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

Dear Sir / Madam,

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

Thank you in advance for your attention to this matter.

Kind Regards,
Jane

Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
I could not confirm what were the studies you conducted in order to determine the young people’s needs for leisure activities other than sports. In addition, could you please make available the studies conducted.
Q2. Do you agree with our draft vision for Rochford District?
In a matter of principle, yes, I agree, but there should be a greater highlight to creating new jobs through the establishment of business incubators and support to traditional and new outdoor markets to support local farmers.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
I don’t agree with the separate visions as it will divert the resources from a global vision for Rochford District in terms of number of houses and the respective infrastructure. As such I think it would be detrimental to have a narrower vision which can overlook the effects that the increase of population in one area will have on the remaining parts of the district.
Q4. Do you agree with the strategic priorities and objectives we have identified?
As principles, yes, but I have several objections in the way they are supposedly achieved.
Strategy Options
Q5. Do you agree with the settlement hierarchy presented?
Yes.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
It is my understanding that Option 4 would be preferable, but the more the building is concentrated into one area, the less green belt would have to be released. I will detail my concerns in Q17.
Q7. Are there any reasonable alternatives to these options that should be considered instead?
Please refer to Q6 and Q17.
Spatial Themes
Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis?
Yes, I was not able to verify what would be the dedicated areas for the construction / improvement of roads and other public transport infrastructure. In addition, I could not confirm where will the new waste management facilities (dumps or recycling centres) will be placed, the way the options are presented it does not allow the public to have a detailed understanding of it.
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?
Yes. No infrastructure or housing development should be authorised to be built in high floor risk areas or coastal change areas. As the plan is omits what would be the estimated costs in terms of the additional infrastructure that would be required for building in these areas, it doesn’t allow for a risk/benefit analysis of allowing to build in risk areas versus costs that would have to be paid in rates by the general public.
Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character?
Yes. In addition, Hockley Woods, Rayleigh Mount and Grove Woods should also be preserved from development.
Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
I agree, provided that the energy production equipment produces a relevant amount of energy.
There are plenty of opportunities to establish micro-production with community funding. I am not an expert, but please refer to the work done in Manchester in this regard http://www.gmcr.org.uk/ .
Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?
I agree that energy efficiency should be an important consideration in any development, and they should be above the bear minimum, but I lack the technical knowledge to comment any further.
Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported?
The Council should encourage companies, charities and individuals to come up with projects and provide administrative and financial support whenever needed to help them see it through.
Considering the availability of surface water and rain in the UK but the lack of natural elevations in the Essex region, consideration should be given to hydro-electric micro-production facilities.
In addition, solar and wind energy should also be encouraged wherever possible.
Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas?
Yes. The principle should be applied by areas.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
Yes, 1) there is no point regarding public transport (bike lanes and walk paths alone are nowhere near the needs of the community) and 2) there is no point regarding the minimization of the impact that new roads will have in the fabric of the places they will go through.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
I do not understand the question, this seems to be a specialist subject I cannot provide input on.
Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
I do not understand the question, this seems to be a specialist subject I cannot provide input on.
Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?
I do not understand the question, this seems to be a specialist subject I cannot provide input on.
Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing?
I do not believe that in an area where young people have very few cheap options to buy a house, the option to primarily develop detached or semi-detached housing (80% of the planned houses) would be adequate as the house prices will still be too high, even with the affordable option.
In order to achieve the same number of houses in a significantly smaller development site, the option to increase the number of terraced houses and flats to 50% of the new builds would decrease the overall cost of providing these new houses, regardless of the affordable housing conditions.
In terms of the number of bedrooms, I agree with it, only the distribution between the house size seems too focused in large and expensive properties with a negligible discount that will not suffice to cover the current or future housing needs. A 20% discount on a £700,000 detached house for a family who can only afford a £250,000 terrace house is not an acceptable trade-off.
Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas?
In the specific case of Rayleigh where I reside, there is a significant shortage of terraced houses and flats which are by design cheaper than the other options, so in order to meet the new housing needs, development should focus on these rather than creating huge new areas of detached and semi-detached houses that will not meet current housing needs.
Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing?
I could not confirm in the plan what areas are being specifically allocated to house rough sleepers and other people in homeless situations.
Q20. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller accommodation needs?
Provided that they are willing to pay for their own accommodation and this does not implicate any increase on the council rates, I do not have any specific input in the solution.
Q21. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs?
Provided that they are willing to pay for their own accommodation and this does not implicate any increase on the council rates, I do not have any specific input in the solution.
Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites?
Provide that they pay for the land they spend their time on and the facilities and amenities provided by the council and this does not implicate any increase on the council rates through the clear-up of their sites, I do not have any specific input in the solution, although I would think that they would be better placed outside urban areas without sacrificing any green belt area.
Employment and Jobs
Q23. With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan?
I could not verify if the council is planning or willing to assist new businesses by providing any reduction in business rates for the first years. Considering the crisis that high-street local businesses are facing to establish themselves and thrive, this would be an incredible tool to employ. I am also not aware of any mention to the creation of new business hubs for creative industries, farmers markets and technology start-ups outside of the airport site. When considering the local importance of informal business sites, such as Battlesbridge Antiques Market, the creation of small business hubs would be extremely effective.
Q24. With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the Green Belt?
As a principle yes, but this has to have a case-by-case analysis of the impacts, namely in terms of polluting employment sites and the needs for infrastructure.
Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?
When establishing the new sites for development, there is an opportunity to require the property developer to establish a commercial presence proportional to the size of the site in order to create basic shopping amenities or go further if the site so justifies in order to attract more retail. For that purpose, the planning must include loading bays in order not to disturb residents and to supply the shops.
Q26. Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?
Considering that the two main villages in Rochford District are traditionally market towns, it is strange that there aren’t any plans to incentivise more street market initiatives, both seasonal and farmers markets.
Q27. Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g. skills or connectivity?
I think more public transport to formal and informal employment sites would greatly stimulate the growth or those sites.
Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system?
The current road infrastructure is already insufficient to move the traffic from the businesses and people going to and from the area adjacent to the airport. In order to increase the ability of the airport to be a major employment site, the roads must be able to allow the circulation of the increased traffic. It is already clear that the construction of an alternative to the A127 or the increase to a dual carriage capacity of an existing road is essential.
Biodiversity
Q29. Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?
Yes, it should include the whole of Hockley Woods.
Q30. Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q33. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Community Infrastructure
Q35. With reference to the options above, or your own options, how can we address the need for sufficient and accessible community infrastructure through the plan?
I could not verify where the schools are going to be built and what is going to be increased in terms of the public transport infrastructure.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?
Depends on the number of houses built and where they are built. I agree that there has to be an increase, but this seems to be a specialist subject I cannot provide input on.
Q37. Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these?
There is an absolute absence of any facilities for young teenagers that don’t involve organised sports or are not paid.
Regarding the schools and healthcare, the current infrastructure is stretched, and doctors are already struggling to keep up with their appointments as it is and this is a nationwide problem. With new houses being built, this should be addressed before the problem gets even worse, but this is a specialist subject I cannot provide further input on.
Open Spaces and Recreation
Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q39. Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q42. Are there particular open spaces that we should be protecting or improving?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Heritage
Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q44. Are there areas of the District we should be considering for conservation area status beyond those listed in this section?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state
Ensure that new types of retail and other businesses are encouraged to establish themselves in the town centres, namely through the reduction or exemption of council rates to give them a chance to survive the initial period. Other than restaurants and beauty services, no new businesses have opened in Rayleigh High Street. This reduces the overall margin of the existing businesses, the attractiveness to the installation of new businesses and the ability to attract visitors to shop in Rayleigh.
Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]
I don’t have an issue with the hierarchy per se, but there should be some protection to the local centres and local parades to ensure that they don’t disappear.
Q48. With reference to Figures 38, 39 and 40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
Yes.
Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]
Yes. In the town centres the primary use must be commercial as the unchecked conversion to housing developments would create many problems with noise complaints and others where they didn’t exist before.
Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]
Yes, as I mentioned before, considering the market town pasts of Rayleigh and Rochford, it would greatly benefit local businesses to incentivise street market initiatives as it would not only provide a greater variety of goods to residents, but it would also provide local businesses the foot traffic.
Transport and Connectivity
Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
The plan has to have appropriate measures in place to secure those roads and railways are built ahead of the conclusion of the developments and not after they are concluded, as it is common sense that once the houses are built, any compulsory purchase of space to build infrastructure will be more expensive.
From what I could understand, any plans to increase the transportation network are left to chance or delegated to other entities.
The increase of the housing without transport will further exacerbate the problems that the road infrastructure is currently facing and there are no plans whatsoever to increase public transportation to places which are already lacking, such as Hullbridge which is almost entirely dependent on Rayleigh’s infrastructure.
It is strange that the Beaulieu Estates managed to have a new train line and the people of Rochford District can’t either get appropriate roads, let alone more train connections. I cannot understand how Chelmsford is able to plan these developments to have transport connectivity and Rochford cannot plan a road.
Q52. Are there areas where improvements to transport connections are needed?
Yes, the A127 needs increasing and there is a lack of an alternative route to this road going into Rochford and Southend.
Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [walking, cycling, rail, bus, road etc.]
Yes. All of the above, the increase in the demographics and the expected establishment of new businesses should account for an increase primarily focused on roads, rail and buses that serves as an alternative to the current routes that are massively overrun.
Green Belt and Rural Issues
Q54. Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities?
I am not aware of it, but this seems to be a specialist subject I cannot provide input on.
Planning for Complete Communities
Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
No. I cannot see this translated in the detailed plan.
Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
I cannot understand the allocation between commercial and housing properties as well as infrastructure, as there are nowhere near enough roads or overpasses in the image provided.
Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate?
No, unless infrastructure is put in place. A simple example is the development in Daws Heath Road, where all these plots are meant to be made available for development, but the end of the road, approaching the A127, is not able to take two cars at the time.
Q56d. Are there areas that require protecting from development?
New developments in the Town Centre that either reduce green areas or affect the Mill Hall and any development that reduces the area of Hockley woods.
Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
The legend to Figure 44 does not allow for enough detail to understand the changes to the green spaces and the purpose of them.

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

I am contacting you to register my utter disbelief and disgust that you wish to build houses on Hockley Woods, which is green belt land. Green Belt land, is land that is never to be built on. This is an area used by so many for physical and mental exercise. While the country was struggling with the pandemic, it was a place many could go to for their wellbeing.

As everyone knows, Rayleigh, as well as other local areas, are already over populated, we have new housing estates on almost any green space that once existed. Roads are always at a standstill due to the amount of traffic; we just can't take anymore.

Every time a new estate is proposed we are told they will build a new primary school, new doctors' surgery, neither of which ever emerge. Another point is that although they promise Primary schools, these children will need to go to secondary school at the age of 11 and no one wants to build a new school for them. Fitzwimac and Sweyne Park have already taken 30 pupils extra per year and cannot continue to do this.

Our doctor's surgery is at breaking point. Trying to get an appointment is almost impossible at times.

While I except you wish to build new houses, please use brown field sites, not green belt.

I have received messages and now a postcard regarding the RDC New Local Plan. We would like you to know that we feel any kind of action to the needed changes within the Rochford District will probably be ignored as many complaints and comments have been made over the many years we have lived here and very little has been done. Our roads in the area are in the most disgusting condition causing danger not only to motorists but cyclists, motor bike riders and pedestrians. The work that does get done is inadequate and has to be redone on frequent occasions. Drains are blocked and cause rain to flood roads. The housing estates are being built regardless of the lack of infastructure, the inability for some children to attend schools within their catchment areas, due to overcrowding, a lack of GP surgeries, parking facilities, which are overpriced and inadequate. The bus service regardless of the increased population is still poor, sites which are part of our heritage are either sold off or left to deteriorate as is the site where the old police station is in Rochford. The possibility of Mill Hall being pulled down, leaving no social centre for sport, entertaining etc. is also on the cards. Shops are closing due to high business rents and are left in poor condition making them undesirable to new business ventures. The gatehouse at the end of Hawkwell Park Drive is falling into disrepair beyond belief with overgrown garden etc. We thought this was a listed Grade 11 building. The cake shop next to it is a disgrace and would not tempt me or many people i know to have a cake made there particularly when you see the state of the waste ground outside. The parking at the end of Hawkwell Park Drive is appalling causing back ups of traffic into the road around which cars/vans turning off the main road are unable to progress. The overspill of cars from White Hart Lane Service Station, which are left in Hawkwell Park Drive and Park Gardens is also unacceptable. The cost of our Council tax is high enough to warrant all of these problems being resolved and I am afraid, as are many people I know, feeling that your request that we have an input into the future of our area is a complete waste of time.

