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

Response by the Home Builders Federation to the consultation on Rochford Local Plan
1. Thank you for consulting the Home Builders Federation (HBF) on the spatial options for the Rochford Local Plan. The HBF is the principal representative body
of the housebuilding industry in England and Wales and our representations reflect the views of discussions with our membership of national and multinational corporations through to regional developers and small local housebuilders. Our members account for over 80% of all new housing built in England and Wales in any one year.

Spatial Strategy options
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
2. Before considering what the most appropriate spatial strategy for Rochford might be it is necessary to consider the level of development that the Council will need to deliver over the plan period. The Council correctly note that the minimum number of homes they should be planning for over a 20-year period is the 7,200 homes arrived at using the standard method. However, this is the minimum number of homes that needs to be planned for and the Council will need to carefully consider whether a higher housing requirement is necessary to support economic growth, infrastructure improvements or address the needs elsewhere.
3. In particular it will be important for the Council to work closely with Southend Borough Council (SBC) which has a minimum housing requirement using the standard method of 1,180 new homes per annum. As the Council will be aware SBC set out in their latest consultation that even with Green Belt release, they are only able to deliver around 20,000 new homes to meet their total requirement over the plan period of 23,620 homes. It is clear that SBC will need support from Rochford and other neighbouring boroughs to meet their housing needs in full. The Council should therefore plan for a level of housing growth that meets both their own needs as well as the unmet needs of SBC.
4. The Council have considered this within the third scenario suggesting that a 50% buffer could be planned for in its local plan. Whist the HBF consider the inclusion of buffers within land supply as an essential requirement if needs are to be met in full the Council must distinguish between homes that it is required to deliver to meet the needs of neighbouring areas or support economic growth and a buffer between minimum needs and supply, which is included to provide greater certainty that housing needs will be met. Meeting the unmet needs of SBC will, in line with paragraph 60 of the NPPF, be added to the number of homes to be planned for in Rochford and as such be an increase in the housing requirement for this local plan rather than part of any buffer in supply over their own housing needs.
5. It is also essential that these are planned for now and not deferred to subsequent plan updates or the proposed South Essex Joint Spatial Plan. Deferring such decisions would be inconsistent with government guidance which states that on examining local plan inspectors will expect to see that strategic policy making authorities have addressed key strategic matters through joint working and not deferred to subsequent plan updates. Deferring decision making to a future local plan for those homes that are needed now is not acceptable as these will be
delivered too late to meet the pressing need for new homes over the next 15 years.
6. Given the likelihood that the Council will need to plan for the unmet needs of Southend alongside their own needs the spatial strategy must deliver the higher growth assumptions set out in this local plan and tested in the Integrated Impact Assessment. As such strategy option 1 must be ruled as it fails to meet the needs of Rochford let alone neighbouring areas. Of the three remaining options the HBF would consider the approach offered by option 4 would offer the most suitable approach to meeting not only the needs of Rochford but also any unmet needs
arising in neighbouring areas.
7. There are a number of reasons for supporting option 4. Firstly, a balanced approach allocating a variety of sites both in terms of size and location will have far greater potential to deliver a wide mix of housing types and style whilst also ensuring homes come forward consistently across the whole plan period. Too often local plans focus allocations on a small number of large strategic sites that inevitably come forward later in the plan period. Whilst such sites are an important part of housing supply their allocation should not be to the detriment of small and medium sized sites. Such sites are important for a number of reasons. Firstly, they come forward quickly helping the Council in securing a sufficient supply of homes in the first five years of its plan and preventing housing needs being unnecessarily
delayed. It is our experience that local plans which rely too heavily on strategic sites and push the majority of delivery toward the end of the plan period can result
in plans arriving at examination without a five-year land supply and being unable to meet its housing needs following revisions in the delivery trajectories of strategic
sites.
8. The second reason for supporting option 4 is that a wider variety of sites, both in terms of location and size, ensures that the plan increases the opportunities for small and medium sized housebuilders to deliver homes in the Borough. Up until the 1980s, small developers once accounted for the construction of half of all homes built in this country resulting in greater variety of product, more competition, and faster build-out rates. Since then, the number of small companies has fallen by 80% following the introduction of the plan-led system in 1990.
9. The HBF has undertaken extensive consultation with its small developer members. One of the chief obstacles for small developers is that funding is extremely difficult to secure with a full, detailed, and implementable planning permission. Securing an implementable planning permission is extremely difficult if small sites are not allocated. Without implementable consents lenders are uneasy about making finance available or else the repayment fees and interest rates they set will be very high. Small developers, consequently, need to invest a
lot of money and time up-front in the risky business of trying to secure an allocation and a planning permission, and this is money that many small developers do not
have.
10. If the Council are to ensure there is a wide variety of SME house builders operating in its administrative area, and the benefits it brings to the speed of delivery and
variety of homes, it must ensure that there is a variety of sites. This is why the Government, through the NPPF, now requires local authorities to allocate sites of varying sizes and why the HBF advocates for the allocation of more small sites in local plans.
11. Finally, there has been significant under delivery in Rochford over recent years. The 2016 and 2017 Strategic Housing Market Assessment assessed that
Rochford district needed to build between 331 and 361 dwellings per annum up to 2037. However, from April 2010 to March 2018 only 1,326 new homes were built
which averages out to 166 homes per year. With this continued under supply of housing Rochford has become the most unaffordable district out of; Basildon, Thurrock, Southend, and Castle Point. The Rochford Local Plan for 2021 goes as far as to say that the ratio between house prices and local earnings is amongst the least affordable in the country, as the average local house price has increased 70% in the past 15 years.
12. With this continuing divergence between house prices and earnings, housingrelated issues such as homelessness and concealed households, where young
people have to stay or return home to their parents for longer than they would like to, becomes an increasing problem within the district. It is therefore important for
the Council to recognise, and give significant weight to, the fact that the higher level of delivery as proposed in option 4 would have the scale and distribution of
growth to address these concerns.

Climate Change and Resilient Environments
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?
13. Whilst the Council can set targets as to the percentage of a home’s energy use that should be obtained from decentralised energy sources it is important that the Council recognises that this will place an additional financial burden on development and will therefore need to be considered in the viability study.

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?
14. No. The housebuilding industry, through the HBF, recognises that there is a need to improve the environmental performance of new residential development. In order to achieve this, we established with a wide range of partners the Future Homes Task Force. This task force examined how the house building industry can work toward delivering net zero carbon homes in order to support the Government’s target of the country delivering net zero carbon emissions by 2050.
The initial outcomes of this work can be found at https://www.futurehomes.org.uk/ with a summary of the Delivery Plan resulting from this work attached to this
response.
15. The delivery plan published by the task force in July outlines the need to operate on a collective basis recognising the need for housebuilders, their supply network and the trades people building homes to successfully transition to the delivery of low carbon homes. In addition, it recognises the need for both national and local government alongside housebuilders to ensure those people buying new homes are confident in the technologies and systems being used.
16. As the Council are aware the proposed amendments to the building regulations will see development up to 2025 deliver a 31% improvement on C02 emissions
compared to current standards. The Future Homes Standard that will be introduced from 2025 will see new homes emit 75% fewer emissions than current standards. However, to deliver further reductions and achieve the national commitment of net zero emissions by 2050 will require the decarbonisation of energy supply at a national level rather than from the Council setting additional requirements for new homes above those set by Government.
17. Given the improvements that will be made through the amendments to building regulation the HBF do not consider it necessary for additional local standards to
be set with regard to energy efficiency and CO2 emissions. Only through a nationally consistent and phased approach to the introduction of the new
standards and technologies will the house building industry be able to maintain housing supply, ensure consumer confidence and deliver the required
improvements in emissions.
18. A national and standardised approach to improving the energy efficiency of buildings is the most effective approach to ensuring improvements in energy
efficiency whilst also ensuring the continued delivery of housing and infrastructure. The HBF considers a universal standard is necessary to allow the development of supply chains that focus upon responding to agreed national targets, and for training providers to plan their programmes to equip the labour force to meet these
new requirements. Importantly, a phased approach to delivering these improvements ensures those people buying new homes are fully aware of the new
technologies being used in their homes. It is vital that consumers are confident with the technology being used in their new homes and increase the wider appetite for similar standards to be adopted in the existing stock.
19. The HBF considers it important that Councils recognise that it will take time to ensure that the technology and supply chains required to achieve the significant reductions in emission from new homes required by the Future Homes Standard. There is still considerable work to do to ensure that supply chains are in place to meet demand from the housebuilding industry as well as having a workforce with the technical skills in place to deliver and maintain systems such as ground and air source heat pumps on a much larger scale. It is important that these systems when they are used work to ensure that the public are satisfied with the product and can rely on it to meet their needs.
20. Should the Council seek to go beyond what is required by building regulations then they will need to clearly set out in their viability study the additional costs this will place on development in the Borough. These costs can be significant and in combination with the other costs that are placed on development through the local
plan can lead to development becoming unviable.

Place-making and Design
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?
21. It is not clear what the charter is supposed to offer with regard to decision making process and whether these will be reflected in the policies set out in the Local
Plan. In order to provide an effective steer to applicants and decision makers the Council must set out its expectations in policy and ensure that these are consistent with the approach set out in nationally in the NPPF and its supporting guidance.

Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
22. The principles set out in the charter are laudable but, as set out above, it is more important that the Council clearly set out in policy any requirements regarding
place making in the Borough. These policies should be based on evidence, fully costed in the viability study and be consistent with national policy.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
23. It is not necessary to create new design guides, codes or master plans alongside the new local plan. Seeking to develop these at the same time can place an
additional burden on the Council’s recourses taking away offer time best spent on preparing the local plan and extending the timescale for its production. Any required design codes or master plans can be developed subsequently.

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?

Housing type
24. As suggested earlier in order to ensure a variety of types of homes both in terms of type and tenue is to allocate a wide variety of sites in terms of size and location. Different sites will lend themselves to different types and density of development that will inevitably ensure a variety of homes will come forward. It is also important to remember that evidence on housing needs with regard to housing type is a snap shot in time for the whole of the Borough. It is important to recognise that the type of housing needed will change over time and will be vary between areas. As such it is also important to ensure that there is flexibility within any policy on the size of homes to be provided with the mix of housing to be determined at the point of application having regard to local evidence of needs, the nature of the site and the
types of home that have been provided.

Affordable housing
25. With regard to affordable housing tenures, we expect the Council will set out a requirement in policy for the number of affordable homes it requires. In determining this proportion, the Council will need to consider the viability of delivering affordable housing alongside all the other policy costs that are likely to be required in this local plan. In considering all these costs it is important, as set out in paragraph 58 of the NPPF that the Council are confident that decision makers can assume a development meeting all costs is viable given that the
Government are seeking to reduce the number of sites on which affordable housing contributions are negotiated. This may require a policy that varies such requirements on the basis of location or type of development reflecting the different costs and values that occur across the Borough. In order to assist local planning authorities in preparing their viability assessments the HBF have
prepared a briefing note setting out our members key concerns with regard to viability testing and the approach taken by Councils which is attached to this response. Whilst this note focuses on all aspects of the viability testing of the residential development and should be taken into account, we would like to highlight four particular issues with whole plan viability assessments.
26. The first issue is with regard to the approach taken to abnormal infrastructure costs. These are the costs above base construction and external costs that are required to ensure the site is deliverable. Prior to the 2019 NPPF viability assessments have taken the approach that these cannot be quantified and were addressed through the site-by-site negotiation. However, this option is now
significantly restricted by paragraph 57 of the 2019 NPPF. As such these abnormal costs must be factored into whole plan viability assessments. We recognise that
the very nature of an abnormal costs is difficult to quantify, but it is a fact that they are often substantial and can have a significant impact on viability. Where and how
these costs arise is also variable. They can occur in site preparation but can also arise with regard to the increasing costs of delivering infrastructure, such as
upgrades to increase the capacity of utilities. It is also the case that abnormal costs are higher on brownfield sites where there can be a higher degree of uncertainty as to the nature of the site and the work required to make it developable.
27. Whilst the HBF recognise that abnormal costs are expected to come off the land value, we are concerned that if abnormal costs are high then it will result in sites
not being developed as the land value will be insufficient to incentivise the landowner to sell. It is therefore important that a significant buffer is included within
the viability assessment to take account of these costs if the Council are to state with certainty that those sites allocated in the plan will come forward without negotiation.
28. Secondly, we would encourage the Council to use the upper end of any of the ranges suggested with regards to fees and profit margins. Again, these will vary from developer to developer but given that the Government want to minimise negotiation on planning obligations it would make sense to use the highest point of any range. The changing landscape with regard to viability assessment could lead to development slowing significantly if the correct variables are not taken into
account.
29. Thirdly, the council must ensure that all the policy costs associated with the local plan are included within the viability assessment. Whilst affordable housing and
infrastructure contributions from the majority of the additional costs that are placed on developers by the Council it is important that the cumulative impact of all
policies are tested. With regard to the local plan review the Council will need to consider the impact of its proposed policies on bio-diversity net gains, electric
vehicle charging, sustainable design and construction; and renewable energy. The viability assessment will also need consider the impact of future national policies on viability and whether there is sufficient headroom to ensure these standards can be addressed alongside the policies in the local plan.
30. Finally, the approach to land values needs to be a balanced approach and one that recognises that there will be a point at which land will just not come forward if
values are too low to take account of policy and infrastructure costs. There are a variety of reasons why a landowner is looking to sell their land and it cannot be
assumed that they will absorb significant reductions in land values to meet policy costs. Land is a long-term investment and the returns being offered must take
account of this.

Technical standards
31. If the Council wish to apply the optional technical standards for accessible and adaptable homes and the Nationally Described Space Standards, it will need to
ensure that it has the necessary evidence to support any proposed policy as required by current national policy and its supporting guidance. There must be robust evidence that these policies are needed and that the will not have an adverse impact on the viability of new development.

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?

32. No specific mention is made within this section in relation to housing for older people. The HBF consider it important that local plans look to allocate specific sites to meet the needs of older people. In particular the Council must look, in the first instance, to allocate those sites submitted for older people’s accommodation that are in the most sustainable locations close to key services. As well as allocating specific sites for older people’s housing we would suggest that the local plan sets out in policy:
• a target for the delivery of homes for older people and maintains a supply of land to meet that target. Whilst we recognise that there is not a requirement in national policy for the Council to maintain a specific supply of accommodation for older people identifying the level of need and monitoring supply would aid decision makers in the application of this policy and ensuring needs are met over the plan period. Such an approach would also ensure effective monitoring in relation meeting the needs of older people and encourage positive decision making if there is a deficiency in supply.
• support and encouragement for older persons accommodation on brownfield and other land in established urban and suburban environments and which is not allocated given the level of need and that older people are most likely to prefer to continue to reside in
established areas with which they are familiar.

Biodiversity
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?

33. Whilst some sites might be abler to deliver net gains the Council must recognise that it will not be possible for some sites to meet the 10% legal requirement without
some form of off-site delivery. We would suggest that how a developer meets this legal requirement is best determined by the developer and not the local authority.

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?

34. The priority for the Council and its partners should be to protect and maximise existing facilities to deliver the necessary services and wherever possible maximising such services on site. Such an approach will be the most effective approach to meeting changing needs and ensure the long-term sustainability of existing facilities. In many areas’ community centres and halls, libraries and other facilities are often under used and to require additional provision from development is unnecessary and inconsistent with the principles set out in paragraph 57 of the NPPF and paragraph 122 of the CIL Regulations 2010. We would suggest that greater levels of co-location would be a more appropriate response than requiring new development to provide or contribute to additional facilities. Where a site is required to provide new infrastructure, this must be at a level to meet the additional needs created by that development. Development should not be required to address existing shortfalls in supply following under investment at the local or county level.

Conclusion
35. We hope these representations are of assistance in taking the plan forward.
Should you require any further clarification on the issues raised in this representation please contact me.

Objection to New Local Plan
I would like to put forward my objection to this confusing and ill thought out proposal, which does not seem to take account of what is needed to have a fully functioning close knit community which after the terrible few years we have had with Covid has been shown to be vital for our Economy and well being, not to mention the environmental impact which with Global warming cannot and should not be taken lightly.

My husband travels extensively and it takes him longer to get the short distance out of our local area than it does to travel most the rest of his journey. The road systems are heaving with the volume of traffic and adding to this by building more housing will exacerbate the grid lock.

Every time housing plots are developed they seemed to be tweaked so the builders do not have to have to provide the essential infrastructure and vital services; dentists, doctors, schools to take in all the new people that will need to be accommodated in the area. If this is allowed to continue with the new proposals then peoples health and education will be blighted and we will know exactly who to blame for the shambolic lack of planning and organisation.

