioritised over a carcentric highway use. We regret we do not because it is unrealistic, our response must be to inject a note of realism looking forward based on RDCs policies and past action. This goes to the heart of the new Local Plan.
We regret a realistic Vision Statement based on the current trajectory of further development recommended in the Draft Local Plan will be rather more dystopian. We could see a Rayleigh chocked by traffic. Although pollution should decrease with electric vehicles the advent of driverless vehicles, both domestic and commercial, servicing an ever-expanding population could result in gridlock. Pollution will increase from fossil burning home heating systems in many of the new homes. Failure to support public transport will inevitably maroon older residents in their homes far from those few
facilities and shops that remain in our town centre.
Public services offered by police and council (most likely giant unitary council catering for half million people based far away in an urban area), will seem very distant to most people. Most of the green open spaces not in public ownership, also some that are publicly owned, will be built on and have disappeared by 2050. Many public facilities and local public service providers will be taken away and sold off to property developers. The town centres will cease to be the shopping and social areas we know today as a result of Council plans and changing shopping habits. Rayleigh retail business will have closed and online and out of town retail parks will prosper with their free parking facilities. In the same way that London boroughs developed through the decades and centuries, the traditional housing we know today, with private gardens will be replaced by blocks of flats with large vehicle parking areas with recharge points.
2/ Another vision could be forged with the right policies in an enlightened Local Plan. RDC could opt for a garden village settlement away from all the Districts Towns and villages. Rayleigh like other towns that have suffered from overdevelopment in recent decades and should be protect from large scale private development during the forthcoming Plan Period. Only development or local needs should be permitted. Local facilities like Mill Hall would be saved and car parking retained and made
cheaper to assist local town centre business to survive what will be a challenging period. Secondary
shopping facilities in Rayleigh would be supported and encouraged with public finance where required. Public transport would be supported and encouragement, especially when given for children to reach school without parents’ vehicles. Renovation and refurbishment of historic buildings with modern green energy would be promoted over demolition and intensification. Public services would be encouraged to return/expand to Rayleigh, in existing buildings like Council Offices, Police Station and Library etc. The town centre should be the heart of our community not just something you drive
through to reach somewhere else. This could be our vision and our aim for the future.
b. 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?
Balancing access against increased congestion will be the issue for a lot of the sites in Rayleigh. If you keep adding small developments to the boundaries of the town, it will overcrowd existing houses and add to urban sprawl.
i. Rayleigh has taken the brunt of development without significant infrastructural improvement.
ii. Commercial [offices, industrial, retail, other]
Commercial development should be supported in town centres, secondary shopping facilities and on approved industrial estates (the latter should not become retail / entertainment locations and residential development should not encroach on them to avoid conflict). Community Improvement Districts should be established
iii. Community infrastructure [open space, education, healthcare, allotments, other]
Community infrastructure should be preserved and extended. Access to town centres and secondary
shopping by bicycle and foot should be made easier and safer.
c. Are there areas in Rayleigh that development should
generally be presumed appropriate? Why these areas? [Please state reasoning]
No. Large scale residential development in Rayleigh should be resisted in the new Local Plan. So called
windfall development should be incorporated in the overall development targets thereby reducing
large scale development.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Conservation areas and green belt and sites subject to the exclusion criteria on the call for sites should be protected. Proposed sites within Rayleigh and on the Western side should not be considered for development. Only an infrastructure plan would provide evidence that the chosen sites are sustainable in the long term, and greenbelt and environmental policies should be adhered to in relation to open spaces on the edge or within the town.
e. Do you agree that the local green spaces shown on
Figure 44 hold local significance? Are there any other
open spaces that hold particular local significance?
All green spaces, no matter how small, hold some significance, especially to those who use them for
recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets
Q57.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Hockley Wood
Q58.
a. Do you agree with our vision for Hockley and
Hawkwell? Is there anything you feel is missing?
[Please state reasoning]
Yes. Insofar as it relates to Rayleigh.
Q58.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
As Hockley Woods is the largest remaining wild woodland in the country you should be doing
EVERYTHING you can to save it from development, either adjacent to or close by. You should also actively be adding to it by planting more trees to future proof its existence and status. You must protect any thoroughfares that access Hockley Wood.
Q60.
a. Do you agree with our vision for Hullbridge? Is there
anything you feel is missing? [Please state reasoning]
Yes. Insofar as it relates to Rayleigh.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Anything too close to the river due to flood risk.
e. Do you agree that the local green spaces shown on
Figure 48 hold local significance? Are there any other
open spaces that hold particular local significance?
[Please state reasoning]
All green spaces, no matter how small, hold some significance, especially to those who use them for
recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the
Governments home building targets
Q63.
a. Do you agree with our vision for Rawreth? Is there
anything you feel is missing? [Please state reasoning]
Yes. Insofar as it relates to Rayleigh.
c. Are there areas in Rawreth that development should
generally be presumed appropriate? Why these
areas? [Please state reasoning]
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Protection needs to be given to development that change the dynamics of the village and those areas that border Wickford. There needs to be a significant amount of green belt land left to separate the two areas to prevent urban sprawl. Rawreth Lane gets heavily congested at peak times, and with Wolsey Park still not complete this is likely to increase. If there is an accident or breakdown on the road network, it has a huge knock on through Rayleigh and the surrounding areas and Watery Lane isn’t a reliable back up for when there are issue. Therefore, further development on the boundary or
otherwise could be detrimental to not only local residents but the wider District too. RDC should be supporting farmers wherever possible to continue to grow their crops in the district and protect suitable farm land in the area. We do not want to lose the local producers

Q66. Do you agree that our rural communities do not
require individual vision statements? Are there
communities that you feel should have their own
vision? [Please state reasoning]
At this time – yes, but we feel they should have some consideration in the future, in order to protect
them. It would be for the communities to decide their vision statements and we would be happy to
support them.
Q67. Do you agree with our vision for our rural
communities? Is there anything you feel is missing?
[Please state reasoning]
Yes.
Q68. Are there other courses of action the Council could
take to improve the completeness of our rural
communities?
Listen to the residents to see where they would like to go next. See if they require anything specific; travel links, facilities, affordable housing and so on. Empower Parish and Town Councils to take
relevant local actions

Introduction

The purpose of this letter is to provide my feedback to your current public consultation .

I appreciate the hard work that you have put in at the time of the pandemic in putting this together.

I also appreciate the difficulties that the District Planners face, given the current hiatus in the governments new approach to planning, plus given the difficulties in predicting what our economic future will be post-pandemic.


Comments on the Consultation itself

For a public consultation it seemed very technical and full of planning jargon, rather than being written in plain English.

In my view there were far too many questions. At times these read more like a set of examination questions about Spatial Planning rather than a public consultation.

Questions written by experts for experts to answer, with lots of references to “showing your reasoning”. This gave them an off-putting rather than engaging appearance.

Please note therefore that in providing this response I have followed specific Section / Chapter headings rather than reply to each individual question asked.


District Profile

Population Statistics = a strange change of approach.

Population growth statistics are probably the most important single metric in the whole planning document, yet you have chosen to abandon the parish based method shown in the current plan (2011) and the previous options paper (2018), replacing instead with the vaguely defined Settlements table.

Presenting a confusing and contradictory picture

I found your approach here very confusing.

You have rolled parishes up and/or split them into different units making comparison difficult, compromising the consistency of the information provided, thereby making understanding the figures significantly more difficult.

For example your 2018 paper showed the population of Great Wakering as 5587 and Barling Magna as 1740, giving an total of 7327.

Yet your current stats show a rolled up total of 6225. These imply that the population has shrunk by over 1000 people, which is definitely not the case. Such shifting sands provide no firm basis for robust and rigorous analysis or decision making.

Use proper hard credible metrics

The current table is confusing and not based on a solid administrative foundation = the Civil Parishes.

I suggest you return to using a standard consistent basis for showing population change by using the current administrative parishes for these figures, splitting them below Parish as you think necessary to show specific locations (Stonebridge/Sutton, Little Wakering)

By all means use this in addition to Parish statistics but not instead of the Parish ones, because they are the unit of financial disbursement of Council tax precepts.

And here as a starting point instead of using estimated growth, you should have solid figures for every year up to the current one, based on the disbursement of precept year-on-year from the District to each Civil Parish which I understand is based on the population for each Parich.

A suggested alternative

I would produce a table as suggested below showing figures for each Civil Parish within the District

2011 census figures 2018 Precept figures estimated precept figures, , for 2023*
* to reflect position as at 2023 = the start of the new plan.

Figures should include known and agreed developments already taking place and likely to be completed by that date, for example in Great Wakering = Star Lane Brickworks (100+ dwellings), land South of High Street / West of Little Wakering Road = 250 dwellings =

= an overall village population increase of some 500+ residents.


Presenting your figures in this way should give you, your council members, and the residents a much clearer, more rigorous, more robust, less abstract, more understandable and more justifiable and defensible basis for this particular round of the new District Plan, than using only the table as currently shown.


Spatial Strategy Options

Option 3a = the best strategic solution

Option 3a based to west of Rayleigh is the only sensible place to put the bulk of the new dwellings, based on its proximity to the A127 / A130 corridor, the ONLY major road links into / out of the District.

This option assumes that ECC can actually start doing something about improving the Fairglen interchange rather than just talking about it.

Here it can be noted that since the date of the last local plan in 2011, Southend Unitary Authority has done 3 significant changes to the A127 junctions (Cuckoo Corner, Kent Elms and currently The Bell ), while the County seems to have done little for the road users in the District at all. Certainly nothing of note to the roads between Rochford and GW.

Unless a major new road is built into the District to relive the increasing pressure on East / West travel in / out of the District, and this is a highly unlikely development in the next 20 years at least, then approving new developments away from the two major arterial routes referred to above, to elsewhere in the District, just places further burdens on the already over-stretched and over-stressed largely minor road network in the rest of the District, and the further east you go the worse it gets.

Such poor travel links as well as being a burden on residents also compromises the ability to attract into and keep business in the area.

Option 2 is tactical not strategic

Option 2 of just “bolting-on” more and more developments at the tactical level on the side of existing locations is not the answer because this approach delivers none of the benefits that a strategic solution, with planned-in transport, digital, education, health and other essential infrastructure, would bring.


Spatial Themes - suggested additions

Waste and Recycling

I didn’t see many specific references to this subject.

It is strange because the District has much to be proud of in promoting recycling through the weekly bin collection.

In comparison the County provision is poor. For GW residents with items to recycle, a 20mile+ round trip to the Rayleigh tip is the only option. The monthly "in village" collection only covers non-recyclables.

If districts are to deliver on their agendas it is time the County did it’s bit to improve and extend such facilities. Make it easy to recycle and people will recycle, as the District has successfully proved, time and again


Digital Infrastructure

Given its importance to every aspect of modern life, I would add a specific subject here i.e. the need to upgrade digital facilities and telecommunications capability across the district, especially for existing remoter areas.

For example, you will only be able to deliver the digital health facilities you mention, if there is sufficient connectivity and bandwidth to do so. Yet much of GW’s telecoms infrastructure is still through copper wire carried by telegraph poles.

Integrating this infrastructure is much easier for new developments, but plans need also to be put in place to modernize the existing infrastructure throughout the District as well.



Green Belt Policy

Worryingly your paper talks about “less valuable Green Belt”. I’m not sure what this is or who decides which bits are more or less valuable.

Given that in West Great Wakering, the two major developments approved under the current plan, plus the proposed new business park, have already eroded this green belt buffer.

