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

I wish to register my objection to Option 3. Your stated Cons include significantly re-drawing the Green Belt. I feel very strongly that this is immoral and bad policy which will impact future generations. Once released, landscape will be gone forever. While other options exist, though less efficient, this should be the way to provide housing. South-East Essex towns will otherwise creep further until there is no space to breathe and that will be our legacy. In Rochford, the Hall Road concentrated build did not provide expected infrastructure. A repeat of that policy in Rochford would be very damaging.

Option 3A to develop west of Rayleigh. This has the least impact culturally on the district. It also impacts less on green land on the other smaller but already closer towns in the area (land either side of the train line between West Hawkwell/Hockley and Ashingdon/East Hakwell.

This option also has great transport links that filter straight on to main roads.

Option to build east of Rochford is viable, but would need a lot of thought for infrastructure.

Option to build north of Southend should not be considered, this eats in to the existing Green Belt between the two districts.

Support Option 1 for brownfield sites being the priority.

Option 2a and Options 3 seem the most appropriate if urban intensification is not sufficient for delivery - as these focus development around main towns and settlements which can accommodate more growth and will be more sustainable for services and infrastructure. Growth on lower tier settlements, such as Tier 3 and 4 should be limited due to pressure on services and infrastructure.

Settlements such as Tier 3 and Tier 4 will loose the character of villages - and loss of green belt will be more significant in harm terms. If growth happens adjacent to Tier 1 and 2 settlements they will still be accessible and provide growth/additional services for Tier 1 and 2 settlements.

Within constraint of four options we should progress Strategy Option 1: Urban Intensification.
I feel this is the least damaging of the four options as it does not require the loss of further green belt land.

I believe that Rochford should be suggesting that this is over development for the area given the current road network and strain on current services plus the environmental impact on air polution which all the additional traffic will bring.

As before

Central Government needs to finance the transport infrastructure and schools, gps and hospital expansion before they expect increased homes and businesses the infrastructure should come before the development otherwise it never happens.

A balanced approach is required. Some urban intensification is necessary and desirable, rather than developing on Green Belt. Where Greenbelt has to be used, smaller sites on the edge of the urbanised area should be preferred. Large urban extensions should be the last option.
This could be partially achieved by correcting irregular Green Belt boundary anomalies such as exist around CFS 047

I support option 1. We need to challenge our "growth need" with central government. These mandatory housing targets derrived from an algorithmic formula are a one size fits all approach which does not work. We should not be using this to release large swathes of our precious green belt. RDC has some of the most beautiful countryside in South Essex, we should be doing everything we can to protect it. We must push back against the Government on this. Note the recent pause on planning reforms my Michael Gove.

Option 1 as this has the least enviromental impact on wildlife, ecology and biodiversity.

Strategic Option 1, Town centres provide the greatest diversity, job opportunities and facilities for first time buyers, the elderly and low income families. As we have spread our town developments away from town centres we have seen more and more traffic and a continuing collapse in town centre occupancy. Putting communities back in to these towns is the best way or regenerating them. We should concentrate on repurposing land already with infrastructure already to support it. The council are the guardians of our rural and natural land and it should be seen as a last resort to develop land.

Too much house building allready, not enough infrastructure to support it

Too much house building allready not enough infrastructure to support existing

Putting more housing in Rayleigh is unworkable. The town is gridlocked. It doesn’t have enough infrastructure to cope with the current load that it has. The idea of “garden villages” where infrastructure could be put in (housing, medical centres, schooling etc) will not work in the areas you suggest because outside of their immediate vicinity you are still tapping into existing, inadequate infrastructure. Putting a development at Rawreth is going to block the West exit out of Rayleigh and try to disperse into roads that cannot sustain the level of traffic that was planned 10 years ago (and not completed yet). The same with any garden village being proposed even deeper into East Essex - the traffic still has to move through the bottleneck that is Rayleigh and Benfleet with NO proposal to connect these villages to major roads directly. No bypass around Rayleigh suggested and yet you build houses on any available land that will hinder you being able to offer this as a suggestion at a later date. Sort out the infrastructure first.

I believe option 3a is the best strategy development of land to the west of Rayleigh for the following reasons:

This area has by far the best transport links, amenities and infrastructure in place and stops the need to eat significantly into greenbelt land, which should be protected at all costs.

This would mean that small historic village locations such as Great Wakering and Rochford (albeit Rochford has already undergone significant development) remain as unspoilt as possible by development and remain areas of local natural beauty for all. Wildlife should also be considered.