Increasingly our environment needs our help, the impact on the future generation will be impossible to rectify if we do not take the issue seriously. We love our local wildlife, we have seen Owls, Deer, Newts, Bats and many others species they cannot be moved on continually they will just be unable to flourish and will no longer exist. Concreting over the landscape will destroy our wildlife and will mean that the increased risk of flooding we have seen in our area will mean that we are storing up problems for our future, (historically Hawkwell is on a flood plan we ignore this at our peril).

We have the opportunity to cherish our community, be forward thinking and create a better future so far I haven’t seen anything from the council that makes me believe that they have the ability to achieve this.

The Local Plan/Spatial document on your website is very complicated and difficult to understand and so I have given up with that and stake below what I feel.
It seems that Rayleigh is AGAIN in the pipeline for much more housing development according to the local Lib Dems. The former Housing Secretary, Robert Jenrick, wanted to rip up the planning rules and allow people no say in what happens in their areas. He has now been replaced by Michael Gove, who wants to review the situation after so much backlash from the public over excessive over-development everywhere.
In Rayleigh we have had our fair share of housing development over the years and to have another local because landowners want to make money in their eagerness to sell their land for housing is totally unfair. It means Rayleigh just becoming an easy option dumping ground, with all the inherent problems such as traffic congestion, pressure on local services, the disappearance of green space and turning what is a pleasant place into nothing more than a concrete jungle.
Yes people needp laces to live but it is hoped having a new Housing Secretary appointment, a fairer scheme can be considered which will share out housing more equally instead of particular areas being crammed with over-development.
What about the consideration perhaps of Option 3a and 3b areas for a garden village somewhere near Fossetts Way on the Southend border?
Hopefully there can now be a pause and rethink about the housing development situation!?

I feel the need to contact you to put my comments forward regarding the new local plan that is currently being consulted on. I understand that the council is under pressure to build homes to meet housing needs but I really do question who these new homes are for. We live in the area (Hullbridge). We have a 22 year old daughter and a 25 year old son. We are sadly in the process of having 500 homes built just down the road to us and a further huge development near Makro in Rayleigh and our own children and other local families cannot afford them! This cannot be right surely! If any housing is to be considered then it really does need to be affordable for local families and not sold on to inner and outer London housing associations!!

After looking at the area map in great detail and the proposed development sites being put forward, I would suggest that all housing is in one location either as mentioned in the consultation document: 3a - West of Rayleigh or 3b North of Southend.

Hullbridge once again, appears to have been targeted as a major area for development. My own garden and the land that we back onto, is designated as Green Belt/Agricultural land, yet this is still being considered. We wish to ask some questions and bring to your attention some issues with this that may have been completely overlooked when setting out this consultation document and map of proposed sites, in particular those EAST of Ferry Road CFS128, CFS265, CFS151, CFS172, CFS042, CFS041, CFS243, CFS237, CFS100:

• Most if not all of this land is designated green belt land and we have already had a large amount of housing in our 'village'. We want to maintain our village status!

• CFS151, CFS128, CFS172, CFS265 - have a large number of very old oak and ash trees bordering the land that should not be destroyed but have the potential of being so if the sites are developed. A neighbour had plans turned down for a wooden annexe because it would mean that trees needed to be cut down so this should also be the case when considering future development sites.

• CFS 151/CFS172 - I am not sure if you are aware but there is a history of JAPENESE KNOT WEED on/ near to both of these sites. I am sure that any future developer/prospective purchasers of homes on these sites would be very interested to know this, as any future homes could be rendered completely worthless.

• CFS151/CFS172 - The lane that borders this land (Long Lane) is a bridleway and pubic footpath that allows riders and the public to enjoy our countryside safely. We do not want, nor can we afford for these to be lost. Horse riders are already in danger when trying to access these bridleways from the main road (Lower Road). The road is so busy without the additional traffic that new homes would bring!

• CFS100 - This land was part of the old NSEC site and must be contaminated land. We would like to know how this is going to be dealt with, if development plans go through?

• CFS128 - This land is a haven for wildlife, including munt jac deer and barn owls that roost in the barn on site. Other areas should be considered before destroying the habitat of these animals. Where will they go if you build homes on all the fields in this area?

• There is a distinct lack of infrastructure in our village to cope with the amount of housing proposed! This was completely overlooked in order to push through plans for the 500 homes currently being built West of Ferry Road in Hullbridge and we are paying for it! Our roads are busier than ever. We now struggle to get a doctors appointment, there is one private dentist that only opens a few days a week and the public transport is totally unacceptable and unreliable, especially when it comes to getting children to and from school. We have the following questions that we would like to be carefully considered and then answered before any further homes are built in this area:
1. When were traffic surveys carried out? If they were during or since the pandemic, or conducted during the school holidays, then they will not give an accurate reflection of the amount of traffic that passes through our village nor the congestion that we face coming in and out of our village. A six minute journey has taken over an hour when Watery Lane is closed!
2. Has the Environment Agency's new potential flood maps been considered? This shows that most of Hullbridge will flood by 2040. It is going to be very difficult for home owners to get house insurance now that this new map has been released and will make it more difficult to sell homes.
3. What public transport will be available for any prospective new home owners East of Ferry Road? We DO NOT HAVE ANY public transport links, yet it was scored a '5' as 'very good public transport links'. This is not correct at all and does not even reflect the number of buses that leave Ferry Road per hour, let alone public transport for homes at the top of Coventry Hill. A score of '5' means 10+ buses an hour. This is totally inaccurate! The 820 bus school bus service for children travelling to and from Sweyne Park school has just been suspended, leaving many school children without a bus service to school. The bus company's answer is to use public transport but as I have previously mentioned, this is completely inadequate and we are already seeing children left stranded at the bus stops both in Hullbridge and then near Rayleigh station. Stopping this service will only put more pressure on our roads and add to pollution levels. This is without the number of new homes that you are once again considering for Hullbridge.
4. What traffic calming measures will be put into place to slow traffic down for any vehicles on the proposed sites to enter/exit Lower Road? Nobody has listened to current residents regarding the danger that we face pulling out onto Lower Road where it bends and narrows. We have been asking for a speed camera or flashing speed signs for years and have been passed back and forth between the council and highways, with no resolution at all.
5. What increase in local services will we see? Our doctors are already over stretched and the building of 500 homes West of Ferry Road has not yet reached completion, so we are yet to see the full impact of these new homes, let alone the homes proposed in this new local plan. Will there be additional doctors surgeries built? Will there be an NHS dentist? How will you ensure that local school children can get a place in the village school? What measures will be put into place to prevent the flooding, as detailed in the Environment Agency's map? How will you ensure that children have access to school transport to and from the local secondary school? What will you do to ensure that vital services such as policing, waste collections, postal services and emergency services are maintained with the influx of residents? Most of the services are overstretched as it is!
I fully appreciate that you are under pressure from the Government to build new homes but 4298 homes in our village is far too many and will more than double the size of our village, meaning that we will are unable to preserve our rural coastal village outlook.
Any homes that are built should have a large proportion set aside for residents of Rochford District Council to purchase affordable housing. There is not any point in building homes that are going to be bought up by wealthier London Boroughs, leaving our own local families without homes! This should not just be a money making/box ticking exercise but something that has a positive impact on local families in within Rochford District Council boundaries.

To Rochford council
We would like to raise our objections to the proposed sites identified in the Hockley Local Action Plan and in particular the sites listed above currently in the consultation process for future development. We live at the above property and moved to Hockley to live in a semi-rural village and to enjoy open spaces, wild life and all that county living offers, away from heavy traffic and poor air pollution. We understand the need for more housing in the southeast and would support housing projects which included their own infrastructure and facilities ie roads, schools, Doctors etc in an area that does not impact on existing towns and village which are already over- developed for the services and infrastructure in place.
The proposed development of the above sites would have a direct impact on our property and lifestyle and we oppose the development of those sites for the following reasons:
Housing built on CFS242 and CFS150 is likely to overlook our garden and the trees surrounding our property would need to be removed to enable building, spoiling our outlook and tranquillity and could result in property prices being affected as the desirability of the area would be compromised. Our property is located at the bottom of victor gardens which is on an incline and already suffers with water drainage problems and during the winter months the garden becomes water logged. Further development on CFS242 & CFS150 would impact further on water drainage in the area.
The Nature reserve is very close to the proposed sites and building on these areas would impact on the wildlife significantly.
We oppose the building on any green belt land to protect the countryside, Footpaths and bridleways which would be lost.
Parking in Victor gardens is likely to be impacted with further development. Many of the houses in the road have already been extended and some single plots purchased by builders and then replaced by two large properties which has increased the traffic and parking in the road.
We also oppose the over development of Hockley/Hawkwell to protect it as a village.
The roads are already very congested and presenting problems in the area and further development would cause major problems getting in and out of the village without new road structures being put in place.
Many of the local schools are already full or close to full capacity and more housing would result in a lack of school places and choice for local children. If more educational facilities are not provided with further development then our children’s education will be compromised at the expense of development and housing.
The health facilities in the area are already overstretched and more housing in the area will definitely impact on our heath services.
Having lived and worked in this area for over 25years we feel that Hockley/Hawkwell is already overdeveloped for the infrastructure and facilities in place and therefore oppose further major development/ housing of this area.

I feel the need to contact you to put my comments forward regarding the new local plan that is currently being consulted on. I understand that the council is under pressure to build homes to meet housing needs but I really do question who these new homes are for. We live in the area (Hullbridge). We have a 22 year old daughter and a 25 year old son. We are sadly in the process of having 500 homes built just down the road to us and a further huge development near Makro in Rayleigh and our own children and other local families cannot afford them! This cannot be right surely! If any housing is to be considered then it really does need to be affordable for local families and not sold on to inner and outer London housing associations!!

After looking at the area map in great detail and the proposed development sites being put forward, I would suggest that all housing is in one location either as mentioned in the consultation document: 3a - West of Rayleigh or 3b North of Southend.

Hullbridge once again, appears to have been targeted as a major area for development. My own garden and the land that we back onto, is designated as Green Belt/Agricultural land, yet this is still being considered. We wish to ask some questions and bring to your attention some issues with this that may have been completely overlooked when setting out this consultation document and map of proposed sites, in particular those EAST of Ferry Road CFS128, CFS265, CFS151, CFS172, CFS042, CFS041, CFS243, CFS237, CFS100:

• Most if not all of this land is designated green belt land and we have already had a large amount of housing in our 'village'. We want to maintain our village status!

• CFS151, CFS128, CFS172, CFS265 - have a large number of very old oak and ash trees bordering the land that should not be destroyed but have the potential of being so if the sites are developed. A neighbour had plans turned down for a wooden annexe because it would mean that trees needed to be cut down so this should also be the case when considering future development sites.

• CFS 151/CFS172 - I am not sure if you are aware but there is a history of JAPENESE KNOT WEED on/ near to both of these sites. I am sure that any future developer/prospective purchasers of homes on these sites would be very interested to know this, as any future homes could be rendered completely worthless.

• CFS151/CFS172 - The lane that borders this land (Long Lane) is a bridleway and pubic footpath that allows riders and the public to enjoy our countryside safely. We do not want, nor can we afford for these to be lost. Horse riders are already in danger when trying to access these bridleways from the main road (Lower Road). The road is so busy without the additional traffic that new homes would bring!

• CFS100 - This land was part of the old NSEC site and must be contaminated land. We would like to know how this is going to be dealt with, if development plans go through?

• CFS128 - This land is a haven for wildlife, including munt jac deer and barn owls that roost in the barn on site. Other areas should be considered before destroying the habitat of these animals. Where will they go if you build homes on all the fields in this area?

• There is a distinct lack of infrastructure in our village to cope with the amount of housing proposed! This was completely overlooked in order to push through plans for the 500 homes currently being built West of Ferry Road in Hullbridge and we are paying for it! Our roads are busier than ever. We now struggle to get a doctors appointment, there is one private dentist that only opens a few days a week and the public transport is totally unacceptable and unreliable, especially when it comes to getting children to and from school. We have the following questions that we would like to be carefully considered and then answered before any further homes are built in this area:
1. When were traffic surveys carried out? If they were during or since the pandemic, or conducted during the school holidays, then they will not give an accurate reflection of the amount of traffic that passes through our village nor the congestion that we face coming in and out of our village. A six minute journey has taken over an hour when Watery Lane is closed!
2. Has the Environment Agency's new potential flood maps been considered? This shows that most of Hullbridge will flood by 2040. It is going to be very difficult for home owners to get house insurance now that this new map has been released and will make it more difficult to sell homes.
3. What public transport will be available for any prospective new home owners East of Ferry Road? We DO NOT HAVE ANY public transport links, yet it was scored a '5' as 'very good public transport links'. This is not correct at all and does not even reflect the number of buses that leave Ferry Road per hour, let alone public transport for homes at the top of Coventry Hill. A score of '5' means 10+ buses an hour. This is totally inaccurate! The 820 bus school bus service for children travelling to and from Sweyne Park school has just been suspended, leaving many school children without a bus service to school. The bus company's answer is to use public transport but as I have previously mentioned, this is completely inadequate and we are already seeing children left stranded at the bus stops both in Hullbridge and then near Rayleigh station. Stopping this service will only put more pressure on our roads and add to pollution levels. This is without the number of new homes that you are once again considering for Hullbridge.
4. What traffic calming measures will be put into place to slow traffic down for any vehicles on the proposed sites to enter/exit Lower Road? Nobody has listened to current residents regarding the danger that we face pulling out onto Lower Road where it bends and narrows. We have been asking for a speed camera or flashing speed signs for years and have been passed back and forth between the council and highways, with no resolution at all.
5. What increase in local services will we see? Our doctors are already over stretched and the building of 500 homes West of Ferry Road has not yet reached completion, so we are yet to see the full impact of these new homes, let alone the homes proposed in this new local plan. Will there be additional doctors surgeries built? Will there be an NHS dentist? How will you ensure that local school children can get a place in the village school? What measures will be put into place to prevent the flooding, as detailed in the Environment Agency's map? How will you ensure that children have access to school transport to and from the local secondary school as this has already been cancelled by the bus service and is causing chaos trying to get the children to and from school? What will you do to ensure that vital services such as policing, waste collections, postal services and emergency services are maintained with the influx of residents? Most of the services are overstretched as it is!
I fully appreciate that you are under pressure from the Government to build new homes but 4298 homes in our village is far too many and will more than double the size of our village, meaning that we will are unable to preserve our rural coastal village outlook.
Any homes that are built should have a large proportion set aside for residents of Rochford District Council to purchase affordable housing. There is not any point in building homes that are going to be bought up by wealthier London Boroughs, leaving our own local families without homes! This should not just be a money making/box ticking exercise but something that has a positive impact on local families in within Rochford District Council boundaries.

Thank you for taking the time to read our comments. I look forward to your answers to our questions.

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.

I have studied the planning suggestions and do not believe that planning a number of individual developments is the solution to the current housing needs.
Anyone who lives in Rayleigh (I have for 51 years) will know that are roads are already terribly congested and services stretched. Also a plan that just provides houses but no new infrastructure, jobs etc is not the complete answer to the problems.
Dotting houses around the town, slotting in 50,100,500 houses in areas that will use the existing roads and services will only cause more problems.
The needs of the existing people in our towns, as well as the welfare of new residents should be considered very carefully.
Building a whole new community or “garden village” would provide not only the houses but would generate the need for additional services. Potentially doctors, clinics, nurseries, shops perhaps even schools creating a significant number of local jobs instead of pushing even more people onto the commuter trains that are already over subscribed.

Consultation Process -The volume and format of information contained in the consultation was difficult to access and view online. It was difficult to understand the context of the consultation and RDC are not reaching residents who have no internet.

Infrastructure - This is a key concern for residents exacerbated by the volume of recent and proposed development causing additional pressure on roads, education, social services, health facilities and local employment opportunities. In particular our roads and cycle paths are in a very pitiful state of repair and are only likely to worsen with significant further development.
The Infrastructure Funding Statement states all financial and non-financial developer contributions relating to Section 106 conditions should be completed but this has not always been the case and is not the case when larger sites are split up.
Open Spaces - The value of our open spaces and the issues with climate change have 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 limited access in terms of roads into and out of the area. Open space is at a premium. Development of many of the proposed sites would mean a further reduction in air quality, increase in light pollution and the loss of trees and farming land at a time when food production and supply is becoming a cause for concern. Sites of Special Scientific Interest will also be affected. Essential green belt is being allowed to erode. The use of empty buildings and Brownfield sites should be evaluated first and consideration should be given to identifying an area where a discrete garden village with appropriate infrastructure, separate from current settlements, could be created.