1.0 Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options on behalf of Bellway Strategic in relation to Land at Hambro Hill, Rayleigh (‘the Site’).
1.2 The Site has previously been submitted into the Call for Sites under reference CFS105. The site extends to some 10.3ha and has been promoted by Bellway Strategic for a sympathetically planned development at Rayleigh, adjacent to the urban area, open space, and a proposed Regional Park.
1.3 Representations were submitted for the site under the Call for Sites in 2015 and the Issues and Options consultation in 2018, under a different promotor.
1.4 The condition of the site is a mixture of a minerals site and grassland. It is not open to
the public. The site is predominantly grassland but with significant areas of despoiled land used for sand extraction. Alongside the site to the northwest are commercial uses, containing large areas of hardstanding, a compound for vehicle storage, and warehousestyle buildings. The site is clearly separated from the farmland that stretches from the north of the site across to Hockley. It has a very different character to the surrounding
land by virtue of its use for mineral extraction and its isolation created by residential development to the south, west and east, commercial development to the west and north, and a small woodland to the northeast.
1.5 The site is designated as Green Belt in the current adopted Development Plan, which remains the only constraint to the delivery of the site. While within the Green Belt, the site is immediately adjacent to the settlement boundary of Rayleigh, the districts largest
settlement, and is located on the eastern side of the District’s largest settlement. The site has development to the south, east and west, with open space to the north that is proposed to be identified as a regional park. Accordingly, the allocation of the site would make use of the previously despoiled site and be able to provide a more attractive transition into the new parkland, if allocated.
1.6 The site has a planning history which includes the granting of planning consent for the extraction of sand in 1987 (application ROC/916/86). Notwithstanding the green belt designation of land in this area, the established commercial uses on land to the west and
northwest, and the quarrying activity on the site itself, combined with the neighbouring residential development, all identify the site as being less-valued Green Belt land that is not visible from public viewpoints
1.7 The land is served by an existing vehicular access. The site is located in proximity to the junction of Hambro Hill with Hockley Road, and is well placed in relation to the wider strategic highway network and access to Rayleigh, which contains a full range of services
and facilities to serve any future residents. The site is extremely well served by public transport, is in good proximity to both primary and secondary schools, health, open space, the town centre and employment opportunities. It is within reasonable walking distance of the rail station, which can also be reached easily by cycle or public transport. The site represents one of the most suitable sites in terms of sustainable transportation.
1.8 The site is entirely contained within Flood Zone 1. As such, the site is at a low risk of tidal or fluvial flooding and is appropriate for any form of development from a flood risk perspective.
1.9 The site is not subject to any environmental, ecological or heritage designations that would prohibit or constrain its potential to deliver housing sustainably. The site represents a logical extension to the existing settlement boundary, which would deliver an attractive development of market and affordable housing positioned alongside a potentially significant area of open space. When planned considerately and comprehensively, the site would be capable of delivering an extremely attractive extension to Rayleigh.
1.10 The site was assessed as part of the Council’s Strategic Housing and Employment Land Availability Assessment 2017 (SHELAA 2017) to determine its suitability, achievability and availability as a site to help meet the District’s housing needs.
1.11 Appendix C of the Assessment identifies the site as being:
‘Concreate, gated drive way with large car park and vehicle scrap yard with a metal container used as a reception. Unsurfaced ramp to vacant field with overhead
cable traversing the site with trees and hedgerows on the boundary. Large warehouse-style buildings to the rear of the site’
1.12 The adjacent land uses were identified as residential / woodland and notes that there are no constraints on the site (SSSI, Ancient woodland, SLA, SAC, etc). The assessment identifies an active sand and gravel extraction permission.
1.13 Under Housing Development Potential the assessment considers the site to be available and achievable. For suitable, the Assessment states ‘unknown’ and the supporting text states that this will be unknown until a Green Belt assessment is undertaken.
Accordingly, the 2017 SHELAA Assessment finds the site to be suitable on all matters, with the outcome of a pending Green Belt Assessment being the only outstanding matter commented upon in the Assessment.
1.14 Commentary on the Green Belt Assessment is provided later in this response. In summary, it is considered that the Green Belt Study (2020) considered an exceptionally large parcel of land (Parcel P23), extending to 93ha between Rayleigh and Hockley. The
extent of the parcel did not reflect the extent of the two sites submitted to the SHELAA that fall within it, being:
 Site 105 (this representation) - 10.3ha and
 Site CFS040 - 1.11ha.
1.15 In comparison the Green Belt parcel was nearly 88% larger than the total area of land submitted to the Council that falls within the Parcel. Further, by identifying the parcel as land between Rayleigh and Hockley, the larger site inevitably scores strongly for Purpose 2 - preventing neighbouring towns from merging:
1.16 Given the open landscape and natural condition of the majority of the land in the parcel, which was not submitted for consideration for development, it is predictable that the
Parcel would score highly for Purpose 3, to safeguard the countryside from encroachment. The Parcel also scores strongly for assisting in urban regeneration by
directing development to derelict or other urban land.
1.17 A more detailed consideration of site 105 is provided at Stage 2 (Appendix 4 of the GBS) which provides an Area Assessment for Area AA38 (pages 77-78). The Assessment finds the overall score to be a moderate-high harm from release of the site. However, in the justification this appears to be reached as a result of a relatively open boundary to the north, which could readily be contained by new landscaping that would be ubiquitous of new large scale residential development. The Assessment considers the release of the Site to weaken the Green Belt purposes of land to the west, but this is currently
identified for open space and would therefore be protected for that other purpose. The assessment also appears to downplay the description of the Site from the SHELAA (provided above) as being alongside previously developed land and its condition as a minerals extraction site.
1.18 As a general assessment of the overall conclusions to the Assessment and the Purposes
of the Green Belt, as shown at pages 40-45 of the Assessment (figures 3.1 - 3.6), it is clear that there is little differentiation between the results across parcels. There is a general north/south split for purpose 1, an east/west split for purpose 2, and very little variation for purposes 3, 4 and 5. For the overall contribution to the Green Belt, there is a strong rating for all of the land lying between Rayleigh, Hockley and Rochford, with lower ratings for the parcels of land radiating away from these towns.
1.19 Accordingly, development of the parcel is identified as being less-harmful than it would be for land between Rayleigh, Hockley and Rochford and the scores of parcels have a clear geographic spread that does not differentiate parcels to any significant degree in a way that clear guides the spatial distribution to prefer one approach compared to another, in terms of protecting Green Belt land. Further, the parcel is much larger than the two sites submitted within it (105 and 40), representing an artificially high overall contribution
compared to any releases that may be proposed through the Local Plan. Finally, when considering the site itself, the current condition and uses on the site appear to have been downplayed.
1.20 In combination with the sustainable location and positive SHELAA assessment, with only the Green Belt assessment outstanding at the time, the Site is considered to represent a highly suitable, available and achievable development opportunity. In combination with
other opportunities for land within the parcel, the site is a highly attractive location for a modest development of around 250 dwellings that would not undermine the purposes of including land within the Green Belt.
1.21 It is worth noting that, in this instance, the allocation of the site within the Green Belt is directly contrary to the fifth purpose of including land in the Green Belt, as it discourages the regeneration of the brownfield parts of the site.

2.0 Response to Spatial Options Consultation Questions
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
2.1 In combination with an overall vision for the district, a vision for each settlement (or some of the settlement) may be helpful in articulating a specific, focused objectives for a settlement, distinguishing its development aims from another settlement. It is important that the visions do not prevent development from reacting to change, such as the demands and expectations from homes and businesses, technology, and construction
methods.
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?
2.2 The Priorities and objectives identify a fairly broad approach to development demands, covering a lot of aspects of development under each priority. It is recommended that these could be more focused on the spatial challenges and opportunities to ensure they
add value to the plan making process.
2.3 While recognizing that the spatial Options are still open to be determined, one omission is that there is no clear indication of where the district may seek to direct development. There is reference to supporting rural areas but there should be a clear steer towards growth in the most sustainable locations. Regardless of the eventual decision on the spatial distribution, the Vision should identify that the majority of growth will be in the
most sustainable locations and close to existing larger settlements where services are most accessible and available. While we support some development in more rural areas, as currently drafted the Vision appears to articulate the approach to rural diversification, support for rural economic development and supporting rural communities, far more clearly than it does any urban developments or extensions to existing settlements.
Presumably urban extensions will provide the larger share of growth over the plan period and therefore the Vision should more clearly articulate the support for urban developments and extensions to existing settlement. In addition, there appears to be some potential strain between the support for rural development in the Strategic Priorities compared to the objectives in Priority 5 - Making provisions for climate change, conservation and enhancement.
2.4 For the above reasons, we recommend that references to delivering sufficient, sustainable housing is welcome but this should be emboldened by a clear indication of where the majority of growth may be directed and why. Following the adoption of a spatial
strategy it is recommended that the Vision is updated to include where the majority of development will be directed to, and that this should identify the larger settlements as providing the best opportunities for the majority of sustainable development.
2.5 We also consider that the objectives are too ambiguous in relation to affordability and recommend that there should be a distinct objective to improve the affordability of housing in Rochford District, as identified in the spatial challenges.
2.6 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”.
(RLPSO, page 12).
2.7 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’).
This is significantly greater than the national average, and indicates housing affordability has worsened considerably in recent years.
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 In addition, 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. Whilst empirical data is currently limited, there are early indications there has already been an increased desire to move from more to less urban areas, due to a greater desire for homes with larger gardens, space for home offices, better access to good quality open space, and situated within less densely populated areas.
2.10 At the same time, the pandemic has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely expected there will be a degree of return to office-working, it is anticipated that the need for employees to be physically present within a particular office will be substantially reduced.
2.11 As a consequence, it can be predicted 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 rail 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 may well prove an increasingly popular 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. Ensuring a sufficient supply of homes will be imperative if the Council is to tackle the issue of housing affordability in the District.
2.12 The RLPSO’s proposed Strategic Objective 3 is:
“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 support this and, in addition, suggest this objective should recognise that the critical role house-building plays in supporting the local economy, and the economic benefits house building 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.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
2.16 We agree that Rayleigh should be identified as the highest ranked settlement, reflecting the wide range of services and facilities available, alongside sustainable transport options and employment opportunities.
2.17 The RLPSO estimates (Figure 7) the 2018 population of the town to be 33,663, equating to 39% of the District’s total population.
2.18 In preparing the Core Strategy (2011), the Council identified that 44.4% of the demand for housing on the Council’s housing waiting list was focused on Rayleigh.
2.19 The adopted Core Strategy also noted, at paragraph 2.68, that Rayleigh has the best access to services within the District. As a retail centre, Rayleigh is by far the largest in the District. The RLPSO recognises this, identifying Rayleigh as the lone Tier 1 settlement in the District.
2.20 Rayleigh is one of only three settlements in the District served by a railway station, and is better served by bus services than the majority of the District. Combined with the range of facilities and services contained within the town itself, it perhaps has the best
potential of the District’s settlements to accommodate growth without reliance on use of the private car.
2.21 It is clear that a significant proportion of the District’s housing growth should be directed to Rayleigh as part of any spatial strategy, and that such development would be
sustainable.
2.22 Finally, it is not clear that Hockley and Rochford (including Ashingdon) provide only local services, as set out in the hierarchy and we recommend the assessment could benefit from not elevating Rayleigh too far above these other settlements, with the implications this may have on growth in these other sustainable locations, the scale of inward investment, and the benefits that come from development.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
2.23 Given the market and affordable housing needs, affordability issues and heritage and environmental constraints in the District, it is important that the overall strategy seeks to provide a wide range of housing options throughout the Plan period in suitable locations. As such, the strategy should utilise a range of different sites to maximise options to bring forward these new homes and associated infrastructure.
2.24 The temporal dimension of any strategy will also be an important consideration. The Local Plan should seek to ensure that homes can be provided across the plan period, including within the early years. Indeed, it is particularly important for the strategy to deliver homes in the early years of the plan period, given current housing needs against housing delivery.
2.25 For the Local Plan strategy to be sound, we consider that it will need to direct a significant proportion of housing growth to Rayleigh as the most sustainable settlement in the district.
2.26 We consider Option One to be far less likely to result in a sound Local Plan, or to deliver attractive sustainable development that would be welcome in the district, in comparison to the other Options. Option 1 (urban intensification) states this option entails making best possible use of [our] existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations). The RLPSO claims this approach could deliver 4,200 dwellings over the next 10 years.
2.27 It is important to recognise that in order to be consider sound, the Local Plan is required to meet objectively assessed housing needs. The RLPSO reports that the minimum housing requirement for the District over a 20-year period is 7,200 dwellings.
2.28 If Option 1 were to deliver 4,200 dwellings, this would result a significant housing shortage in the District. This would result in significant negative social and economic
impacts – it would not deliver sustainable development.
2.29 Furthermore, we question whether urban intensification would deliver as many as 4,200 new homes unless densities were increased in a greater number of locations that simply the town centres. To achieve this would require an average of 420 dwellings per annum (dpa) to be sustained over a 10-year period. The Council’s Annual Monitoring Report
2019/20 reports that over the10-year period between April 2010 and March 2020, the District averaged delivery of 176.8 dpa.
2.30 The 1,768 dwellings delivered over this period included a significant number from allocations made through the Rochford Allocations Plan (2014), and did not merely comprise dwellings provided through the redevelopment of previously developed land / urban intensification.
2.31 It is also relevant to note that over the last 10 years, local and national policy has supported the redevelopment of suitable previously developed land for residential use. It is likely that much previously developed land that is suitable and viable for residential
development has already been redeveloped for housing.
2.32 It is also unclear whether a strategy of intensification could meet the range of different housing needs. The RLPSO appears to suggest that it would deliver a low proportion of affordable housing (only 800 out of a total of 4,200).
2.33 A further concern is whether urban intensification would result in the same level of infrastructure improvements and other community benefits that larger allocations are capable of delivering.
2.34 Finally in relation to Option 1, it is unclear what the spatial distribution of housing would be through this approach, and whether it would result in a sustainable pattern of growth.
2.35 Rather than relying on urban intensification, it is clear that if the Local Plan strategy is to be sound and is to deliver sustainable development, it will be necessary to release some Green Belt and allocate land for residential development.
2.36 The NPPF confirms (paragraph 140) that it is appropriate for Local Plans to make alterations to the Green Belt boundary, provided there are exceptional circumstances for doing so, and that these are justified and evidenced. It is considered that within Rochford, a case can readily be made that exceptional circumstances exist to justify the release of land from the Green Belt given the scale of the District’s objectively assessed
need, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet those needs.
2.37 With Option 1 failing to deliver the growth required, we consider the other options to represent far more appropriate strategies for the Plan and provide a short commentary on these below.
2.38 Strategy Option 2 is to focus on urban extensions, Option 2a focuses such growth on the District’s main towns; and Option 2b dispersing to all settlements based on the settlement hierarchy.
2.39 Option 2a would identify sustainable sites at the edge of settlements, which would include Rayleigh, to deliver a range of housing developments. This provides flexibility to utilise smaller sites to deliver homes earlier, alongside larger sites to meet the overall housing need, as urban extensions. Option 2b disperses the growth in accordance with a settlement hierarchy. There is merit in both Options, but would advise that when factors such as accessibility, service availability and constraints are considered, the same sites may well be identified under either option. Further, a rigid application of a settlement
hierarchy can be problematic if suitable sites in more sustainable locations are omitted in favour of following the hierarchy. Finally, lower-tier settlements are often overlooked for any development opportunities through a hierarchy approach, again potentially omitting suitable sites.
2.40 Option 3 focuses growth on one of three locations (west of Rayleigh (3a); north of Southend (3b); and east of Rochford (3c)). We consider there is merit to strategic scale growth that can help deliver significant infrastructure improvements, however, this needs
to be complemented by the delivery of a range of different sites, including those that can deliver in the shorter term and do not require significant infrastructure improvements. It is also important to reflect that the District comprises a number of distinct settlements
with their own identities and communities, all of which the Local Plan should seek to support. We therefore caution against concentrating on a few strategic allocations to
meet housing need as this may not deliver consistently over the plan period and may result in an inflexible approach for the authority if any of those sites do not deliver as expected. We therefore recommend that growth in and around existing settlements should always form part of the Council’s strategy.
2.41 Strategy Option 4 entails a mix of the other options, and rightly recognises that the allocation of strategic growth sites and the allocation of urban extensions are not mutually exclusive. We consider this option to be the most appropriate for Rochfrod district and note that it scored positively in the Integrated Impact Assessment (IIA) in relation to its social, economic and environmental impacts. This option will allow current housing needs to be addressed in the short and medium term while enabling provision for strategic allocations. It will also allow for proportionate growth to be directed to the
District’s various communities through settlement extensions, including Rayleigh, whichwe consider should always form part of the distribution strategy to provide sustainable development.
2.42 A balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.
2.43 The Bellway Strategic Site at Hambro Hill can form an important part of such a strategy, delivering around 250 homes in a highly sustainable location. The Site is unconstrained, is partly developed already with good access, and can start delivering homes early in the
Plan period and through into the medium term at a character that respects Rayleigh while transitioning to open space beyond.
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?
2.44 We caution against applying the same approach everywhere in the District as different areas within Rochford are very different to one another.
2.45 With over 300 listed buildings and 10 conservation areas in the District, clearly some areas have a historic nature that needs to be considered, whereas others will not.
2.46 Should the Council seek a District wide place-making charter, this will need to be relatively high level to ensure that it does not unduly restrict development and prevent it from being appropriate to its context, as recognised in Section 12 of the NPPF 2.47 Any place-making charter should be formulated through consultation with stakeholders, including developers, to ensure that it is realistic, achievable and does not result in development becoming unviable. Such a charter should be published as part of the Local Plan to ensure that all parties have an opportunity to comment and input.
Q16a. Do you consider the new design guides, codes or masterplans should be created alongside the new Local Plan?
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?
2.48 Given the pressing housing and affordability needs within the District, it is important that homes are delivered as soon as possible. This is particularly pertinent given that adoption of the Local Plan is not anticipated until late 2023 at the earliest. We primarily recommend that design guides, codes and Masterplans are not necessary in order to achieve good quality development, and the planning system is capable of ensuring good design is achieved without the need for additional layers of design work to be added to the process.
2.49 If the Council seek to deliver design guides or codes, these should be developed alongside the Local Plan with input from stakeholders to ensure that once the Plan is adopted development can commence without delay. There is otherwise the risk that the Council adopt a Plan but development is significantly delayed, to the detriment of residents in need of new homes.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of
housing?
2.50 With areas within the District having different characteristics and development over the Plan period likely to be of varying scales, it is important for developments to be able to provide homes suitable for the site and location. A fixed housing mix across the district will not work, as different locations are suitable for different lifestyles. Option 2 provides flexibility, which is welcomed and this is the option we believe the Council should proceed with. It also recognises that different scales of development can be better placed to
provide greater flexibility of types of housing, such as self-build Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred?
2.51 We consider the provision of additional parkland has the potential to have numerous ecological and social benefits. In particular, the Central Woodlands Arc Regional Parkland appears to have considerable potential to provide an alternative recreational
destination to internationally important habitats within the District, including Special Protection Areas.
2.52 From Figure 32 of the RLPSO, it appears that the proposed extent of the Central Woodlands Arc Regional Parkland, passes very close to – or even adjoins – the extent of existing settlements, including in Hullbridge. If such parkland is to be provided, it is considered that it should be located such that it can be sustainably accessed by existing and future residents. However, at the same time, it is important that the precise
boundaries of any such designation do not preclude highly sustainable sites for housing from consideration for residential allocation.
Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
2.53 We agree with the principles of the vision. We would caution against identifying a strict boundary for the settlement area, as the experience of the urban area does not have a clean cut off between (for example) Rayleigh and Hockley. Accordingly, we consider that Hambro Hill (105) is better aligned to Rayleigh than to Hockley and should be considered in that regard.
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?
2.54 Land at Hambro Hill, Site CFS105, is on the boundary of the area identified in figure 44.
The land should be included within the area of Rayleigh for the reasons above. That is, the site is most closely associated with Rayleigh and would be capable of providing a sustainable and attractive development on a despoiled site in the highest tier settlement
in the district. To associate the site with Hockley misses the spatial position of the site adjacent to the boundary with Rayleigh, with a considerable area of open space between the site and the urban edge of Hockley, extending to some 80ha. This appears to follow the political ward boundary but has little relationship to how the site is experienced and its relationship to Rayleigh. We strongly recommend that this is corrected.
2.55 The site should be used to provide housing alongside new public open space.
2.56 The site already benefits from access to existing infrastructure and would therefore
represent and effective and efficient use of land. The site is within walking distance of
all categories of school, GP surgery, open space, the Town Centre and the rail station, all of which are made even more accessible with the ready access to bus routes. 2.57 Accordingly, the site should be identified as part of Rayleigh and we consider it to be ideally located for residential development, as identified by the Council in the SHELAA. The only constraint on the site is its current Green Belt designation. The need to release
land in the Green Belt is covered elsewhere in these responses, alongside a comparative assessment of the harm of releasing this site from the Green Belt, which is considered to be superior to other more high performing green belt land, while on other criteria the site scores no worse that vast tracts of land in the district.
2.58 The Site represents a logical extension to Rayleigh that would provide a sustainable development of around 250 dwellings. The Site is well placed to deliver much needed homes for residents, whilst contributing towards local infrastructure, both directly from the development and in the long term from spending in the local economy by residents. With the exception of the Green Belt policy constraint, it is unconstrained and represents a logical ‘filling in’ of the existing development pattern.