If you are serious about maintaining the character of the village, to ensure that GW remains “vibrant and distinctive’, to deliver on your excellently worded “Draft Vision", will require you to vigorously and robustly defend the village from further developmental incursions into the village’s surrounding Green Belt land. In particular, to ensure it is not subsumed into other neighbouring areas, especially North Shoebury, by avoiding the threat of such coalescence.


Bio-Diversity

Wildlife / natural environment pretty much goes hand in hand with a strong adherence to Green Belt policy. Your recognition of the valuable role played by Star Lane LWS / local Geological site is welcomed but it will be placed under considerable stress if what remains of the Green Belt in WGW is further eroded.


Spatial Themes - Flood Risk

Most of the flood prevention measures refers to maritime flooding, but recent climate events have shown increasing vulnerability to extreme pluvial flooding events as well.

Paving over more Green Belt especially in those areas where significant new building has already taken / is currently taking place, further increases this risk. This is especially so in low-lying areas, as precious soak-aways have been lost and it becomes a vicious circle = more building = less natural ground = more risk of flooding as previously robust and resilient locations lose that capability and become unable to cope with heavy rainfall.

Building more new homes on flood risk areas will just leave new residents unable to get flood insurance and puts existing residents at increased risk as well, as existing mains drainage of varying age and vintage is found to be inadequate.


Transport and Connectivity

Public Transport

A lot of fine words with virtually no chance of being delivered.

The inverted pyramid is fine in theory but fails in practice because the public transport links from/to GW are so poor.

Since the previous plan the foreign-owned Arriva Bus Company has got rid of the main service 4/4A, pretty much a dedicated service to and from the village to Southend, and replaced it by the much poorer extended 7 /8 service. This change seriously compromised its convenience, punctuality, reliability so much so that people have left the village because of it. I used to use the old service a lot, the replacement has sent me back to my car.

Put the 4 / 4A (or an equivalent) back on and see if it persuades private car drivers to get back on the bus, because although Stephenson’s 14 service is much better than Arriva's, = more reliable / punctual, it runs less frequently, So using a car is so much more convenient, comfortable and reliable than current public transport options.

And as for Sundays, the service has been cut it back to only a 2 hourly service = 4 buses for the whole day in each direction. This is no way to incentivise anyone to move from car to bus, unless you have absolutely no other means of transport at all.

Walking

Walking within the village is OK but to go beyond it, forget it, until significant upgrade to pavements and road crossings in the area are made.

For example, the Star Lane / Poynters Lane junction is a horror-show. To encourage more people to walk, they need to feel safe doing so. A significant upgrade to current pavements out of the village would be required to deliver on this agenda, but in the last 10 years under the current plan nothing has happened to improve this aspect at all.

This paper is full of fine words and aspirations. But as was the current plan, sadly it is just all words and no action, in spite of the fact that developments in the area which might have been expected to bring such improvements, but have so far not delivered them.


Conclusion

I trust this is satisfactory and you find these comments of use.

Thank you for providing residents with the opportunity to comment on the future of the District.

I look forward to receiving details of the future development of the plans for the District'


The following occurred to me at lunchtime today, for possible inclusion under the Spatial Themes heading.

Electronic Car Charging

The government has stated its intention to promote the adoption of electronic car use, by phasing out the building of new petrol and diesel based vehicles.

This initiative is due to come into effect during the lifetime of the new District plan.

To be succesful it will require the installation of potentially significant amounts of charging facilities and supporting infrastructure.

This will present the District with significant Planning challenges:

1. to ensure that ALL new developments have sufficient car charging facilities and capability, built-in from the very start of the Planning process for such developments

2 this will include ensuring that the requisite electrical supply and delivery capability exists for individual dwellings, shared dwellings, other types of premises e.g. garages, retail, business premises.

additional electrical supply infrastructure might also be needed to be planned in here.

3 consideration of the impact of these rerquirerments on the existing installed base of all types of residential, business, retail, community premises.

this will be easier in some places which have their own private driveways, parking facilities, etc.

but it will present a considerable challenge for older properties, especially residential premises with on-street parking in narrow car-crowded streets, where parking outside ones own property might be difficult.

4. this would argue for the development, location and installation of community charging facilities, all of which will need to be planned for.

SITE ASSESSMENT PROFORMA: CFS180
In relation to the ‘spatial options consultation’, I would like to request you go back to government to politely tell them where they can place their housing targets!
Not sure if you have heard about the IPCC report but WE ARE IN A CLIMATE EMERGENCY, humanity would be grateful if you would start taking action towards that instead, as it is a much bigger priority that a new local plan!
We may need our greenbelt and agricultural land to grow crops if food supplies become affected, it is madness to consider covering them in concrete! Our roads are constantly gridlocked through infrastructure neglect and surely must be at dangerous pollution levels already. Not to mention the fact that a lot of the district is expected to be under water by 2050!
In light of the above, here are my reasons for objecting to this site:

Critical Drainage Risk
3
Green Belt Harm
1

Please could I add some comments to the spatial options consultation!



Firstly, I’d like to express my concern/feedback regarding the online consultation itself:
• I felt the online setup was really badly organised and far too complicated to navigate, even for those who are quite comfortable using the internet. It deeply concerns me how many residents will not have been able to respond due to this.
• The leaflet that residents received via the post was lacking any information on how they could send their input, other than via the internet! I didn’t notice any email addresses, telephone numbers or postal address for replies, in my opinion this also excludes many residents from responding!
• I appreciate you organised pop up events around the district, however Hawkwell only had 1 option and that was during the day, this meant that workers/commuters were excluded from face to face support.
• Whilst I have had a couple of good conversations with district councillors, there are many that have been unresponsive and invisible during the consultation (specifically those in Hawkwell East who I have contacted as a resident).
• As a Parish Councillor whose colleagues are mainly of the older generation and don’t use the internet, I was quite upset to see them struggling to navigate the ridiculous amount of paperwork and information that needed printing for them, in order for us to create a council response. This leaves me worried about how our older generations within the community will have coped. Was there any support provided to our residents who might not be able to manage the consultation for themselves and that don’t have any friends or family etc to assist them?

•
In relation to the actual content of the consultation, I believe that before any consideration should be given to further development, RDC need to address the issues with our existing infrastructure. Our current services (doctors/dentists etc), schools and roads all appear to be over capacity, at breaking point in some places. This is where RDC’s priorities should be. It makes no sense to me why you would issue a consultation regarding future housing development, without a full infrastructure plan in place first. In addition to this, I also strongly feel that RDC should be responding to government to negotiate a reduction/cancellation of the unrealistic housing target that has been thrust upon our already cramped district.

I have looked at many of the sites listed in the consultation and I find it extremely disturbing how many of them:
• are on green belt land, which needs to be protected at all costs as it provides vital habitats for the other species that also live on our planet (humans are not the only ones who need a home!)
• contain ancient woodland, which in my opinion is irreplaceable.
• are on agricultural sites, which if the predictions regarding the impacts of climate change and the food shortages (due to global crop failure), we may need this land for future farming.

Apart from the standard infrastructure details that I wasn’t able to locate in the consultation and I believe should have been provided (e.g. Up to date traffic assessments, statistics/reports on doctor/dental surgeries and schools, in relation to their current and predicted capacities ((based on current resident records)), I feel it is also essential that the council arranges:
• An up to date air quality assessment and associated comprehensive report – the traffic volumes have increased significantly over recent years, surely this means that pollution levels will also have increased, which can cause serious health issues for residents.
• An in-depth Flood Risk assessment – according to the ‘climate central coastal risk screening tool’ the land projected to be below annual flood level in 2050, includes a large part of the district (areas affected include Foulness, Wakering, Barling, Paglesham, Stambridge, South Fambridge, Hullbridge, Canewdon and Rochford). This worries me for many reasons:
o It means all current housing, retail sites and infrastructure in those areas could be at risk.
o It may mean that people are not able to obtain mortgages or insurance in parts of the district.
o Many homes in the district already suffer from surface flooding when we have torrential downpours, this can only get worse.

Please could I ask that instead of continuing with this consultation, you instead invest the time into lobbying government, addressing our existing infrastructure problems and planning for protection of residents, wildlife and property, from the effects of climate change.

Dear Planners

COL38
I notice you can no longer comment by clicking on the Spatial option map, is this because you have realised it should not be used for building, as in July 2000 it was agreed by RDC it should go to Ashingdon Parish Council to continue as a play space on a Peppercorn rent for 100 yrs (I was at the council meeting when it was agreed )

CFS023

1) This will strip the Green Belt land Bordering Beckney woods which is ancient woodland which in turn could damage the woods
2) The tranquillity required for the cattery would be lost.
3) The site does not have a gentle slope as mentioned in an earlier SHELAA report it is 60-80 ft North south and west east
4) We suffer from fluvial flooding due to the slopes and as there is blue clay needing deeper foundations this would exacerbate the problem by changing the water table
5) There would be a large impact on the wild life, a large variety of birds bats and adders also Foxes Badgers Muntjac deer .Crested newts have appeared in ponds.
6) Harrogate Drive is very narrow single track no footpath and there is no main Sewer. Wild life would suffer from loss of hedge rows
7) The entrance to Harrogate drive and the site would require a major change to the entrance from Greensward lane including losing property .The owner of [redacted] Greensward lane is adamant it is not for sale so it should be in white on option map.(How many more are like that?)
8) Any houses built would loose any privacy we have due to the large slopes
9) We already suffer from low water pressure and any more houses would worsen the situation

Overall

A) Once again infrastructure should come 1st the report should have been with the consultation.We have been complaining for years and nothing has improved I went to Rayleigh last week and there were queues from Spa Road to Hambro Hill no roadworks or bin lorries holding things up and it was not the rush hour!!
B) It would be far better to have a large site nearer main roads e.g. Lubbards Farm area it could also benefit from the power available from the Solar Farm addition to the Rayleigh substation. Instead of a collection of bits as proposed along Greensward lane
C) No space at local surgeries so more doctors
D) Schools are already close to max capacity
E) More facilities and care required for the ageing community
F) More Hospital beds
G) RDC should agree an overall plan for a new village in conjunction with Southend and Castle point
H) The action plan would have more comments if it was simpler to use for the older population.
I) Any development should have affordable housing not all high end, Hall Road suffers from that.

We do find these development of green belts really troubling. The fact that you seem content to ride roughshod over the purpose of this legislation in halting urban sprawl is a major concern to us, as we chose to move here to get away from such sprawl. While building on green belts is permitted, it is only to be undertaken in exceptional circumstances. We do not feel this is exceptional in any way.

We are concerned that you make no effort to give any breakdown of the infrastructure improvements that you would need to undertake with each of the plots. How can you ask residents to give their opinions without supplying this vital data? Certain developments might be more palatable if you had included the link roads, schools and doctors surgeries which would be included. Current infrastructure is already seeing long delays in getting to see doctors and children not being offered their first place in primary schools (which ironically causes more road traffic). We find this lack of planning surprising as it is clear you have done intensive reviews of each of the plots, without seeming considering this vital factor.

The fact that the roads are already in a very poor state of repair, gives us no confidence that such improvement can be achieved prior to building, or even post the builds.

With reference to the areas near where we live, without understanding the infrastructure improvements needed, it is difficult to draw up a comprehensive list of objections. However, to start the ball rolling, with this development, we would like you to formall record the following objections.

Site reference: CFS023

1. You are looking to build right on the edge of ancient and well used woodland, which would clearly damage it physically, but also the nature of the woodlands itself.

2. To build the road into this development you would need to compulsory purchase a large number of plots to be able to put in a road and footpath of a suitable width.

3. Again ,with regard to the road, you would also need to cut down a number of trees which currently line the track, a number of them appear to be very old.

4. Our house is only a few meters from the proposed road, which would reduce our privacy as well as increase air pollution, and noise levels.