Potential Developments in Hockley - The plan proposes around 1000 additional houses in Hockley with additional developments on land bordering the Parish. This density will have a major detrimental impact on the quality of life for residents. A particular concern is traffic. The volume of traffic on the B1013, into which most of the proposed new sites, including CFS045, CFS064, CFS160 & 161, CFS074, CFS194, CFS169, CFS150 and CFS020 will feed, is already at an unacceptable level. Many proposed sites are not within walking distance of services and bus services are limited. Current high levels of traffic mean that there is already a detrimental effect on the quality of life for residents as well as local commerce and potentially on individuals’ health, given levels of pollution. Additional traffic, potentially thousands of cars, will only worsen matters.

The proposal for development on land at Belchamps is particularly worrying due to the lack of open space for activities available to youngsters and community groups in the Rochford District. The site has been a very valuable well used resource and it is important this is retained for our future generations.

Whilst I understand the need to provide additional housing in Hockley, infrastructure requirements need to be considered and addressed alongside any consideration of potential development sites. Also proper consideration needs to be given to identifying development away from existing settlements. Whilst this may be unattractive due to upfront costs, such an approach could save money in the long term.

Objections to Spatial Options Paper
Areas in Hullbridge to the East and West of current Residential Streets.
To the East CF5099, CF5149, CF5006
To the West CF5003, CF5193, CF5190, CF5172, CF5265, CF5151, CF5128.
These plans are totally premature, as the impact on the infrastructure of the 4 developments within the district are mostly unfinished, therefore no accurate assessment can be made.
None of these sites comply with Government Guidelines N.P.P.F July 21.
Which include the following guidelines and statements.
Infrastructure first. Until all developments are completed, no new assessments can be made on Health, schools, public transport, road capacity. Therefore no accurate data can be reached. The A127 has clearly reached it’s capacity, taking 1 ½ Hrs to do a 30 min journey in rush hour. Many road users taking the alternative route via Hullbridge. Deliveries have been aborted due to traffic chaos affecting residents and businesses.
Green Belt/ Farmland. should only be used as a last resort.
Flooding. Land with the potential to flood now or in the future should not be considered unless mitigation measures can prevent flooding. This would prove impossible to secure all the riverbank and hold back the tide. Climate change has this area prone to flooding within 20 years. Additional building on this land would impact on current housing.
Many of the roads adjoining these sites are without surface water drainage.
Carbon emissions in the Rayleigh area are the highest in Essex, with the county having the most cars in the UK. This is a health risk. Builders have already removed trees and hedge rows which need to be replaced, to help address this. No further decline should be permitted.
Housing development should only be permitted to provide for the requirements of existing residents, and then should be within villages and towns avoiding expanding boundaries close to other parishes, villages and towns, to avoid urban sprawl.
These developments should be withdrawn immediately.

I have lived in the district for 50 years during which time thousands of houses have been built - the vast majority on green field sites.
Any reasoned objective analysis will show that travelling by car into, within and out of the District has become much of a lottery with more frequent gridlocks occurring for a whole variety of reasons. This unacceptable situation will be exacerbated by further house building.
The stark reality is that any improvement on the totally inadequate road network will require the building of further roads or bypasses on greenfield sites.
We live in the most densely part of a country which in itself is the most densely populated in Europe. To continue to concrete over greenfield land is completely irresponsible and will not be for the benefit of the current or future generations.
The ludicrously high and apparently uncoordinated targets imposed on individual Councils should be challenged and more innovative and socially responsible solutions sought at a national level on both the supply of and demand for housing.

I have used email as I found the on-line portal difficult to navigate

My objections/comments are as follows:

The draft vision that Rochford will be a green and pleasant place is flawed if we give away large swathes of green belt.
The strategic option 2 provides an inordinate amount of development in Rayleigh as a whole. There is already major congestion on the town’s roads in particular London Road, Rawreth Lane, A130, A127 and Hockley Road. These roads are at capacity especially during rush hours, and other peak times such as school start/finish times.
In particular the proposed developments:
CFS 027, 029, 053, 054, 086, and 098 all proposed in an area bounded by Hockley Road and Bull Lane would create further congestion on already busy roads (Hockley Road) and untold congestion in Bull Lane area which is simply not capable of carrying the amount of traffic that would be generated.
Valuable green belt land would be lost which has an effect on everybody’s wellbeing as well as the wildlife that would be displaced, a bridal path would also be lost between Napier and Wellington Roads.
The number of homes would also generate more private motor vehicles, and any talk of cycle routes is nonsense as the size of the local roads are not capable of adding cycle routes.
My opinion is that Strategic option 3 would be the most preferable even though it is your submission that it might be the hardest of your options.

I agree with your settlement hierarchy but just because Rayleigh is at the top that should not mean that it becomes over developed and loses its identity and becomes an urban sprawl. You state Rayleigh has a large town centre, this is true if you want a haircut or something to eat but for anything else you are wanting. It is not a requirement for more retail space but you should be looking at why are retailers moving out of the high street, is it because of high business rates, the movement of shopping habits to the Internet and are these changes that are unlikely to be reversed. The local doctor’s surgeries are at capacity and being able to register with an NHS dentist almost impossible. Rayleigh does not have a Police station that is open to callers for either advice or to report an incident.

Strategic priorities
1. Southend Airport - I disagree that there is a need to further develop this airport, it has been difficult to attract operators to the airport with EasyJet withdrawing and Ryan Air running routes that go via Ireland, so Southend to Bristol 6 hours with one change, since COVID has struck the reduction in air traffic has reduced the noise nuisance especially to those directly under the flight path.
2 - Shops and leisure - Rayleigh town centre does not have shops that provide day to day requirements meaning travel to out of town sites, leisure facilities are at maximum capacity with the ability to book into Clements Hall leisure centre difficult at peak times 3. Transport - Most of the district’s roads are already running at capacity in peak times with severe delays common. There is no way that dedicated cycle routes could be implemented due to road sizes and if they were it would cause more congestion which in turn would harm the environment due to emissions.
4. Although there are no hospitals in the district those in adjoining districts are at capacity with some of the worst waiting lists in the country. Our doctors and dentists are at capacity and if you were to progress strategic option 2 it will be difficult to provide increased school capacity in the right place as the developments are spread over a large number of areas.
Lastly you state that 57% of the required housing would be in Detached/Semi detached housing of 3-5 bedrooms, based on property prices in Rayleigh this is not going to be affordable for the younger generation, but will attract families which come with 2 plus cars to an already over crowded town.

The whole basis of your presentation is severely flawed. The future development of the Rochford District Council area is dependent on the provision of a strong supportive infrastructure. Rochford itself is slowly being strangled by its poor and inadequate highway system as just one example. The compilers of this report only allude to infrastructure within objective 10. Focusing on just two roads Sutton Road is no longer capable of supporting the size and volume of traffic especially accessing and exiting the Purdeys Estate. Despite how Essex County Council try to play down the issue Ashington Road is frequently congested without the addition of further houses built in the area. Whilst the development of a new road structure is outside the Councils brief and is a financial cost to the County Council and central government Rochford Council must take a stand to insist that their local plan is dependent upon such a suitable road structure being in place. You should not need reminding that the role of the Council is to serve to its best ability its population not central government.
If no road infrastructure is put in place and housing development continues the result will be further road congestion, increased traffic movements, poor public transport and detrimental air quality as well as a greater risk of flooding as more of the open green space is lost.
I would urge the council and councillors to make a stand for all our sakes.

I wish to object strongly to the Councils local plan for any thought of any more development in Great Wakering. I have lived here for 50 years and have seen major housing new builds in the last few years.
Star lane = 180+78+20. Some completed others planning permitted West of Little Wakering Road = 120. In construction Alexandra Street = 25 planning permitted Red Lion =4 + 4 Apartments completed.
427 in total !
There has been no infrastructure to support this number all ready School already full Doctors overrun Traffic already causing problems ,possible 600 extra cars.
Existing extra people (not local)will increase village population by over 16% Council wants to build more houses ?

Rochford housing needs 7200 in next 20 years
4000 all ready identified (Hall Road, London road) Total 3200 Rochford population 3200➗87000 x 100 = 4.8% increase ,potential in 2040 Great Wakering population 427➗6000 x 100 =7.1% at present.
How can the Rochford Council Planning Dept. Even consider more development!
Many people have told me there’s no point in objections as the Rochford planners will agree to new builds, so what’s the point ,thinking they know what people who live here want, they don’t want a 100 houses in the High Street and Little Wakering Road with a rural view spoilt buy new builds.

Great Wakering is all ready over subscribed with new builds, no more please, we do not want to become Rochford’s dumping ground to make up the numbers.

Dear Sir / Madam
Rochford Local Plan Spatial Options (Regulation 18)
Thank you for the opportunity to comment on your Spatial Options Document. These representations are submitted on behalf of Rydon Homes which has land interests to the south of Wellington Road, Rayleigh (Call for Sites references CFS053 and CFS086). Rydon is promoting the land for the residential development of around 110 homes (including affordable housing.
By way of clarification, the Rydon representations comprise of the following documents :
- this letter which provides a strategic overview of the issues raised in the Regulation 18 document
- a schedule which provides responses to certain of the questions posed in the
Regulation 18 document
- a Green Belt assessment prepared by Liz Lake Associates
- a Landscape Assessment prepared by Liz Lake Associates
- Transport Strategy site prepared by Vectos
- Local Plan Evidence Base Appraisal Technical Note prepared by Vectos
- Surface Water Flood Risk Technical Note, prepared by Stuart Michael Associates
- Design Assessment prepared by Omega.

Overview of the Regulation 18 Document
The strategic direction of the Reg 18 Plan is strongly supported since it seeks to move towards a more sustainable pattern of development where new development can be low carbon and be located where a good range of facilities can be accessed by foot, cycle or
public transport. It is considered that these over-arching principles strongly point to a strategy which locates most development in the main towns. In this context, Rayleigh should be considered the primary focus for development in the District since
- it is the largest town, by a large degree
- it contains the widest range of facilities, services, jobs and public transport
- it is the only ‘Tier 1’ settlement in the District and is at the top of the District retail hierarchy
- this approach is also supported by the conclusions of your Integrated Impact Assessment.
Whilst it is accepted that major urban extensions can sometimes have the ‘critical mass’ to deliver infrastructure, many Local Plans have been found unsound because of a lack of range and choice of sites plus the delivery risks involved in a strategy based around a very limited number of large sites. A failure of one large site can prejudice the whole plan.
It is for these reasons that in addition to Rayleigh being the primary focus for development in the District, the new housing allocations should be in the form of a mix of sizes and locations around the town. This will allow scope for diversity, choice and the involvement of smaller
housebuilders. It is also a robust delivery strategy. For reasons explained below, it is considered that the land south of Wellington Road fulfils all the objectives of your emerging Local Plan and can assist in improving the ‘completeness’ score of Rayleigh.
The consultation document seeks views on the overall level of development in the District. Comments on the three options are :
- Option 1 ‘Current Trajectory’ (4,500 homes) : This would substantially undershoot the Government’s standard methodology and is a strategy which is likely
to fail at Examination
- Option 2 ‘Standard Methodology’ (7,200 homes) : This is the absolute minimum housing provision needed to avoid the plan being found unsound
- Option 3 ‘Standard Methodology + 50%’ : Whether the uplift is 50% or some other figure is not the real issue. Government policy states that the Local Authorities
should seek to meet the unmet needs of adjoining areas, where this is achievable. In view of this, the Local Plan evidence base should investigate the degree to which
Rochford can exceed 7,200 homes in the period to 2040 in order to meet unmet housing needs from adjoining areas and provide more affordable housing.
For these reasons, the Plan should adopt ‘Option 3’ and seek to provide housing in excess of 7,200 homes.
South of Wellington Road
As noted above, Rydon is promoting 6.31hectares of land south of Wellington Road as a housing allocation for around 100 homes.
In addition to complying with your emerging strategy of locating allocations is sustainable locations where facilities can be accessed by foot, cycle and public transport, the promotion of this site is supported by Rydon’s own evidence base. These documents are attached, but can be summarised below :
1. Green Belt Review by LLA : This report assess the Green Belt role of the site and places this in the context of the Council’s study undertaken by LUC. The main
problem with the LUC report is that its site assessment is insufficiently ‘fine grained’ to pick up smaller sub areas which have development potential within large parcels
which, overall, are not seen as having potential. The LLA report then provides a Green Belt assessment of a sub area made up of only sites CFS053 and 086. This
identifies how this site is effectively an indent in the eastern built-up edge of Rayleigh with development on three sides. It also has a strong tree / hedgerow boundary on its eastern side and its topography slopes inward towards the urban area of the town. In
combination, this means that the site could be developed without materially compromising the purposes of the wider Green Belt around Rayleigh.
2. Landscape Assessment by LLA : This ties in closely with the LLA Green Belt review and demonstrates that sites CFS053 and 086 have significantly different
landscape characteristics from the wider area of open countryside to the east. As such, it is capable (with mitigation) of being developed with limited impact on the
wider landscape.
3. Sustainable Transport Assessment by Vectos : Whilst the Local Plan concept of ‘completeness’ is supported, it is felt that the methodology used is flawed. As a
consequence, sites CFS053 and 086 are given much poorer ‘completeness’ scores than they actually merit. The Vectos report suggests some amendments to the
methodology to make it both more logical and accurate. As a consequence, the Rydon sites, with the existing public footpath / bridleway route to Napier Road and on
to the Town Centre can be seen as very sustainable location. It will also assist the achievement of ‘completeness’ in Rayleigh.
4. Drainage Report by SMA : In response to the drainage concern identified in the Site Assessment, Stuart Michael Associates (SMA) have been commissioned by Rydon
Homes Ltd to assess the impact of the risk of flooding from surface water on the Site.
Whilst the site is located within Flood Zone 1, the site is also identified as being low, medium and high risk of surface water flooding. SMA’s report confirms that any
surface water flooding is constrained to the peripheries and low lying areas of the site within and adjacent to the existing watercourses. Proposals can therefore be brought forward with no risk of flooding. It should be noted that the proposals could also include provision to mitigate risk of flooding to properties outside the site and
downstream of the site.
5. Design Assessment by Omega : The Design report seeks to synthesise all the evidence contained in the Rydon evidence base to produce an illustrative masterplan. This shows a development of between 92 and 110 homes arranged within generous levels of open space. The urban context analysis indicates certain design themes which could be adopted to ensure that a sense of place can be created, as well as somewhere which echoes the essential characteristics of the best of Rayleigh’s urban fabric.

Conclusions
Rydon welcomes the publication of the Regulation 18 document and supports many of its aims and objectives which work towards a more sustainable and low carbon future. As part of this, your own evidence base and the Integrated Impact Assessment would suggest that the town of Raleigh should be the primary focus of new development. Rydon support this and consider that its own evidence base clearly makes the case for the allocation of around 110 homes south of Wellington Road.
Should you wish to discuss these representations in more detail, we would be pleased to arrange an early meeting.

Rochford Local Plan Regulation 18 Spatial Options Consultation
Representations on behalf of Rydon Homes
Responses to Questions
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?
A : The draft ‘Vision’ for Rochford contains many appropriate and supportable elements, but it should contain a commitment to delivering sufficient high quality homes to meet need.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
A : Yes, there should be separate ‘Visions’ for each of the main settlements. This will help capture their diversity and distinctiveness. It may be necessary to have a a generic ‘villages / hamlets’ Vision for the smallest communities.
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?
A : The strategic objectives are generally supported. However, the number should be expanded to cover cross-cutting themes. An example would be to make the link between the objective for zero carbon and the concentration of new development in sustainable locations (ie. the larger towns) explicit.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
A : Yes, the settlement hierarchy is sound. It correctly identifies Rayleigh as the Tier 1 primary settlement in the District.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
A : Dealing first with the level of Growth, Option 1 (Current Trajectory) would fail to meet the standard methodology figure. As a consequence, it is probable that the Plan would be found unsound and fail. Option 2 (Standard Methodology) is the minimum possible figure
that the Plan could pursue and could still be found unsound since it would not be attempting to meet the unmet needs of adjoining local authorities. Option 3 (Standard Methodology + 50%) has the greatest chance of being found sound since it would allow Rochford to meet some unmet needs from adjoining authorities and would allow a greater portion of affordable housing in the District to be met. The reference to 50% in Option 3 is misleading. Option 3 should just have the objective of exceeding the standard methodology figure by whatever the District can accommodate. This may be +15%, it may be +60%. The evidence needs to be produced to justify a specific figure.
With regard to the spatial strategy options, the most sustainable and deliverable option is 2A (Urban Extensions Focussed on Main Towns). However, in reality, this is likely to take the form of Option 4 (Balanced Contribution) since in order to meet the overall housing
provision, there will need to be both urban intensification and some strategic releases at the main towns.