3.0 Comments on Integrated Impact Assessment
Assessment Framework
3.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identify.
3.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?
3.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.
3.4 The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. 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

1. INTRODUCTION
1.1 Rochford District Council is seeking feedback from interested parties on its identified ‘Options’ in the
New Local Plan: Spatial Options document.
1.2 Lee Evans Planning have been instructed to make representations on behalf of Ms Suzanne Redwood,
Mr Roger Lambourne and Mr Colin Humphries.
1.3 Section 2 sets out relevant extant Planning Policy considerations.
1.4 Section 3 reviews and comments on the Spatial Options document, including providing responses to
Questions outlined in the Consultation.

2. CURRENT POLICY POSITION
National Planning Policy Framework
2.1 The National Planning Policy Framework sets out the meaning and role of sustainable development and how planning can help to achieve it. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.
2.2 A rising population and longer life expectancy requires growth and an increase in the volume and
choice of housing. The NPPF identifies the need to complement this growth with high standards of
design and to protect our built, natural and historic environments. The NPPF also highlights the
fundamental role that sustainable development plays in the plan-making and decision making process.
So that sustainable development is pursued in a positive way, at the heart of the Framework is a presumption in favour of sustainable development
2.3 The NPPF serves to provide a framework around which the community and the councils can produce
the local and neighbourhood plans, which reflect the needs and priorities of the community.
The National Planning Policy Framework must be taken into account in preparing the development plan, and is a material consideration in planning decisions.
2.5 Paragraph 8 of the NPPF reiterates the role of the planning system and the contribution it must make to realising sustainable development. Sustainable development has three dimensions to it; economic,
social and environmental.
• an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and
coordinating the provision of infrastructure;
• a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and
• an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate
change, including moving to a low carbon economy.
2.6 The NPPF considers in further detail the need to protect and improve the quality of the built, natural and historic environment. One aspect of this aim is to widen the choice of quality homes. This can be achieved through the plan-making process, as discussed in paragraph 11.
Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet the development
needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when
assessed against the policies in this Framework taken as a whole.
2.7 Paragraph 60 notes the need to boost the supply of homes through land allocation. To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.
2.8 Paragraph 61 outlines the approach to determining housing need. The New Local Plan; Spatial Options
document is unclear on the degree to which the duty to cooperate has been explored with neighbouring areas, suggesting that at present the assumption should be made that all identified housing need must be delivered within the district.
To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
2.9 Each year the local planning authority will identify their supply of specific deliverable sites to provide the next five years of housing with an additional 5% buffer. This will allow for both choice and competition in the market. Developable sites that can accommodate for years 6-10 of the plan period and beyond will also be identified.
2.10 A 10% buffer should be provided “where the local planning authority wishes to demonstrate a five year
supply of deliverable sites through an annual position statement or recently adopted plan, to account for any fluctuations in the market during that year”.
2.11 A 20% buffer should be provided “where there has been significant under delivery of housing over the
previous three years, to improve the prospect of achieving the planned supply”. The NPPG elaborates
by stating that “A 20% buffer will apply to a local planning authority’s five-year land supply if housing delivery falls below 85%”.
2.12 If a five year supply of deliverable housing cannot be demonstrated policies relating to the supply of housing should not be considered to be up-to-date. All housing applications should be considered on the basis of a presumption in favour of sustainable development as has been discussed above. The most recent Authority Monitoring Report (draft 2019-2020), suggests that there exists a district housing need of 1,800 homes over a five year period (equating to 360 homes per year) and that the Council could at that time illustrate a 6.32 year housing land supply at a 5% buffer level, and 5.53 year supply at the 20% buffer, albeit it is noted that this was only draft and requires updating for the 2020-2021 period. The current supply is unknown but the Spatial Options document notes that the need for 360 homes per
year over the course of the Plan (20 years), equating to 7,200 homes total, remains. This figure does not include for assisting other districts in the duty to cooperate or any 5/20% buffer, so could well be higher. Notwithstanding this, there is a clear need to increase the allocation of housing land in the new Local Plan to illustrate the potential for 7,200 homes to be delivered.
2.13 Paragraph 73 highlights the opportunity for larger scale development and the benefits of this approach
in achieving the necessary supply of housing. It is possible that new settlements or extensions to
existing settlements can provide a route to sustainable development.
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, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).
2.14 Paragraph 23 notes that Local Plans should plan positively for development by allocating sites for
development and identify land where development would be inappropriate due to its environmental or historic significance.
Broad locations for development should be indicated on a key diagram, and landuse designations and allocations identified on a policies map. Strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning or and allocating sufficient sites to deliver the strategic priorities of the area
2.15 Paragraph 138 of the NPPF refers to the purposes of the Green Belt;
Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
2.16 Local Plans will be examined by an independent inspector before they are adopted. To be considered
ready for adoption they will need to be shown to be ‘sound’, as per paragraph 35 of the NPPF;
Local plans and spatial development strategies are examined to assess whether they have been
prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are
‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. Rochford District Core Strategy and the Allocations Plan
2.17 The key strategic documents in the local development plan are the adopted Core Strategy 2011 and the Allocations Plan 2014. These are both dated documents and would be considered out of date where
the content conflicts with NPPF policy. Nonetheless, they provide a useful basis against which to subsequently consider the options in the New Local Plan consultation.
2.18 The following exerts are of interest;
District
2.41 “Failure to provide affordable housing that meets the needs of the District’s residents may lead to
continued out-migration, to the detriment of the vitality of local communities.” (p31)
Rayleigh
“The largest settlement is Rayleigh which, in 2001, was home to 30,196 people (38% of the District’s
residents at that time).” (p28)
Housing Development
2.39 “As well as directing housing growth to areas of need/demand, and away from unsustainable
locations subject to constraints, the Council must consider the relationship of housing growth to areas
of employment growth.” (p30)
Vision – Medium/Long Term “A range of high-quality, sustainable new dwellings that meet the needs
of local people of all social groups are in place and integrated into communities. The vast majority of
the District’s Green Belt remains undeveloped. New infrastructure has accompanied new residential
development, meeting the need of local communities.” (p41)
Policy H1 – the efficient use of land for housing
“The remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land will be met through extensions to the residential envelopes of existing settlements as outlined in Policy H2.” (p45)
The Green Belt
Housing Objective “Prioritise the redevelopment of appropriate brownfield sites for housing, to minimise the release of Green Belt land for development” (p41).
“In order to fulfil the requirements of the East of England Plan and to meet the housing need of the District, the Council is required to allocate additional land for residential development, including land, which is currently allocated as Green Belt, due to the limited supply” (p45).
“it must be also mindful of the need to maintain Green Belt as far as possible.” (p46)
2.19 The extant Core Strategy outlines a strong protection of the Green Belt, as per national policy. However, this was predicated on an old housing need and supply, which is now out of line with current demand
and what can be achieved through existing permissions, allocations, brownfield sites and windfall forecasts. Rayleigh is considered a focal settlement and one that has both a sizeable population already and the infrastructure to service those residents.
2.20 Notwithstanding the above, the Council recognised the need to review the designation of the Green Belt in the face of the relatively low housing need at the time the Core Strategy was drafted. It states;
The Council will continue to support the principles of restricting development in the Green Belt, as set out in PPG2, and will preserve the character and openness of the Green Belt. However, a small proportion of the District’s Green Belt will have to have its designation reviewed to allow the development of additional housing and business premises, taking account of the very limited
opportunities to accommodate further development within existing settlements.
2.21 This position regarding housing need and lack of land supply (before moving onto Green Belt land), will
be felt more acutely during the drafting of this new Local Plan.

3. NEW LOCAL PLAN: SPATIAL OPTIONS QUESTIONS
3.1 It is noted that in its introductory section the Spatial Options document considers the need to “coordinate the delivery of much needed housing”. It also states that;

“Rochford should consider every opportunity to meet its own housing needs within its own authority
area, with a focus on genuinely affordable housing that meets genuinely local needs”
3.2 Given the extent of Green Belt in this part of South East Essex, it is considered likely that as in Rochford,
surrounding districts will find it difficult to deliver their full quota of required housing land supply within
existing settlements and on brownfield land, i.e. there will be a need to use Green Belt. To this end it is
submitted that they will be unable to offer assistance to Rochford in providing surplus land to accommodate housing delivery. We support the Spatial Options document in the above assertion.
3.3 This will necessitate a review of Green Belt designation to a greater extent than that previously carried out with the adopted Core Strategy. As noted above, Green Belt serves 5 purposes; “to check the
unrestricted sprawl of large built-up areas, to prevent neighbouring towns merging into one another, to
assist in safeguarding the countryside from encroachment, to preserve the setting and special character of historic towns and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” It is submitted that where these matters are less acutely felt, and in those areas of lesser
landscape quality, new housing land allocations could be proposed within the currently designated Green Belt, to assist with achieving the necessary housing land supply. The Core Strategy acknowledges this approach;
The term ‘Green Belt’ refers to a planning designation and is not necessarily a description of quality of
the land. Land designated as Green Belt can include, primarily for historical reasons, developed land and
brownfield sites. As such, whilst it is considered that all land currently designated as Green Belt helps achieve the five green belt purposes as set out in the NPPF to at least a degree, some green belt land is less worthy of continued protection.
3.4 This is acknowledged in the New Local Plan: Spatial Options document, which considers 4no. spatial
options for delivery of necessary development and infrastructure. All but Option 1 would necessitate
the use of Green Belt.
Question 5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
3.6 We support the settlement hierarchy presented. This focuses development at the most appropriate
settlements in the order of their ability to support new development. Rayleigh benefits from a strong existing resident mass and thus has a viability for growth and expansion of businesses and communities. We would submit that the majority of new development, and residential site allocations, should be around Rayleigh.
Question 6. Which of the identified strategy options do you consider should be taken forward in the Plan?
3.7 We support Strategy Option 2 and in particular Option 2a. This option provides a balanced response to the housing need of 7,200 – 10,800 dwellings (delivering between 8,700 to 10,700 dwellings), the necessary mass to support a good level of new infrastructure and facilities, and the need to minimise as much as possible the release of Green Belt for development.
3.8 Option 1 would not deliver the required housing land necessary to respond to the identified housing
need over the course of the Plan, and as discussed, it is considered unlikely that other surrounding districts would be able to assist with additional land. Option 3 would necessitate a significant release of Green Belt and would have a significant impact on the character of the surrounding Green Belt due to the size of a new villages/towns. As with to Option 3, Option 4 would require a sizeable release of Green Belt and significant impact on surrounding land around any new villages/towns.
3.9 Figure 23 of the Spatial Options document provides a Sustainability Appraisal of the various Options and this illustrates the balance that Option 2 provides, albeit it is noted that Option 4 scores best.
However, due to its mix of strategies for the delivery of development we would note a concern that it would pose significant complexities in implementing. In order to achieve the development required the full mix of strategies would be required, and if one were to fail or be delayed (as is a real risk with new villages/towns), a shortfall in housing or employment space could result, putting the Council’s position at risk.
Question 56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
3.10 We support the vision for Rayleigh. It is and should remain the only Tier 1 settlement given its existing
population mass, infrastructure/facilities provision and ability to accommodate significant growth relative to other settlements. The growth and expansion of Rayleigh with urban extensions would generate a sizeable portion of the housing quota required to respond to the identified housing need. Through the development of the majority of those sites submitted for consideration around the edges of Rayleigh, this focal settlement could alleviate pressures on more rural settings and larger swathes of
Green Belt throughout the rest of the district.
Questions 56b, 56c, 56d and 56e.
3.11 It is submitted that land at Call for Sites references CFS044 and CFS256 would offer an opportunity to
contribute to identified housing need delivery in a Green Belt location that could maintain the five purposes of Green Belt and in a location that has reduced landscape quality but is also well screened from surrounding areas. The attached initial Scoping Landscape Statement and Transport Planning Technical Note support that proposal.
3.12 The Council have carried out an initial assessment of these sites, as below.

[SEE DOCUMENT FOR IMAGE]

3.13 Whilst the appraisals above highlight the impact upon Green Belt, as discussed it is submitted that most
virgin sites put forward will impact upon that designation. It is considered that a sequential assessment
of the districts Green Belt would be appropriate in this regard and could highlight those sites that would
have a lesser visual impact and still maintain the purposes of Green Belt as best possible. The above
sites are expected to respond positively in both regards. The accompanying Scoping Landscape Statement concludes thus;
The landscape is subdivided into paddocks and is not of the highest visual quality, but the structure is strong and there are valued elements within it. The site is well contained by woodland and hedgerows, which should be used to inform design work for any forthcoming development proposal. Development of the site would take place within the current Green Belt designation / boundary, but the impact of development upon the openness of the Green Belt would be limited, due to the site's location adjacent to the existing urban area, its location within an enclave of landscape defined by the urban area and the A127, and the fact that the site's character is already enclosed, offering few publicly
accessible viewpoints.
Development of the site would not bring about coalescence of settlement, due to the strong landscape
barrier represented by the A127 itself, and the extensive Pound Wood Nature Reserve to the south of it,
separating the site from Daws Heath. Should the site be brought forward for development, design work should be informed by a full understanding of local landscape and visual character. The enclosed and compartmentalised character of the site should be retained and used as a constraint for design.
3.14 The Sustainability Appraisal also scores the sites low on ‘Existing site access’. However, the
accompanying Transport Planning Technical Note identifies 3no. possible accesses to the site, two of
which would be new accesses. It comments thus;
A number of options have been identified as having good potential for providing vehicle access to the site to unlock its development potential and deliver between 200 and 300 residential dwellings as part of the new Rochford Local Plan.
Providing a sustainable transport link from the site to the north is considered important to unlock the full sustainable development potential of the site as there are a number of local facilities and services on this section of A1015 Eastwood Road including bus stops.
3.15 It is submitted that in other key criteria the sites score well in the Sustainability Appraisal and in
combination would provide a high scoring option as a residential/housing allocation (including market
and affordable).
3.16 It is submitted that generally the area of these sites is well suited to accommodating a moderate
amount of new development. It is well enclosed by existing built form with the edge of Rayleigh to the
immediate north and the A127 to the immediate south. As such it would not lead to an interruption of
open land and countryside to the detriment of the landscape and quality of Green Belt. Furthermore,
this area scores well in terms of its Walking Completeness Score, in particular the two sites identified,
which are adjacent to land scoring of 8-10.
3.17 In combination with other similarly sized sites in this location to the south east of Rayleigh, a good level
of housing land supply could be achieved across numerous parcels (each able to provide in the region
100 to 400 dwellings). This would not necessitate significant new infrastructure but rather upgrades to
existing. Furthermore, the delivery of this volume of dwellings across several parcels would allow for
the retention of important green spaces and structural planting in between, which could serve to
maintain the green character of this urban/rural fringe and complement the Green Belt beyond.
3.18 We Support the allocation of Open Space and Local Wildlife Sites to the east of Rayleigh. It is
submitted that development on or adjacent to these protected sites could negatively impact upon
them, through increased light/air/noise pollution and walker/visitors (in the case of the wildlife sites).
There is an added logic in retaining these sites as open space and wildlife sites (for their intrinsic value)
as they could double as Green Belt.