5. Having any development along the already crowded Greensward Lane/Ashingdon Road with its large number of schools located on or adjacent, would simply cause more road congestion, and with the road already often reduced to a crawl, which in turn would also increase the air and noise pollution for residents.


You have placed scores against schools and healthcare, but have you approached these establishments to ask if they can service these new developments? You simply cannot score against existing needs, but need to score against the projected ones. For example I know an existing local primary is full, so how can you score a 5.

Our view is that if more new houses are needed, you should focus on new town developments where you can suitably create the infrastructure needed, as part of the development itself. People moving there would fully understand what they are moving into. We would suggest building close to the A130 to the West, with their improved road links, or to the South East with links to A1159/A13. We would also suggest working alongside the surrounding councils of Wickford and Southend to produce a fully joined up offering as joint developments.

We see a number of these proposals, as death by a thousand cuts to small towns such as Hockley, which will forever change their makeup and character. We were under the impression that it was the council’s duty to protect the hamlets under their charters, but these plans seem to go totally against these aims.

With Covid, we are likely to see homework now becoming more widely used. This in turn will see more offices converting to residential use (such as Victoria Ave, in Southend), which may have a big impact on the need to build more homes in rural areas such as ours.

To restate our initial comments, we believe on top of the callus building on Green Belt, you need to produce a fully realised infrastructure plan for the regions first, to sit alongside any proposals. Only then should residents be asked for their views.

New Local Plan: Spatial Options Document 2021
Thank you for this opportunity to respond to the latest consultation. Our comments follow those made on previous
consultation documents, namely:
1 July 2015 – Draft Environmental Capacity Study
18 May 2016 – Draft Statement of Community Involvement
8 March 2018 – Issues and Options consultation.
Please find our responses to particular questions below.
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?
As mentioned in our letter responding to the draft Environmental Capacity Study, full consideration should be given
to the Environment Agency’s Essex and South Suffolk Shoreline Management Plan.
Q4: Do you agree with the strategic priorities and objectives we have identified?
Yes. We welcome and commend the Council’s clear priority in Strategy Priority 5 to conserve and enhance the natural
environment as well as a clear ambition to create habitat networks. This is consistent with national planning policy.
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?
Mandatory biodiversity gain (BNG) should go beyond mitigating and compensating the impacts of development by
enhancing natural capital, supporting the recovery of nature and meeting future environmental challenges. Done
correctly, it should help to deliver sustainable development, restore nature, and create and enhance places where
people live and work.
The council’s approach to BNG should be underpinned with clear targets for protecting and restoring biodiversity and
its effectiveness evaluated on a regular basis. BNG must be in addition to, and not instead of existing statutory
biodiversity protection and it should only apply to developments that do not have an impact on protected areas, e.g.
Special Protection Areas (SPAs), Special Areas of Conservation (SAC), Ramsar sites and Sites of Special Scientific
Interest (SSSIs).
A fundamental risk of BNG, is that it will be considered a licence to trash habitats as destruction of a habitat can be
offset by creation of another. To avoid this, the net gain approach must apply and enforce the mitigation hierarchy,
so all efforts are made to avoid and mitigate harm through appropriate location and design choices. Compensation (offsetting) of residual impacts on habitats and species should be a last resort. Re-creating or restoring complex
natural processes is inherently difficult and full of risk so in-situ conservation is always preferable. Once the mitigation
hierarchy has been strictly applied, the development should be achieving no net loss of biodiversity. Net gain
approaches can then be explored as additional
To answer the question specifically, where new habitat is created, it is normally preferable to do so on the
development site. If this is not possible or desirable due to unavoidable impacts, it should be in an area identified in
a local or strategic biodiversity enhancement plan (e.g. the evolving Local Nature Recovery Strategies [LNRS]).
Q32. With reference to the options above, or your own options, how do you feel that we can best deliver a quality
green and blue infrastructure network through the plan?
The RSPB would like to see a strategic approach adopted for the delivery of new and enhanced green and blue
infrastructure. We are currently working with a number of partners in Essex to establish a Local Nature Partnership
(LNP) as well as the evolving process of Local Nature Recovery Strategies (LNRS) which have recently been piloted
elsewhere in the UK.
Protecting and enhancing the established network of designated sites is the fundamental first step. It is widely
recognised that much of the land surrounding our coastal SPAs and SSSIs is functionally-linked to these sites (i.e. it is
unprotected land that supports numbers of birds such as dark-bellied brent geese in significant numbers). Identifying
and mapping these areas at a spatial-level would assist the council in maximising the benefits to the natural
environment
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most
appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred?
The RSPB supports the recognition giving to the network of coastal sites in the “island wetlands” complex which are
reflected by their suite of national and internationally important nature conservation designations.
However, it is critical that the sensitivity of the internationally important species and habitats is accounted for
rigorously in the planning of any such proposals. A Habitats Regulations Assessment (HRA) of the plan should be
instigated at the earliest opportunity in order to achieve this. Responding to the Issues and Options consultation in
March 2018 in relation to HRA, we said:
“We recognise that a number of HRAs relating to previous development plans and strategies have been
provided as part of the evidence base. Whilst informative, these are not up to date. However, we note and
welcome your commitment to presenting a draft HRA at the next stage of the plan process (per paragraph
1.12) and we look forward to commenting on this document. If you require any assistance in its formation,
we would be happy to assist.”

Dear Sir/Madam
SPATIAL OPTIONS DOCUMENT 2021 .NOTIFICATION OF CONSULTATION UNDER REGULATION 18 OF THE TOWN AND COUNTRY PLANNING (LOCAL PLANNING) (ENGLAND) REGULATIONS 2012, AS AMENDED.

Thank you for the opportunity to comment on the Spatial Options Document 2021. We have reviewed the document and have provided comments in regards to Water Resources, Flood Risk and Ecology. In our response we have commented on specific questions raised in the consultation, where we feel the plan can be
enhanced or strengthened.

Water Resources
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?
There needs to be consideration of the South Essex Joint Strategic Plan and the water cycle study. This can highlight where they may be restrictions on development.

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?

Strategic Priority 3 mentions providing ‘sufficient provision of infrastructure’. There needs to consideration of this for wastewater/foul water in a strategic objective. Strategic Objective 9 could be amended to cover this: ‘To ensure that all new homes and commercial premises are supported by appropriate, timely and necessary infrastructure to mitigate potential impact, including those relating to transport, utilities, telecommunications (including broadband), open spaces and greenways, flood risk, wastewater treatment capacity, education, health and other community facilities.
This is required in order to ensure development is phased in line with treatment capacity to protect the water environment. If sufficient capacity is not available this can affect the locations of development.
Strategic Objective 20 mentions protecting the ‘natural environment’. This could be strengthened by the addition of rivers and other freshwaters’. This is because the
Water Framework Directive (WFD) requires protection of all waters; rivers, lakes and coastal/estuarine waters.
Options - The options include possible development at several towns. These are served by Water recycling centres, the main ones being Rochford, Rayleigh East,
Rayleigh west. All have some capacity at the moment for development but we recommend early discussions with AWS and use of a water cycle study to ensure
that developments are located and phased with wastewater treatment capacity.

Q10.Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character?
Page 37 talks about protecting a natural environment and about protected areas. But all water environments are protected under the requirements of the WFD. Assessment of large developments need to consider the main requirements of this directive – that there will not be a deterioration in the water environment and that required improvements in quality are not compromised. The river roach and its tributaries are within the Rochford area, and tributaries of the River Crouch.

Flood Risk
Q2 Do you agree with the draft vision for Rochford?
It would be good to see something in here regarding flood risk, it could maybe fit under the Environment heading and state: We will aim to manage flood risk and
look to sequentially site development out of the flood zone to try to reduce flood risk both now and with the effects of climate change.

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 from flooding and coastal erosion where possible?
Yes we agree sequentially siting development out of flood zones. This in itself is the best way that they can best protect their communities from flood risk.
You should also note that since the previous consultation regarding the local plan climate change allowances have been updated, the latest guidance can be found
at: https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances.

Ecology
We generally agree with the vision and proposals for biodiversity and blue / green infrastructure included in the plan. The following link could be added as a resource
regarding green infrastructure http://www.biogeomorph.org/greengrey/

We trust this information is useful.

Yours faithfully

Mr. Pat Abbott
Planning Advisor
Direct dial 0208 4748011
Direct e-mail pat.abbott@environment-agency.gov.u

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.

I am responding to the new Local Plan for the area and am making the following objections for the proposed developments in Hullbridge:

* The previous Local Plan/Core Strategy has resulted in significant strain on public services, roads etc despite repeated requests to both County and District for proper infra structure. As a result, the latter councils did not complete transport or sustainable
infrastructure assessments prior to this consultation. This needs
be addressed urgently in light of the new Local Plan.

* Vision statement: this was written by Rochford Council without any consultation of our local community in Hullbridge. There is a lack of understanding of our local community and its future. For instance, some of the 'promoted sites' have been put forward without the landowner's consent and are therefore inappropriate. An example of this is land that was agricultural and which has now been developed into a very successful vineyard.
Hullbridge has a 'village' community feel but with any additional building it is in severe danger of losing this and just becoming urban sprawl.

* Negative impact would be made to the precious Green Belt and Coastal Protection Belt if further building were allowed to go ahead.

* There would be critical flood and drainage risks. For instance, Watery Lane still floods although this was disregarded in the previous Local Plan. By 2040, Hullbridge will have a significant proportion of the village below sea level, hence making it unsuitable for building.

* Negative impact on local habitats: animals, birds and insects are being squeezed into smaller and smaller green spaces and this is detrimental to both them and us. As a direct result of the recent house building in Hullbridge, the number of dead animals killed by increased traffic has risen significantly.

*Proximity to local transport: the number 20 bus runs along Ferry Road which is a significant distance from any proposed new builds.
This puts pressure on people to use cars which adds to further pollution. RDC say that there are 4 -7 buses an hour on Ferry Road but this is a huge inflation of the truth!

* Lack of accessible open spaces and amenities: there is a distinct lack of these in Hullbridge and an assessment needs to take place in advance of any further development.

* Loss of footpaths and/or bridleways: there has already been a loss of these owing to the building of the roundabout at Rawreth Lane and further loss would be extremely detrimental to people and those on horseback.

* Impact on agricultural land: we need agricultural land to provide food for us and for animals and brownfield sites should be considered before any greenbelt land is considered for building.

* Existing community infrastructure: there are poor road links, few sustainable transport options and huge pressure already on local education/schools, medical services, youth services, leisure facilities etc. Roads cannot cope with cope with increased traffic; it is very difficult to get a GP appointment; there are long waiting lists at our local hospital in Southend.

* Here in Hullbridge, we are keen to protect our rural coastal village outlook and vehemently object to unnecessary building which will spoil the nature of our village.

* I am not in favour of any further building but if I had to choose one spatial option it would be 3 as these are considered priority options and would keep any new housing on one area.

Response of London Southend Airport Company Ltd to Rochford Local Plan: Spatial Options Consultation 2021

LSA is delighted to respond on the new local plan.
Our focus is primarily in relation to establishing a positive policy framework for continued growth and development of London Southend Airport (LSA), in accordance with up to date national policy that supports airport’s making best use of their existing runways, and in recognition of the important role and highly positive contribution the development of LSA can make to the District.

In addition, our response also makes suggestions to be considered for improved connectivity to the airport to the east of the railway line.

We would be keen engage with the Council on the drafting of policies and supporting text and urge the
continued close cooperation with Southend Borough Council on their new local plan.

Your sincerely
Glyn Jones
Chief Executive Officer

Rochford Local Plan: Spatial Options Consultation Paper 2021
Response of London Southend Airport Company Ltd
Policy Approach in Relation to Future of London Southend Airport
We are pleased to note the Consultation includes a section on the future of London Southend Airport (LSA).