Q7. Are there any reasonable alternatives to these options that should be considered instead?
A : A refined option would be a Balanced Contribution made up of
(i) Some urban intensification
(ii) Small / medium urban extensions at main towns
(iii) A limited number of strategic releases to ‘top up’ the yield from (i) and (ii) to meet the selected housing provision.

Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis?
A : Zero carbon should be added to the list of themes.

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?
A : A sequential approach to flood risk is both logical and in accordance with the guidance in the NPPF.

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?
A : The Coastal Protection Belt and Upper Roach Valley should have continued protection.

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 : Agree in principle, the difficult question is what is the appropriate percentage which is both viable and deliverable.

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?
A : This may not be necessary since the Government is already proposing to strengthen Building Regulations to deliver high energy efficient standards. If the Local Plan was to propose even higher standards, this would need to be rigorously tested in terms of the impacts on both viability and delivery.

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?
A : Yes, a high level ‘place making charter’ would be useful, in principle to provide guidance whilst not being inflexible.

Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
A : The principles are generally supportable. However, carbon negativity (as opposed to being carbon neutral) is unrealistic.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
A : Rydon supports this objective in principle. However, design guides, codes and masterplans should only be produced in full collaboration with landowners and developers. Any documents should be regarded as flexible and allow alternative approaches to come
forward, where these can be fully justified.

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?
A : A single Design Guide for the whole District would become too generic and fail to identify what makes each settlement unique. Settlement specific design guides would be most effective, as long as they do not stifle innovation and can allow alternatives approaches,
where fully justified.

Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?
A : It is important that any documents are not too prescriptive and allow a degree of flexibility. All documents should include a date by which they will be reviewed.
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?
A : The appropriate response is to negotiate a site specific mix which is appropriate to the settlement and the characteristics of the site itself (Option 2). National Space Standards are appropriate. The approach to Part M4 of the Building Regulations could reflect that adopted in the London Plan.

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?
A : Option 4A is the most appropriate solution to meeting open space needs if they can all be met on site. Any needs which cannot be met on site should be met by off site contributions.

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?
A : Option 2 (incorporating Town Centre policies in the Local Plan) is the most appropriate approach.

Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make?
A : Given the status of Rayleigh as the Tier 1 settlement in the Settlement Hierarchy and its wide range of shops and services, it should be defined as the only ‘Primary Town Centre’ at the top of the retail hierarchy.

Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
A : The Vision for Rayleigh is appropriate in that it captures the need for new allocations to be accessible by foot, cycle or public transport.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other
A : Rydon is promoting the residential allocation of sites CFS053 and 086 south of Wellington Road, Rayleigh for around 110 homes. The justification for this allocation is set out in the attached Sellwood Planning covering letter plus
- The Green Belt Review by Liz lake Associates
- The Landscape Assessment by Liz Lake Associates
- The Sustainable Transport Assessment of the Promotion Site by Vectos
- Drainage report by SLR
- Design Assessment by Omega.
In summary, the land being promoted by Rydon accords with the emerging spatial strategy of the Local Plan in that it is located in Rayleigh which is the most sustainable settlement in the District with the greatest range of services, facilities, jobs and public transport. Within Rayleigh, the site is within easy walking / cycling distance of a wide range of facilities and can assist in the achievement of the ‘completeness’ objective of the Local Plan. The development of the site will cause no material harm to the wider Green Belt and countryside since it represents an indent in the built form on the eastern side of Rayleigh, with development on three sides. The eastern boundary of the site is strongly vegetated and when combined with the topography would represent a strong and defensible long term boundary to
the Green Belt in this location.

Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate? Why these areas?
A : Yes, sites CFS053 and 086 south of Wellington Road.
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 : The green spaces shown are of local significance and should be identified as such. No additional green spaces should be identified as having local significance.

Building objections
Hi there im a resident of hullbridge and want to object totally to any new building in the area as well as other surrounding areas.

Reasons being that we don’t have enough doctors hospitals schools or roads to cope at the minute let alone if there was any more building!

Firstly I should like to say that I think the presentation of this to the local people is far too complicated and I feel many people will just “give up” trying to respond However, I will attempt to put my views to the best of my ability.
I feel strongly that there should be no further major development in Hullbridge as this would damage the environment, compromise and have a detrimental impact on existing wildlife and result in more pollution and flooding. With the current UK emphasis on planting trees and hedgerows to help reduce pollution and benefit our natural wildlife, any further major development would go completely against this philosophy.
With the information given to me, I feel that the best option would be to build all housing in one location west of Rayleigh where there are already good transport links via A127, A130 and A13 These roads would serve as good links for work and business in Basildon, Southend, Wickford, Chelmsford, Thames Gateway and Tilbury2.
This option would enable a “tailor-made” approach to good housing and infrastructure, schools, GP surgeries, open spaces and community facilities. This option would not put extra strain on the current villages whose roads, facilities and amenities are already stretched to breaking point. An example of this is the current through traffic on Lower Road in Hullbridge where there has been a vast increase in the volume of traffic and consequential increase in air pollution (due to recent developments in Rochford and Ashingdon). Lower Road has become a rat run for traffic from Southend and en route areas through to to Chelmsford. The increased volume and speed of traffic along Lower Road makes getting in and out of residential driveways on to Lower Road extremely hazardous; it can take anything up to ten minutes to pull off our driveway safely. The increase in Lower Road traffic has resulted in numerous accidents in recent times, one of which was sadly a fatality. The keep left sign on Lower Road near the junction with Long Lane has been completely demolished by a car on one occasion. On another occasion a car hit the lamp-post bringing it completely down. Numerous animals have been run over. A car ran into a van that was trying to exit his own driveway on to Lower Road. A man was knocked off his motorbike in Lower Road. The air ambulance has had to attend incidents in Lower Road twice within five days recently. It is virtually impossible to cross Lower Road safely on foot and one lady recently told me she has become virtually housebound in Central Avenue as, because of continuous stream of traffic, she cannot get across Lower Road on her mobility scooter and there is no pavement for her to travel along to get to Hullbridge village shops and GP.
In addition, heavy goods vehicles are continually using Lower Road and these are putting excessive strain on the underground utilities. This means we are constantly experiencing the road being dug up for water main repairs, gas leaks, etc. Even a major sinkhole appeared in Hullbridge Road in the summer 2021.
Hullbridge has limited school facilities and I understand that only last year an infant school child was allocated a place in a Harlow school as there were no other local options available at that time.
The only GP surgery in the village is at capacity and getting through on the telephone is extremely problematic because so many people are trying to get appointments. In addition there is a shortage of doctors.
In Lower Road Hullbridge, there is no regular bus service, which means children at the south end of Hullbridge have a thirty minutes’ walk to the local infants and junior schools. This is tiring for five year olds and difficult in the winter months when it is dark and often wet. As there is no regular bus service along Lower Road, senior school children have a long walk along a busy main road to catch the bus at Coventry Corner (the nearest bus stop for number 20 bus). When the bus arrives, it is often full up with children and commuters who have previously boarded in the village along Ferry Road.
At the south end of Hullbridge there are no public recreational facilities. There is a local sports club but this is not open to the general public to allow children to just play and run around. In addition there are no general community facilities for the older people at the south end of Hullbridge.
We do have a number of valued and well used footpaths and bridle ways but these would be lost if there were to be further development in Hullbridge.
I understand that according to a recent report, much of the proposed development area in Hullbridge will be below sea level by 2050 - it makes no sense to consider further development on such vulnerable sites.
It is for these reasons that I feel further major development in Hullbridge should not be permitted.

I am concerned about the sites which have been suggested for potential development around Hullbridge. With 500 houses already being built the village, which has an existing population of less than 7000, Hullbridge will be overwhelmed if these developments are allowed to go ahead. In addition to concerns about the loss of character which will be suffered there are also practical objections:

Many of the sites which have been proposed are currently agricultural land. We are being encouraged to use local produce yet the land it comes from is being lost to development.

Poor infrastructure. Hullbridge Road/Lower Road is the main access road to Hullbridge (Watery Lane is too narrow and prone to flooding). The road network cannot cope with current levels of road usage and the addition of a large number of extra vehicles will make the situation intolerable. When Hullbridge Road or Lower Road are blocked (which unfortunately seems to happen frequently) the whole area comes to a standstill in a very short time.

No plans are included for the provision of new schools, medical facilities, leisure facilities or public transport. The existing infrastructure does not have the capacity to absorb large numbers of new residents.

Risk of flooding. We are told that water levels will rise significantly over the next few years. This will put the low lying areas of Hullbridge at a high risk of flooding. Many of the existing roads have no surface water drainage and at times of heavy rainfall the high levels of surface water cause a problem.

Whilst a small amount of development around the village seems inevitable I believe that in order to accommodate the volume of development required in the district it would be better to choose strategy 3 and build all the housing in one location. This would mean that suitable infrastructure could be incorporated into the development and a sustainable community could be developed rather than just large numbers of new homes tacked on to existing communities.

Dear Sir / Madam,

Q60a. Do you agree with our vision for Hullbridge? Is there anything you feel is missing?
Answer - No we do not agree with the vision for Hullbridge.

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?
Answer - Our preferred option would be #3 (West of Rayleigh, North of Southend or East of Rochford).

Q60c. Are there areas in Hullbridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning] Answer - No, the infrastructure cannot cope with further development, i.e. if there is an issue to Lower Road or Watery Lane, the whole area becomes gridlocked. The doctors surgery is overwhelmed at the best of times now let alone if more pressure is put on it. The local primary school will need extending to cope with the additional children that will need educating locally.

Q60d. Are there areas that require protecting from development? Why these areas? [Please state reasoning] Answer - Yes, all of them, the infrastructure within Hullbridge cannot sustain further development. Any improvements to the infrastructure (i.e. widening of watery lane / third route in/out), upgrading of the doctors surgery and school so they will be able to cope with the additional pressures should be completed prior to any development works.

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] Answer - In a world that is under serious threat from climate change, surely all green areas hold significance.

Comments on RDC Local Plan Consultation for Hockley Sept 2021
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.

Infrastructure - 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.

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. Many 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. Sites of Special Scientific Interest will also be affected.
The Merryfields Avenue proposal has been previously rejected by residents due to access issues as the land borders on the Nature Reserve. Consideration should be given to incorporating it into the Reserve rather than releasing it for development.

• 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;
• 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;
• Essential green belt is being allowed to erode further which will be impossible to replace;
• Enforcement on unauthorised development is not adequately managed.
• The volume of traffic has increased to an unacceptable level on the B1013 causing noise, smells and
disturbance; Is the traffic survey up to date;
• 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. 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. The site has been a very valuable well used resource and it is important this is retained for our future generations.
We have to consider some growth in Hockley and surrounding areas but a more measured approach must
be taken on the sites put forward by landowners. The views of our residents on the Consultation should be
acted upon by RDC and unsuitable and overdeveloped areas withdrawn from the Plan.

I would like to put forward my own opinions regarding the Spatial Options Consultation for my local area of Hullbridge and also for Rochford as a whole.

Vision for Hullbridge:

A large area of Hullbridge is NOT accessible by walking or public transport. If the proposed sites to the East along Lower Road are developed this will add to the horrific congestion on Lower Road from Coventry Hill. There are no pavements or crossings and personally, I am unable to cross over to the other side from Central Avenue where I live. It is dangerous standing on the "pavement" (such as it is) as there is no room to step back from the large lorries often going past. If building work continues this will worsen. There are no regular bus services along this route despite the bus stops and old timetables. If I find I can no longer drive I will be marooned in my road along with many others like myself.

There are indeed a growing number of older residents in this area. I feel the current trend of making bungalows into houses with loft conversions is not helping their housing needs. Rather than develop more of HUllbridge for family housing a site needs to be set aside for maybe sheltered warden controlled housing and care facilities close to the facilities around the Doctors Surgery in Ferry Road.

Our riverfront does NOT need to be developed - it is fine as it is - I feel that any development of the riverfront would be very detrimental to the rural coastal village outlook and the Hullbridge Foreshores.. A regional park to the West is a wonderful idea - a local country park would preserve habitats and wild life for the future. Much of this land to the West is flood plain and would be problematic if built on.

Building of homes:

If every site in Hullbridge is developed the scanty local facilities would totally be overwhelmed! There would be more pollution from more cars commuting to Rayleigh station or Hockley.

This is no doubt true of many of the existing towns and villages. WE are already in danger from eroding green belt. Rather than develop the needed new homes piecemeal without adequate infrastructure I feel it would be better to place them all on one site much like South Woodham Ferrears. However if any of the sites proposed are to the East of Rochford or North of Southend I feel it would place a larger burden on already busy roads. I have two suggestions:

Build on the Potential cross Boundary Opportunity marked to the West of Rayleigh - this is close to major roads and a railway line and a new station could easily be sited. This has the benefit of keeping the traffic away from local towns and not adding to congestion.

I also feel that the airport will not recover from the lost business due to the pandemic and in any case I know from experience working there how awful the pollution is from aircraft - not to mention the many cars and lorries also going there. There are already roads and a rail station and buses. Why not build on the airport. It is my understanding that the land belongs to Rochford in any case.

I hope my views are useful to the council.

I wish to register my objection to the options that involve further building in Rayleigh The town cannot cope with existing levels of traffic and demand on schools, doctors dentists etc.
The traffic situation is already dire at many varied hours of the day in the High Road near Great Wheatley, with traffic frequently at a standstill in both directions. , and is often problematic coming in and out of Rayleigh on all other main roads.

In particular I wish to STRONGLY OBJECT to the potential use of Green Belt land north of Great Wheatley Road ( Site Refeernce CFS077); this area has limited access and would add an intolerable burden to the existing choked road network in the immediate surroundings I further understand that there are protection orders on trees in the site, as well as , I believe, issues with protected wildlife.

In addition sites CFS087, and CFS121 would also further foul up the traffic system in the most congested part of Rayleigh.

As a general principle I consider it unacceptable to allow development of green belt land when there are brown field sites elsewhere that could potentially be developed.

ROCHFORD DISTRICT COUNCIL SPATIAL OPTIONS CONSULTATION (REGULATION 18) - BARRATT DAVID WILSON HOMES RESPONSE: LAND EAST OF STAR LANE AND NORTH OF POYNTERS LANE, GREAT WAKERING

On behalf of our client, Barratt David Wilson Homes (‘BDW’), please find enclosed representations to the
Spatial Options consultation currently being undertaken by Rochford District Council (‘the Council’).

Background

BDW
BDW is the nation’s leading housebuilder, creating great new places to live throughout Britain. In 2019/20,
BDW delivered over 12,600 new homes.

BDW are experts in land acquisition, obtaining planning consents and building the highest quality homes in
places people aspire to live. This expertise has been shared with the Council in recent times through the
delivery of other schemes in the District – including the High Elms Park development in Hullbridge.

BDW is committed to being a sustainable housebuilder and continue to integrate sustainability into their
business practices, helping to create better homes and communities and a strong business for the longer term.

Land east of Star Lane and north of Poynters Lane, Great Wakering
BDW is currently promoting Land east of Star Lane and north of Poynters Lane, Great Wakering as an
allocation for housing in the emerging Local Plan. This land ownership covers two HELAA parcels: CFS057
and CFS070. These representations are supported by a Framework Plan which is appended to this letter,
alongside a site location plan.

BDW would like to make the following observations on the content of the Spatial Options consultation.

Vision, Priorities and Objectives
Q2: Do you agree with our draft vision for Rochford District?

Whilst BDW agree with the draft vision for Rochford District in principle, we would like to make the following
observations.

As currently drafted, no reflection of the purpose, aims and objectives of the emerging South Essex Joint Spatial Plan (JSP) is made. The Statement of Common Ground (SoCG) (2018) between the six constitutive Councils (plus Essex County Council) involves a commitment to work together on strategic planning matters, including meeting the housing needs of entire sub-region in full (our emphasis) (see Chapter 9). The relationship between Rochford and Southend-on-Sea is imperative to achieving this, as recognised by the current in-tandem production of new Local Plans in these areas – including the production of a joint evidence base (e.g. Green Belt, HELAA). The evidence base (see HELAA June 2020 Update) is clear that Southend will be unable to meet its objectively assessed housing need on deliverable sites within its administrative boundaries in both policy-on and policy-off scenarios (a shortfall of 6,671 dwellings from 2020-2040), whilst Rochford (in a policy-off scenario) contains deliverable sites to provide a surplus of 35,935 dwellings from 2020-2040 – including Land east of Star Lane and north of Poynters Lane, Great Wakering. Given the relationship between the two administrative areas, it is imperative that the Council works constructively with
Southend (and other Council’s within the South Essex JSP) to meet the commitment of the JSP to deliver
South Essex’s housing need in full. It is important that the commitment to working with the JSP Councils to meet the needs of the area in full is recognised in the development of a vision that looks further ahead than
just the Plan period (i.e. to at least 30 years) to ensure future generations have clarity on the growth of the
District in the context of the JSP area.