I have to put the point forward that there should be no more houses built in the area until a new road is built to take the extra vehicles. South of Lower Road, Hockley was proposed a very long time ago.

Infrastructure is roads, hospitals, doctors, schools. These services have not expanded but the housebuilding, and therefore population, has. You are just making our lives more uncomfortable.

1.0 Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options on behalf of Bellway Strategic Land in relation to Land North of Brays Lane, Ashingdon (‘the Site’).
1.2 The Site has previously been submitted into the Call for Sites, references CFS126 and CFS007, which Bellway Strategic Land are promoting together to ensure a
comprehensively planned extension to Ashingdon.
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 market and affordable housing need in a logical way at the edge of an existing settlement.
1.4 The only current constraint to development is the location of the Site within the Green Belt, with it being unconstrained in other regards. The Site can be used much more effectively to deliver around 250 new market and affordable homes to meet the identified needs within the District and provide new public open space.
1.5 A Vision Document (Appendix A) is submitted as part of these representations to provide further detail about the Site and its proposed development.
2.0 Response to Spatial Options Consultation Questions
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
2.1 A vision for each settlement could be helpful, but we would highlight that these should not be too restrictive. Given the length of time the Local Plan will cover, there will be changes in the local areas, some of which could be significant. It is important that the visions do not stop development reacting to such changes or the potential responding to new technology, and does not stifle innovation.
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?
2.2 We suggest that objectives of the Local Plan should include to improve the affordability of housing for people of Rochford District.
2.3 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”. (RLPSO,
page 12).
2.4 The most recent data available reports that the median house price in the District is 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). This is significantly greater than the national average, and indicates housing affordability
has worsened drastically in recent years.
2.5 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.
2.6 In addition, 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. Whilst empirical data is currently limited, there are early indications there has already been an increased desire to move from more to less urban areas, due to a greater desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.
2.7 At the same time, the pandemic has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely expected there will be a degree of return to office-working, it is anticipated that the need for employees to be physically present within a particular office will be substantially reduced.
2.8 As a consequence, it can be readily predicated 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 may well prove an increasingly popular 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. Ensuring a sufficient supply of homes will be imperative if the Council is to tackle the issue of housing
affordability in the District.
2.9 The RLPSO’s proposed Strategic Objective 3 is:
“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”
2.10 We support this and, in addition, suggest this objective should recognise that the critical role house-building plays in supporting the local economy, and the economic benefits house builder would have for the District.
2.11 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.
2.12 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.
2.13 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.
2.14 Furthermore, ensuring the provision of sufficient, suitable accommodation is important to securing investment and employers in the District.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
2.15 We agree that Rochford, including Ashingdon, should be highly ranked within the settlement hierarchy to reflect the wide range of services and facilities available,
alongside sustainable transport options and employment opportunities.
2.16 As the RLPSO recognises, Rochford and Ashingdon together form a functionallyconnected settlement.
2.17 Its ranking as Tier 2 is justified given the range of facilities available, but we would highlight that it would be beneficial for the settlement hierarchy itself to state ‘Hockley, Rochford and Ashingdon’, rather than referring to Ashingdon in the accompanying text only. This will be clearer and provide greater clarity to the decision maker.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
2.18 Given the market and affordable housing needs, affordability issues and heritage and environmental constraints in the District, it is important that the overall strategy seeks to provide a wide range of housing options throughout the Plan period in suitable locations. As such, the strategy should utilise a range of different sites to maximise options to bring forward these new homes and associated infrastructure.
2.19 The temporal dimension of any strategy will also be an important consideration. The Local Plan should seek to ensure that homes can be provided across the plan period, including within the early years. Indeed, it is particularly important for the strategy to deliver homes in the early years of the plan period, given current, acute housing needs.
2.20 For the Local Plan strategy to be sound, we consider that it will need to direct a significant proportion of housing growth to Rochford / Ashingdon.
2.21 As the RLPSO recognises, Rochford and Ashingdon together form a functionallyconnected settlement home to around 18,000 residents. Between Rochford town centre and a number of neighbourhood centres located throughout the wider settlement, the Rochford provides for a wide range of services and business spaces, including a number of specialist employment areas supporting nearby London Southend Airport. The
settlement also benefits from a railway station and has good public transport links, particularly when compared to much of the District.
2.22 Rochford / Ashingdon is characterised as a top tier settlement within the current Development Plan, i.e. one of the most sustainable settlements to which to direct
additional growth.
2.23 The Census 2011 suggested that Ashingdon Parish has an ageing population, with a
median age of 45, compared to the nation median of 39. Nevertheless, in 2011 over
20% of the population of Rochford and Ashingdon were aged 17 or under – children / young adults still make up a significant proportion of the local population, suggesting a
relatively large cohort of young people growing up in the area who may well wish to form their own households within the community in which they were raised. However, in the last 10 years, the average price paid for a homes in Ashingdon has increased 61% and the current average dwelling value is estimated to be £337,818. This suggests a lack of housing supply compared to need in the area.
2.24 Rochford and Ashingdon benefit from a range of facilities, services and employment opportunities, many of which are located in Ashingdon, as shown in Figure 2 and discussed in the previous section of this document. This resulted it being categorised (along with Rochford) as a top tier settlement in the District’s hierarchy within the current Development Plan
2.25 Ashingdon was identified as a suitable location to accommodate a proportion of the District’s housing needs through the Rochford Core Strategy (2011) – an approach that was confirmed as sound through a robust examination of proposals. The characteristics of Ashingdon remain broadly the same as they were 10 years ago, and it is evidently still a sustainable location to accommodate some growth.
2.26 One of the options presented by the RLPSO is considered far less likely to result in a sound Local Plan or to deliver sustainable development: Option 1 (urban intensification).
The RLPSP states this option entails making best possible use of our existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification
could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations). The RLPSO claims this approach could deliver 4,200 dwellings over the next 10 years.
2.27 It is important to recognise that in order to be consider sound, the Local Plan is required to meet objectively assessed housing needs. The RLPSO reports that the minimum housing requirement for the District over a 20-year period is 7,200 dwellings.
2.28 If Option 1 were to deliver 4,200 dwellings, this would result a significant housing shortage in the District. This would result in significant negative social and economic impacts – it would not deliver sustainable development.
2.29 Furthermore, we question whether urban intensification would deliver as many as 4,200
new homes.
2.30 To achieve this would require an average of 420 dwellings per annum (dpa) to be sustained over a 10-year period.
2.31 The Council’s Annual Monitoring Report 2019/20 reports that over the10-year period between April 2010 and March 2020, the District averaged delivery of 176.8 dpa
2.32 The 1,768 dwellings delivered over this period included a significant number from allocations made through the Rochford Allocations Plan (2014), and did not merely comprise dwellings provided through redeveloped of previously developed land / urban intensification.
2.33 It is also relevant to note that over the last 10 years, local and national policy has supported the redevelopment of suitable previously developed land for residential use. It is likely that much previously developed land that is suitable and viable for residential development has already been redeveloped for housing.
2.34 Even if urban intensification could meet housing needs in full, it would be highly questionable as to whether such development would be suitable. To deliver such a quantum of development within existing settlement boundaries would clearly necessitate
significantly greater densities of development than existing. This in turn would likely result in harm to the existing character of the District’s settlement, and risk harm to amenity of existing residents.
2.35 In addition, it is unlikely that such urban intensification could meet the range of different
housing needs. The RLPSO appears to suggest that it would deliver a low proportion of affordable housing (only 800 out of a total of 4,200).
2.36 A further concern is whether urban intensification would result in the same level of infrastructure improvements and other community benefits that larger allocations are capable of delivering.
2.37 Finally in relation to Option 1, it is unclear what the spatial distribution of housing would be through this approach, and whether it would result in a sustainable pattern of growth.
2.38 Rather than relying on urban intensification, it is clear that if the Local Plan strategy is to be sound and is to deliver sustainable development, it will be necessary to release some Green Belt and allocate land for residential development.
2.39 The NPPF confirms (paragraph 140) that it is appropriate for Local Plans to make alterations to the Green Belt boundary, provided there are exceptional circumstances for doing so, and that these are justified and evidenced.
2.40 Exceptional circumstances are not defined in national policy or guidance. However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:
 The scale of the objectively assessed need;
 Constraints on supply/availability of land with the potential to accommodate
sustainable development;
 Difficulties in achieving sustainable development without impinging on the Green
Belt;
 The nature and extent of the harm to the Green Belt; and
 The extent to which impacts on the purposes of the Green Belt may be mitigated as
far as practicable.
2.41 Given the scale of the District’s objectively assessed need faced, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green Belt through the preparation of this Local Plan.
2.42 Overall, we consider that a balanced combination of utilising appropriate small scale and larger sites, on both brownfield and greenfield sites is the best approach to seek to meet identified housing needs within the District.
2.43 A balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.
2.44 Bellway Strategic Land’s Site north of Brays Lane can form part of this approach, delivering around 250 homes in a sustainable location. The Site is relatively
unconstrained and can start delivering homes early in the Plan period, continuing to deliver in the medium term. It has the potential to deliver much needed new market and
affordable homes to the area at a density and layout that reflects the existing pattern and character of development in the locality.
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?
2.45 We caution against applying the same approach everywhere in the District as different areas within Rochford are very different to one another.
2.46 With over 300 listed buildings and 10 conservation areas in the District, clearly some areas have a historic nature that needs to be considered, whereas others, such as east of Ashingdon, do not have such heritage considerations.
2.47 Should the Council seek a District wide place-making charter, this will need to be relatively high level to ensure that it does not unduly restrict development and prevent it from being appropriate to its context, as recognised in Section 12 of the NPPF. A small scale proposal on brownfield land in the middle of a town, for example, will have very different design requirements to a larger scheme of homes on the edge of a settlement.
2.48 Any place-making charter should be formulated through consultation with stakeholders, including developers, to ensure that it is realistic, achievable and does not result in development becoming unviable. Such a charter should be published as part of the Local
Plan to ensure that all parties have an opportunity to comment and input.
Q16a. Do you consider the new design guides, codes or masterplans should be created alongside the new Local Plan?
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?
2.49 Given the pressing housing and affordability needs within the District, it is important that homes are delivered as soon as possible. This is particularly pertinent given that adoption of the Local Plan is not anticipated until late 2023 at the earliest. If the Council seek to deliver design guides or codes, these should be developed alongside the Local Plan with input from stakeholders to ensure that once the Plan is adopted development can commence without delay.
2.50 There is otherwise the risk that the Council adopt a Plan but development is significantly delayed, to the detriment of residents in need of new homes.
2.51 An alternative could be to allow developers to produce design guidance for allocated sites with input from the Council, local community, etc. As set out in the submitted Vision Document, Bellway Strategic Land has begun to consider the design of the land north of
Brays Lane and how development could appear.
2.52 This has been based on technical work and an assessment of the nearby area, building on the successful scheme opposite. Whilst we are keen to engage with the Council, stakeholders and local community in relation to the layout to progress this further, it is not considered that detailed design guidance is required to deliver a successful scheme on this site given the work already undertaken and success of the scheme opposite.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of
housing?
2.53 With areas within the District having different characteristics and development over the Plan period likely to be of varying scales, it is important for developments to be able to provide homes suitable for the site and location.
2.54 Option 1 appears too inflexible in this regard and does not recognise that individual areas have different needs in terms of housing requirements. Such an approach risks being overly restrictive and not allowing development to be appropriate to its context.
2.55 Option 2 does provide such flexibility, which is welcomed and the option we believe the Council should proceed with. It also recognises that different scales of development can be better placed to provide greater flexibility of types of housing, such as self-build.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
2.56 Utilising a range of sites across the District, especially edge of settlement extensions,
can provide significant opportunities for new green and blue infrastructure.
2.57 As set out in the Vision Document, land north of Brays Lane can provide significant new public open space, connecting to footpaths in the wider area. This will assist in delivering new green infrastructure for both existing and future residents.
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing?
2.58 Whilst we agree with the principles of the vision, it should also include reference to the provision of new homes to meet local needs and help sustain the existing services and facilities.
2.59 Not providing any new homes in the area risks affordability issues worsening and negative social and economic impacts.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rochford and Ashingdon?
2.60 Land north of Brays Lane should be utilised to provide new market and affordable homes, alongside new public open space, site references CFS007 and CFS126.
2.61 Utilising such locations already benefitting from infrastructure allows development to commence early in the Plan period to start delivering homes.
2.62 As set out in the Vision Document, the Site is within a sustainable location in close proximity to a wide range of services and facilities within easy reach by sustainable
transport methods.
2.63 The Site represents a logical infill adjacent to the existing settlement, extending no further east than existing development to the south.
2.64 The Site is currently defined as being within the Green Belt, being the only constraint to its development.
2.65 Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’) considered the Site as part of Parcel 61 in the Stage 1 Assessment. Parcel 61 is a large area of land covering the entire eastern side of Rochford and Ashingdon. Clearly an assessment of this size parcel of land has limited use when assessing specific sites given that the characteristics are very different. We would caution the Council against giving this weight in the assessment process. Instead, as identified through the Welwyn Hatfield Local Plan Examination, it is important that Green Belt is considered at a sufficient fine grain. In the Examination of this Local Plan, the Inspector advised as follows: “The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied
to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might reasonably be considered further”. (EX39 of the Welwyn Hatfield Local Plan Examination, December 2017).
2.66 The Green Belt Study (2020) Stage 2 assessment did not consider the Site specifically in detail. The Site was considered as assessment area AA112. However, only a brief assessment is provided with an overall conclusion on the level of harm rather than a detailed assessment against each purpose of the Green Belt.
2.67 The Green Belt Study (2020) found that the Site makes a moderate contribution to preventing sprawl of the built-up area and a strong contribution to preventing
encroachment on the countryside. For any site not already within a built up area, these conclusions are highly likely to be similar, which must be recognised. Furthermore, as the Site is bounded by existing residential development on three sides, it is important to
consider how its development would be perceived, which is as an extension to the built up area rather than a site within the countryside.
2.68 The Site would ‘round off’ the existing settlement pattern and is already well connected to existing development. As such, it is considered to have low potential to lead to unrestricted urban sprawl when considered against purpose 1 of the Green Belt.
2.69 In relation to purpose 2, the Site is some distance from the nearest other settlement, being approximately 2 miles from Canewdon to the east. Its development would not have any risk of either actual or perceived coalescence of Ashingdon with any other
settlement.
2.70 In respect of purpose 3, there is no existing, strong defensible boundary between the urban area and adjoining countryside. There are hedgerows associated with existing garden boundaries, but no dominant landscape feature. Existing development is present
and visible within the landscape, with the site providing an opportunity to reframe this edge. The Site is not currently considered to strongly assist in safeguarding the
countryside from encroachment.
2.71 The Site is not adjacent to a conservation area or any listed buildings. Ashingdon itself has a limited number of listed buildings, with two to the very north and to the south a considerable number within Rochford. This is pertinent given that there are over 300 listed buildings within the District. The Site makes no contribution towards preserving the setting and special character of historic towns in respect of purpose 4.
2.72 In respect of purpose 5, this is only applicable where development needs can be met in full on previously developed land. For Rochford District, this is not an option as the amount of market and affordable homes that could be delivered is significantly below the
identified need.
2.73 The above assessments have been informed by the site-specific Landscape / Visual
Appraisal prepared for the Site and previously submitted to the Council. Overall it is
considered that the Site makes limited contribution towards the purposes of the Green Belt, and its residential development would not undermine the strategic purposes of the Green Belt.
2.74 The Council’s SHELAA 2017 considered that the Site is available and achievable, with the suitability dependent on an assessment of the Green Belt purposes. It was considered suitable in other regards. As set out above, the Site is considered to make limited contribution towards the Green Belt purposes and should be considered suitable, available and achievable.
2.75 As set out in greater detail in the submitted Vision Document, the Site is unconstrained and located in an already sustainable location. It can provide around 250 new homes, including a mix of sizes, market and affordable.
2.76 With infrastructure already in place, homes can start to be delivered early in the Plan period to meet identified needs.
2.77 The proposal on the Site is of a scale suitable for its surroundings, reflecting its location
adjoining the built up area of Ashingdon. It can reflect the popular and well received
Bellway development opposite on the south of Brays Lane, continuing this high quality design to provide new homes and public open spaces.
2.78 Overall, the Site is well placed to deliver much needed homes for residents, whilst contributing towards local infrastructure, both directly from the development and in the long term from spending in the local economy by residents. With the exception of the Green Belt policy constraint, it is unconstrained and represents a logical ‘filling in’ of the existing development pattern.