Although on paper option 4 seems to cover growth needs for our district, option 1 is more desirable to the impact on loss of greenbelt. If option 4 were to proceed, developers must be made to deliver on new infrastructure including promise of schools, healthcare, shops and of course new roads. Time and again the promise of affordable homes has not been delivered. Too many Executive homes being built, left empty or rented out. We are losing our younger population as they move to more affordable areas of the county.

Health and wellbing

None appear to have a positive impact on environmental quality

None of the options are desirable. However, options 3b and 3c would be least objectionable, as they will have least impact of the gridlocked roads and infrastructure around Rayleigh.

Pretty much all the options seem to go against the vision of a nice green areas and quality housing. They all impact the environment, natural resources and climate change (your assessment is clearly wrong here as 4000+ houses will have a detrimental impact on climate) they are all going to impact transport (roads are all overloaded now and there is limited scope for major improvement). You also state affordable housing of about 30% but in chapter 1 you mention new national policy only requires 10% so how would you ensure 30%?

I support 2a because the infrastructure is already in place in larger towns and there’s would be less impact on the countryside.

Overall the final mixed seems appropriate. I would object to some of the detail. In particular the development to the west of Rayleigh and the A130 in particular - which would appear to be in practice an extension of Wickford/ Shotgate rather than contributing to Rayleigh. I would restrict housing development to the areas to the east of the A130 building on and improving the infrastructure along London Road and Rawreth Lane. The green belt between Rayleigh and Wickford needs to be maintained.

Strategy option 4 could provide for necessary development and provision of additional services without expanding existing settlements to the point of characterless and dispiriting urban sprawl, which is already blighting Rayleigh. The selection of sites for new settlements or extensions to existing settlements, and their design, should ensure that walking, cycling, and public transport connections are viable transport options for the people who live there. The Plan should rule out major new road links so as not to further fragment the District's landscapes.

Strategy option 3. It provides large scale development that would have the space to fit in the new infrastructure, such as schools, doctors and shops. The areas would be planned into an effectively blank canvas allowing the best chance to build sustainably, rather than trying to force additional housing onto infrastructure that's only just coping with current demand. The proposed sites have good links to the major roads e.g. A127 to provide transport to employment areas.

Strategy options 3 should be taken forward as it would result in new neighbourhoods in their own right and with larger developments new infrastructure will have to be put in place therefore not relying on already struggling infrastructure of our existing towns. Most of our current infrastructure is already over capacity and no amount of money from developers will solve some of these issues.

Thurrock Council supports the proposed Spatial Spatial Strategy Option 4: Balanced Option for the New Rochford Local Plan that would seek to provide a mix of Urban Intensification, Urban Extensions and Concentrated Growth Options. It is considered that the Balanced Option would provide a more flexible response for housing delivery and supply including a mix of housing development locations and site options whilst also providing the critical mass to deliver infrastructure. The Option 4 would also be more likely to deliver the higher Growth Scenario of Standard Methodology Plus Buffer which includes the potential for cross –boundary development in meeting needs from elsewhere.

It is noted that Option 4 also provides better socio-economic benefits compared to other options.

Thurrock Council supports the Growth Scenario for the Rochford Council New Local Plan which seeks to meet the Standard Methodology housing number but also includes a buffer that would provide a driver for economic growth and/or address unmet need from elsewhere.

It is stated that Rochford Council currently proposes that the Standard Methodology Plus Buffer Scenario provides a buffer of 3600 homes above the Standard Methodology requirement for Rochford borough which represents a 50% uplift. Providing such a buffer may assist in meeting unmet need from elsewhere and in particular adjoining local authorities within South Essex.

However towards the end of the Rochford Spatial Options consultation it is noted that neighbouring Southend on Sea Borough Council has undertaken a Regulation 18 consultation, “Refining the Plan Options” on its New Local Plan. Within the Southend Council proposals there is a Strategy Option D that seeks to meet part of its Standard Methodology dwelling requirement by locating growth within Rochford district boundary of up to 3,950 dwellings during the plan period to 2040 and potentially 4,900 dwellings beyond the plan period.

The dwelling number of at least 3,950 dwellings proposed by Southend Council in Rochford district in a cross boundary development is higher than the 3,600 dwellings potentially proposed by Rochford Council in its Standard Methodology Plus Buffer options to assist in meeting unmet need. There is also an additional 1,000 dwellings proposed beyond the plan period to be located in Rochford district.