National Aviation Policy
The section on the Future of LSA refers to current national policy which supports airports making best use
of their existing runways.
The text on page 91 refers to The Aviation Policy Framework (2013) and the Beyond the Horizon – The
future of UK aviation (2018) policy. It is also worth noting that in response to the challenges of tackling climate change, the government has also recently published its Transport Decarbonisation Plan and commenced consultation on its ‘Jet Zero’ strategy.

In the Transport Decarbonisation Plan (TDP), published by the Department for Transport in July 2021, the
Government explains that:
“International connectivity is a vital part of Global Britain and everyone should continue to have access to affordable flights, allowing them to go on holiday, visit family and do business.”
The Jet Zero consultation sets out how Government intends to preserve the benefits of air travel and deliver clean growth consistent with its 2050 net zero target. It also confirms that the international connectivity provided by UK’s aviation sector is vital to the country’s long term economic prosperity, and subject to the aviation sector playing its role in decarbonising the UK economy and delivering net zero aviation by 2050, that:
“everyone should continue to have access to affordable flights, allowing them to enjoy holidays, visit friends and family overseas and to travel for business”.
The TDP and Jet Zero represent the most recent expressions of policy, set out the Government’s position
that growth in aviation is compatible with meeting the UK's greenhouse gas reduction targets and reaffirm specific support for making best use of existing runways.
Growth and Development of London Southend Airport
Prior to the outbreak of the COVID pandemic, passenger numbers at LSA had increased to 2.2m in 2019
and some 1,500 people were employed at the airport. More broadly, the airport supported 2,200 direct,
indirect and induced jobs, over 1,400 of which were in South Essex, and contributed £77m per annum to
South Essex economy.

The pandemic has had a devastating impact on the global aviation industry in 2020. Southend, along with
all other UK airports, has experienced a significant reduction in passenger traffic, as a result of both Government imposed restrictions on air travel and reduced passenger demand at this time.
Whilst it is expected that Government travel restrictions will continue to impact on passenger demand and traffic levels throughout 2021 and into 2022, we expect traffic levels will start to recover as Government restrictions ease and that material recovery from the pandemic is anticipated by 2023-4.
By 2026, we expect LSA’s passenger throughput to have surpassed Pre-COVID levels and that the airport will be welcoming some 3 to 3.5 million passengers per year through the existing infrastructure. With investment to construct the developments permitted by existing planning consents, and operating within the existing Section 106 movement cap of 53,300 movements, we consider that the airport could serve some 7 to 8m passengers by the end of the 2020s.
During the local plan period, and with further investment in new facilities it is possible that passenger traffic could grow beyond 7-8m passengers and serve up to 12mppa. Growth to this level will require new planning consents, including a relaxation of the current movement cap on the number of aircraft operations.

These levels of growth reflect the fact that LSA is very much part of the London aviation “system”, with over 60% of LSA’s departing passengers self-identifying as originating in London in 2019, and the widely recognised position that airports in London and the South East are increasingly facing longer term capacity constraints where demand for travel will outstrip capacity.
An economic assessment carried out by PA Consulting on behalf of LSACL, forecasts that LSA would then be the location for 6,600 jobs with a further 3,300 indirect and induced FTEs jobs. Over 6,100 of these would be in South Essex and valued at over £0.5bn in South Essex economy.
We have also now commenced studies to understand what the implications of further growth of LSA would be, including on noise, transport and air quality. These studies will form part of our plan to consult on un updated Masterplan. The outputs form the studies and the development of the masterplan can be used to inform the preparation of the new Rochford Local Plan (as well as the new Southend Local Plan).

Policy for London Southend Airport
Planned in the right way, the development of LSA can make a highly positive contribution to the vision for the District, and a number of the strategic objectives set out in the Consultation Paper.
As noted in the “Economy” section of the draft Vision, the connectivity offered by a successful LSA will support the attractiveness of the area for business and investment. The success of LSA is vital to the economic prosperity of Southend, Rochford and the surrounding area and we are pleased that the text on page 91 recognises the important role LSA plays in supporting employment and the local economy.
Whilst the COVID pandemic has seen job numbers at the airport reduce to less than 900 from a peak of over 1,500 in 2019, we are expecting employment levels to return as passenger growth recovers. Job growth at the airport would support the objective of reducing levels of out commuting from the district as well as supporting skills development. Transport infrastructure at the airport could also support objectives related to improved local transport and connectivity.
The growth of the airport will have implications for the local area, and we agree that that the characterisation of these (on page 91) is fair representation of the range of positive impacts to be encouraged and environmental matters that would need to be addressed in future development plans.

Response to Question 28 Future of London Southend Airport
Question 28 of the Consultation seeks views on policy options available for the future planning of LSA.
LSACL consider that whichever options is followed, cooperation on the policy with Southend BC will be
important, and it would be helpful if both authorities adopted similar approaches.
We consider that the current Joint Area Action Plan (JAAP) has served the area well. Equally, with consent
now having been granted for the new business park (which formed a major component of the JAAP), we
do not consider there is now a need for an updated formal statutory Joint Area Action Plan to guide the
future planning of the airport and its surroundings.
We consider that the Local Plan should contain a section and policy or policies for the development and growth of LSA. We support a combination of Options 2 and 3:
i) Policy Supporting Development of London Southend Airport
In accordance with national policy, there should be a clear policy expressing support in principle of LSA’s
growth and development, subject to the normal local environmental safeguards, including noise, air quality and transport being acceptably addressed and mitigated in any new proposals. We would envisage the Local Plan defining the boundary of the airport and supporting development and redevelopment within the boundary of facilities that support the airport’s operation, growth and development. The policy would refer to the updated masterplan being prepared by LSACL which would be used to guide development of the airport.
This is the most common approach adopted by other planning authorities which contain a commercial
airport in their area.
Any proposals for development at the airport that would require the alterations to the current terms of the Section 106 agreement, would require the agreement of both Rochford and Southend Councils.
Therefore cooperation on the revised policy is essential.
We would be keen to engage with both Councils on the drafting of this policy and supporting text.
ii) Policy on Airport Related Parking
We consider it would be appropriate for a policy to be included in the Plan that airport related parking should only permitted within or immediately adjacent to the airport boundary. This is an approach that a
number of local authorities have adopted, and has been found to be sound and justified at local plan
examinations. In particular, it is the approach that recognises that whilst many passengers will drive to the
airport, it reduces the length and number of journeys by avoiding passengers parking more remotely and having to take extra journey’s via shuttle buses or valet parking operatives.

Response to Question 28 Future of London Southend Airport and Q52 (Transport Connections)
Question 52 of the Consultation asks where improvements could be made to transport connections and what could be done to improve connectivity.
Access to the London Southend Airport Rail Station
We consider that the Local Plan should consider how access to LSA’s rail station could be made more
convenient for local residents. At the present time a number local residents walk to the station, but the
route to the station, particularly from the residential areas to the east of Southend Road could be made shorter and more direct if an access was provided to the east side of the station through the “green buffer” (currently protected by policy ENV6 of the Joint Area Action Plan). It is recognised that such an improvement would also probably require the extension of a parking control schemes to prevent ‘fly parking’.
We consider the new local plan presents a timely opportunity to review whether the “green buffer” land
east of the railway could be more effectively used in connection with the railway and the airport, whilst
retaining and potentially enhancing the quality and effectiveness of the buffer for local residents. This site
could for example provide an excellent opportunity for improved local bus connectivity / interchange to the railway station and airport. Planned and designed in a sensitive way, and with higher quality landscaping, the buffer could be enhanced, whilst at the same time facilitating improved connectivity.

Dear Sir,
I write to submit feedback on the proposed new housing development sites in our area.

(New Local Plan: Spatial Options Document 2021) https://rochford.oc2.uk/document/207/28308#d28422

In common with the majority of residents I believe Rayleigh and surrounding areas already have enormous new build projects underway. We should stop further housing sprawl especially on the outskirts of towns such as Rayleigh where upgrading the road system is impractical. The uncertainty of the situation is causing anxiety amongst my friends and neighbours who maybe directly impacted.

My concerns are the usual ones:
• Loss of greenbelt and wildlife habitat
• Traffic congestion and associated air pollution
(Inability to widen the narrow residential roads in Rayleigh)
• Surface water drainage
• School and GP services

Fundamentally I fear we are on a path of infinite housing growth that surely cannot be sustained without deterioration to our quality of life. I feel we should halt all new housing developments on town borders (greenbelt land) and create new towns with the required infrastructure instead.

Thank you for the opportunity to provide my feedback, please find my responses to the questions enclosed.

RDC/Spatial Consultation 2021 Questions

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?
A: Evaluate the impact of the current developments, especially in Rayleigh and Hullbridge.
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? [Please state reasoning]
A: Mostly, although I do not feel you have included enough information on how you might achieve housing for the hidden homeless or those on low incomes, emergency housing provision, schemes to allow the elderly in large houses to be able to downsize or how you plan to provide suitable commercial units of varying sizes, to allow businesses to up or downsize into a suitably sized premises without them needing to relocate into another area.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making? [Please state reasoning]
A: Yes, as each settlement has its own characteristics and needs.
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? [Please state reasoning]
A: Don’t know.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required? [Please state reasoning]
A: Yes. Rayleigh is the largest town in the district but you need to maintain the green boundaries between the surrounding areas.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan? [Please state reasoning]
A: A combination of 3 and 4.
Creating a new town would enable all the infrastructure to be put in place, allowing more scope for cycling routes and pedestrianised areas. This will stop the urban sprawl which is currently happening in the larger town (and proposed in option 1), creating traffic havoc and pollution. Combining this with option 4 could help with spreading the balance of housing needs, traffic, etc. across the whole of the district and not just in one place.
Q7. Are there any reasonable alternatives to these options that should be considered instead? [Please state reasoning]
A: Windfalls should be included in the housing quota.
Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis? [Please state reasoning]
A: Yes: Cultural and Accessibility.
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? [Please state reasoning]
A: Yes. We need to ensure we have a suitable plan to protect not only our towns and village communities (houses/businesses) but also the natural areas as well. We need adequate defences to limit flooding in all areas, protecting people and wildlife. Maybe these could be incorporated in the “natural” landscape theming so as to deflect any water away from these areas. New developments not only need to address their carbon footprint but also the design of the housing they build so that they limit flood damage.
Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character? [Please state reasoning]
A: Yes. I feel all of our coastal areas and areas of special interest, where there is a significant risk of flooding and harm to the environment needs careful consideration. Our ancient woodlands also need to be protected and well managed.
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 low-carbon or renewable energy?
A: Vast swathes of land being used for solar panels or unsightly wind farms should not be allowed. I do not feel we have used the potential of tidal renewable energy themes. We have potential in some areas to explore this without defacing our district. All new homes should be fitted with solar, either on their roof or windows and commercial properties could be encouraged to fit solar panels to their roof.
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? [Please state reasoning].
A: I believe that we should aim to achieve a higher standard if possible and encourage developers to put forward new ways of achieving this. We are planning for future generations and should not be stuck in the past. Why go for minimum standards? Always aim higher!
Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported? [Please state reasoning]
A: Solar in all new development as standard. Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs (there are many flat roofed buildings all over the district that could accommodate solar panels without damaging the landscape). Explore tidal energy and seek out suitable locations in order to ascertain whether it is viable. No wind turbines! They would ruin the landscape.
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? [Please state reasoning]
A: The district has some very distinct areas and a “one shoe fits all” would be detrimental to some smaller communities. The place-making charter should be bespoke, with each area being considered in its own right. The rules on building should be strict so as to enhance the areas of development and needs to consider the wider picture in respect of amenities, open spaces, retail, schools, services, pollution, character and accessibility (to name but a few). There should not be deviation of plans unless there are exceptional circumstances. Time and time again out SPD2 documents are ignored and ugly extensions and dormers are built to the detriment of the area.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included? [Please state reasoning]
A: They are, as long as they are adhered to.
Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
A: Yes.
➔ 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? [Please state reasoning]
A: You need different design guides/etc as our district is unique and diverse and the “one shoe fits all" would be detrimental to its character and charm.
➔ Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting? [Please state reasoning].
A: You need to ensure that the character and heritage of our settlements are adhered to whilst allowing for some growth, in order to rejuvenate the smaller settlements if needed.
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? [Please state reasoning]
A: By working closely with planners and developers, as well as different charities and communities, residents and businesses. You will then get a better understanding as to what you need and what will be achievable.
Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas? [Please state reasoning]
A: The district has a large number of houses, existing and approved that have 4 or 5 bedrooms. The number of homes available with 2 or 3 bedrooms is minimal, which increases their price and availability. The smaller properties are the ones that need to be affordable for families. We should ensure that our “affordable“ properties are not all flats and that the minimum (or higher) standards are met for gardens/recreational space. There are sure to be single, elderly residents that would like to downsize from their large family homes, into a smaller, more manageable one but do not wish to go into an assisted living/residential /retirement home. They may want a 1 or 2 bedroomed property, maybe one storey, or low rise apartment that they own freehold. We also need to consider that some of our residents may need residential care and we should be looking at ways to cope with the rising number of elderly and provide accommodation for them also. We desperately need to meet the needs of the hidden homeless. The adult children on low wages that have no hope of starting a life of their own away from their parents. By living in these conditions, even if the family unit is tight and loving, it will cause mental health issues, stress and anxiety. We also need accessible properties for our disabled members of our community, where they are assisted in order to fulfil a normal as possible life. Emergency and social housing also need to be addressed.

Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing? [Please state reasoning]
A: Housing for the hidden homeless – those “sofa surfing”, or adult children living at home with parents as they are on low wages or wages that would not allow them to move out to rent or buy somewhere on their own. Adapted homes for the disabled (physical, blind, etc.). Smaller, free hold properties for the older generation to enable them to downsize from large family homes. Social housing. Emergency housing.
Q20. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller accommodation needs? [Please state reasoning]
A: You need to find a permanent site that has a little room to expand but not exponentially. The “Traveller” life has changed over the years and many will not fit into this category. We need to be integrating those not deemed into the classification into everyday life and housing. We also need it to be managed so that illegal building work and population do not exceed its capacity. This site will need good access and be somewhere where it does not impose or affect other residents.
Q21. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs? [Please state reasoning]
A: You need to find a permanent site that has a little room to expand but not exponentially. The “Traveller” life has changed over the years and many will not fit into this category. We need to be integrating those not deemed into the classification into everyday life and housing. We also need it to be managed so that illegal building work and population do not exceed its capacity. This site will need good access and be somewhere where it does not impose or affect other residents.

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites? [Please state reasoning]
A: Easy access re large vehicles to the site and main roads to ensure the residential roads are not blocked by the larger vehicles. Room for some expansion that would not encroach on the surrounding area. Away from residents to reduce disturbance of vehicle movements. Not in an area of interest or recreation where the landscape would be blighted by the appearance of many vehicles. Not all in one area – spread out our quota across the district in order to avoid another Crays Farm scenario.

Q23. With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan? [Please state reasoning]
A: The council needs to stop developing existing commercial land into housing. Too many sites have already been lost and many more are planned to go. They can then concentrate on helping those businesses wanting to expand to be able to do so. They should look to working with local schools and colleges, as well as businesses and the job centre, to see what sustainable employment is needed in the district. They then need to assist in schemes to train all ages get back into work or upskill.
Q24. With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the Green Belt? [Please state reasoning]
A: No. The current employment site allocations on Figure 30 do not provide enough space to meet the District’s employment needs through to 2040. We have around 87,000 people in the district. There is no data on the form to suggest how many of these are in employment and how many are looking for work but the council need to reassess its future needs in order to future-proof our residents’ opportunities. We only need to formally protect sites that have a future and a potential to expand or continue effectively. Green belt sites should be assessed separately and decisions made on merit.
Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?
A: Option 3 could deliver new opportunities for employment as it would be a new site completely. Industrial units of various sizes, with room for expansion plus retail, hospitality and other employment could be included in the criteria for the development. Option 4 could assess existing sites across the district and the options to be able to expand, as well as areas for new sites.
Q26. Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?
A: Environmental services - woodland conservation/management. (We need to find funding for this as it is important!) HGV training school.
Q27. Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g. skills or connectivity?
A: Better road networks and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training.
Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system? [Please state reasoning]
A: Unsure, but I feel there is not enough room for too much expansion ie. add another run way. The council could consider a park and ride park, to divert some traffic away from the residential area, which could create jobs for security services, bus drivers, attendants, cleaners, etc. Expansion of the airport may affect the Grade 1 listed St Laurence and All Saints Church and this needs careful consideration.
Q29. Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
A: We all should be doing everything in our power to protect wildlife sites. All wildlife is important and we have been neglecting them, and slowly chipping away at them for years. Wildlife now enter suburban areas as their own habitats have diminished and they can no longer fend for themselves adequately from nature. We have a decline in Badgers and hedgehogs as well as rabbits, frogs, newts, voles and shrews. Ask yourselves: when did you last see a live hedgehog or badger? Most (especially badgers) are usually dead (along with foxes and deer) by the side of our roads. We have removed places that have housed bats and now we do not see them flying around the district in the numbers they did. Designating initial sites is a step in the right direction but we have to do more. It is proven that our mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was. Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. You mention that Doggett Pond no longer meets the standard but are there no steps to improve its status instead of dismissing it? It is obviously an important site for the wildlife in that area. To lose it would be to our detriment. We should be looking at creating new sites with every large housing development, and adding them to our protected list in order to improve our district and our own wellbeing. We should no allow private households to take over grass areas and verges (or concreting the verges over for parking and cost savings). These areas, although small are still areas for wildlife (bees and butterflies - also in decline, as well as bugs which feed our birds). We should create new wildlife meadows to encourage the pollinators in order to future proof our own existence. We should be exploring smaller sites that we could enhance, manage and protect in order to give future generations something to look back on and feel proud that we have given them a legacy. Something that we can be proud of.
Q30. Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
A: Yes. We need to protect them for future generations and teach our children their history and importance so that they can continue to keep them safe.
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?
A: On site. You can then assess in real time and sort out any issues you would not have known about off site.
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? [Please state reasoning]
A: You need to enhance and maintain what we already have by ensuring the necessary links are in place to link as many as possible, and ensuring that public rights of way are not blocked by land owners and are kept free from debris. You also need to assess some paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look into offering this in the larger spaces (ie in the car park – a small toilet block and hand washing facilities). Obtaining funding from large (and medium) developments for enhancement of existing areas as well as providing new spaces and facilities is a step in the right direction.
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
A: They are a step in the right direction but you need to assess periodically in order to be able to add further links to any new parkland that may be created in the future. The map is unclear as it does not show exact routes. There is a large open space to the South West of Rayleigh (on the border), South of Bardfield Way and The Grange/Wheatley Wood, which could be enhanced.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure? [Please state reasoning]
A: Enhancing the areas we have and ensuring developers include green space/recreational facility areas within their developments. A new, separate development would be able to deliver this within their plan layout. Ensuring there are suitable links, access and footpaths. Making sure some of these footpaths are accessible for the disabled.

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? [Please state reasoning]
A: Ensuring that funding for existing facilities comes from new developments and making sure that these facilities are built during the time of the development (not like the London Road/Rawreth Lane development where a site was “provided” for healthcare but has not been built). Assess the shortfall of facilities and networks before plans are approved so that adequate planning and funding can be secured before any building takes place.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure? [Please state reasoning]
A: A new town would have this infrastructure built into its plans. Funding for improvements must otherwise come from developers if an area is already overpopulated.
Q37. Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these? [Please state reasoning]
A: Rayleigh is overcrowded. It has a road network no longer fit for purpose. The schools are almost full. It is difficult to obtain a GP or dental appointment. There is little to no disabled play areas/equipment. There is always issues with waste collections, drain & road cleaning and verge trimming. The council does not have the staff to deal with all these issues. The council needs to either build another waste recycling site (as the one in Castle road is no longer capable of expanding and meeting the needs of its ever growing population) or develop a better waste collection program which allows extra waste to be collected next to bins. It also needs to find a site to address/install commercial waste facilities to stop fly tipping.
Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan? [Please state reasoning]
A: Improve what we already have. The tennis courts on Fairview Park need improvement. Safeguard our open spaces to ensure we have wildlife and recreation. Develop different types of sporting facilities – not just football pitches. There is a need for a larger skateboard park and BMX track. We need to offer free recreation for our teenagers.
Q39. Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering? [Please state reasoning]
A: The development of 3G pitches seems to be the trendy thing to do but they are plastic grass at the end of the day and we should be looking at ways to reduce our plastic use. If there is an area that already exists that is in a poor start of repair then it may be an option – especially if the “grass” is made from recyclables, but we should be thinking outside the box and not covering our parks with it.
Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering? [Please state reasoning]
A: They look suitable. They will probably need funding.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
A: A new development would be able to deliver this in their plans or fund improvements for existing facilities.
Q42. Are there particular open spaces that we should be protecting or improving? [Please note, you will have an opportunity to make specific comments on open spaces and local green spaces in the settlement profiles set out later in this report]
A: The sites will be specific in each parish. You need to protect all of these recreational spaces and improve if necessary as once lost to development, they can ever come back.
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? [Please state reasoning]
A: You need to reassess your policies on planning regarding alterations made to the buildings on your list, especially in our conservation areas. There have been a few occasions where buildings of “interest” (or other) have been altered, and that places in conservation areas have been allowed canopies, shutters and internal illumination of signage without challenge. Any building work (if any) needs to be sympathetic to the area and you should be able to request amendments to frontage, even if they have had it up for some time. Shop fronts are huge areas of uninteresting glass with garish colours. Signage and advertising (‘A’ board’s litter our pavements without challenge and large barriers are erected onto the pavements – totally out of character with a conservation area in a heritage town. Stick to your policies.
Q44. Are there areas of the District we should be considering for conservation area status beyond those listed in this section? [Please state reasoning]
A: Unsure although we need to stop taking areas of our precious woodland to make way for housing.
Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets? [Please state reasoning]
A: Don’t know. Mill Hall? Over 50 years old. Cultural centre in a conservation area. Needs massive investment and management. A new survey needs to be taken to ascertain whether there are any other areas that should be considered. There are many buildings along the High Road into Rayleigh (but not in the conservation area) which should be considered.
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state reasoning]
A: You can only have a vibrant town centre if there are shops to go to. If these units are subsequently changed to residential then our town centres will be fractured and uninviting. The new Use Class E will mean it will be even more important for the council to protect our retail outlets. You need to work actively with premises owners in order to assist in the re-letting of any empty shops. Maybe offer a reduced rent to new businesses as a start-up scheme (you could contain this as a “local” business only – allowing the entrepreneurs in the Rochford District a chance to showcase their business). You also need to be able to negotiate with the owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows (ie. photos of the old towns or useful information) to make them more attractive.
You will need good access links with an excellent road and cycle network and reliable public transport that links effectively from all the villages to all the towns.
Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]
A: Yes.
Q48. With reference to Figures 38-40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
A: Yes
Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]
A: Yes. We do not want rows of hairdresser or rows of takeaways etc. as this would eventually kill off our high streets. We need to have a balance of outlets. You would lose the vibrancy you are hoping to achieve if you allowed this. You should also consider restricting use to giant chains as these tend to be the first to go in a crisis and make high streets lose their individuality by them all looking the same.
Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]
A: Unfortunately, some of our smaller retail areas have been sold off and housing development has been allowed (eg. Rayleigh - rear of Marks & Spencer and Dairy Crest plus Lancaster Road [builders’ yard]). In a new development there would be scope to add a small/medium/large precinct of retail etc. depending on the development size.
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? [Please state reasoning]
A: The council needs to address the “No development before infrastructure” mantra! Too many houses are being built without adequate road networks in place (including walking and cycling routes). A new road could be built from the A1245 to Hullbridge, limiting the traffic on Rawreth Lane. More work need to be done (and quickly) on the A127 and The Carpenters Arms roundabout. The feeder lanes proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions need to be done ASAP as this is a bottleneck. Hockley needs another access although I am unsure how that can be achieved. New developments should put in cycle paths and walkways and they could be made to link up with existing paths (which need updating and attention).
Q52. Are there areas where improvements to transport connections are needed? What could be done to help improve connectivity in these areas?
A: More work need to be done (and quickly) on the A127 and The Carpenters Arms roundabout. The feeder lanes proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions need to be done ASAP as this is a bottleneck. Hockley needs another access.