3.0 Comments on Integrated Impact Assessment
Assessment Framework
3.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups
in the community; and 2) maintain and enhance community and settlement identify.
3.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs
of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities,
including specialist services for disabled and older people?
3.3 We support the above decision-aiding question, but suggest that, in addition to meeting
the District’s housing needs (including affordable housing), the Local Plan should seek
to improve the affordability of housing for local residents.
3.4 The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened
significantly in recent years – and to a much greater extent than the national average. 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.

Please see below our supportive comments on the Council’s Spatial Strategy Consultation, forming part of the new Local Plan process.

Q. 6. Balanced Option 4 .

Land North of Southend CFS 260 ( including the linked lettered sites ) is supported and should be able to provide a large tranche of new development that is required. The need for substantial land release is acknowledged, both for residential as well as employment. This site helps to fulfil the numbers for both Rochford DC and Southend BC. The site is large enough and capable of contributing to highway improvements to improve accessibility to the eastern end of the District and east Southend. Proximity to Temple Farm and Purdeys Industrial estates as well as the Airport is an advantage.

We would like to point out what could be misleading in the Site Appraisal Papers, …. CFS 261, Land to the East of Oxford Road, 147 Ha. is included in the North of Southend Cluster, instead of the East of Rochford Cluster. For clarification, our comments above on Q6 Option 4 do not refer to CFS 261.

As part of the Balanced Option, we support smaller schemes which can be brought forward whilst the larger strategic site is being worked up. They also have the benefit of a more diverse style of homes, spreading the commute journeys and meeting the demands of the market in terms of location. In particular we support…

CFS 126, North of Brays Lane. Besides proximity to The King Edmund School and Golden Cross Retail, this site has ready made access to Brays Lane. With release from Green Belt restrictions, construction could be undertaken at an early phase. Please note that under the Water Apparatus scoring that the main sewer passes through the site with 3 manholes accessible.

CFS 217 Land at Doggetts Chase, Rochford. Wedged between existing housing in Doggetts Close and the Public Open Space this site lends itself for development as sympathetically designed retirement housing.

CFS 218 Land at Oxford Road, Rochford . A small site at the end of Oxford Road and with two sides adjacent to the playing fields of the King Edmund School, this can no longer be accessed for agriculture. It is also compromised by manholes for the main sewer. Therefore its release from the Green Belt would be justified.


Q 53 Roads. In conjunction with Cluster North of Southend, CFS260, a new road could resolve a long-standing problem by linking the A 127 at Tesco /RBS roundabout, the Airport and eastwards towards Fossetts Farm and the east of the District.

Q 51. Connectivity. To improve the economic activity in Rochford Town Centre, especially for retail, efforts should be made to create a foot / cycle path more directly between Dalys Road and the Square. Currently the only way is via North Street where the pavements on both sides are very narrow as is also the road. When the development of the old hospital site took place, the NHS was reluctant to enter into a dialogue which would have created some community benefits out of this major development in the centre of Rochford. As a result there is a barrier across the town which should be addressed.

We live in Barling Magna and have done so for 35 years and never have we been so concerned about an issue.

I have serious concerns around the consultation document itself, it uses place names like ‘Stonebridge’ rather than a ward name, it has omissions of current ongoing developments , which when completed will add to the general congestion on some roads. Because, I was informed, they have consent they do not need to be shown as this reflects a call for new land. But surely we need to now about them to assess the overall amount of development in an area before we can assess if we can accept more.

It says, and Rochford has confirmed, ‘infrastructure first’, but there is no indication as to how or where this infrastructure would be - whether it be first or last, so how can one assess a site without knowing where the new road would go to get there?

The Council should not reach any conclusions until Government Housing Policy and numbers to be found has been confirmed.

The consultation has divided large swathes of offered land up into small parcels and invites comments on the parcels rather than the overall principal of a development in that area. This contributes to a very difficult to follow consultation made far worse by poor software running the consultation.

On the above points alone I question the validity of this consultation.

The consultation invites comments on the future categorisation of land, residential, employment, green etc. However, most of the land that has been put forward is currently green belt land, and it’s development would be against current RDC policies.

“The land in question forms part of the Metropolitan Green belt. Such land can only be developed for ‘Exceptional circumstances’ as detailed in the Planning Policy Guidance Note 2 (PPG2), and states in para 143 that Inappropriate development is by definition harmful to Green Belt’’ and in Para 145 that ‘’A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt.” There are exceptions but these do not include house building on anything other than a minor scale.

I suspect that most of the residents would wish it to remain green belt. What is the point of having green belt land if, just because it is easier to build on than brownfield it becomes an option in the next consultation etc. Government policy has indicated that the use of green belt land should not be assumed and indeed this classification could be sufficient to rule out its use other than for minor applications.

Now, more than ever, development should look to be sustainable, indeed it is beholden on our Cllrs and our Council Planning Dept to ensure that it is.

Sustainability comes in many shapes, from the loss of a land use, through the materials used for building plus a plethora of issues like heat pumps, solar, glazing etc and this must include the sourcing of such items, through to accessibility, congestion, new roads needed and reliance on various forms of transport, easy access to work, education, health etc. Economic sustainability must also be assured and this goes beyond economic delivery but also includes the longer term economic viability for both new and current residents.

Based upon the above I would make the following comments-

• No housing development, from Rayleigh eastwards, in the current green belt or on agricultural land should be permissible on sustainability grounds other than small infill of ribbon development areas, extension to existing dwellings in green belt and ‘granny flats’ where space and neighbour privacy permits etc. Allow residents to make the most of their properties rather than needing to move.
• All current green belt land adjoining woodland, parkland, ancient copses etc should be retained and reinforced as protected green space and backfill towards these important wildlife havens and CO2 catchments should be prohibited.
• The destruction of arable land should not be permitted. We need to be as self sufficient in food matters as we can be, importing from Canada or France for example is far less sustainable and could become more difficult in the future.
• Access to and through Hockley, Ashingdon and Rochford is beyond capacity and cannot be expected to take any more traffic. A journey that 15 years ago took 15 mins now takes 30 minutes minimum and often more. Traffic around Rochford is often at a standstill due to parking, deliveries etc and at the morning and afternoon busy times it is totally snarled up.
• Brown field sites and intensification of existing dwelling areas should only be developed with a very light touch unless easy access to jobs, schools etc without adding to road congestion can be imposed and maintained.
• Rochford should not accept development that is accessed by highways that are not within the district or where necessary facilities including jobs are not able to be provided within close proximity preventing the need for more vehicle movements on already over congested roads.
• Reliance on Southend facilities, the A127 within Southend and Bournes Green Chase etc. should not be countenanced. Southend has high unemployment in many wards and high deprivation in the central wards, good jobs that provide good incomes are scarce in Southend, Shoebury, Rochford, Wakering, Barling, Paglesham etc. Thus any new residents moving into the area will be driving in and out each day or trying to access trains with limited parking.
• The lack of suitable employment the further east you go is also a major factor in the sustainability of the economic issues. Barling on good run is 30 mins from Rayleigh Weir, more development can only slow this even more.
• All construction materials will have to get to the east of Rayleigh via already tired and congested roads causing yet more delays, polluted air and disruption for residents and importantly businesses in the east of Southend. The greater the congestion into Southend the fewer returning tourists and the fewer jobs in Southend!

On a more positive note and in recognition that RDC, BDC and SBC all have to provide some new dwellings that will probably not be able to be fully accommodated within the town centres or brown field sites there are a few areas where I consider development would be sustainable,
• Along the north side of the A127, accessed by a new slip road off the A127.
• Land adjoining or close to the A130 in the south Rawreth area, (CFS146,147,167,144,168,145,137,055,121 ) here sufficient development could take place in conjunction with Basildon and Southend to absorb much of the dwelling numbers currently required by Government whilst at the same being large enough to sustain education facilities, healthcare, small retail and supermarkets etc alongside leisure and sports. Good access is here for work with A130 to Chelmsford, A127 to Basildon and Rayleigh, A13 to Thames corridor etc and those commuting by train can access Rayleigh Station relatively easily (or even a new station). As when and if the A127 is ever upgraded into Southend adequately and as when and if their unemployment rates improve then more work opportunities will open up.

• I support strategy option 3a a massed development west of Rayleigh, indeed I see a small new garden town as the only sensible, sustainable and long term economic option. This would not destroy the country side around existing villages nor lead to more traffic and congestion issues east of Rayleigh. It also allows for co-operation from different authorities to work together for benefit of their residents.
• I do not support the other strategy options as a means to provide any significant numbers of dwellings.

More specifically


CFS064, CFS264, CFS040, CFS161, and any further development along or requiring access to the roads Church Road, Folly Lane, Folly Chase, High Road, Main Road, Aldermans Hill etc and all the way through to Rochford Town Centre via Hall Road and Stroud Green should be considered as over-development and an undesirable change of use.
These roads cannot be improved to accommodate the already excessive traffic. Some sites along or close to these roads are encroaching on potential wildlife areas and others are on the periphery of woodland etc. None of these sites would generate enough to provide the necessary highway improvements, even assuming this were possible, Rayleigh has singularly failed to sort out its traffic congestion problems despite many attempts to do so. Nor would they generate sufficient for the other infrastructure contributions that would be needed to make these areas better, more attractive areas to live in for both new and existing residents. The result would be a significant loss of amenity and worsening living conditions for the existing residents.

CFS004, Barling, this site could take a few houses as extension of ribbon development but the land would be better suited to be used as woodland or wild flower meadow to the rear, and form parking for the school to the front of the site if agriculture is no longer viable. The numbers suggested to be built on this site are way more than sensible, not least due to the location near a school, the specifics of the road there, the very difficult parking in the area and the risk of flood. 29 new homes means at least 29 if not far more vehicles going into and out of the village each day, more school places etc,.

All development in Barling, Little and Great Wakering on greenfield or agricultural sites should not be considered further. I have already discussed the sustainability of areas to the east of the district and here more than ever that is important. Also, however, this land offers a real buffer against the muddling of Southend and Rochford, which is intrinsic to the identity of the 3 areas and also offers open space and leisure for Southend residents in the east of the borough . Green space is hardly prolific in this sector of Southend. I also disagree with the ‘convenient’ adding of these three areas together to form a tier, Barling is not part of nor similar to the Wakerings and should be considered along with tier 4 villages.

The roads in the Barling area are small narrow roads often without pavements, there are sharp bends and ditches etc, these are rural roads and should remain so.

Most of us live in these areas and especially in Barling because we like the rural feel of the area. We want to preserve that way of life and major developments
taking years to build and then thousands of residents with cars causing congestion and poorer air quality will destroy it forever. Given the way the estuaries divide up our district we need to preserve the countryside within each estuary sector. Thames - Roach and Roach - Crouch.

I trust you will carefully consider the above points when deciding the outcome of the consultation and that you realise the strength of feeling of residents.

Thank you for taking the time to read our concerns and suggestions

With reference to the above Consultation , I have the following comments for your perusal.

I have lived in Great Wakering since 1972 , it was then a quiet village with lots of amenities serving a lovely community.
Over recent years there have been several housing developments which meant many changes to the village .
The village secondary school in the High Street was made the primary school and all school children over the age of 11 are now bussed to King Edmund School in Ashingdon Road, Rochford and this causes traffic chaos at peak school times with large double decker buses clogging up the roads.
Similarly the doctor's surgery once did a good job serving the community, now it is almost impossible to get an appointment due to the increased number of new patients being registered.
The High Street itself has never been improved to allow for the extra traffic with no parking/pick up facilities at the school for the children's safety.
Several of the local shops have closed as people seem to prefer to drive to the bigger stores, more traffic congestion.
A village is a community where people can depend on each other , with groups for pensioners, mothers and babies and sports clubs for children to get together and have fun after school ,in safety. I feel the larger the community the less likely these social places are being used , especially at times when people should be pulling together and caring for one another.

So with even more development these things will only get worse.
There are just two main roads into the village and if there are any major issues concerning evacuation this could cause major problems for emergency vehicles requiring access to the village as well as people leaving. There are also many more traffic accidents on rural roads where new residents are unfamiliar with the ways of the countryside and the necessity to take more care.

The area of Great Wakering is in reality a dead end so to get anywhere you must drive through Southend where the traffic conditions and congestion are a massive problem and more development to the east will only make this worse.

I love the village and hope it can be left as it is for many years to come. I realise housing development is necessary but feel brown fill sites should be the planners first consideration before taking over more of our rural countryside.

Thank you for reading my email

Re: Consultation on New Local Plan Spatial Options

I am writing to you to give my feedback on the new local plans for Hullbridge and the surrounding areas.

I have been a resident of Hullbridge for over twenty years and in this time have seen lots of change and development not only to Hullbridge but to the surrounding areas, but during this time have not seen many changes or upgrades to the local infrastructure.