With regards to ‘Our Society’, the Council’s supporting text should be evolved to recognise that although
focussing on previously developed land may be the priority, the evidence base demonstrates there is
insufficient land within these categories to deliver its objectively assessed needs. The HELAA (June 2020
Update) demonstrates a total of 4,320 dwellings can be provided (including a 39dpa windfall) on previously
developed / currently approved sites – a shortfall of 2,880 dwellings. The Urban Capacity Study indicates that
this, at a maximum, can be increased to 5,000 dwellings, still leaving the Council with a shortfall. The Vision
needs to evolve to cover a longer period (as per Paragraph 22 of the NPPF) and recognise that growth on
greenfield sites (including Green Belt) must now take place under an appropriate strategy – which should allow
for a mix of sites and a range of homes to be delivered which can help combat affordability issues and support
Growth across the plan period (see our answer to Q6).

With regards to ‘Our Environment’, the Council’s pledge to retain an extensive Metropolitan Green Belt
designation is noted, but in light of the evidence regarding objectively assessed development needs it is
important that this is clearly defined to allow for future growth to be accommodated within the Green Belt
following Plan reviews.

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

BDW agree with this approach, in principle, insofar as it allows for both the correct quantum and type of
development to be delivered within each settlement to meet the Council’s identified needs.
Please also see our response to Q5, Q6, Q7 and Q59.

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

BDW broadly agree to the strategic priorities and objectives identified in principle.

However, as set out in our response to Q1, BDW consider the Council should amend Strategic Priority 1,
Objective 1 to reflect the need to deliver its objectively assessed needs – as a minimum – including
consideration of the contribution that could be made to solving housing numbers across the South Essex JSP
area.

Strategy Options

Q5: Do you agree with the settlement hierarchy presented?

No.

We have reviewed the Council’s Settlement Role and Hierarchy Study (SRH) (2020) (undertaken by Troy
Planning for both Southend-on-Sea and Rochford) and the supporting Topic Paper 4: ‘Complete Communities’
(produced by Rochford District Council and focussing solely on Rochford District) to inform this view.
We do not wholly oppose the Council’s decision to consider the ‘completeness’ of settlements as a means of
both formulating the position of settlements within the hierarchy, as well as the likely level of development
required within these settlements to instigate their completeness. The latter is particularly beneficial with
regards to promoting sustainable development in rural areas, as required by Paragraph 79 of the NPPF.
We also welcome the elements of the conclusions with regard to ‘capacity for growth’ (see Paragraph 11.17 –
Paragraph 11.36 of the SRH) which aptly reflects that ‘significant growth’ would be suitable in Rayleigh,
Rochford (with Ashingdon) and Hockley (with Hawkwell); ‘some growth’ at Great Wakering and Hullbridge; and
‘sustained limited growth’ at Rawreth, Great Stambridge, Stonebridge, Paglesham, South Fambridge and
Canewdon – with the latter comparatively more ‘complete’ then the others.

However, BDW consider there are elements to the approach taken to the SRH Study could be improved and
given greater weight.

Firstly, we feel it is the presence of day-to-day facilities that is the most important consideration on the
sustainability / completeness of a settlement. Based on Table 2 of the Topic Paper (pg. 10), the settlements
can be ranked accordingly:

Settlement - Rayleigh
Total Facilities - 17
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 3/5
Sport & Leisure - 2/2

Settlement - Rochford (including Ashingdon)
Total Facilities - 17
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 3/5
Sport & Leisure - 2/2

Settlement - Hockley (including Hawkwell)
Total Facilities - 16
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 2/5
Sport & Leisure - 2/2

Settlement - Wakerings and Barling
Total Facilities - 12
Green Infrastructure - 2/4
Education - 2/3
Civic - 3/5
Health - 2/3
Town Centre Uses - 1/5
Sport & Leisure - 2/2

Settlement - Hullbridge
Total Facilities - 12
Green Infrastructure - 2/4
Education - 1/3
Civic - 4/5
Health - 2/3
Town Centre Uses - 1/5
Sport & Leisure - 2/2

Settlement - Canewdon
Total Facilities - 7
Green Infrastructure - 2/4
Education - 1/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 1/5
Sport & Leisure - 1/2

Settlement - Rawreth
Total Facilities - 6
Green Infrastructure - 1/4
Education - 1/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 2/2

Settlement - Paglesham
Total Facilities - 3
Green Infrastructure - 1/4
Education - 0/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - Great Stambridge
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - South Fambridge
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - Stonebridge (including Sutton)
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

The table above shows a clear hierarchy across the settlements. Rayleigh, Rochford (including Ashingdon)
and Hockley (including Hawkwell) are all equally as sustainable and have high / the highest levels of
completeness. Thereafter, the Wakerings and Barling, and Hullbridge, are the next most “complete”
settlements – with moderate levels of completeness. The rural settlements are comparably lower, with the
exception of Canewdon and Rawreth which are relatively more complete.

Whilst it is recognised that walking and active travel should be promoted, the SRH’s approach of using the %
of each space within a defined walking catchment of the services within the settlement fails to account for three
key points:

The areas of settlements with the highest completeness scores across the Districts are the central areas
of Rayleigh, Hockley (including Hawkwell), and Rochford (including Ashingdon). However, as the Council’s evidence base shows, the ability to locate new housing in these central areas is restricted by both capacity and its requirement to deliver dwellinghouses (rather than flats) – notwithstanding the aims to seek to support development in rural areas. Accordingly, this would require locating development in areas where walking completeness is not as high in peripheral areas, which as the data demonstrates, is equally issue across all settlements.

Secondly, and related to the above, the aggregated scores mask the most suitable sites within individual
settlements. For example, in Wakerings and Barling, the inclusion of the peripheral areas of the cluster
contribute predominantly to the settlement’s poorer walkability. BDW’s site at Land east of Star Lane and
north of Poynters Lane, Great Wakering is well related to the centre of Great Wakering – and would have a far greater walkability score than more peripheral edges.

Finally, and related to the above, the completeness of settlements can only be improved where sufficient
development is provided to add additional infrastructure. For example, BDW’s site in Great Wakering would allow sufficient justification for the expansion of the adjacent school – with land reserved for this purpose.

In regard of the SRH’s assessment of public transport services, it has only looked at the quantitative aspects
via the frequency of services. Paragraph 105 recognises that maximising sustainable transport solutions will
vary between urban and rural areas. Indeed, predominantly, this will be recognised as the frequency of
services – and therefore the qualitative aspect of these services is equally, if not, more important. In the case
of Great Wakering, 91% of the settlement has access to a non-frequent bus service. However, a number of
the available services (e.g. 8, 14) allow access to Southend – which the SRH recognises as the Tier 1
Settlement for both areas combined. With the exception of the most complete settlements in Rochford, Great
Wakering is a sustainably located settlement with (relatively) good transport access to Southend.

In light of our thoughts above, we consider the Council should retain its existing hierarchy – as set out at
paragraph 4.9 of the Core Strategy:

Tier 1: Rayleigh; Rochford (and Ashingdon); Hockley (and Hawkwell)
Tier 2: Hullbridge and Great Wakering
Tier 3: Canewdon
Tier 4: All other settlements

In accordance with the ‘capacity for growth’ conclusions, Tier 1 should seek to receive ‘significant growth’, Tier
2 ‘some growth’, and Tier 3 and 4 ‘sustained limited growth’ – although with recognition that Canewdon is far
more sustainable than other rural settlements. The Council should seek to distribute growth accordingly,
informed by the relative constraints of each site.

As an additional observation, the Council will have to consider how any extension North / North East of
Southend would be considered within the settlement hierarchy if this option is to be carried forward.

Q6: Which of the identified strategy options do you consider should be taken forward in the Plan?
We support Spatial Option 2B primarily, but also Option 4.

We have reviewed the supporting Topic Paper 11: ‘Strategy Options’ (produced by Rochford District Council) to inform this view.

As recognised by the Council, Option 1 would fail to deliver its development needs. The HELAA (June 2020
Update) and Urban Capacity Study (2020) have concluded that insufficient space exists within the existing urban areas and on previously developed sites to meet the Council’s identified need. Paragraph 61 of the
NPPF is clear that local housing need defined by the standard method determines “the minimum number of
homes needed […] unless exceptional circumstances justify an alternative approach”. In the absence of
exceptional circumstances required to justify an alternative approach, Option 1 cannot be reasonably
progressed by the Council.

Accordingly, the Council will be required to release Green Belt Land.

Option 2a would fail to promote sustainable development in rural areas, in order to enhance or maintain their
vitality – as required by paragraph 78 of the NPPF. As our answers to this consultation have demonstrated,
there are capable sites – such as Land east of Star Lane and north of Poynters Lane, Great Wakering – which
have the potential to deliver such growth, as well as to fund the additional infrastructure these communities
need.

Whilst Option 3a, 3b and 3c could instigate the delivery of large numbers of dwellings (notwithstanding the
potential to deliver development that meets cross-boundary issues – see below) the Council should have due regard to the fact that large strategic sites often have longer build-out times, and the requirement of Paragraph
69 to identify at least 10% of housing requirement on small- and medium-sites. Furthermore, as noted above,
there are clear opportunities for this delivery to be directed to existing settlements.

In light of the above, we consider Option 2B would provide a more dispersed growth strategy that provides
opportunities to balance housing trajectory across the District – on both small and large sites, brownfield and
greenfield sites, and across different settlements.

We loosely also support Option 4, which recognises that a combination of all listed strategies to deliver the
broad range of requirements of national policy and the development Rochford needs. Option 4 will be heavily
influenced by any decision of the Council to deliver housing in excess of its minimum. The evidence currently
demonstrates that Southend will require cross-boundary delivery due to insufficient land, and Rochford should
continue to work constructively with Southend (and other surrounding authorities) to ensure that housing
delivery is satisfied across the South Essex Housing Market Area.

Q7: Are there are any reasonable alternatives to these options that should be considered further?
See our response to Q6.

Spatial Themes

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

No.

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.

Paragraph 162 of the NPPF confirms the aim of the sequential test is to steer new development to areas with
the lowest risk of flooding from any source, and that development should not be allocated or permitted if there
are reasonable available sites appropriate for the proposed development in areas at lowest risk of flooding.

The evidence provided by the South Essex Level 1 Strategic Flood Risk Assessment (April 2018) confirms
Land east of Star Lane and north of Poynters Lane, Great Wakering is predominantly located in Flood Zone 1
(including accounting for climate change). As illustrated on the Framework Plan, it is possible for development
to be concentrated in these areas, with those small areas of Flood Zones 2/3 being kept free from development.

In accordance with Paragraph 162, this site should be a preferred option for allocation.

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?


BDW would expect these designations to be afforded the necessary weight in the emerging Local Plan and/or
at the planning application stage. Subject to the Council selecting either Option 2b or 4 as set out in the response to Q.6 above, BDW also suggests that sites which are unconstrained from such designations should be the focus of allocations in the emerging Local Plan.

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?

Whilst BDW support the principle of requiring a percentage of energy in developments to be from low-carbon and renewable sources, this should be subject to consideration of viability.

BDW is committed to being a sustainable housebuilder and continue to integrate sustainability into their
business practices, helping to create better homes and communities and a stronger business for the longer term. BDW has a proven track record as a sustainable housebuilder, including achieving a 22% reduction in
carbon emissions since 2015 and aims to be the country’s leading sustainable national housebuilder by
achieving net zero greenhouse gas emissions by 2040 (the first major housebuilder to do so); in addition to 100% of their own electricity to be renewable by 2025; and new homes design to be net zero carbon from
2030.

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?

Whilst BDW support the principle of requiring energy efficiency standards of developments to be higher than
the building regulations, this should not be a requirement for all developments. The ability to achieve this will be subject to the viability of a scheme.

Therefore, to be acceptable in planning terms, developments should meet the energy efficiency standard set out by building regulations. If a scheme were to exceed building regulations, this should be recognised as a bespoke merit / positive of the scheme that should weigh favourably in the planning balance.

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?

BDW support the inclusion of a place-making charter and the listed standards, in principle.

Whilst broad objectives (e.g. aiming for carbon-neutrality; tackling air quality; promoting active travel) may help
achieve a collective Vision for the area, sufficient account and flexibility must be given for settlement / site-specific circumstances.

Please see our response to Q16 and Q59.

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

Please see our response to Q14.

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

Yes.

Following the recent update to the NPPF, paragraph 128 now requires all local planning authorities to prepare
design guides or codes consistent with the principles set out in the National Design Guide and National Model
Design Code.

Please see our detailed response to Q16b. and Q16c.

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?

BDW oppose the imposition of a single, broad design guide/code for the District. As the Council recognise,
this would fail to account for and preserve the mix of historic, natural, and urban environments that help to
create distinctive local vernacular and character. Conversely, BDW would also oppose the production of
specific, prescriptive design codes on a site-by-site basis which would not provide sufficient flexibility, restrict
the use of innovative methods and technologies, and frustrate artistic interpretation – all of which may impact
a development’s viability and contribution to “beauty”.

BDW support the imposition of broad strategic objectives (as set out in the place-making charter, as well as the National Design Guide and National Model Design Code) with sufficient flexibility for design to be responsive to circumstances of a site as they evolve. This might include more specific, but still broad objectives are settlement/area level.

Indeed, paragraph 129 of the NPPF advises that developers may also choose to prepare design codes in
support of planning application for sites they wish to develop. This option would give the freedom to provide
interpretation and sufficient resourcing from the private sector to develop appropriate design codes, in
accordance with the National Design Guide and National Model Design Code.

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

Please see also our response to Q16b.

BDW would expect the Council’s adopted design guides/codes to implement broad objectives (at District and Area level) that reflect the 10 characteristics of well-designed places, as set out in the National Model Design
Code. More site-specific design would be influenced by developer produced design codes at submission stage,
reflecting the broad aims.

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?

BDW support Option 4. This would involve taking a market-led approach to housing mix and not specifying
the types, tenures and sizes of houses that need to be delivered through a specific policy.

Option 4 would provide the flexibility required to address site-specific circumstances and respond to the types
of housing required as set out in the most up-to-date housing market assessments. This is the current approach to defining dwelling types, as set out in Policy H5 (Dwelling Types) of the adopted Core Strategy. Option 1 and 3 are too prescriptive and could lead to sites being unviable and not reflecting the needs of the local area. This in turn could delay allocated sites coming forward, leaving the Council facing problems with housing delivery.

If Option 4 was not preferred by the Council, and sufficient evidence was provided to justify such an Option, Option 2 would provide a suitable alternative, as it would factor in a level of negotiation on suitable housing mix (subject to market conditions and viability) – whilst seeking to take account of, and be responsive to, the type or location of development.

BDW support Option 5 in principle, requiring all new homes to meet the Nationally Described Space Standard
(NDSS). As recognised by the Council, the NDSS is currently an optional technical standard, and the Council
would be required to provide sufficient justification for implementing the standard – taking account of need and
viability.

With regard to Option 6 and 7, the requirement for new homes to meet Part M4(2) and Part M4(3) of the
Building Regulations is also an optional technical standard. PPG Paragraph 007 (Reference ID: 56-007-
20150327) confirms that, based on a housing needs assessment, it is for the local planning authority to set out
how it intends to approach demonstrating a need for this requirement, taking account of such information as
the likely future need for housing for older and disabled people (including wheelchair user dwellings), the
accessibility and adaptability of existing housing stock, and the overall impact on viability. In respect of Part
M4(3), Paragraph 009 (Reference ID: 56-009-20150327) is clear that where local plan policies requiring
wheelchair accessible homes are implemented, these should be applied only to dwellings where the local
planning authority is responsible for allocating or nominating a person to live within that dwelling. BDW would expect the appropriate evidence to be provided (within the updated SHMA or a Local Housing Needs
Assessment) to justify the inclusion of these bespoke policies.

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?

As set out in Figure 28 of the consultation document (taken from the South Essex SHMA) the overwhelming
need for dwellings in Rochford District are houses (85%), rather than flatted development (15%). BDW observe
the allocation of smaller, urban/previously developed sites will not satisfy the prevailing demand for
dwellinghouses, which typically require a greater extent of land.