Thurrock Council notes the difference in approach and dwelling numbers for potential cross-boundary development in this location as set out in the draft local plan consultations of both authorities. Clarification is sought on this matter and it is recommended that both authorities will need to consider this matter through further collaboration under the Duty to Cooperate to undertake additional evidence work to assess the deliverability of such development and seek to reach an agreement on a dwelling number for any cross-boundary development to inform the next stages of plan preparation.

The NPPF makes it clear at para 61 that Local Planning Authorities should be looking to use the Standard Method to determine how many homes are required, stating, “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance…”.

Accordingly, it is confusing at Figure 15 that it includes a ‘current trajectory’ scenario of only 4,500 homes when this scenario will not deliver the Standard Method requirement of a minimum of 7,200 homes. The Council could, therefore, be clearer in this regard and confirm that this Scenario cannot be taken forward in isolation.

The Plan presents four options; Persimmon Homes would support a combination of Options 1 and 2. Our comments of which are as follows:

• Strategic Option 1 – The Paper itself acknowledges that this Option will not be able to fully meet the Standard Method requirement, as well as acknowledging that it will not be able to deliver the brand new infrastructure that is required alongside new homes.

It is also identified within the Integrated Impact Assessment that the lower growth options will not deliver the required levels of growth, stating on page 25 that:

“The lower growth option will not meet the needs of all people in the district during the plan period. The medium and higher growth options will meet the needs of all people in the district and improve accessibility to housing, employment, training, health, and leisure opportunities. The higher growth option is more likely to meet the needs of not only people in the district but beyond, as well and encourage the integration and interaction of cross-boundary communities through the delivery of large-scale developments. The medium and higher growth options are also considered for their overall potential to deliver a wider range of housing types, tenures and sizes, particularly catering for the needs of groups with protected characteristics, such as specialist housing for the elderly and disabled.”

Furthermore, the Integrated Impact Assessment states that:

“…smaller scale development proposals bring less opportunity for strategic infrastructure improvements, and may place increased pressure on local road networks.”

The Paper also identifies that said option to increase densities in urban areas are unlikely to be compatible with historic centres and local character, as confirmed within the Integrated Impact Assessment, which states:

“…it is recognised that the lower growth option will focus development in existing urban areas, with a higher potential in this respect to impact on historic centres.”

It also goes on to confirm:

“Option 1 would not deliver sufficient housing to meet local needs over the Plan period, in this respect it is also likely to deliver less affordable housing and long-term negative effects can be anticipated.”

Again, we would request that the Council undertake updated Conservation Area Appraisals and Settlement Surveys so that the Council has the required evidence base to consider if increased densities, taller buildings etc. would be appropriate in the historic centres and urban areas, as this would help inform the actual number of dwellings available under this option.

We would also question that this Option uses sites that have retained site allocations from the 2011 Core Strategy, and would question why these sites have not been developed by now – are these sites developable and deliverable as per the tests of the NPPF. This is something that the District Council should review.

Accordingly, this option cannot be taken forward within the next stage of the Local Plan on its own, though it is acknowledged that some level of urban intensification on appropriate sites may be suitable to help meet the Standard Method.

• Strategic Option 2 – Option 2a proposes Urban Extensions focused in the main towns; as Rayleigh is the Districts sole Tier 1 settlement, it is logical and sensible that urban extensions should be focused in Rayleigh. Furthermore, it benefits from not being restricted by any flood zones, being sequentially preferable to many other settlements in the District.

The Spatial Options document identifies that this option would be able to deliver new infrastructure; meet local housing needs; and deliver quickly; all of which Persimmon Homes endorses.

This Option would also deliver the required level of growth required for employment needs, as confirmed within the Integrated Impact Assessment:

“The medium and higher growth options are more likely to have a significant positive effect on this IIA theme through the delivery of new employment land and retail floorspace. These options are also likely to deliver more new infrastructure upgrades and sustainable transport routes to attract further inward investment. Further to this, the higher growth options could contribute to the delivery of sub-regional improvements to green and blue infrastructure, which could have a positive effect on the tourism economy. Whilst positive effects are considered likely under all options, the lower growth option is considered less likely to lead to positive effects of significance.”

It goes on to state:

“Urban extensions under Options 2a and 2b provide large scale development opportunities that can deliver new infrastructure provisions to support both existing (particularly those in edge of settlement locations) and future residents.”



It concludes:

“Significant positive effects are considered likely under Options 2a, 2b and 4.”