I believe building more houses within Hullbridge would cause a negative impact to our village and our way of life, as follow:

• There will be more harm to the green belt land in our area, which should stay as green belt and be protected for future generations.
• More properties will be at risk of flooding and draining risks, and by 2040 Hullbridge will have a significant proportion of the village below sea level
• The impact on natural habitats of wild animals and birds being reduced or even lost
• The lack of accessible open spaces and amenities for people of all ages
• Loss of footpaths or bridleways which many people in Hullbridge and surrounding areas currently enjoy and use
• Only the First Bus group operates a bus service out of Hullbridge, which is the number 20 and only runs every 15 minutes. This was recently confirmed by a First Bus Group representative in an interview with the Echo Newspaper. If the bus is delayed or cancelled, which can happen and result in delays to people’s journeys. First Group have recently withdrawn the school bus service to Sweyne Park School. This has caused lots of problems and has had a detrimental impact to children/families that rely on this service and resulted in more traffic on the roads due to parents having to take their children to school. Surely this is not good for air pollutions within the area.
• The existing community infrastructure needs to be considered, with poor road links within the area and only one main road in and out of Hullbridge (Hullbridge Road/Lower Road). When these roads are restricted due to road works or quite recently where Hullbridge Road was partly closed completely due to a sink hole in the road and also Watery Lane being closed due to maintenance, the only way out of Hullbridge was via Hockley which caused chaos in both areas and resulted in long delays. People struggle to easily get doctor’s appointments at the local surgery. The school in Hullbridge has had to increase the yearly intake to accommodate new children moving into the area and local children are not always able to get a place within the school. Hullbridge only has one small play park for the children to use, whereas other areas have larger play areas and more leisure facilities.
• Due to the number of new houses already being built it now takes over 20 minutes to get out of Hullbridge either along The Hullbridge Road/Rawreth Lane or Watery Lane. The same applies in the evening when the traffic queues are just as long.
• The preservation of our rural coastal village outlook will be lost.

I believe by not building these houses in the Hullbridge, you will preserve our natural wildlife sites, local geological sites, and sites of specific scientific interest i.e., Hullbridge Meadows and Hullbridge Foreshores.

Over development of this area, has not only impacted residences of Hullbridge, but surroundings area as well. It is well known that roads such as London Road in Rayleigh and Crown Hill in Rayleigh are heavily congested at certain points during the day and at the weekend and trying to get through Rayleigh to Rayleigh Weir or back from the Rayleigh Weir to Rayleigh High Street at the weekend is awful and as my point above mentions is not good for air pollution within this area.

My suggestions would be that the council builds all new housing for this area within one location, possibly North of Southend where they could also consider including a school. Southend also has better transport links with two main railway lines going into the area and more bus routes available. This has been done at Beaulieu Park near Chelmsford which also now has a new school from preschool age up to secondary school and I believe will have a train station added in the future. This area is much larger than Hullbridge and can accommodate such development.

Good morning
Ref Numbers
Cfs027 Cfs098 Cfs086 csf029 cfs053
We strongly object to this proposed development. Rayleigh is already grid locked with traffic on the surrounding roads in this area. This is our precious green belt land, other ways should be found to achieve the plan. Particularly to the west of rayliegh where there is more access to the main road and rail network.
Please keep us updated on the project and note our objections.

Ref Numbers
Cfs027 Cfs098 Cfs086 csf029 cfs053
We strongly object to this proposed development. Rayleigh is already grid locked with traffic on the surrounding roads in this area. This is our precious green belt land, other ways should be found to achieve the plan. Particularly to the west of rayliegh where there is more access to the main road and rail network.
Please keep us updated on the project and note our objections.

SPATIAL OPTIONS CONSULTATION - NEW LOCAL PLAN
REF: CFS027, CFS098, CFS086, CFS029, CFS053
AND OTHER PROPOSED DEVELOPMENT SITES AROUND RAYLEIGH

Looking at the proposed development sites for Rayleigh, it is not difficult to conclude that we are quickly becoming engulfed as a borough within Greater London where Rayleigh’s identity will be erased. Rayleigh is a ‘Market Town’ and has an immense amount of history to preserve and protect.

Sunderland is one such place where surrounding villages have lost their identity with village backing onto village without any green space to separate identities. I have experienced the effect of suffocation this creates, which definitely has an effect on one’s mental health. Rayleigh and Hullbridge are within metres of realising this scenario!

The impact that the proposed plan will have on the area is immense – trying to cross Rayleigh by car from the Rayleigh/Hockley boundary to The Weir takes at least half an hour on a good day, where a journey to Duxford only takes an hour! The amount of traffic on our roads has increased twofold bringing with it an increase in pollution, which has already been reported as dangerously high at times in Rayleigh Town. Our health is at risk. Even trying to sit in your garden these days brings with it a ‘hum’ of constant traffic along the Hockley Road and trying to cross the Hockley Road on foot is like taking a risk with your life.

The effect that building to this scale will have on the A13 and A127 is incomprehensible. The A127 from 3pm onwards is already just a car park and the added traffic on the A13, although improvements are being made for Tilbury Docks traffic, will undoubtedly resemble the A127, especially with an unprecedented building plan around Linford and the proposed building of a New Thames Tunnel crossing. We are at crisis point without adding to this crisis.

Where is all the added traffic to go? We have no added infrastructure at all in Rayleigh. The most recent development in progress along Rawreth Lane was promised to include a new school and doctor’s surgery, but, yet again, developers appear to have pulled back on this promise and the Council fails to make sure such facilities are put in place. How are we, the public, to believe that these further proposed developments will cater for an increase in such essential needs? Without them our schools, doctors, and hospital (already at breaking point) will no longer be able to provide a decent level of service, if any. No wonder house sales have increased in the area with residents moving out.

The public’s mental health is seriously under attack. During Covid lockdowns it was literally a breath of fresh air to be able to walk in open spaces, especially where proposed sites between Wellington Road and Bull Lane are concerned, taking in the land behind Nelson Road, Albert Road and off the top of Bull Lane. As a community we need our open spaces for our sanity and to thrive. Nelson Road is already fast becoming a rat run and, as mention before, Hockley Road is becoming chocked with traffic. A new development on these sites will be extremely detrimental with a threat of losing Hockley Woods (another historic area connected to Henry VIII) to further development.

Rayleigh is a dumping ground for large estates of houses with even our children not being able to afford to live in the area. ‘Affordable homes’ are ‘not affordable’. It doesn’t help with people from the London area moving out of London to the suburbs adding to house price increases. My three children have had to leave the district, my youngest only being able to afford property from Manchester northwards! This also affects family dynamics, not only with children having to move to the other side of the country, but having to live at home into their thirties. Instead of all the massive executive homes being built, what is wrong with terraced houses to help our young buy at truly affordable prices and get on the housing ladder? It should also allow more land to be used more economically providing a greater number of homes. I’m not saying halt building entirely, but small pockets of building will be more acceptable than these such vast proposals.

Even if ‘locals’ wanted to buy, it appears London councils are buying up property in the area because it is cheaper than housing their residents in London, i.e. Hall Road development. What a blot on the landscape Hall Road is with houses packed in like slum buildings of old (on top of each other) and the height of properties being so overbearing. It appears this is what Rayleigh is to expect too by looking at the Rawreth Lane development and all that may follow.

There are very little facilities for the adolescent members of our community to engage in enjoyment, even when my children were young there was a huge lack of something for them to do and nothing appears to be available with the Council wanting to demolish the only community hall we have at Bellingham Lane. As a result of losing community spaces no doubt Rayleigh will be looking at an increase in crime (adding to a presently overstretched police force) and the influx of residents from London boroughs may well add to an increase in the already budding gang culture in the South East. These points have to be considered.

I strongly oppose to demolishing Rayleigh Mill Community Hall. To engulf the area in flats is unthinkable what with taking away visible access to The Mount and surrounding it in yet more concrete. Regal House will be so close to the proposed flats and reducing car parking spaces is also unbelievable. It isn’t easy to park in Rayleigh at the best of times and there is no park and ride scheme. I am aghast at a new community hall plan being so small, especially with the amount of increased housing that is being proposed in Rayleigh. It will no way be ‘fit for purpose’. As a resident, my family and I have/ utilise The Mill Hall on many occasions. Our community ‘needs’ this coming together space.

Surely sacrificing an area of green belt away from existing towns to provide a ‘New Town/Garden Village’ would be a better proposition to ease the impact that such a New Local Plan for the Rochford District would create. Fossetts Way requires serious consideration to ease the burden on Rayleigh.

Rayleigh is being suffocated and living within it is becoming suffocating too – it will no longer be the town it was. We have too much development already and to build at this level will kill Rayleigh’s energy and spirit.

For the above reasons, I am opposing such large schemes of development in and immediately surrounding Rayleigh.

The new local plan is as close to a disaster to the existing local community without an earthquake event.
It is not a new plan but simply a plan that continues the mistakes that have been made over the past decade.
Too many houses;
Green belt and Environmental impact noted and ignored;
Insufficient transport and infrastructure plans;
No acknowledgement that schools, doctors and social support providers lack behind or never turn up;
no protection of the identity of Rayleigh;
This plan will cripple the local economy and environment and finally join Rayleigh into part of the London conurbation that the green belt and responsible planners were supposed to avoid.

Development of land in Rayleigh and surrounding areas
Please please stop building on our beautiful countryside. We don’t have the infrastructure to cope with it. The main roads A127, A13 and A12 are horrendous to travel on now let alone when all these new developments are built. Trying to get an appointment with a dentist or GP is nigh on impossible and has been getting worse the more that new houses have been built.
Rayleigh and it’s surrounding areas are gradually going to become just another suburb of London. Stop allowing us to lose our identity as a market town with nearby rivers and woods and beautiful countryside. The new developments all boast about the ease of travel on our main roads and the surrounding countryside. The more they build the less countryside there will be and with the present climate change, more flooding.
Why are you allowing this to happen? You are supposed to represent the people of Rochford and Rayleigh but you aren’t.

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council’s in-house development arm, in support of the release of Land to the south of the former Adult Community Learning Centre (ACL Centre), Rocheway, Rochford (hereby referred to as the “Site” or the “Rocheway Site”) from the Green Belt and allocation for residential development.
1.2 The site is owned by Essex County Council (ECC) and is currently designated as existing open space in the adopted Local Plan. The Site has been used under license for 10 months of the year by Hambro Colts FC, a local youth football team. However, at the end of the 2020/1 football season the Colts relocated to a different ground in Hullbridge, which means that the Rocheway
Site is now without a community sports user and is not open for general public use.
1.3 The New Local Plan presents Rochford District Council (RDC) with an opportunity to take a
comprehensive approach to the consideration of open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate.
1.4 In this context, we therefore consider that the site has excellent residential redevelopment potential taking account of its sustainable location within walking and cycling distance of Rochford town Centre and the opportunity presented by the extant planning permission for the redevelopment of the former ACL Centre, granted under 17/00102/FUL, which would provide means of vehicle access to the site from the north.
1.5 Coupled with this, we propose that the loss of the existing vacant playing pitch space can be compensated for through better provision in terms of quantity and quality in an alternative suitable location

2.0 Background to the Site
2.1 The extent of the Site is shown on the accompanying plan at Appendix 1 of this document. The Site is currently designated as open space under adopted policy OSL1 and it falls within the Green Belt.
2.2 The Site is formed of playing fields to the south of the former Adult Community Learning Centre site (“ACL Centre”), constructed in the mid-1930s as a school which was later converted into its use as an ACL Centre. The designated open space to the south of the ACL was therefore originally intended as a playing field for the school and not as a purpose-built open space.
2.3 The Site is defined by strong physical hedgerow boundaries to its western, southern and eastern sides. Designated amenity open space at Millview Meadows is immediately to the west of the site and arable agricultural land is to the east. The Site located within easy walking distance of Rochford town centre’s many services, facilities and retail offer via safe, convenient and well-lit
pedestrian routes. Rochford town centre also offers regular bus routes to Southend-on-Sea and Rayleigh and mainline railway links to London Liverpool Street and London Southend Airport. The Site is considered to be sustainably located.

Planning History
2.4 The ACL Centre site directly to the north of the Site is subject to a planning consent, granted under 17/00102/FUL in March 2018 by Rochford District Council, for the redevelopment comprising a 60 dwelling Independent Living Residential Care Home (Class C2) and 14 dwelling houses (Class C3). The development is being implemented.
2.5 An extract from the approved layout plan is shown below. It includes a proposed spine road that would provide access to the dwellings to the west and the Independent Living scheme to the east. The access road extends through the site to its southern boundary with the playing fields.

[see document for image]

2.6 The development is phased to enable delivery of the 14 residential dwellings prior to the delivery of the C2 scheme. As part of this approach it was necessary for a displacement car park facility to be provided for the playing fields so that the future use of the playing fields would not be prejudiced. Therefore, application 17/00807/FUL was submitted to and in November 2017
approved by Rochford District Council for the provision of a car park and area for demountable buildings for use as a changing room to serve the playing field. This planning permission is subject to conditions, amongst others, requiring that:
● The car park area in its entirety should be constructed and operational prior to the commencement of the Phase 2 development on the former ACL Centre site.
● The demountable buildings forming the changing room and W.C facilities should be provided and made available for use prior to the beneficial use of the car park

2.8 From the above it is possible to confirm that the delivery of the displacement car park and changing facilities on the playing field land is triggered by the commencement of the Phase 2 part of the development on the ACL site.
2.9 The Phase 2 part of the development is yet to commence. The facilities consented under 17/00807/FUL are therefore yet to be delivered onsite.