In addition, whilst a strategy that focused development within and adjoining the main built-up areas with an
emphasis on the re-use of previously developed land would promote urban regeneration, it must be
emphasised that this strategy could result in the under delivery of affordable housing owing to viability issues.

It is well documented that the provision of affordable housing on brownfield land / urban sites is challenging
due to the expense associated with acquisition costs, remediation and/or higher than normal construction
costs. Given that market housing is required to subsidise the construction of the affordable housing, the
inevitable consequence is that Council’s targets for the delivery of affordable housing are seldom met when
such a growth strategy is adopted. This, in part, forms our reasoning for a more dispersed, mixed strategy
which includes the release of both underperforming areas of Green Belt which would allow the expansion of
existing towns and villages. Paragraph 73 of the NPPF states “the supply of large numbers of new homes can
often be best achieved through planning for larger scale development, such as new settlements or significant
extensions to existing villages and towns” should be supported.

Such a strategy will also ensure the required level of affordable housing is delivered as schemes on greenfield
sites can viably support delivery of affordable housing compared to brownfield land for the reasons referred to
above.

Utilising this strategy will also disperse the effects of development, rather than focus this predominantly on a
single area – which could ultimately lead to negative impacts such as traffic congestion, noise and air pollution
and stretched community resources/infrastructure – for example. Dispersal will allow a greater range of
housing choice and provide the right type of homes in the right areas to meet the needs of all communities – one of the key parts of the Council’s vision.

A more dispersed growth strategy also provides opportunities to balance housing trajectory across the District and the wider South Essex HMA – as greenfield sites typically have quicker lead-in times / build out rates
compared to those often associated with complex brownfield sites.

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?
No.

Biodiversity

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?

Whilst the Environmental Bill is still to receive Royal Assent, the intention of the policy to achieve biodiversity
net gains is clear and supported in principle by BDW.

This does not mean the Council should not seek to encourage developments to secure biodiversity net gain in
excess of the 10% set in the draft Environmental Bill – which of course will be a legal minimum. However, any
requirement to demonstrate a net gain in excess of 10% should be subject to a viability assessment and should
not be considered a requirement to make the development acceptable in planning terms (i.e. any provision in excess of the 10% figure should be considered an additional benefit of a proposed scheme).

PPG Paragraph 022 (Reference ID: 8-022-20190721) advises that biodiversity net gain can be achieved on-site, off-site or through a combination of both on-site and off-site measures. National guidance does not
explicitly state the percentage split between such provision, but Paragraph 023 (Reference ID: 8-023-
20190721) confirms such gain can be delivered entirely on-site or by using off-site gains where necessary.

Therefore, BDW would expect the Council to reflect the ambitions of the Environmental Bill and incorporate
the necessary level of flexibility in any allocation requirement and/or policy, providing opportunities to create networks to not just support biodiversity enhancement on-site, but also to encourage residents to have access to the natural environment on other sites (off-site) across the District. This would ensure improvements are both beneficial and viable.

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?

BDW support a combination of all Options identified by the Council in addressing the need for sufficient and
accessible community infrastructure through the plan.

Whilst the Council should seek to invest and protect existing community infrastructure, it should seek to first
locate development in areas with adequate proximity to existing infrastructure before seeking to promote sites
that are capable of facilitating the delivery of much needed community infrastructure in other areas. The latter
is evidence in the Land east of Star Lane and north of Poynters Lane, Great Wakering – which has reserved
land in order to deliver a new school in Great Wakering on the current Great Wakering Primary Academy site.

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

Yes.

The Council recognise a widespread lack of access to community facilities across the District. Where greater
access is more recognised in the major settlements, a concentration of development may put stress on these
existing facilities – whilst not delivering in more rural settlements.

Therefore, the implementation of Option 2b and/or Option 4 – both of which would permit urban extensions
across the settlement hierarchy – would permit the wider delivery of existing facilities whilst not creating
pressure spots.

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?

Yes – see our response to Q.36.

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?

BDW support Option 4.

Larger and strategic developments are capable of delivering areas for open space and recreation as part of a holistic development of a site. As evidenced in the Framework Plan, BDW consider a variety of public open
spaces, including strategic, local equipped areas of play (LEAPs) and a Multi-Use Games Areas (MUGAs) can
be incorporated into the proposals.

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

As set out in our response to Q38, BDW considers the Council should consider the potential for larger and
strategic-level development sites to deliver areas for open space and recreation as part of a holistic
development of a site.

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?

Yes.

Larger and strategic development sites are capable of delivering areas for open space and recreation as part
of a holistic development of a site.

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

No.

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?
BDW support a combination of all Options identified by the Council in addressing the need for sufficient and
accessible community infrastructure through the plan.

As set out in our response to Q5 and Q6, the Council should seek to incorporate a dispersed growth strategy.
A more dispersed growth strategy will provide a balance between utilising and optimising existing connections
in the more sustainable settlements, whilst providing improvements to less sustainable locations. A more
dispersed growth strategy will also work to avoid overuse and unnecessary congestion on more densely
populated areas, which bring with them problems of air quality and noise pollution.

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

Please also see our response to Q51.

As part of a more dispersed Growth Strategy, the Council should seek to ease congestion by locating
development in locations which can benefit from wider improvements – such as, as the Council recognise, bus
services to Great Wakering. This should be combined and recognised with the delivery of such infrastructure
through contribution and/or bespoke delivery in larger allocations.

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.]

Please see our response to Q52 / Q53.

Planning for Complete Communities

Wakerings and Barling

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

As per our response to Q4, through the lack of current alternative evidence, we consider the Wakerings and
Barling (in particular, Great Wakering) should remain a Tier 2 settlement.

BDW consider the restriction of Great Wakering to “development that […] is locally-responsive and aimed at
meeting the ongoing housing and employment needs of local residents” fails to account for the opportunity
provided by this comparatively sustainable settlement to provide a substantial contribution to the District’s
housing need with the proposed allocation at Land east of Star Lane and north of Poynters Lane, Great
Wakering.

The consultation document considers that the majority of Great Wakering has “reasonable walking access to
day-to-day services”, with BDW’s promoted site within the higher end of the walking completeness score (8-
10). In line with our Preferred Growth Strategy (Option 2b or 4), we consider this site has the potential to provide substantial growth at this settlement required to facilitate investment in infrastructure across the plan area, including the delivery of the school allocation and other infrastructure improvements – a key objective of the plan.

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

1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other

BDW consider Land east of Star Lane and north of Poynters Lane, Great Wakering (HELAA Refs: CS057 and CS070) as suitable, available, and deliverable sites for approximately 800 dwellings.

Next Steps

We trust the above is clear and look forward to being notified as to the next steps with the emerging Local
Plan, and if you can please confirm receipt, it would be much appreciated.

Yours faithfully
David Churchill
Partner

1.0 Introduction

1.1 These representations are submitted to the Rochford New Local Plan Spatial Options (RLPSO) on behalf of Mr P Noonan and in relation to to Land West of Ash Green,
Ashingdon (‘the Site’).
1.2 The Site has previously been submitted in response to the Council’s the Call for Sites, and is reference CFS094 in the Council’s plan-making process.
1.3 Representations were submitted to the New Local Plan Issues and Options consultation in 2018 to further promote the allocation of the Site to help meet development needs through a sustainable, and proportionate, extension to Canewdon that would help
support the vitality of the village.

2.0 Response to Local Plan Spatial Options Consultation Questions
Q4. Do you agree with the strategic priorities and objectives we have identifies? Is there anything missing from the strategic priorities or objectives that you feel
needs to be included?

2.1 We consider that Strategic Objective 1 could be clearer that the provision of homes to meet local needs entails providing housing close to existing communities. As currently drafted, it could be inferred that the priority is working with neighbouring authorities, rather than trying to meet local housing needs and support existing communities within the District boundary as a priority.
2.2 Providing homes adjacent to existing built up areas allows local residents to remain within their local community and close to family, friends, and other informal social networks that form an important part of everyday life. It would provide greater choice for
existing residents, and reduce the risk that existing members of the community may have to move elsewhere due to a lack of suitable housing.
2.3 We suggest that Strategic Objective 1 should be amended to:
To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs, through providing homes close to existing communities, utilising previously developed land and working with neighbouring authorities if required.
2.4 In addition, we suggest that objectives of the Local Plan should include to improve the affordability of housing for people of Rochford District.
2.5 The RLPSO notes (page 12) that:
“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times to average
annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”
2.6 The most recent data available1 reports that the median house price in the District is 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’).
2.7 The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average.
2.8 In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.
2.9 Additionally, and whilst empirical data is currently limited, the longer term impact on housing demand resulting from the Covid-19 pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Early indications
are that there has already been an increased desire to move from more to less urban areas, driven by what has been dubbed the ‘race for space’ – the desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.
2.10 At the same time, the situation has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely anticipated that there will be a degree of return to office-working, it is expected that the need for employees to be physically present within a particular office will be substantially reduced.
2.11 As a consequence, it is anticipated that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London. As a consequence, the area could prove an increasingly population destination for those migrating out of higher density areas in and around London. This in turn is likely to put considerable pressure on the housing market. If insufficient homes are provided, it is also likely to result in a significant worsening of affordability.
2.12 We support Strategic Objective 3:
“To facilitate accelerated growth in our local economy through supporting the delivery of suitably located land which meets businesses needs at each stage of their lifecycle (including delivering grow-on space to enable local businesses to flourish), the continued functioning of London Southend Airport as a thriving regional airport,
serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park”
2.13 We suggest that, in addition, this objective should recognise that the critical role housebuilding plays in supporting the local economy, and the economic benefits house builder would have for the District.
2.14 As the Local Plan Spatial Options recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.
2.15 Employment relating directly to the construction of the development will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.
2.16 Development of additional homes in the District will also engender sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of new homes on first occupation, on home set up cost, and on an ongoing basis in local shops and services in the area.
2.17 Conversely, failure to deliver sufficient homes for the District would not only result in a failure to support the local construction industry and failure to realise the potential opportunities outline above, it would also likely significantly deter inward investment by potential employers, if insufficient, affordable accommodation was not available locally to provide a local workforce.

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

2.18 It will be important that, for whichever spatial strategy is ultimately chose, the Local Plan directs a proportion of growth to the District’s smaller settlements.
2.19 Equally, it will be important that sites allocated for development include those which are able to deliver relatively early in the plan period, and without significant infrastructure improvements being required beforehand, in order to meet current housing needs.
2.20 The NPPF calls planning to enable smaller settlements to grow and thrive, and for growth to be located in rural areas where it will enhance or maintain the vitality of rural communities.
2.21 Canewdon is an established rural community, with its own identity dating back hundreds of years.
2.22 As the RLPSO notes, the village benefits from a good range of service for a settlement of its size. Its local services and facilities include a primary school, church, convenience store, village hall, parks, and allotments.
2.23 Canewdon is an active community, home to a number of clubs and societies including Community Association, church, Scouts, cricket club, baby and toddler group, and horticultural society.
2.24 It is imperative that the village community is supported by the Local Plan, and services and facilities are sustained and enhanced. In order to achieve this, we consider it is critical that proportionate growth is directed to Canewdon.
2.25 We suggest that the western side of Canewdon should be considered the preferred location for additional growth in Canewdon. There are opportunities to provide growth on this side of the village from which Canewdon’s service and facilities are very much within walking distance. As the same time, it is recognised that not all of residents’ needs can be met within the village itself, and that vehicular movements to / from the village are likely to be generated as a result of any additional development. Development on the western side of Canewdon has the advantage in relation to this issue of not causing additional traffic to be generated within the village itself, and instead there are opportunities for future residents of development on this side of the village to access
Rochford and other centres beyond without having to drive through the centre of Canewdon.

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?

2.26 As noted in our response to Q6, it is critical that the Local Plan seeks to direct sufficient growth to the District’s various settlements such that inter alia local services and facilities can be sustained.

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

2.27 The Site (CFS094) is considered suitable, available and achievable to provide a modest, proportionate number of additional homes for Canewdon, helping to support the vitality of the village community and forming part of a sustainable strategy for the development
of the District.
2.28 It is important that the New Local Plan enables the sustainable growth of the village of Canewdon.
2.29 Canewdon is an established rural community, with a population of 1,473 (Census 2011). It contains a number of facilities and services, incliuding primary school, community facilities, church, a village shop, public house and recreational ground.
2.30 Canewdon is identified as a tier 3 settlement in the current Development Plan, and the Rochford Core Strategy (2011) directed a modest level of growth to the village, reflecting its character and position within the settlement hierarchy.
2.31 The approach of directing a small level of growth through the Rochford Core Strategy (2011) to Canewdon, through an extension to the west of the village envelope for 60 dwellings, was robustly examined through the plan-making process and found to be a sustainable approach.
2.32 An extension to the village to accommodate 60 dwellings was considered an appropriate approach as part of a balanced strategy to delivering housing need across the District within the context of the housing need at that time – 250 dwellings per annum. There was nothing to suggest that within the context of a greater housing need, the village could not support a proportionate increase in this number.
2.33 It is important for the vitality of the village that the Rochford Local Plan ensures Canewdon is able to grow sustainably over the plan period. Failure to direct
proportionate growth to the village could result in no additional homes being provided for the community over the entirety of the plan period (up to 2037), given that the existing Green Belt boundary is drawn tightly around the village envelope. Lack of any additional homes would result in there being a significant risk of harm to the vitality of the village, and to the sustainability of its services and facilities.
2.34 National policy is clear on the importance of promoting thriving rural communities. The NPPF states (paragraph) 79 that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services”.
2.35 In addition, the Planning Practice Guidance (PPG) notes that housing in rural settlements can be important in ensuring their sustainability, and that villages in rural areas often face issues relating to housing supply and affordability. It states:
“People living in rural areas can face particular challenges in terms of housing supply and affordability, while the location of new housing can also be important for the broader sustainability of rural communities”.
2.36 As such, not only would it be entirely appropriate for the Rochford Local Plan to direct a proportionate level of growth to Canewdon, but it is difficult to see how sustainable development could be achieved for the District – and for the Canewdon in particular – without ensuring some homes will be provded in the village over the course of the plan period.
2.37 In respect of site CFS094 itself, it is is located immediately to the north of land allocated for development in the Rochford Allocations Plan (2014) (Site SER7); and is commensurate with the general location 'South Canewdon' identified for development of
60 dwellings in the Rochford Core Strategy (2011).
2.38 Whilst the Core Strategy (2011) identified the general location South Canewdon for 60 dwellings, the Allocations Plan sought to restrict Site SER7 to a maximum of 49 dwellings. Two subsequent planning applications have been granted, which together deliver a total of 49 dwellings in this location. Allocation of CFS094, and its subsequent development for c. 8 dwellings, together with the delivery of 49 dwellings at SER7, would result in a total of c.57 dwellings within this general location - a situation that would conform with the Council's strategy for delivery of housing as set out in the Rochford Core Strategy; and one which has already been tested and found to be sustainable.
2.39 The Site would evidently enable the provision of an appropriately modest number of new homes for the village, reflecting its characteristics.
2.40 Separately, it is relevant to note that the main centres in proximity to Canewdon are located to the south and west of the village. As such, development on this side of the village would minimise the amount of traffic having to travel through the village’s highway
network to reach nearby destinations, with resultant benefits in terms of limiting congestion on the village highways, potential issues in respect of air quality, etc.
2.41 It is pertinent to note the reason why the Rochford Core Strategy identified the general location in which CFS094 sites as being appropriate for housing. This is summarised in the Rochford Core Strategy Sustainability Appraisal Addendum (2011), which states:
“Canewdon is recognised as a distinct settlement with its own community and therefore housing needs, and development at this settlement corresponds towards
the balanced approach to housing distribution supported by sustainability appraisal. The location is not subject to significant environmental or physical constraints. In addition, the proposed location sets to provide good accessibility to Rochford town centre and would minimise the impact on traffic passing through the village centre”.
2.42 It is considered that the above is still very much applicable today, and supports the allocation of CFS094 through the Local Plan.
2.43 The allocation of SER7 to the south of CFS094 thorugh the Rochford Allocations Plan (2014) has, it should be noted, left the Site as a small parcel of Green Belt land sandwiched between residential areas to the south and east; churchyard to the north; and road to the west. The access road to the west, running north-south adjacent to SER7 and this site, represents a robust and logical new Green Belt boundary, and would address the present somewhat anomalous position in respect of the present position of the boundary.
2.44 The Site is located within the Canewdon Church Conservation Area, on the southern boundary of this area.
2.45 The Conservation Area designation does not preclude the site from having the potential to accommodate residential development - any development would have to be designed to respect the character and appearance of the Conservation Area.
2.46 The Council has assessed CFS094 through the Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017)
2.47 This c that the Site is not subject to any constraints that would prohibit its development.
2.48 The SHELAA (2017) identifies that the Site has good access to the educational facilities.
It also notes that the Site’s proximity to open spaces / leisure facilities; public transport; and existing residential areas is good. It rates the proximity to healthcare facilities as ‘medium’. Only one local service’s proximity to the site is rates as poor – retail facilities. Whilst it is acknowledged that the Site is not located in close proximity to retail centre, this is of course a function of it being a proposed extension to a village which is not a
retail centre. However, it should be noted that the Site is located in proximity to the village shop. Not only would this be a benefit for future residents living at the Site, but its allocation and development could also help support the village shop, helping to sustain a local service for the community.
2.49 The SHELAA (2017) concludes that the Site’s suitability for development will be dependent on a Green Belt assessment.
2.50 Subsequently, the Council has published the Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’).
2.51 The Green Belt Study (2020) suggests that development of the Site would only result in ‘low-moderate’ harm to the Green Belt.
2.52 It states:
“The assessment area makes a strong contribution to preventing encroachment on the countryside. The area is open and undeveloped, however, it is contained by inset
development to the east and south and by a washed over church yard to the north. Release of the assessment area therefore would form a stronger Green Belt boundary along the road the west, limiting harm to the land to the west of the road. Although the release of this site would increase the containment of the land to the north of the site, it is not considered to adversely affect the openness of the Green Belt to the north as the land is already partially developed and largely used as a church yard”.
2.53 As a site, the development of which has been assessed as resulting in a low-moderate harm to the Green Belt, the Green Belt Study (2020) suggests CFS094 is one of the most suitable sites for allocation from a Green Belt perspective. The Green Belt Study
(2020) notes that only 0.4% of Green Belt assessed was identified as being less harmful to the purposes of the Green belt than the Site.
2.54 As such, and in particular when one has regard to the SHELAA (2017) and Green Bely Study (2020) is it considered that the Council’s evidence supports the allocation of CFS094.