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.]
A: A new road from A1245 to Hullbridge is needed as Watery Lane is too narrow and winding, and is closed on a regular basis due to flooding. More (smaller) buses to link our towns and villages. Trams, although they seem a good idea, would cause congestion on our narrow roads and be unsustainable. Designated cycling paths (not on the roads or pavements) adjacent to our road networks would help improve traffic flow and these would need to be linked to be efficient.
Q54. Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided? [Please note you may wish to comment on the use of specific areas of land in the next section]
A: Yes, but if they are to be affordable only, then they should be offered to local residents first and not anyone from afar who wants a cheap house or for those with a buy to let mortgage.
Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities? [Please stare reasoning]
A: Improve public transport.
Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing? [Please state reasoning]
A: Yes but you also need to include a reduced volume of traffic and air pollution. The High Street is usually grid locked and this causes dangerous pollution for our pedestrians/shoppers/residents. An active Police presence.
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?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Access and increased congestion is going to be an issue with a lot of the sites in Rayleigh. If you keep adding small developments to the boundaries of the town we will create an overcrowded impacting on the developments already there and an urban sprawl effect. CFS 121 has potential for a new woodland area which could soak up some of the carbon emissions from the A127 traffic.
Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: We should be restricting any further large developments in Rayleigh and need to assess the impact of the current developments first.
Q56d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: CSF027 – The access road (Bull Lane) is a known rat run and is extremely busy. Any further traffic, which will also compete with large agricultural vehicles, could be a danger to the residents already there. Bull Lane near this point has also been flooded several times recently. CFS023 – Access to this road is via Wellington Road. It can be extremely difficult, especially at peak times (non-pandemic) to access to and from Hockley Road. Adding a large development here will have an adverse impact on existing residents and car users alike. Also, if these 2 developments are linked to Albert Road, the installation of a through road to Bull Lane will cause issues in parking, access and wellbeing as the road would become another rat run!
Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
The green space north of CFS121 could be linked by a new bridge over the railway and create a new habitat for wildlife, with meadows and woodlands, walks and a lake/pond. A car park with facilities could be created and a small retail space could be offered for snacks etc.
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]
A: I feel CFS261 would cause great harm to the area, with a potential of over 4,000 houses on the site. The road network is not sufficient to cope with half that amount of dwellings and new schools would need to be built.
Q57b. With reference to Figure 45 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 Rochford and Ashingdon?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q57c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q57d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q57e. Do you agree that the local green spaces shown on Figure 45 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold some significance, especially to those who use them for recreation, and have community value. These should be protected.

Q58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing? [Please state reasoning]
A: Don’t know.
Q58b. With reference to Figure 46 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 Hockley and Hawkwell?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q58c. Are there areas in Hockley and Hawkwell that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know
Q58d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: As Hockley Woods is the largest remaining wild woodland in the country you should be doing EVERYTHING you can to save it from development, either adjacent to or close by. You should also actively be adding to it by planting more trees to future proof its existence and status.
Q58e. Do you agree that the local green spaces shown on Figure 46 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q59a. Do you agree with our vision for the Wakerings and Barling? Is there anything you feel is missing? [Please state reasoning]
A: Don’t know.
Q59b. With reference to Figure 47 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 the Wakerings and Barling?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q59c. Are there areas in the Wakerings and Barling that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Any development needs to be sympathetic of the area.
Q59d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Don’t know.
Q59e. Do you agree that the local green spaces shown on Figure 47 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: Don’t know.
Q60a. Do you agree with our vision for Hullbridge? Is there anything you feel is missing? [Please state reasoning]
A: Yes, although you need to address the road networks as well as those you have suggested. A new link road from A1245 to Hullbridge, adjacent to Watery Lane would serve the increased population with an improved access route and divert traffic away from other areas.
Q60b. With reference to Figure 48 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 Hullbridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Some of the sites have potential to include a mix of shops, leisure, recreation, offices and housing but a study needs to be made to assess the impact of the current development
Q60c. Are there areas in Hullbridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q60d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Anything too close to the river due to flood risk.
Q60e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q61a. Do you agree with our vision for Canewdon? Is there anything you feel is missing? [Please state reasoning]
A: Yes. A small amount of housing can be sustainable there as long as the community feel it is needed.
Q61b. With reference to Figure 49 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 Canewdon?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Opportunities for mixed retail, commercial and housing could be achieved with some sympathetic development in this area.

Q61c. Are there areas in Canewdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q61d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Don’t know.
Q61e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing? [Please state reasoning]
A: Yes.
Q62b. With reference to Figure 50 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 Great Stambridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Any development needs to be sensitive and sympathetic to this small village.
Q62c. Are there areas in Great Stambridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q62d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Don’t know.
Q62e. Do you agree that the local green spaces shown on Figure 50 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q63a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state reasoning]
A: Don’t know.
Q63b. With reference to Figure 51 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 Rawreth?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q63c. Are there areas in Rawreth that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Yes. Those that border the main roads as this makes easy access.
Q63d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Those that change the dynamics of the village and those areas that border Wickford. There needs to be a significate amount of green belt land left to separate the 2 areas to prevent urban sprawl.
Q63e. Do you agree that the local green spaces shown on Figure 51 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q64a. Do you agree with our vision for Paglesham? Is there anything you feel is missing? [Please state reasoning]
A: I think the 30 houses is the maximum you should build to keep this hamlet special. Maybe less. The community should be consulted for their requirements.
Q64b. With reference to Figure 52 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 Paglesham?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: The 30 proposed houses should reflect the history of the area and should be modest in size and scale. These does not seem to be scope for any other building project with exception to open space. Any development should be sympathetic to the design and scale of the areas history.
Q64c. Are there areas in Paglesham that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Those proposed seem appropriate subject to local knowledge and support.
Q64d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: No building anywhere where it is liable to flood. No building near the waterfront in order to protect its charm and history.
Q64e. Do you agree that the local green spaces shown on Figure 52 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q65a. Do you agree with our vision for Sutton and Stonebridge? Is there anything you feel is missing? [Please state reasoning]
A: Yes. These areas should remain low key but have better access to services.
Q65b. With reference to Figure 53 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 Sutton and Stonebridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know, but mass development should not go ahead. The potential of building thousands of houses, retail etc would be devastating. If any form of development was to go ahead then this should be in the way of a nature reserve/woodland etc.
Q65c. Are there areas in Sutton and Stonebridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q65d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Most of the area unless it is the creation of new woodland, ponds, meadows, etc.
Q65e. Do you agree that the local green spaces shown on Figure 53 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q66. Do you agree that our rural communities do not require individual vision statements? Are there communities that you feel should have their own vision? [Please state reasoning]
A: At this time – yes, but I feel they should have some consideration in the future in order to protect them.
Q67. Do you agree with our vision for our rural communities? Is there anything you feel is missing? [Please state reasoning]
A: Yes. Nothing missing I can think of.
Q68. Are there other courses of action the Council could take to improve the completeness of our rural communities?
A: Survey and listen to the residents to see where they would like to go next. See if they require anything specific (travel links, facilities, affordable housing, etc.)

RDC/Spatial Consultation 2021 Questions. Hullbridge Parish Council official response/answers. 14th September 2021.

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?

Hullbridge Parish Council feels strongly that a local highways study needs to take place. The document only refers to a study of the main roads in the south Essex infrastructure position statement. This states in 4.2.4 that much of the main road network which leads to our district is operating at, or near, capacity in peak periods.

We cannot understand why Rochford District Council would base its planning upon the 2025 flood risk area when developments could reasonably be expected to be in place for more than 100+ years. All evidence from the IPCC and other scientific institutions demonstrate that global sea level rise is a real and presently accelerating threat. In addition, the British Geological survey shows that the Eurasian tectonic plate is tilting along an axis between the Wash and the Bristol Channel, this means
that Essex is sinking at a rate of 0.4 to 0.7mm per year (ref. research carried out at Durham University and published in the Journal ‘GSA Today’). These projections are not the worst-case scenario, and the sea level rise could be much worse if climate change continues raising
temperatures beyond 1.5 degrees centigrade.

The map generated by Coastal Climate Central for 2050 shows that all of the promoted sites to the west of Hullbridge will be in the flood risk area, and that those to the North East of Hullbridge are also in the flood risk area. Rochford District Council needs to ensure that no site at risk of flooding by 2050 is developed.

The Coastal Climate Central 2050 map shows large part of Rochford including Hullbridge below flood
levels:
https://coastal.climatecentral.org/map/15/0.6252/51.6246/?theme=sea_level_rise&map_ type=year&basemap=roadmap&contiguous=true&elevation_model=best_available&fo recast_year=2050&pathway=rcp45&percentile=p50&refresh=true&return_level=return_
level_1&slr_model=kopp_2014

Q2. Do you agree with our draft vision for Rochford District?

Hullbridge Parish Council believes that the vison should take into consideration the differences in towns and villages; for example, Rayleigh or Rochford may have a more business focus, whereas Hullbridge may be more of a rural community with a greater need to cater for its older population who do not need employment but do need more health services. In principle, the results of this
consultation need to feed into it to make specific plans for each settlement.

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

Hullbridge Parish Council agrees that there should be separate visions for each settlement, however, these should be determined by each Parish Council working with residents - this is the appropriate level of localisation. Whilst agreeing with the principle of the localisation approach, it is not visible in the document as a whole. As we have already covered, there should be separate visons for each settlement. In this way it will support planning decisions at a local and district level to ensure the unique character of each distinct settlement remains rather than developing into one indistinct mass.

Q4. Do you agree with the strategic priorities and objectives we have identified?

Strategic Option 2 fails to address the problem of the aging population within the district. This is in large part due to the failure to provide adequate low rent social housing to enable young people to remain in the district and to develop stable family units. The failure of Housing Associations to meet this need is well documented nationally, and locally the largest Housing Association (Sanctuary) has a poor record of maintaining properties and honouring contractual promises made when the council’s housing stock transferred. The strategy should provide council housing (preferably directly managed) with genuinely affordable rents and secure tenancies in small local exception sites. There also needs to be provision within these sites for social housing accommodation for elderly residents.

With regard to objective 12 we are concerned that Rayleigh tip has been put forward for development.
If so there still needs to be a site for waste disposal close to Rayleigh. The restrictions on vans needs to be lifted to prevent fly tipping.