3.0 Responses to the Spatial Options Questionnaire
Hierarchy of Settlements
Question 5 – Do you agree with the Settlement Hierarchy presented?
If not, what changes do you think are required?
3.1 Yes, we agree with the Settlement Hierarchy. It suitably recognises the availability of services and connections within each of the settlements and appropriately categorises them into tiers based on how the towns and villages perform in relation to both sustainability and employment.
3.2 Rochford is identified as a Tier 2 settlement and we consider this is appropriate in light of the range of services and community facilities it offers, and its overall sustainability. It would therefore be appropriate for a commensurate level of the District’s growth to be directed to Rochford town.
Spatial Strategy Options
Question 6 – Which of the identified strategy options do you consider should be taken forward in the Plan?
3.3 As a general comment, we note that the Council correctly identifies that the minimum number of homes it 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 arising from neighbouring authorities.
3.4 In particular it will be important for the Council to work closely with Southend Borough Council (SBC) which has a minimum housing requirement of 1,180 new homes per annum using the standard method. As the Council will be aware, SBC set out in its latest consultation that even
with Green Belt release, it is only able to deliver around 20,000 new homes to meet its 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 its housing needs in full. Rochford District Council should therefore plan for a level of housing growth that meets both their own needs as
well as the unmet needs of SBC.
Strategy Option 1 – Urban Intensification – we do not support this option.
3.5 In light of our comments above, this option must be ruled out as it fails to meet the needs of Rochford, let alone neighbouring areas.
3.6 This option alone would not provide the necessary quantum of land to meet the identified housing need. This strategy requires the least use of greenfield land and, by definition, would involve no further release of land from the Metropolitan Green Belt. We recognise that focusing purely on brownfield and under-utilised land provides opportunities for infill development, however this does
not allow for the necessary larger scale development options, would fail to deliver new infrastructure, and is not a sufficient option to provide the unit numbers and infrastructure Rochford requires.
Strategy Option 2 - Urban Extensions – we support option 2a insofar as it is relevant to the growth of Rochford town.
3.7 Option two is split into two sections. Section 2a focuses urban extensions in main towns. Option
2b looks to deliver urban extensions dispersed to settlements based on hierarchy.
3.8 Option 2 provides significantly better opportunities to deliver the housing and infrastructure
targets than Option 1. Option 2a ensures development is focused in sustainable locations where transport connections are established and sustainable to support the development, including Rochford town. New urban extensions focussed on the main towns in Option 2a gives the opportunity to provide additional services and facilities and provide improvements to existing
infrastructure to support the new development in addition to the existing communities.
3.9 Insofar as this option is relevant to Rochford town, we support the proposals in Option 2a to direct growth to suitable deliverable sites in and on the edge of Rochford.
3.10 We would be unsupportive of Option 2b if it would result in large scale development being directed to less sustainable locations in the district, such as the Tier 3 settlements, at the expense of suitable alternative locations in higher tier settlements such as Rochford town, including the Site at Rocheway. This would not be justified and a Plan based on this approach would therefore be unsound.
Strategy Option 3 - Concentrated Growth – we do not support this option.
3.11 A strategy option that seeks to deliver the whole local plan requirement for housing in a concentrated development (or concentrated developments) runs the very serious risk of being undeliverable. Too often local plans focus allocations on a small number of large strategic sites that inevitably come forward later in the plan period, or worse, fail at Examination. Whilst such
sites can be an important part of housing supply, their allocation should not be to the detriment of deliverable small and medium sized sites, such as the Site at Rocheway.
3.12 A clear example of the risks of concentrated growth is the North Essex Authorities, where three new Garden Communities were proposed to deliver a proportion of housing across three local authorities later into the Plan period. In 2020, following the Examination, the Inspector concluded that two of the three garden communities were not viable and therefore not deliverable, leaving the authorities without 37,500 planned new homes for the Plan period and beyond.
3.13 Another current local example of this is in Maldon, whose Local Plan (adopted in 2017) places a
substantive reliance on the large-scale Garden Suburbs. The latest 5-year housing land supply statement confirms that the supply of housing arising from these allocations is falling below the previously anticipated trajectories. This means that the Council cannot currently demonstrate a 5-year supply of housing.
3.14 We therefore consider that this option runs the very serious risk of non-delivery and is unlikely to be capable of being found sound at Examination.
Strategy Option 4 – Balanced Combination – We support this option insofar as it relates to the allocation of suitable available Greenfield sites on the edge of Rochford town.
3.15 Option 4 provides a balanced approach, allocating a variety of sites both in terms of size and location which would 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.
3.16 This Option also increases the opportunities for small and medium sized housebuilders to deliver
homes in the District. It provides good opportunities for sustainable growth within Rochford with an appropriate scale of development based on the settlement hierarchy. This option is not restrictive on the location or scale of development.
3.17 Based on the response set out above we are supportive of Options 2a or 4 insofar as they direct
proportionate levels of growth to the higher order settlements in the hierarchy, including Rochford
town. Our support for either of these two options is conditional on the proposed allocation of the
Rocheway Site, which is suitable, deliverable and sustainably located.
Open Spaces and Recreation
3.18 Our responses to Open Spaces and Recreation questions are in the context of the current designation of the Rocheway Site in RDC’s Allocations Plan as an area of Existing Open Space.
Question 38 – 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?
3.19 We support Option 3 as suggested by RDC which proposes to “embed a hierarchy approach into policy that seeks to prioritise and direct investment to the most important recreational facilities, including potential hub sites and key centres”. This would ensure that the funding and resource is appropriately directed to the most important, larger, locations where they are needed the most, to enable the provision and maintenance of higher quality facilities in the district in areas of high
utilisation. Coupled with this, we would support the rationalisation of low value playing pitch sites
that are rarely used and/or are without appropriate ancillary facilities, such as the Rocheway Site. As the landowner of the Rocheway Site, Essex County Council is also prepared to make a financial contribution towards the creation, improvement of, or extension to an existing multi-pitch hub site or key centre as identified in the Local Plan, to ensure that there is no net loss of pitch space.
3.20 We would therefore support the review of open spaces which do not feature within the list of hub sites and key centres, including those that are rarely used and without appropriate ancillary facilities, so that the case for rationalisation can be suitably planned for in the event such a course of action is deemed appropriate as part of the wider Local Plan proposals.
3.21 Land to the south of the former ACL Centre, Rocheway, is currently unused by the community
following its vacation by the Hambro Colts football club in 2021. This is not picked up in RDC’s Playing Pitch Strategy, which was published in 2018 and is now already three years old. The Hambro Colts were the sole users of the Site but now that it is vacant, following their move to alternative grounds in Hullbridge, the future of the Rocheway Site is uncertain. It would therefore be inappropriate for the Rocheway Site to be identified as a facility of “local importance” until an update to the Playing Pitch Strategy is undertaken in line with its own recommendation1 , which identifies that “without any form of review and update within this time period [three years] it would be difficult to make the case that the supply and demand information and assessment work is
sufficiently robust.”
3.22 The Rocheway Site is comprised of grass pitches and, in an era of challenging public sector budgets, their ongoing maintenance without a user in the community is an unnecessary burden.
This is compounded by the fact that local authorities, including Essex County Council as landowner of the Rocheway Site, are not eligible for Grass Maintenance Fund grants2
.
3.23 The Playing Pitch Strategy acknowledges on page 7 that “as the resources to improve grass pitches are limited, an increase in 3G provision could help to reduce grass pitch shortfalls through the transfer of play....”. The Local Football Facility Plan (LFFP) for Rochford, [repared by Knight, Kavanagh and Page (KKP) with support from local partners including The FA, Essex County FA,
Football Foundation, Rochford District Council, Sport England and Active Essex, was published in 2018. The purpose of the LFFP is to enable investment in football facilities to be accurately targeted. The LFFP is the go-to document for football facility investment in Rochford and aims to:
● create a network of 3G Artificial Turf Pitches;
● improve grass pitches;
● develop and improve changing rooms and pavilions; and
● develop small-sided football facilities, particularly for informal football.
3.24 The LFFP identifies eight priority projects for potential investment. Prioritisation has been
informed by local partners with the rationale of selecting sites in the poorest condition, that were most well utilised or of strategic focus to improve Local Authority pitches. These include:
● John Fisher, Rayleigh;
● Ashingdon Recreation Ground;
● Fairview Playing Field, Rayleigh;
● Great Wakering Recreation Ground;
● The Warren, Rawreth;
● Hullbridge Sports Association;
● Apex Sports Ground, Hockley; and
● Rochford Recreation Ground.
3.25 It should be noted that the Rocheway Site does not feature as a target for future investment within the LFFP.
3.26 In line with the conclusions of the Playing Pitch Strategy, we consider that where there are low value playing pitch sites that are rarely used and/or are without appropriate ancillary facilities, such as the Rocheway Site, they should be rationalised, coupled with a contribution towards the creation, improvement of, or extension to an existing multi-pitch hub site or key centre as identified in the Local Plan.
Question 40 – Are the listed potential hub site and key centres the
right ones? Are there other locations that we should be considering?
3.27 In line with our response to Question 38 above – yes, we agree that the hub sites and key centres referred to in the table are correct. We do not consider that “all other facilities” should be identified as being of local importance until the 2018 Playing Pitch Strategy has been updated to reflect changes of circumstance on sites that have occurred in the past three-year period, in line
with its own recommendations. This specifically affects the Rocheway Site, which is no longer with a user in the community and should not automatically be subject to continued designation as open space in light of this change in circumstance.
Question 41 – 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?
3.28 Yes, there is an opportunity to allocate the Rocheway Site for residential development, which is
now without a community sports user, to help deliver improvements to sport facility provision onthe hub sites and/or key centres in Rochford. This approach would deliver tangible planning benefits because the Rocheway Site is in a highly sustainable location near to the core of
Rochford town centre. It would therefore be extremely well suited to residential development.
Coupled with this, financial contributions collected as a result of the allocation and development of the Site could be directly used to help fund (and expand upon the scope of) the planned improvements to hub sites and key centres as identified in the Local Football Facility Plan for Rochford. This would provide a clear planning benefit that would accord with Sport England guidance and NPPF paragraph 99, which requires the “loss from the development to be replaced by equivalent or better provision in terms of quality and quantity in a suitable location”.
3.29 For ease of reference an extract from Figure 45 of the consultation document showing the sites
put forward for the development in and around Rochford is shown below.
[see document for image]
3.30 It may be seen that the Site is identified as an area of “Other Open Space”. Without a user of the playing pitches on the Site, it is of no benefit to the community in this retained use as it is not open for public use. It should therefore be re-allocated for residential development, as part of a wider strategy involving contributions from its development to help fund improvements to other
nearby sports facilities.
Question 42 – Are there particular open spaces that we should be
protecting or improving?
3.31 Yes, we consider that Millview Meadows in Rochford should continue to be protected and identified for improved accessibility, on the condition that an allocation for residential development of the adjacent Rocheway Site is key to unlocking these improvements.
3.32 Millview Meadows is a 4.5 hectare park located directly adjacent to the west of the Rocheway Site. The park is identified on the satellite image below
3.33 The most up-to-date evidence base that audits the quality of this park is RDC’s 2009 Open Space Study. It is identified as an “Amenity Greenspace” with the following description:
“Poor accessibility (situated between houses), no information sign identifying the area, pathway around open space, grass area with planting, some seating and bins provided, broken fence to rear of playing field, no lighting”.
3.34 The only formal means of access to Millview Meadows is via a narrow alley between two residential properties at Spindle Beams to the west, as correctly described in the Study. Access is convoluted and tortuous for any visitor who does not live in the adjacent estate.
3.35 The accessibility of Millview Meadows has not increased since 2009 despite its relative quality and maintenance staying the same. In light of its size and proximity to existing and future potential residents in the core of Rochford town, Millview Meadows is severely let down by its lack of formalised access point(s).
3.36 RDC notes that feedback from the Issues & Options consultation was clear about the importance of residents having access to well-maintained and accessible open and green spaces. The Rocheway Site offers the significant potential to improve access to this underused and underappreciated local park. But access improvements that maximise the benefit of this existing
local resource can only be delivered as part of a masterplanned approach involving the residential development of the adjacent Rocheway Site.

Planning for Complete Communities
Question 57a - Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing?
3.37 Yes, we agree with RDC’s vision for Rochford and Ashingdon. In particular, we note that the Vision Statement says that “its town centre should be reimagined to become a more sustainable and vibrant space whilst retaining its historic character. It should make the most of its proximity to key employment sites and London Southend Airport to significantly grow its economic potential and the range of jobs it provides for.”
3.38 The Vision is appropriate given the Tier 2 status of these two settlements. The best way of ensuring that the Vision is realised is by allocating suitable available deliverable sites for residential development on the edge of Rochford. Land south of the former ACL Centre,
Rocheway is capable of delivering residential development that would maintain the town centre’s
vibrancy and make the most of its proximity to key local employment sites.
Question 57b - With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare,
allotments, other]
4. Other
3.39 We consider that promoted site CFS050 should be allocated for housing. CFS050 is the Land south of the former ACL Centre, Rocheway.
3.40 The proposed development is market led residential housing. As CFS050 is a greenfield site, it is
capable of accommodating a policy compliant quota of affordable housing and infrastructure provision. As the Site’s promoter is also the landowner, Essex County Council, we can ensure that, if allocated, the loss of the existing vacant playing pitch space can be compensated for through better provision in terms of quantity and quality in an alternative suitable location, in
accordance with Sport England guidance.
3.41 There are few comparable sites in Rochford which offer such an opportunity to maximise the potential to enhance the completeness of the town. Land south of the former ACL Centre would enhance the completeness of Rochford
3.42 The NPPF states at paragraph 142 that when drawing up Green Belt boundaries, the need to
promote sustainable patterns of development should be taken into account. At paragraph 105 the NPPF states that “the planning system should actively manage patterns of growth in support of [sustainable transport] objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine
choice of transport modes”.
3.43 Allocation of this site for development would substantially improve the completeness of Rochford
because it is located within a highly accessible location very close to the town centre. This is perfectly encapsulated within the Walkability Map extract below, which shows that the Site is within the only part of the town where the highest scoring walking completeness area (shown by the yellow shading) overlaps with the open countryside to the east. A lack of any residential
development in this location would fail to capitalise on this excellent location which can help meet
RDC’s strategic objectives

[see document for image]

3.44 Further residential development to the eastern side of the town centre would capitalise on this location’s high walkability and access to services/facilities which, in recent decades, have not been realised as the town has essentially grown in other directions primarily to the north and west, with substantially lower walkability than the land south of the ACL Centre site at Rocheway.

3.45 Coupled with the above, the Site is only 800 metres (or a 10-minute walk) from Rochford train station, which provides regular mainline services to Southend Victoria, Southend Airport and London.
3.46 The Site is also within cycling distance of the district’s major employment areas including Southend Airport, Purdeys Industrial Estate, Rochford Business Park and the emerging Saxon Business Park.
3.47 Further development to the east, specifically at Site CFS050, would therefore plainly improve the
completeness of Rochford.
Land south of the former ACL Centre is suitable
3.48 The Site is a suitable location for development, is free from technical constraints and is unencumbered. To justify this assertion, we have extracted the Appraisal for the CFS050 site from RDC’s Site Appraisal paper as contained within the evidence base – see below.

[see document for image]

3.49 Against the assessment criteria in the Site Appraisal paper, site CFS050 scores very well. Most of its assessed criteria fall into the green (i.e. performing well/unconstrained), scoring either 4 or 5 out of a possible 5 points in respect of its suitability. The Site is noted as being deliverable for housing, subject to policy. We agree with this assessment, as there are no overriding constraints to development. In this respect it will be noted that the Site performs well against the criteria relating to ecology, resource, air quality, site conditions, access to facilities and Green Belt impact.
3.50 In respect of Green Belt, we note the findings of the Green Belt Study (Assessed under parcel AA120) and propose that the existing Green Belt boundary is re-drawn along the Site’s existing eastern boundary, which is formed of mature trees and hedgerow and could be strengthened as part of a scheme’s masterplan, so that the Site is included within a revised development
boundary for Rochford, in accordance with NPPF paragraph 143f).
3.51 In only one case does the Appraisal attribute a low score of 1 out of 5 – relating to “access to bus services”. Allied to this it should be noted that the Site scores 4 out of 5 against the “distance to bus services” criterion. We agree with this as the nearest bus stops to the Site are
less than 400 metres away, on East Street/North Street. But we do not agree that the Site has poor access to bus services. The extract from the Essex Bus Map3 below shows that the numbers 7 and 8 buses, frequent services at every 15 minutes, pass through East Street/North
Street on their way to local destinations including Rayleigh, Hockley, Southend Airport, central Southend and Shoeburyness, amongst other local villages. School services also offer transport to secondary schools in Rayleigh and Southend.

[see document for image]

3.52 Based on these observations, when assessed against the Appraisal’s methodology, the “access to bus services” score should instead be at least 3 out of 5.
3.53 In two cases the Appraisal attributes a low score of 2 out of 5 – relating to heritage (built assets)
and site conditions and hazards (water).
3.54 In respect of the Built Heritage, RDC’s Conservation Area Appraisal & Management Plan shows
that the nearest designated heritage assets (Grade II listed 26 and 28 East Street and the
Rochford Conservation Area boundary) are approximately 200 metres from the Site. It should be
noted that the development of the former ACL centre (consented under 17/00102/FUL) directly to
the north, there was no suggestion that the scheme would cause any harm to heritage assets.
According to the methodology, we therefore consider that the Site should be attributed a score of 3 out of 5 on the basis that, at the very least, any impacts could be mitigated through scheme design.

3.55 In respect of site conditions and hazards (water), the Appraisal attributes the Site a score of 2, which is defined in the methodology as “containing water supply apparatus or easements”. It should be noted that the development of the adjacent former ACL centre, which historically formed part of the same site as CFS050, is currently being delivered onsite. This means that the
presence of any water apparatus should not present an insurmountable constraint to development and would be accounted for as part of the design.
3.56 Taking account of the above, we consider that the Site is entirely suitable for development.
Land south of the former ACL Centre is available and deliverable
3.57 Land south of the former ACL Centre is in single public sector ownership and is wholly within the
control of Essex County Council. Essex Housing on behalf of Essex County Council has a growing track record of securing viable planning permissions for and then delivering sites for new housing across the County, including sites at Goldlay Gardens and Moulsham Lodge in Chelmsford, Norton Road in Ingatestone, the former County Hospital in Colchester, and the former ACL Centre at Rocheway adjacent to the north of this Site, which is currently being delivered. As the Site’s promoter is also the landowner, Essex County Council, it can be ensuredthat the loss of the existing underutilised and poor-quality playing pitch space can be compensated for through better provision in terms of quantity and quality in an alternative suitable location, in accordance with Sport England guidance.
Increasing the accessibility of Millview Meadows

3.58 As set out above, the release of the Rocheway Site from the Green Belt and allocation for residential development as part of the new Local Plan brings with it the opportunity to vastly enhance the accessibility to Millview Meadows, the public park to adjacent to the west of the Site which suffers from very poor accessibility despite being open to the public. It should be possible
to create new pedestrian access points into the park as part of a masterplanned new development on the Rocheway Site.
Enhancing local sports facilities
3.59 As set out under the relevant chapter heading above, the development of the Rocheway Site
offers the opportunity to direct financial contributions towards the substantive improvement of other local sports hub sites and/or key centres identified in the Local Plan and through the supporting evidence base, to ensure that there is no net loss of pitch space

Strategy Options.
Q6. Option 3a should be the preferred option as it naturally produces the required supporting infrastructure and is the least likely of all options to increase pressure on the existing infrastructure in the rest of the district. It could possibly be combined with a small amount of development elsewhere but that should be restricted to providing local employment opportunities and the housing needs of an ageing population, both of which should have less effect on infrastructure than general housing. However, it should be remembered that most of that ageing population are owner-occupiers who have spent their lives in houses with gardens and may not wish to move to apartments. If there were no bungalows developed for them with at least minimal gardens, they may be likely to stay where they are and so not free up family homes for others. This problem has already been exacerbated by the conversion of many bungalows in the district to chalets or houses.