The delivery of sites under the medium and higher levels of growth would also allow for the delivery of climate change measures that are required and discussed later in the Spatial Options Document. The delivery of these measures may not be possible through reusing existing buildings (Strategic Option 1) as confirmed within the Integrated Impact Assessment:

“…the delivery of large-scale growth that is more likely to come forward under the medium and high growth options present more opportunities for the delivery of low carbon infrastructure through economies of scale compared to the lower growth option.”

On the same theme, the medium and higher levels of growth options are much more likely to be able to deliver the biodiversity and green infrastructure improvements and contributions required, than on existing brownfield sites, as also confirmed within the Integrated Impact Assessment:

“The medium and higher growth options are also noted for their potential to support the delivery of strategic green infrastructure provisions and associated biodiversity net gain. This includes improvements being explored in the green infrastructure network across the sub-region through the South Essex Green and Blue Infrastructure Study (2020), such as the Regional Parkland. The Regional Parkland has the potential to act as alternative greenspace targeted at reducing recreational pressures at designated biodiversity sites. These options thus provide a greater contribution to the principles of the Essex Coast Recreational disturbance Avoidance & Mitigation Strategy (RAMS).

The lower level of growth will mainly result in the delivery of new homes on urban and brownfield sites so has greater potential to avoid designated sites and support urban greening to some extent. The urban focus however is less likely to bring forward strategic mitigation, such as the Regional Parkland to mitigate the recreational pressures on designated biodiversity resulting from a growing population. As a result, the medium and higher growth options are considered more likely to perform better overall in relation to this IIA theme; however, the potential for a significant effect is uncertain as will be dependent on the location of growth.”

It continues:

“…the potential for larger-scale development under Options 2a and 2b is recognised for the potential for greater net gains in biodiversity.”

The site that Persimmon Homes is promoting – site CFS087 – would be capable of being delivered under this Option.

• Strategic Option 3 – The Spatial Options document identifies a number of significant ‘Cons’ which would impact upon the delivery of this option (and thus threaten the delivery of the plan as a whole), all of which we would agree with and would therefore recommend that this option is not progresses as:

o The plan identifies that this option involves complex land ownership issues which is likely to be difficult to resolve and address;
o Significant redrawing of the Green Belt boundaries, including proposing development in more sensitive Green Belt locations than other strategic options;
o Focussing development in a single location/settlement would deprive other settlements of being able to accommodate development, and thus potential infrastructure improvements.

On Environmental impacts, the Integrated Impact Assessment identifies that harm that this option would have on Environmental Quality, stating that:

“…extensive countryside development proposed through the concentrated growth options (Options 3a, 3b and 3c); which is considered highly likely to lead to negative effects of significance in this respect. Options 3a and 3b are also likely to intersect the flood plains of the Crouch and Roach tributaries, and development will need to ensure appropriate mitigation to avoid impacts on water quality…Negative effects of significance are considered more likely under Options 3a, 3b, 3c and 4 given the extent of concentrated growth development locations in the countryside.”

• Strategic Option 4 – This option proposes a ‘balanced combination’ of all three; we would recommend a balanced combination of Options 1 and 2 represents the most suitable Spatial Strategy going forwards for the reasons given above and indeed as detailed within the Spatial Options document, and the Integrated Impact Assessment, which concludes:

“Option 4 is noted for its potential to perform better against a wider range of the IIA themes than the remaining options. This predominantly relates to the flexibility provided in a tailored approach, essentially combining the best performing aspects of each individual approach (urban intensification, urban extensions and concentrated growth).”

4 – A balanced approach to growth and delivery seems the most logical, as by allocating different sized developments it will ensure housing and infrastructure delivery throughout the whole plan period. Different sized sites will also serve different community needs. For example, smaller urban extensions will absorb some of the community housing need in areas where services are already provided. Larger growth areas which require their own infrastructure will provide more homes, with a larger number of affordable dwellings, but will only be available for completion in the later stages of the plan period due to their strategic size.

Canewdon Parish Council would prefer Option 2, but the smaller settlements should only take an amount of new residential development proportional to the size of the existing settlements.

I would support option 2a, to infill the main towns so as not to use green belt. In your own words Rochford is congested and saying the likelihood of major infrastructure is less with less housing, that is just an excuse not to carry out improved infrastructure first. In the green belt policy is says that it should 'only be used in exceptional circumstances', but the way you interpret it, is that it is only exceptional circumstances for it not to be released. The council can push back on housing numbers or refuse relocation of Londoners.