We believe that sufficient primary school places should be provided within local communities, and steps should be taken to minimise the use of cars to transport children to schools; we are concerned that this is currently not the case.

Q5. Do you agree with the settlement hierarchy presented?

Yes, the hierarchy seems logical. We feel the strategy should take into account that many more people are working from home, reducing the need to commute to employment centres.

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

It seems that some elements of option 1 and 3 will be required but given the requirement to build more homes the least disruptive option preferred by Hullbridge Parish Council would be to go for option 3a. Option 3a has the advantage of being close to the existing road hubs (A127 and A130) and services, and would be of a sufficient scale to attract section 106 funding for vital infrastructure. 3a would also be close to employment opportunities in Wickford and Basildon.

Option 3b would create considerable pressure on the existing road network and would erode the green belt separation of Southend and Rochford.

Option 3c would place development within the flood risk area and not be sustainable without the need for major road building that would open up the green belt to considerable development in the Crouch Valley.

The building of a major bypass road (as promoted by landowners in the past) to deal with congestion caused by 3b and 3c would destroy the green environment of Rochford and generate further development within the green belt. Development in the villages should be small scale and focussed on providing homes for young families and the elderly.

Small ‘exception’ housing developments added to the village settlements could provide council housing, sheltered housing and bungalows to meet the needs of low-income young families and the elderly. Such provision for the elderly could free up existing houses for younger residents and families to purchase.

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

Using option 3a as a starting point, other areas could be developed in future using option 1 when the
infrastructure is planned and/or in place.

Restrict overdevelopment in rural and village communities to protect the character of village life.

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

We are concerned about the fact that access was denied to the topic papers, and wholeheartedly believe that the existing lifestyle of the area should be protected from overdevelopment.

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?

We agree that it is imperative that both flood risk and coastal change should be central to any development plans going forward; for us in Hullbridge, many of the proposed sites to the west of the existing settlement are projected to be deep within flooding territory by 2050, as are numerous ones in the east as well. With 2050 now less than three decades away, and no sign of any imminent alteration in the path of climate change, development in any of the areas identified to be in potential flood plains today and in the near future must not be considered.

Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character?

The main concern that we have about the Coastal Protection Belt is that it only extends up until 2025
– other areas would need to be included past this date because, as we have mentioned previously, the flood plains across the Rochford district will be vastly different by 2050. It is our view that any and all housing developments proposed in flood plains, current and near future, must not be approved and those that are approved should be given the assurance of protection from flooding over the coming decades. Closer to home, we believe that the river front in Hullbridge should equally be protected for its special landscape character. We would also like to make it known we are very supportive and enthusiastic about the Central Woodlands Arc and the Island Wetland proposals.

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 low-carbon or renewable energy?

Providing that the development is affordable and deliverable, and the cost is not lumped onto the buyer for many years to come then this is the right decision as the future rests in renewable energy. Suggestions from councillors regarding other opportunities to supply renewable energy ranged from a solar farm in a place that will not impact its surroundings to solar panels and/or wind turbines on Foulness Island.

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?

Again, this is something that is a fantastic plan providing the brunt of the cost is not rested on the shoulders of the buyer and that these homes are affordable.

Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported?

The installation of wind and solar power generators, in locations such as Foulness, would certainly assist in supporting the local generation of low-carbon and renewable energy which is a necessity in the modern day.

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?

Yes, these should be settlement specific, to allow for the maintenance of the integrity and specific characteristics of each area, sufficiently detailed to avoid confusion, and widely distributed.

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

Yes, provided individual settlements are consulted and these are adhered to.

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

Yes, providing that each individual settlement is at the heart of it and considered as their own entities with their own individual characteristics. It is imperative that certain areas are protected completely, and that any future developers are aware of the identified characteristics of each area.

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?

Design guides should be area specific under one singular guide which is inclusive to the whole district –
providing it remains flexible to local conditions.

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

As long as the character and aesthetic are maintained concurrently with necessary growth, nothing else
needs to be included.

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?

Meet the need for different types, sizes and tenures of housing (including Affordable, Social, Council and
Specialist Housing) by requiring a standard non-negotiable mix of housing to be provided on all housing
developments.

Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure?
What is required to meet housing needs in these areas?

There is too much focus currently across the district on the provision of 4/5 bedroom properties. This focus needs to shift towards 2/3 bedroom properties which would benefit more local residents/families in search of their first home. "Affordable" homes should not only be flats/apartments but other property types also.

1/2 bed bungalows (or similar) should be a priority, as with an ageing population, there will be increasing
demand for such properties when elderly residents are looking to downsize. RDC should actively discourage bungalows being converted into larger properties. Additional provision for residential care is also a priority.
These can all be accommodated within Strategy Option 3a.

New homes should meet the standards set out in Parts M4(2) or M4(3) of Building Regulations.

Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing?

Affordable homes and social housing to enable single persons or families buy or rent their own home.
Specialist homes for the disabled.
Smaller dedicated properties for the older generation, to enable them to downsize from larger properties, thereby freeing-up larger properties for younger families.

Q20. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller
accommodation needs?

The failure to provide traveller sites has led to many unauthorised sites within the green belt being granted
planning permission on appeal. With Michelin Farm no longer being an option, RDC needs to identify an
alternative appropriate site(s) either from within its ownership or purchased specifically for the purpose.
This site(s) should be located so that it (they) does not cause difficulties with established communities;
fly-tipping and the impact on nearby residents being just one example. Perhaps, particular consideration of a contained site(s) within the Green Belt, so as to obviate the likelihood of unplanned, piecemeal and unauthorised sites fragmenting the green belt.
Consideration also needs to be given to the fact that there are different groups within the Traveller communities who do not want to be placed together and perhaps ways can be found to integrate these into everyday life and housing.

Q21. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller
accommodation needs?

Some Traveller Groups tend to make their own arrangements to use owned land on a temporary basis.
RDC needs to identify a site(s) either from within its ownership or purchased specifically for this purpose.
It (they) would need to be sufficiently away from residences that they would not be disturbed or troubled
by vehicles/caravans arriving or leaving. Perhaps a pre-payment/booking system could be introduced for this purpose and at the same time, reducing the likelihood of over-crowding.

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites?

Locate sites close to main roads to enable easy access for large vehicles, so that residential roads are not congested and nearby residents are not disturbed. Allow a little room for expansion and limit the likelihood encroachment onto neighbouring land.
Locate away from spaces of national, regional, local or community interest or recreation, so as not to spoil the visual amenity of the landscape.
The sites should not be closed and available to the whole Traveller community.

Employment and Jobs
Q23. With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan?

In addition to employment option 11 which states: Working with neighbouring authorities to identify land
for higher or further education facilities where this would address current and future skills shortages, information should be collected and made available on where there are shortages or opportunities coming up. Offer advice to adults wishing to or needing to reskill. Provide local affordable adult education courses on the skills needed. Work with employers, education centres and Essex County Council.

With reference to employment option 4 that states: Meeting future needs by prioritising the delivery of
new employment space alongside any new strategic housing developments. This should apply to the larger scale developments described in spatial strategy option 3. Employment option 4 goes on to specify live work units as an option. This would help with increasing numbers of people working from home. Also start up business centres and co-working spaces would be useful and there are many selfemployed people and small businesses in this area. A sympathetic attitude is required towards people running a business from home provided that the impact on the surrounding area is minimal.

In all of this we need to be mindful of paragraph 83 of the NPPF which requires policies and decisions to accommodate local business needs in a way which is sensitive to the surroundings and prioritises the reuse of existing sites and buildings.

Q24. With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through
to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the green belt?

Consider any brownfield site for employment use these are currently mainly getting used for housing. There needs to be employment opportunities even in the smaller settlements if we are going to be greener and cut down on transport use. Employment option 6 states: Meeting future needs by prioritising the regularisation of informal employment sites such as those shown on figure 30. This would make employment accessible to people living in the rural communities especially if other farms
able to do this could also be identified. Most of the sites are in the western half of the district it would be useful to identify a few more sites in the east to make this a policy that serves the whole district.

Any use that is not heavily disruptive to the surrounding area should be permitted. Planning officers should be able to permit reasonable adjustments requested by residents to make extensions and adaptations to their homes to accommodate working from home or running a business from home.

Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?

Our preferred spatial strategy option is 3a. Concentrated growth is required to bring the necessary infrastructure to make business and employment growth viable. There needs to be links to main roads to accommodate the commercial traffic required to service industry. Improvements to public transport to employment sites are needed.

Employment option 4 which states: Meeting future needs by prioritising the delivery of new employment space alongside any new strategic housing developments, could be delivered by strategy 3a.

Employment Strategy 6, which meets future needs by prioritising the regularisation of informal employment sites, would help deliver more businesses and employment. Employment option 3 refers to Saxon Business Park, Michelin Farm and Star Lane; we should continue to expand and improve these sites, however this needs to be done in conjunction with other options not as a stand-alone policy. These two strategies are needed and can be included in any of the spatial options.

Q26. Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?

Sites set aside for education and health uses in addition to the services they provide, they also provide good employment opportunities. Foulness would be ideal for green industries.

Q27. Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g. skills or connectivity?

Provide appropriate schools and colleges to serve the increase in population due to high development, but locate with public transport links and accessibility by walking or cycling in mind. Also work with neighbouring authorities to identify land for higher or further education facilities where this would address current and future skills shortages as stated in employment option 11.
Work with bus companies and Essex County Council to make our existing employment sites as accessible as possible. Improve footpaths and cycle tracks using government funding applied for by Rochford District Council. Move away from planning employment sites in places that are designed to be accessed by car use. Some employment is going to have to be close to settlements. This of course would have to be take into account paragraph 83 of the NPPF which requires policies and decisions to accommodate local business needs in a way which is sensitive to the surroundings and prioritises the reuse of existing sites and buildings.

Q28. With reference to the options listed above, or your own options, how do you feel
we can best manage the Airport’s adaptations and growth through the planning system?

Protect the airport and encourage airport linked transport adjacent or close to the airport eg, existing airport industrial park and Saxon Business Park. Both airport growth and industry will promote jobs.

The transport system both road network and public transport needs to be improved to make these growing opportunities accessible for all.

Q29. Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?

YES
While Hockley Woods does not seem to be mentioned here, we would have thought this ancient woodland (and similar woodland), and its important wildlife habitat should be included as it provides for a number of rare species including lesser spotted woodpeckers and hawfinches.

The lower Crouch Valley, the River Crouch and its banks are important habitats for fauna including birds that are on the endangered species red list. This includes curlews, whimbrels, and other wading birds. The pasture land flanking the Crouch towards Battlesbridge is an important habitat for skylarks and other species; these areas should be protected.

Restrict development in all other green belt areas, in order to protect nature. Alongside this, provide protection for nature reserves, parkland and areas fronting rivers.

Q30. Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local
Wildlife Sites review? Are there any other sites that you feel are worthy of protection

Yes, as we have already stated, many areas provide habitats for endangered or rare wildlife and therefore are more than worthy of protection.

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?

Onsite reduced developments in general will assist moving new developments to high unemployment
areas.
We agree with the central woodlands arc and island wetlands proposals.

Green and Blue Infrastructure
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?

More investment is required in many areas of infrastructure, from roads to general services. It would be
beneficial to green ideals to restrict or ban development in or near green belt sites and to keep development in the rural areas to a minimum.

Q33. 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?

By lobbying central government to allow revision of RDC plans to support a quality green and blue infrastructure; additionally, Parish Councils could maintain coastal paths with funds from Section 106 agreements.

Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?

Concentrate on brownfield and town sites in order to protect rural communities and the green belt – as
previously alluded, options 3 or 4 mean less development in rural areas and are therefore more
accommodating to the needs of smaller rural areas like Hullbridge, hence our choice of option 3a.