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.

ROCHFORD DISTRICT COUNCIL SPATIAL OPTIONS CONSULTATION (REGULATION 18) - BARRATT DAVID WILSON HOMES RESPONSE: LAND EAST OF STAR LANE AND NORTH OF POYNTERS LANE, GREAT WAKERING

On behalf of our client, Barratt David Wilson Homes (‘BDW’), please find enclosed representations to the
Spatial Options consultation currently being undertaken by Rochford District Council (‘the Council’).
Background
BDW
BDW is the nation’s leading housebuilder, creating great new places to live throughout Britain. In 2019/20,
BDW delivered over 12,600 new homes.
BDW are experts in land acquisition, obtaining planning consents and building the highest quality homes in
places people aspire to live. This expertise has been shared with the Council in recent times through the
delivery of other schemes in the District – including the High Elms Park development in Hullbridge.
BDW is committed to being a sustainable housebuilder and continue to integrate sustainability into their
business practices, helping to create better homes and communities and a strong business for the longer term.

Land South of Hall Road, Rochford
BDW is currently promoting Land South of Hall Road, Rochford (HELAA Ref: CFS084) as an allocation for
housing in the emerging Local Plan for approximately 250 homes. These representations are supported by a
Vision Document which is appended to this letter, alongside a site location plan.
BDW would like to make the following observations on the content of the Spatial Options consultation.

Vision, Priorities and Objectives
Q2: Do you agree with our draft vision for Rochford District?

Whilst BDW agree with the draft vision for Rochford District in principle, we would like to make the following
observations.

As currently drafted, no reflection of the purpose, aims and objectives of the emerging South Essex Joint
Spatial Plan (JSP) is made. The Statement of Common Ground (SoCG) (2018) between the six constitutive
Council’s (plus Essex County Council) involves a commitment to work together on strategic planning matters,
including meeting the housing needs of entire sub-region in full (our emphasis) (see Chapter 9). The relationship between Rochford and Southend-on-Sea is imperative to achieving this, as recognised by the current in-tandem production of new Local Plans in these areas – including the production of a joint evidence base (e.g. Green Belt, HELAA). The evidence base (see HELAA June 2020) is clear that Southend will be unable to meet its objectively assessed housing need on deliverable sites within its administrative boundaries in both policy-on and policy-off scenarios (a shortfall of 6,671 dwellings from 2020-2040), whilst Rochford (in a policy-off scenario) contains deliverable sites to provide a surplus of 35,935 dwellings from 2020-2040 – including Land South of Hall Road, Rochford. Given the relationship between the two administrative areas, it is imperative that the Council works constructively with Southend (and other Council’s within the South Essex JSP) to meet the commitment of the JSP to deliver South Essex’s housing need in full. It is important that the commitment to working with the JSP Councils to meet the needs of the area in full is recognised in the development of a vision that looks further ahead than just the Plan period (i.e. to at least 30 years) to ensure future generations have clarity on the growth of the District in the context of the JSP area.

With regards to ‘Our Society’, the Council’s supporting text should be evolved to recognise that although
focussing on previously developed land may be the priority, the evidence base demonstrates there is
insufficient land within these categories to deliver its objectively assessed needs. The HELAA (June 2020
Update) demonstrates a total of 4,320 dwellings can be provided (including a 39dpa windfall) on previously
developed / currently approved sites – a shortfall of 2,880 dwellings. The Urban Capacity Study indicates that
this, at a maximum, can be increased to 5,000 dwellings, still leaving the Council with a shortfall. The Vision
needs to evolve to cover a longer period (as per Paragraph 22 of the NPPF) and recognise that growth on
greenfield sites (including Green Belt) must now take place under an appropriate strategy – which should allow
for a mix of sites and a range of homes to be delivered which can help combat affordability issues and support
Growth across the plan period (see our answer to Q6).

With regards to ‘Our Environment’, the Council’s pledge to retain an extensive Metropolitan Green Belt
designation is noted, but in light of the evidence regarding objectively assessed development needs it is
important that this is clearly defined to allow for future growth to be accommodated within the Green Belt
following Plan reviews.

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

BDW agree with this approach, in principle, insofar as it allows for both the correct quantum and type of
development to be delivered within each settlement to meet the Council’s identified needs.
Please see also our response to Q5, Q6, Q7 and Q56.

Q4: Do you agree with the strategic priorities and objectives we have identified?
BDW broadly agree to the strategic priorities and objectives identified in principle.
However, as set out in our response to Q1, BDW consider the Council should amend Strategic Priority 1,
Objective 1 to reflect the need to deliver its objectively assessed needs – as a minimum – including
consideration of the contribution that could be made to solving housing numbers across the South Essex JSP
area.

Strategy Options

Q5: Do you agree with the settlement hierarchy presented?
No.

We have reviewed the Council’s Settlement Role and Hierarchy Study (SRH) (2020) (undertaken by Troy
Planning for both Southend-on-Sea and Rochford) and the supporting Topic Paper 4: ‘Complete Communities’
(produced by Rochford District Council and focussing solely on Rochford District) to inform this view.
We do not wholly oppose the Council’s decision to consider the ‘completeness’ of settlements as a means of
both formulating the position of settlements within the hierarchy, as well as the likely level of development
required within these settlements to instigate their completeness. The latter is particularly beneficial with
regards to promoting sustainable development in rural areas, as required by Paragraph 79 of the NPPF.
We also welcome the elements of the conclusions with regard to ‘capacity for growth’ (see Paragraph 11.17 –
Paragraph 11.36 of the SRH) which aptly reflects that ‘significant growth’ would be suitable in Rayleigh,
Rochford (with Ashingdon) and Hockley (with Hawkwell); ‘some growth’ at Great Wakering and Hullbridge; and
‘sustained limited growth’ at Rawreth, Great Stambridge, Stonebridge, Paglesham, South Fambridge and
Canewdon – with the latter comparatively more ‘complete’ then the others.
However, BDW consider there are elements to the approach taken to the SRH Study could be improved and
given greater weight.
Firstly, we feel it is the presence of day-to-day facilities that is the most important consideration on the
sustainability / completeness of a settlement. Based on Table 2 of the Topic Paper (pg. 10), the settlements can be ranked accordingly:

Settlement - Rayleigh
Total Facilities - 17
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 3/5
Sport & Leisure - 2/2

Settlement - Rochford (including Ashingdon)
Total Facilities - 17
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 3/5
Sport & Leisure - 2/2

Settlement - Hockley (including Hawkwell)
Total Facilities - 16
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 2/5
Sport & Leisure - 2/2

Settlement - Wakerings and Barling
Total Facilities - 12
Green Infrastructure - 2/4
Education - 2/3
Civic - 3/5
Health - 2/3
Town Centre Uses - 1/5
Sport & Leisure - 2/2

Settlement - Hullbridge
Total Facilities - 12
Green Infrastructure - 2/4
Education - 1/3
Civic - 4/5
Health - 2/3
Town Centre Uses - 1/5
Sport & Leisure - 2/2

Settlement - Canewdon
Total Facilities - 7
Green Infrastructure - 2/4
Education - 1/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 1/5
Sport & Leisure - 1/2

Settlement - Rawreth
Total Facilities - 6
Green Infrastructure - 1/4
Education - 1/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 2/2

Settlement - Paglesham
Total Facilities - 3
Green Infrastructure - 1/4
Education - 0/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - Great Stambridge
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - South Fambridge
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - Stonebridge (including Sutton)
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

The table above shows a clear hierarchy across the settlements. Rayleigh, Rochford (including Ashingdon)
and Hockley (including Hawkwell) are all equally as sustainable and have high / the highest levels of
completeness. Thereafter, the Wakerings and Barling, and Hullbridge, are the next most “complete”
settlements – with moderate levels of completeness. The rural settlements are comparably lower, with the exception of Canewdon and Rawreth which are relatively more complete.
Whilst, it is recognised that walking and active travel should be promoted, the SRH’s approach of using the %
of each space within a defined walking catchment of the services within the settlement fails to account for three
key points:

• The areas of settlements with the highest completeness scores across the Districts are the central areas of Rayleigh, Hockley (including Hawkwell), and Rochford (including Ashingdon). However, as the Council’s evidence base shows, the ability to locate new housing in these central areas is restricted by both capacity and its requirement to deliver dwellinghouses (rather than flats) – notwithstanding the aims to seek to support development in rural areas. Accordingly, this would require locating development inareas where walking completeness is not as high in peripheral areas, which as the data demonstrates, is equally issue across all settlements.
• Secondly, and related to the above, the aggregated scores mask the most suitable sites within individual
settlements. For example, in Wakerings and Barling, the inclusion of the peripheral areas of the cluster contribute predominantly to the settlement’s poorer walkability. BDW’s site at Land east of Star Lane and north of Poynters Lane, Great Wakering is well related to the centre of Great Wakering – and would have
a far greater walkability score than more peripheral edges.
• Finally, and related to the above, the completeness of settlements can only be improved where sufficient
development is provided to add additional resource. For example, BDW’s site in Great Wakering would allow sufficient justification for the expansion of the school – with land reserved for this purpose.

In regard of the SRH’s assessment of public transport services, it has only looked at the quantitative aspects
via the frequency of services. Paragraph 105 recognises that maximising sustainable transport solutions will
vary between urban and rural areas. Indeed, predominantly, this will be recognised as the frequency of
services – and therefore the qualitative aspect of these services is equally, if not, more important. In the case
of Great Wakering, 91% of the settlement has access to a non-frequent bus service. However, a number of
the available services (e.g. 8, 14) allow access to Southend – which the SRH recognises as the Tier 1
Settlement for both areas combined. With the exception of the most complete settlements in Rochford, Great
Wakering is a sustainably located settlement with (relatively) good transport access to Southend.

In light of our thoughts above, we consider the Council should retain its existing hierarchy – as set out at
paragraph 4.9 of the Core Strategy:
Tier 1: Rayleigh; Rochford (and Ashingdon); Hockley (and Hawkwell)
Tier 2: Hullbridge and Great Wakering
Tier 3: Canewdon
Tier 4: All other settlements

In accordance with the ‘capacity for growth’ conclusions, Tier 1 should seek to receive ‘significant growth’, Tier 2 ‘some growth’, and Tier 3 and 4 ‘sustained limited growth’ – although with recognition that Canewdon is far more sustainable than other rural settlements. The Council should seek to distribute growth accordingly, informed by the relative constraints of each site.
As an additional observation, the Council will have to consider how any extension North / North East of
Southend would be considered within the settlement hierarchy if this option is to be carried forward.

Q6: Which of the identified strategy options do you consider should be taken forward in the Plan?
We support Spatial Option 2B primarily, but also Option 4.
We have reviewed the supporting Topic Paper 11: ‘Strategy Options’ (produced by Rochford District Council) to inform this view.
As recognised by the Council, Option 1 would fail to deliver its development needs. The HELAA (June 2020
Update) and Urban Capacity Study (2020) have concluded that insufficient space exists within the existing urban areas and on previously developed sites to meet the Council’s identified need. Paragraph 61 of the
NPPF is clear that local housing need defined by the standard method determines “the minimum number of
homes needed […] unless exceptional circumstances justify an alternative approach”. In the absence of
exceptional circumstances required to justify an alternative approach, Option 1 cannot be reasonably
progressed by the Council.
Accordingly, the Council will be required to release Green Belt Land.
Option 2a would fail to promote sustainable development in rural areas, in order to enhance or maintain their
vitality – as required by paragraph 78 of the NPPF. As our answers to this consultation have demonstrated,
there are capable sites – such as Land east of Star Lane and north of Poynters Lane, Great Wakering – which
have the potential to deliver such growth, as well as to fund the additional infrastructure these communities
need.

Whilst Option 3a, 3b and 3c could instigate the delivery of large numbers of dwellings (notwithstanding the
potential to deliver development that meets cross-boundary issues – see below) the Council should have due regard to the fact that large strategic sites often have longer build-out times, and the requirement of Paragraph
69 to identify at least 10% of housing requirement on small- and medium-sites. Furthermore, as noted above,
there are clear opportunities for this delivery to be directed to existing settlements.
In light of the above, we consider Option 2B would provide a more dispersed growth strategy that provides
opportunities to balance housing trajectory across the District – on both small and large sites, brownfield and
greenfield sites, and across different settlements.
We loosely also support Option 4, which recognises that a combination of all listed strategies to deliver the broad range of requirements of national policy and the development Rochford needs. Option 4 will be heavily
influenced by any decision of the Council to deliver housing in excess of its minimum. The evidence currently
demonstrates that Southend will require cross-boundary delivery due to insufficient land, and Rochford should
continue to work constructively with Southend (and other surrounding authorities) to ensure that housing
delivery is satisfied across the South Essex Housing Market Area.

Q7: Are there are any reasonable alternatives to these options that should be considered further?
See our response to Q6.

Spatial Themes
Q8: Are there any key spatial themes that you feel we have missed or that require greater emphasis?
No.
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.

Paragraph 162 of the NPPF confirms the aim of the sequential test is to steer new development to areas with
the lowest risk of flooding from any source, and that development should not be allocated or permitted if there
are reasonable available sites appropriate for the proposed development in areas at lowest risk of flooding.
The evidence provided by the South Essex Level 1 Strategic Flood Risk Assessment (April 2018) confirms
Land South of Hall Road, Rochford is predominantly located in Flood Zone 1 (including accounting for climate
change). As set out in the Vision Document, it is possible for development to be concentrated in these areas, with minor parts located in Flood Zones 2/3 free from development. These areas would instead be used for
surface water attenuation and other sustainable urban drainage (SUDS) options to mitigate flood risk. There
is also the opportunity to create biodiversity enhancements in this area.
In accordance with Paragraph 162, this site should be a preferred option for allocation.

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?
BDW would expect these designations to be afforded the necessary weight in the emerging Local Plan and/or
at the planning application stage. Subject to the Council selecting either Option 2b or 4 as set out in the
response to Q.6 above, BDW also suggests that sites which are unconstrained from such designations should
be the focus of allocations in the emerging Local Plan.
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?
Whilst BDW support the principle of requiring a percentage of energy in developments to be from low-carbon and renewable sources, this should be subject to consideration of viability.

BDW is committed to being a sustainable housebuilder and continue to integrate sustainability into their
business practices, helping to create better homes and communities and a stronger business for the longer
term. BDW has a proven track record as a sustainable housebuilder, including achieving a 22% reduction in
carbon emissions since 2015 and aims to be the country’s leading sustainable national housebuilder by
achieving net zero greenhouse gas emissions by 2040 (the first major housebuilder to do so); in addition to 100% of their own electricity to be renewable by 2025; and new homes design to be net zero carbon from
2030.

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?
Whilst BDW support the principle of requiring energy efficiency standards of developments to be higher than
the building regulations, this should not be a requirement for all developments. The ability to achieve this will be subject to the viability of a scheme.
Therefore, to be acceptable in planning terms, developments should meet the energy efficiency standard set out in the building regulations. If a scheme were to exceed building regulations, this should be recognised as a bespoke merit / positive of the scheme, that should weigh favourably in the planning balance.
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?
BDW support the inclusion of a place-making charter and the listed standards, in principle.
Whilst broad objectives (e.g. aiming for carbon-neutrality; tackling air quality; promoting active travel) may help
achieve a collective Vision for the area, sufficient account and flexibility must be given for settlement / site-specific circumstances.
Please see our response to Q16 and Q57.

Q15: Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
Please see our response to Q14.
Q16a: Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
Yes.

Following the recent update to the NPPF, Paragraph 128 now requires all local planning authorities to prepare
design guides or codes consistent with the principles set out in the National Design Guide and National Model
Design Code.
Please see our detailed response to Q16b. and Q16c.

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?
BDW oppose the imposition of a single, broad design guide/code for the District. As the Council recognise,
this would fail to account for and preserve the mix of historic, natural, and urban environments that help to
create distinctive local vernacular and character. Conversely, BDW would also oppose the production of
specific, prescriptive design codes on a site-by-site basis which would not provide sufficient flexibility, restrict the use of innovative methods and technologies, and frustrate artistic interpretation – all of which may impact
a development’s viability and contribution to “beauty”.
BDW support the imposition of broad strategic objectives (as set out in the place-making charter, as well as
the National Design Guide and National Model Design Code) with sufficient flexibility for design to be responsive to circumstances of a site as they evolve. This might include more specific, but still broad objectives are settlement/area level.
Indeed, Paragraph 129 of the NPPF advises that developers may also choose to prepare design codes in
support of planning application for sites they wish to develop. This option would give the freedom to provide
interpretation and sufficient resourcing from the private sector to develop appropriate design codes, in
accordance with the National Design Guide and National Model Design Code.

Q16c: What do you think should be included in design guides/codes/masterplans at the scale you are
suggesting?
Please see also our response to Q16b.
BDW would expect Council’s adopted design guides/codes to implement broad objectives (at District and Area level) that reflect the 10 characteristics of well-designed places, as set out in the National Model Design Code.
More site-specific design would be influenced by developer produced design codes at submission stage,
reflecting the broad aims.

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?

BDW support Option 4. This would involve taking a market-led approach to housing mix and not specifying the types, tenures and sizes of houses that need to be delivered through a specific policy.
Option 4 would provide the flexibility required to address site-specific circumstances and respond to the types
of housing required as set out in the most up-to-date housing market assessments. This is the current approach to defining dwelling types, as set out in Policy H5 (Dwelling Types) of the adopted Core Strategy. Option 1 and 3 are too prescriptive and could lead to sites being unviable and not reflecting the needs of the local area. This in turn could delay allocated sites coming forward, leaving the Council facing problems with housing delivery.
If Option 4 was not preferred by the Council, and sufficient evidence was provided to justify such an Option, Option 2 would provide a suitable alternative, as it would factor in a level of negotiation on suitable housing mix (subject to market conditions and viability) – whilst seeking to take account of, and be responsive to, the type or location of development.
BDW support Option 5 in principle, requiring all new homes to meet the Nationally Described Space Standard
(NDSS). As recognised by the Council, the NDSS is currently an optional technical standard, and the Council
would be required to provide sufficient justification for implementing the standard – taking account of need and
viability.
With regard to Option 6 and 7, the requirement for new homes to meet Part M4(2) and Part M4(3) of the
Building Regulations is also an optional technical standard. PPG Paragraph 007 (Reference ID: 56-007-
20150327) confirms that, based on a housing needs assessment, it is for the local planning authority to set out how it intends to approach demonstrating a need for this requirement, taking account of such information as
the likely future need for housing for older and disabled people (including wheelchair user dwellings), the
accessibility and adaptability of existing housing stock, and the overall impact on viability. In respect of Part
M4(3), Paragraph 009 (Reference ID: 56-009-20150327) is clear that where local plan policies requiring
wheelchair accessible homes are implemented, these should be applied only to dwellings where the local
planning authority is responsible for allocating or nominating a person to live within that dwelling. BDW would expect the appropriate evidence to be provided (within the updated SHMA or a Local Housing Needs
Assessment) to justify the inclusion of these bespoke policies.

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?
As set out in Figure 28 of the consultation document (taken from the South Essex SHMA) the overwhelming
need for dwellings in Rochford District are houses (85%), rather than flatted development (15%). BDW observe
the allocation of smaller, urban/previously developed sites will not satisfy the prevailing demand for
dwellinghouses, which typically require a greater extent of land.

In addition, whilst a strategy that focused development within and adjoining the main built-up areas with an
emphasis on the re-use of previously developed land would promote urban regeneration, it must be
emphasised that this strategy could result in the under delivery of affordable housing owing to viability issues.
It is well documented that the provision of affordable housing on brownfield land / urban sites is challenging
due to the expense associated with acquisition costs, remediation and/or higher than normal construction
costs. Given that market housing is required to subsidise the construction of the affordable housing, the inevitable consequence is that Council’s targets for the delivery of affordable housing are seldom met when such a growth strategy is adopted. This, in part, forms our reasoning for a more dispersed, mixed strategy which includes the release of both underperforming areas of Green Belt which would allow the expansion of existing towns and villages. Paragraph 73 of the NPPF states “the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns” should be supported.
Such a strategy will also ensure the required level of affordable housing is delivered as schemes on greenfield
sites can viably support delivery of affordable housing compared to brownfield land for the reasons referred to
above.
Utilising this strategy will also disperse the effects of development, rather than focus this predominantly on a
single area – which could ultimately lead to negative impacts such as traffic congestion, noise and air pollution
and stretched community resources – for example. Dispersal will allow a greater range of housing choice and provide the right type of homes in the right areas to meet the needs of all communities – one of the key parts
of the Council’s vision.

A more dispersed growth strategy also provides opportunities to balance housing trajectory across the District and the wider South Essex HMA – as greenfield sites typically have quicker lead-in times / build out rates
compared to those often associated with complex brownfield sites.
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?
No

Biodiversity
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?
Whilst the Environmental Bill is still to receive Royal Assent, the intention of the policy to achieve biodiversity
net gains is clear and supported in principle by BDW.
This does not mean the Council should not seek to encourage developments to secure biodiversity net gain in excess of the 10% set in the draft Environmental Bill – which of course is a legal minimum. However, any
requirement to demonstrate a net gain in excess of 10% should be subject to a viability assessment and should
not be considered a requirement to make the development acceptable in planning terms (i.e. any provision in excess of the 10% figure should be considered an additional benefit of a proposed scheme).
PPG Paragraph 022 (Reference ID: 8-022-20190721) advises that biodiversity net gain can be achieved on-site, off-site or through a combination of both on-site and off-site measures. National guidance does not explicitly state the percentage split between such provision, but Paragraph 023 (Reference ID: 8-023-20190721) confirms such gain can be delivered entirely on-site or by using off-site gains where necessary.
Therefore, BDW would expect the Council to reflect the ambitions of the Environmental Bill and incorporate
the necessary level of flexibility in any allocation requirement and/or policy, providing opportunities to create networks to not just support biodiversity enhancement on-site, but also to encourage residents to have access to the natural environment on other sites (off-site) across the District. This would ensure improvements are both beneficial and viable.
BDWs site at Hall Road, Rochford is located on the River Roach and therefore offer substantial opportunities to improve the biodiversity of the site and deliver BNG.

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?
BDW support a combination of all listed Options identified by the Council in addressing the need for sufficient
and accessible community infrastructure through the plan.
Whilst the Council should seek to invest and protect existing community infrastructure, it should seek to first
locate development in areas with adequate proximity to existing infrastructure (such as Land South of Hall
Road, Rochford) before seeking to promote sites that are capable of facilitating the delivery of much needed
community infrastructure in other areas.

Q36: With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?
Yes.
The Council recognise a widespread lack of access to community facilities across the District. Where greater
access is more recognised in the major settlements, a concentration of development may put stress on these
existing facilities – whilst not delivering in more rural settlements.
Therefore, the implementation of Option 2b and/or Option 4 – both of which would permit urban extensions
across the settlement hierarchy – would permit the wider delivery of existing facilities whilst spreading the
existing pressures.

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?
Yes – see our response to Q.36

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?
BDW support Option 4.
Larger and strategic developments are capable of delivering areas for open space and recreation as part of a holistic redevelopment of a site. As set out in our Vision Document, Land South of Hall Road has incorporated
approximately 4.18 ha of public open space, including a local equipped area of play (LEAP) within the current
design.
Q40: Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering?
Yes.
However, the Council should consider that larger and strategic development sites are capable of delivering
areas for open space and recreation as part of a holistic redevelopment of a site.

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?
Yes.
Larger and strategic development sites are capable of delivering areas for open space and recreation as part
of a holistic redevelopment of a site.
Q42: Are there particular open spaces that we should be protecting or improving?
No.

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?
BDW support a combination of all Options identified by the Council in addressing the need for sufficient and
accessible community infrastructure through the plan.
As set out in our response to Q5 and Q6, the Council should seek to incorporate a dispersed growth strategy.
A more dispersed growth strategy will provide a balance between utilising and optimising existing connections in the more sustainable settlements, whilst providing improvements to less sustainable locations. A more
dispersed growth strategy will also work to avoid overuse and unnecessary congestion on more densely
populated areas, which bring with them problems of air quality and noise pollution.

Q52: Are there areas where improvements to transport connections are needed?
Please see also our response to Q51.
As part of a more dispersed Growth Strategy, the Council should seek to ease congestion by locating
development in locations which can benefit from wider improvements. This should be combined and recognised with the delivery of such infrastructure through contribution and/or bespoke delivery in larger allocations.
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.]
Please see also our response to Q52 / Q53.

Planning for Complete Communities
Rochford and Ashingdon
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing?
As per our response to Q4, in lack of current alternative evidence, we consider Rochford and Ashingdon should
remain a Tier 1 Settlement.
However, BDW consider the vision for Rochford and Ashingdon as ‘the gateway to our rural countryside’
undermines the designation of these areas as a Tier 1 settlement.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the land edge blue should be made available for any of the following uses:
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other
BDW consider Land South of Hall Road, Rochford (Ref: CFS084) provides a suitable, available, and deliverable site for approximately 250 dwellings.
The Vision Document supporting this submission provides detailed analysis of its suitability and deliverability, including how opportunities and constraints have been overcome.

Next Steps
We trust the above is clear and look forward to being notified as to the next steps with the emerging Local
Plan, and if you can please confirm receipt, it would be much appreciated.

Yours faithfully

David Churchill
Partner
E: david.churchill@carterjonas.co.u

I would like to comment on your recent proposals for house building particularly in the Hullbridge area.
Whilst I understand a certain amount of house building must take place most the areas proposed are completely unacceptable.
Small plots and areas such as the site of the Coventry Hill service station and the old car scrap yard and brown field sites are acceptable.
Areas such as green belt and agricultural land is totally unacceptable bearing in mind we already have the housing estates in Lower Road and Rawreth Lane in the process of being built. The new roundabout on the corner of Rawreth Lane and Hullbridge Road is far too small and I’m sure not according to original plans. It’s far too dangerous.
The road infrastructure is already overwhelmed and if any council member had been present last Wednesday 1st September when Watery Lane was closed they would have experienced first hand the congestion caused which is always the case when the rat run is blocked for any reason.
The area cannot tolerate any future builds other than those examples mentioned above. There is no provision for additional schools or medical centre which are already being over run.
The council must find any further development sites within brown site areas or not at all.

Objection to the Spatial Options Consultation Proposals.
In Particular around Hockley Hullbridge and Rochford, All of which will add to the problematic traffic issues, with limited road access, also to the limited Healthcare and Schooling provisions.
I am deeply disappointed by the swathes of countryside/Greenbelt that has been highlighted as suitable for conversion to Housing land, from the report you commissioned with Southend by Lichfields in 2020.
I appreciate that East of England designated you in 2005 with the responsibility to enable the provision of 4750 new builds by 2025, which was added to the 20yr Local Strategic Plan, and that you have fallen behind meeting those targets.
I also appreciate all of the reports you have had drawn up and the various calls for land, which have encouraged many greedy land owners, and developers to offer their land for proposed change of use, hoping for the subsequent windfalls they will benefit from.
However, as a property and business owner within RDC over the past 35 years, I am extremely concerned and as I said before, disappointed that, although the area has grown significantly in population, the infrastructure has not grown to meet the existing demands, let alone cope with the increase of some approx. 15000 + people to inhabit these new proposed properties.
The residents of Rochford District have not seen Section 106 enable the provision of new Schools, GP Clinics, Social or Healthcare services. Prior to meeting you today at Hawkwell Baptist Church, it did seem that it was acceptable for RDC to allow the developers to divide the development sites between companies to ensure they reduce their responsibility of Section 106 obligations. However after it was explained that the funds for this provision has been made over to the council, and you pointed out that you have ‘advised‘ the NHS and Education that it is there awaiting them. But they have neglected to utilise these finds nor provide additional support. You told me at your open event today that you ‘consult with’ other parties regarding development proposals. This is not agreement to provide though is it. How can you possibly prepare for the future if the various stakeholders are not working with joined up thinking/synergy. The affected service partners need to be in full agreement prior to passing such huge permissions, otherwise the additional demands fall squarely onto the shoulders of the already overloaded services of Health and Education. The effect of which leaves the general community burdened with additional constraints.
(It’s hard enough as it is to find an NHS dentist or get a doctors appointment currently, classrooms are already overstretched and local schools bursting at the seams).
Local Police services are reducing, and the demands upon them increasing.
Road and access infrastructure has not been enhanced in any way to accommodate such a huge increase of up to 10,000 more vehicles on the roads (2.2 cars per house hold), travelling around the district now takes twice the time it used to 25 yrs ago, with journeys between Rochford and Rayleigh taking up to, and sometimes over, 40 mins during rush hours.
This increased congestion creates pollution, is not environmentally friendly, and will see a sharp increase to RDC’s carbon footprint.
The water gas and sewerage supplies are greatly affected, which will again affect the roadways as new services are provided.
Water run-off from additional ill planned bolt on sites, will also create localised flooding
Previously, Highways discussed the provision of an extension to the A130, another promise that is yet to be fulfilled. Had it have done so, you might have been better placed to have created a new village along its course, with schools GP and transport infrastructure incorporated.
Interestingly, Chelmsford have done just this with Beaulieu Park. The A130 has been improved and enabled a development which incorporates all of the infrastructure requirements to service the new population. This way shops services healthcare outdoor spaces and schooling have been incorporated, and a new village has been born.
They have met their Thames Gateway requirements, and not suffocated the existing population, but enhanced their District, providing both short- and long-term employment in the process. All of which has been accomplished, without disturbance or displacement of the existing local population.
To earmark so much of our territory is heinous, and will destroy the quality of life for tens of thousands of your existing residents.
The creation of a conurbation between Rochford / Hockley /Rayleigh to Wickford would be devastating to the local wildlife, and countryside and to the mental health of your current community as a whole.
In conclusion
Limited infrastructure has been provided or is planned to support the building of significant thousands of properties in the area, and without such regional fundamental investment, (providing enhanced and increased services and roads for all of the designated locations upon your interactive map), I consider this Spatial exercise to be not only premature, but irresponsible to your existing residents and taxpayers.
You would be better placed to enable the majority of the increased housing provision west of Rayleigh where access to the A130 and A127 would enable easy access, and such a large development would ensure that the full support structure is incorporated at the time of the build, in a seamless joined up integrated planned development with all the service providers, that adds benefits for all .

Objection
I would like to put an objection against building new housing in the area of Rochford council especially in smaller areas such as Hullbridge. I feel there is not enough infrastructure in the area to accommodate any more housing. The hospitals schools and doctors are already over run and are struggling to accommodate the people in the area as it is. The green belt land should be left for people to enjoy. Roads around Hullbridge and the surrounding areas struggle at peak times with out the increased traffic and foot fall.

Spatial options
No to all options !
I wonder if people suggesting theses options actually live here & travel to & from work locally ( or at least try too ) Have you tried to book a doctors appointment or access any local services ?
It’s already overcrowded & gridlocked along Ashingdon road at certain times of the day ! What are you thinking of ?‍♂️
You can’t just build houses with no thought for infrastructure !
Asked to comment, so have.