Community Infrastructure
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?

Build property where there is existing infrastructure or where infrastructure can be expanded without
encroaching on green belt etc.

A survey needs to be carried out on local roads to determine what is needed to be upgraded to achieve
any sustainable way for traffic, both domestic and that which uses these as through roads.

With reference to Hullbridge much of it is unadopted roads and cannot support any development, let
alone be able to accommodate the use of these roads as through roads for both building access and ultimate through road access to any development. Provide schools for development areas and provide transport links to these schools. Local schools, both primary and secondary, are already struggling with the increase in pupil numbers coupled with limited capacity.

Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?

Funds were given via section 106 to expand Hullbridge Healthcare Centre and provide more school places - neither of these has happened. This section 106 money was instead given to RDC in respect of the existing Malyons Farm development. More development would make the situation untenable, particularly if further section 106 monies were withheld by RDC and not allocated to benefitting the local community where new developments are built.

Q37. Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare
facilities or community facilities? How can we best address these?

Even with section 106 grants, if made available, healthcare facilities in Hullbridge are severely restricted, especially since the pandemic due to doctor shortage. Further development in Hullbridge would worsen healthcare provision and, even with section 106 grants if released by RDC, will not improve the situation.

Whilst this is outside the control of RDC, developments would cause serious issues particularly as Hullbridge traditionally has an ageing population - one which is obviously more reliant on healthcare, alongside the inevitability of new patients from current and any new developments.

There are currently inadequate or no existent bus and footpath links to areas east of Hullbridge, such as the Dome Area. Any development to the east of Hullbridge would have transport difficulty and also the impact on Lower Road would be unacceptable; this would be the case even bus links were improved.

The same approach needs to be taken with schools and highways and new residents could be short changed without easy access to schools, healthcare and employment.

Open Spaces and Recreation
Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?

With reference to open spaces and recreation option 5, we should improve and maintain what we already have, using section 106 money for improvements. We should ensure that any section 106 money does get spent how and where it was intended. No section 106 money should end up being unused.

We should improve bus links to existing facilities in the district, for example Clements Hall where buses used to run in the past (at least in the school holiday periods). There should be an aim to provide permanent all year-round bus services to our main leisure sites.

The Hockley ‘Park Run’ is very popular. Should the proposed Central Woodlands Arc come into being it
would be ideal for a park run. Orienteering could be an interesting additional activity; local scouting groups, and schooling groups too, would certainly benefit from this.

Q39. Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering?

We should ensure that any proposal for a 3G pitch has the backing of local residents. For reference, in 2016 a 3G pitch was applied for planning permission by The Fitzwimarc School but turned down by Rochford District Council due the objections of local residents.

Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering?

Primary Schools should also be considered along with any site that could host a hockey or a 5 a side pitch.

Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?

Our preferred spatial strategy option is 3a. The section 106 money that comes with the larger developments has more chance of providing good sustainable new facilities.
A bus service needs to be run to facilities like Clements Hall, at least during half term and school holidays, to enable young people to access it from areas where it is currently difficult to access by public transport; this has been done in the past to access sports and in particularly swimming facilities which are not available in Hullbridge or Rawreth. Swimming facilities were excluded from the Rawreth Lane sport facility.

Q42. Are there particular open spaces that we should be protecting or improving?

Hullbridge Recreation Ground. Our nature reserves, parks and woodlands to promote walking and other
appropriate exercising activities.

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?

Protect village and rural areas from over or inappropriate development through careful planning considerations.
Compose a list of sites with local consultation. Then look maintain them with local residents and organisations

Q44. Are there areas of the District we should be considering for conservation area status beyond those listed in this section?

Villages fronting riversides: Hullbridge, Paglesham, Canewdon, South Fambridge.

Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets?

As with protected sites a consultation needs to be done for each locality. With reference to Hullbridge, in addition to the old school, Shell Cottage and River Cottage are already listed. We would add the school house next to the school, Brick Cottages, Tap's Cottage and the Anchor Cottages if they are not already listed buildings.

Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley?
How can we also ensure our village and neighbourhood centres remain vibrant?
[Please state]

Market forces are moving purchases online so town centres need to be more accessible and convenient to encourage day shopping, and also increase night time business where appropriate to take up capacity lost from retail.

Improve transport links to town shopping and amenities. There is no transport link from the Dome that would take their residents into nearby Hockley for example. There are no easy transport links from Hullbridge to Hockley or Rochford.

Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]

Protecting businesses generally will not work as commercially if they are not profitable, they will close
and we will have empty shops. Rochford District Council needs to encourage business with free parking and reduced business rates.

Businesses should be encouraged to work together with a co-operative nature, or a number of shops all open a little later one night of the week to make it worth shoppers coming out in the early evening. Local eateries could offer special deals on those nights.
Community events that encourage shops and businesses to join in – fairs, celebrations, etc.

Q48. With reference to Figures 38, 39 and 40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh,
Rochford and Hockley? If not, what changes would you make? [Please state reasoning]

Keep streets clean and tidy, and repair and repaint street furniture regularly. Conserve the character of the town centres by avoiding high rise development and buildings that are at odds with the street scene.

Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]

Some existing ok but links to, e.g., Clements Hall from Hullbridge non-existent. Businesses cannot be forced into staying unless benefits outlined in Q47 are adhered to which may encourage some business opportunities and current business to remain.

Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]

Spatial strategy 3a will give the most opportunity to expand retail both in terms of including retail space and bringing customers into the town centres nearest to the new developments. The document mentions a cinema. The best site for this would be Saxon Business Park. A bowling alley would work well with this alongside some eateries.

Transport and Connectivity
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?

Certainly, prepare an Infrastructure Delivery Plan that would deliver meaningful improvement to transport networks, including but not exclusively, cycle routes, walking pathways, public transport and roads. However, all these modes are currently completely stretched; modernisation and improvements to all need to happen before future housing developments are built. It should be noted that following the last developments in the Core Strategy, as far as Hullbridge is concerned (and almost certainly elsewhere also), the promised improvements have either not materialised, been completed or proven
to be inadequate.

The plan needs to deliver improvements to public transport by working with bus companies to reestablish bus routes to isolated communities that have been either been terminated or severely curtailed. For example, ‘The Dome’ has a bus service twice a week. Residents regularly complain that they are isolated from everywhere else. It is also claimed that Hullbridge has its own bus service that runs 4 - 7 times a day. This is not the experience of Hullbridge residents and it only needs the slightest issue along Hullbridge Road for the service to either be even further curtailed or suspended entirely.
RDC need to continue to work with Government, Highways England, Essex CC etc to deliver meaningful
road improvements to both the main road arteries and to the local road network. However, any large-scale bypass scheme such as the "Southend Outer Bypass" scheme needs to be opposed. Not only would it cut directly through the Green Belt but it would increase development along its course, which in turn would have enormous negative impact on the Green Belt itself, natural habitats and the environment generally.

Q52. Are there areas where improvements to transport connections are needed?

Whilst some improvements are shortly to commence at the Fairglen Interchange and A130, further improvements are needed to the Junction of Rawreth Lane and the A1245. Perhaps also the A127 could be widened along its length from four lanes to six lanes.

Additionally, the bus service between Hullbridge and Rayleigh can be cut with the slightest issue along
Hullbridge Road and this needs to be addressed urgently. When this happens it consequently results
in more vehicles using Hullbridge road, which in turn exacerbates traffic congestion and leads to other
problems such as pollution.

A bus service between Rochford and Rayleigh via Hullbridge and Hockley and Rayleigh via Hullbridge
would serve to reduce traffic congestion along Lower Road, especially at "rush" hours. This would benefit residents of the Dome as well as properties along the length of Lower Road. It would also serve to provide access for Hullbridge students to access the Greensward Academy that does not exist currently.

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.]

Improvements to existing road networks. Large scale bypass schemes, such as the “Southend Outer”
bypass would be unacceptable because of the hugely detrimental impact on the Green Belt and its
physical and natural environment.

Small low top busses to link smaller communities with larger ones. Trams not a viable option for the more rural areas as roads are too narrow and winding; additionally, would increase congestion on existing roads.

Improvements to the cycle path network, extending and linking the network as and where appropriate and safe.

Green Belt and Rural Issues
Q54. Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need
to be provided?

Yes, but not within the Green Belt and Rural and Village life must be safeguarded. Any such sites must be small scale and have developments that prioritise genuinely "Affordable" homes and/or Social Housing that would benefit local residents/families most.

Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities?

Support changes that would require developers of 10 units or less to pay something akin to s.106/CIL
monies, that would go towards infrastructure improvements, particularly those affecting rural communities.

Q60a. Do you agree with our vision for Hullbridge?

We do not agree with the wording or the aims of the provided vision statement for Hullbridge and have
instead drafted our own (see below). We were sceptical about the suggestion that the river could be used for transport without consideration on the viability or environmental impact of this proposal.

Hullbridge will have expanded on its already self-reliant nature, boasting impressive local businesses and amenities – providing a perfect space for those who wish to enjoy their retirement as well as those with young families. Through small, localised and respectable developments, the thriving community and riverside aesthetic of the village remains as strong as ever; all of this has been achieved through the transparency and openness of different local authorities, residents, businesses and developers on any and all developments going forward.

Q60b. With reference to Figure 48 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?

The biggest issue with further development in Hullbridge is the distinct lack of infrastructure – whether that be roads, schools, transport and other general services – and so, without even mentioning the fact that many sites lay within the projected 2050 flood plains, the suggestion that further development can take place on any considerable scale is untenable. Any consideration of commercial or community infrastructure, such as youth services, care facilities, or local businesses would equally need to be subject to the same discussion and scrutiny.

Q60c. With reference to Figure 48 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?

All of the areas lie within the green belt, and many will be within the projected 2050 flood plains, and so general appropriateness is not met with any; numerous promoted sites are outside walking distance of the majority of services and as such would increase residents using vehicles and increase reliance on our already stretched local infrastructure.

Q60d. Are there areas in Hullbridge that development should generally be presumed appropriate?

Significant portions of Hullbridge remain vital for local wildlife, its habitats, and the natural environment. As such, any and all developments along the River Crouch, the surrounding areas of Kendal Park and those that lie north of Lower Road should be protected from development.

Q60e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there areas that require protecting from development?

Yes, all of those identified as such in Figure 48 are definitely areas of local significance and are correct to be identified as such. Other areas that should be outlined include the Rose Garden, the banks of the River Crouch and the upcoming green space and Memorial Gardens provided as part of the recent Malyons Farm development.

Q66. Do you agree that our rural communities do not require individual vision statements? Are there communities that you feel should have their own vision?
[Please state reasoning]

No - All communities should have their own individual, locally-determined vision statements, especially the more rural ones. Each settlement has its own distinct character and the vision statement would serve to aid the planning process in safeguarding their individual character.

Q67. Do you agree with our vision for our rural communities? Is there anything you feel is missing? [Please state reasoning]

Yes in the broadest terms. We would want it to re-iterate that the individual character and seeming uniqueness of our rural communities needs to be, and will be, safeguarded. By extension, we would like to see more activity in this regard from all tiers of Government.

Q68. Are there other courses of action the Council could take to improve the completeness of our rural communities?

Respect the green belt that surrounds our rural communities and our higher tier settlements; thereby
ensuring a buffer ("defensible boundary") that would actively prevent communities merging into one
conglomeration.

Create a Country Park to the west of Hullbridge.
Improve village roads, transport, educational and utility infrastructure. All of which are already in desperate need of improvement and renovation. For example, it is questionable whether the sewerage system in Hullbridge could cope with any further development without expansion and upgrading.