Transport and Connectivity.
Q51. Option 1 is clearly the only way to minimise environmental damage.
Q53. The A127 should be the main East-West route and there may be potential to widen it from 4 to 6 lanes from the M25 to as far East as The Bell without major impact on more than a few adjoining properties. Additional traffic should not be encouraged on Lower Rd due to congestion at Hullbridge and the previously-suggested Rochford Outer Bypass or any similar proposal should continue to be rejected as it would increase pressure for development in greenbelt along its route, particularly where it linked to local routes.

Planning for Complete Communities.
Hullbridge.
Q60a. While I generally agree with the vision, I do not consider it practical for Hullbridge to be more accessible by river-based transport or for the coastline to be opened up without damage to the river’s environmental importance.
Q60b. It might be possible to develop a small business park for offices and light industrial uses on that part of site CFS100 on the West side of Burlington Gardens as that is a brownfield site, albeit in greenbelt.
Q60c. No other sites are considered suitable as most put forward are wholly or largely outside walking distance of the majority of services and are extremely unlikely to provide any additional services.
Q60d. If High Elms is included, Hullbridge will already have seen a20%+ increase in dwellings over the last 10-15 years so all other areas should be protected. Of the sites put forward, many are at least partly at risk of flooding, notably in Northern areas and along Watery Lane and its junction with Lower Rd/Hullbridge Rd and also Pooles Lane/Kingsmans Farm Rd. Those Northerly sites should also be rejected due to their proximity to the environmentally sensitive and protected River Crouch. Other sites should be rejected as they reduce the greenbelt distance between Hullbridge and Rayleigh/Hockley or are to the West of the High Elms development which RDC described as providing a ‘defensible greenbelt boundary’.

Plan for more houses in and around Hullbridge
I live in Burnham road
1)
We already have horrendous traffic build up nearly every day and some days cannot even get out of our village . The pressure these extra houses would cause is unacceptable
2) It is pretty impossible to get a doctors appointment now and no infrastructure appears to be being put in to accommodate the new houses already being built let alone more.
3 the local schools are overflowing are new schools being built?
4 more green belt land being built will turn what was once a lovely village into a concrete jungle
4) water pressure is now a problem since The new houses have been built, numerous burst water pipes already- even more houses and the pipes will not cope at all
5) Hullbridge has had enough disruption already with traffic lights springing up daily .
6 ). Please stick to brownfield sites

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

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

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

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

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

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

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

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

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

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

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

• Hello, please see my comments on the Spatial Options Considerations with particular regard to the following sites CFS027, CFS029, CFS053, CFS086 and CFS098. I strongly object to the redevelopment of the the areas listed above and I have summarised my reasoning below.
Traffic congestion/pollution
The proposal amounts to some 350 new properties being build along with new/upgraded access points. This will amount to a significant increase in traffic in the area and the resulting traffic pollution, traffic noise and highway safety concerns.
There are many children who use Victoria Park and Fairview park for their recreation and consideration should be given to their safety and wellbeing which could be impacted by the increase in traffic.
The local road infrastructure is not sufficient to deal with this increase in traffic. For example, Nelson Road is a very narrow road and is already used as a rat run, the increase in traffic volumes will further exacerbate the problem,
The same can be said of Helena Road, Victoria Road and Bull Lane. The increase in traffic volumes resulting from the proposed redevelopment will obviously make the situation much worse.
Rayleigh is already extremely congested with traffic. Take for example the Hockley to Rayleigh Road (B1013). This is already very heavily used, as is Hambro Hill, which is used a main thoroughfare between North Rayleigh and Hullbridge. This of course will also have adverse implications for Ashingdon, Hawkwell, Rochford and other surrounding villages
Parking is already a problem in Rayleigh town centre, the addition of several hundred cars will increase the strain on the already overstretched local parking facilities
Another consideration is the high volumes of traffic in Rayleigh caused when there is an issue with traffic on the the A127, A13, Rayleigh weir. Rayleigh is used as the alternative route which often causes Rayleigh to be gridlocked. This also has a knock on affect for Hullbridge, Ashingdon, Hawkwell, Rochford, Hadleigh, Benfleet and other surrounding villages.
Other Considerations

The preservation of our green belt and open spaces is essential. This is especially relevant in todays climate where open spaces and places to exercise have been paramount in helping people with mental health issues.

The encroachment of our countryside through more development should be prevented to safeguard our natural habitat and the 'merging' of towns/villages should be avoided.

Take for example the redevelopment of Bullwood Hall and the proposal to establish further housing on the sites I mention earlier in this correspondence. Hockley and Rayleigh get ever closer, it's only a matter of time before they become one.

With regard to the proposed development of agricultural land. With the urgency in trying to rectify the issues surrounding climate change why take away a green space and build properties causing more pollution to add to the problem.

Now that we have left the European Union surely it is incumbent upon us as a nation to become more self sufficient in all aspects including food production, This means preserving our agriculture and agricultural land.

The destruction of our local wild life environment would also be catastrophic. There are deer, badgers, foxes, bats and many species of birds in the area behind Nelson Rd/Napier Rd which will be lost to the area.

There must also be careful consideration given to additional schools, GP surgeries, dentists and clinics required. As I'm sure you are aware, to get an appointment with a doctor or dentist now proves to be difficult. With more people moving to the area this will only aggravate the situation.

I am objecting to the removal and redevelopment of Mill Hall. This is a community building in a conservation area. You are proposing thousands more houses/flats and looking to reduce the size of Mill Hall drastically. This is an area of historic interest, we need the Mill Hall for all members of the community. It is an ideal building to house the Rochford Tapestries. I also object to any building on green belt. No thought has been given to any infrastructure, flooding or pollution. Or the fact we have poor bus routes, insufficient doctors surgeries, the Puzey Practice running at 22k patients and local schools are full. There are only 2 main routes in our area B1013 and Ashingdon Road, which CANNOT absorb any more traffic.

I strongly object to the development of Green Belt land in Rayleigh, Hockley and Rochford. We have already destroyed too many natural landscapes and woodlands; we can’t afford to lose any more. These trees and landscapes help fight climate change by storing carbon produced by burning fossil fuels. Cutting them down and replacing them with housing will not only destroy this valuable carbon store but release more into the atmosphere by disturbing the soil. These developments will also destroy the natural habitat of wildlife and insects vital to the survival of humans.
In addition to the above such increased housing will put already strained local infrastructure under impossible pressure. Schools, Doctors, Dentists are already almost impossible to access, this will make it completely impossible. Are there any plans for new schools, doctors’ surgeries and roads to cope with the increase in the population?
The roads around this area are already clogged with traffic which not only leads to frustrated motorists but also increases pollution. More housing will add to already clogged roads and pollution.
We have problems already with sewerage pipes in the area, more houses will put such services under even more danger of failure.
The impact of this development will be catastrophic for Rayleigh and the Rochford, Hockley area and its residents and should not proceed.

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

I sat down with the intention of completing the consultation questionnaire, however with its 68 questions, some multiple part, and the plethora of related material it appears to be designed for people with far more time on their hands than your average resident. Perhaps cynically, I fear this may not be accidental.

I would like to make my views known on the local plan and would hope they are considered although not on the official questionnaire.

My primary concern is that of potential development that will affect me and my family directly, notably that at Napier Road, Bull Lane, Wellington Road, but looking at the whole plan I find the amount and type of land earmarked as "promoted" as staggering. On the whole this is arable farmland, development of which will further erode what used to be a pleasant semi rural district. Where is the sense in developing prime agricultural land creating further reliance on food imports?
I note that there is provision within option 4 for the creation of a new country park - There is already ample country side crisscrossed by footpaths. You are proposing to develop it then attempt to justify this by creating a "country park" to which people would flock in their droves, no doubt by car further exacerbating the traffic problems as per Cherry Orchard.

I could go into the effect on traffic and infrastructure in general, as well but as you should be aware this is already groaning under the existing population, not to mention illegal levels of pollution in Rayleigh High Street. From a brief review of the impact assessment almost all options appear to have a negative effect on environmental quality and either negative or uncertain on landscape so I fail to see how this can produce a positive effect on health and wellbeing as displayed universally for all options. As for a positive impact on transport and movement as shown for options 3 and 4 - I find this incredibly hard to believe and am sure an alternative report could easily counter the assertion. Unfortunately there is no option for residents to commission anything of the sort.

I would assume that housing quotas are foisted upon the district by Westminster and there is "nothing that can be done about it". I would also guess that the majority of responses from residents will not be in favour of the local plan and as such believe that our elected members should be doing all they can to resist further development of the area, In short; Rochford Is full up.

EXECUTIVE SUMMARY
There is a compelling case for the allocation of the subject landholding at Tithe Park, Poynters Lane
in the emerging Rochford Local Plan. The proposal at Tithe Park will deliver up to 525 homes, facilitate the provision of a secondary school including scope for SEND and also contribute towards green and blue infrastructure by way of enhanced connections through the site, along with the extension of Friars Park.
The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive Contribution to housing delivery in the early years of the Local Plan.
The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. Furthermore, our client has undertaken a range of technical assessments in respect of the subject site which reinforce the Council’s evidence and
demonstrate that there are no impediments to this site in coming forward.
Crucially this area is assessed as being of medium to low landscape quality, value and sensitivity. It does not perform a strong Green Belt function. The development of this site will provide a logical planned extension which would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, to form a robust and consistent boundary to the redefined Green Belt.
The site is highly sustainable particularly given the high frequency local bus services which currently serve the site, with an average of 13 bus services per hour. Moreover, the provision of community infrastructure on this site would greatly enhance the sustainability credentials of the local area including Great Wakering.
The emerging Rochford Local Plan must meet their own housing needs, along with examining the potential to accommodate some of the unmet need arising from Southend-on-Sea Borough. Given the lack of undeveloped brownfield sites in RDC available for development, it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford. The Framework requires that in such instances first consideration needs to be given to land well served by public transport, such as the subject site.

There are currently no secondary schools in the south-eastern part of Rochford District to serve the site and settlements such as Barling, Great Wakering and Little Wakering, indicating that pupils from these areas need to travel some distance to facilities in other parts of Rochford or Southend/Shoeburyness. Moreover, the schools that are in the wider locality are poorly performing. There are currently no specific Special Educational Needs & Disability (SEND) facilities within
Rochford. While there are limited facilities in Southend, the school performance of these SEND schools is poor when compared to authority and national averages. The NPPF highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities. Paragraph 95 states that local planning authorities should take a proactive,
positive and collaborative approach to meeting this requirement, and to development that will widen
choice in education. Local planning authorities should give great weight to the need to create schools
through the preparation of plans. In light of the above, there is a compelling case for the delivery of a Secondary school and SEND provision in this area.
The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary
and SEND education facilities in this locality and also can contribute towards green and blue infrastructure delivery including the extension of Friars Park.
In summary the key benefits of allocating the subject site include -
• Delivery of up to 525 homes which will make a positive contribution towards the Council’s housing
needs in the short term;
• Ensure a diverse range of tenures (market and affordable) and range of house types;
• Provision of the land to deliver a Secondary School along with scope for a SEND facility;
• Enhance connections and green links through the site improving green and blue infrastructure and extending Friars Park;
• Deliver a robust landscaping strategy which achieves biodiversity net gain;
• Enhancement of Public Rights of Way through the site;
• Support local highway improvements from the site and encourage sustainable transport behaviours.

INTRODUCTION
1.1 These representations have been prepared by Iceni Projects Ltd (“Iceni”) on behalf of Stolkin and Clements (Southend) LLP in respect of the Tithe Park, Poynters Lane, Great Wakering. Our clients
are the freehold owners of this site and are committed to working with the Council and key
stakeholders to deliver a sustainable residential scheme and facilitate the provision of community
infrastructure in this location.
1.2 For reference, enclosed with these representations is a Design Document prepared by Turner Architects which sets out the vision, key features and development potential of the site.
1.3 The preparation of a new Local Plan for Rochford provides an important opportunity in which to deliver positive growth for Rochford and the existing community, along with delivering new homes and infrastructure. This proposal at Poynters Lane is complementary to the Vision for Great Wakering
as set out in the Consultation and will assist the Council in meeting their strategic objectives including the delivery of a Secondary School.
1.4 The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no Impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. The only considerations that the Local Plan evidence base raised in respect of this site relates to green belt; mineral safeguarding and agricultural land
classification and that the site is removed from a secondary school. These matters are considered in
further detail in these representations where it is demonstrated that there are no impediments to this
site in coming forward.
1.5 These representations in relation to Tithe Park are structured as follows:
• Section 2 provides an overview of the site location and context, along with the accessibility of the site to public transport and local services;
• Section 3 summarises the relevant national planning policy framework in so far as it relates to the subject site and proposals;
• Section 4 details housing and education needs in Rochford District;
• Section 5 sets out the evidence base prepared by the Council to date in relation to this site and also the technical reports prepared by our client which demonstrates the suitability of this site for development;
• Section 6 sets out the case for the allocation of the subject site at Tithe Park; &
• Section 7 contains the Conclusion and provides a response to the Questions contained in the Consultation.
SITE CONTEXT
Site Description
2.1 The site comprises a large, rectangular, open parcel of land to the south of Poynters Lane, with an area of 33 hectares, to the north-west of North Shoebury, within the administrative boundary of Rochford District Council. The site is located further south of Great Wakering High Street. The site wraps around a collection of farm buildings at Tithe Farm, and the properties at Tithe Cottages. The southern boundary of the site adjoins the borough of Southend-on-Sea.
2.2 The landholding is bound to the north by Poynters Lane and bordered to the west and south by postwar housing, and open space at Friars Park. To the east, lies an area of unmanaged scrub and grassland and a pocket of commercial development located at the junction of Poynters Lane and Wakering Road. North of this, on the opposite side of Poynters Lane is further residential and
commercial development at Crouchmans Cottages and Crouchmans Farm.
2.3 To the north of the site is an area of arable farmland, beyond which the settlement at Great Wakering
lies. The historic core of Great Wakering lies within the eastern part of the settlement. The village has grown in the latter part of the 20th Century, with housing estates extending the settlement to the north and south of the High Street. New development is currently ongoing at the southwestern edge of the village. Recent development has also occurred off Alexander Road, forming a cluster of housing, which extends someway south of the main part of the village.
2.4 The site is not covered by any statutory or non-statutory designations. The nearest listed building is
the Grade II North Shoebury House, which is located on Poynters Lane to the north-west of the Site. Foulness Ramsar site, Special Protection Area (‘SPA’) and Site of Special Scientific Interest (‘SSSI’) is situated to the east of the site.
2.5 There are a number of local services and amenities located within North Shoebury and Great Wakering including areas of open space, schools, shops, businesses and places of worship. A public footpath crosses the eastern part of the Site, linking Poynters Lane to Friars Park. A second public footpath follows the western boundary of the Site.
2.6 Views towards the site from the surrounding area are limited, due to its proximity to surrounding urban development. In terms of landscape character, the site is closely associated with the surrounding urban land uses, and it has an urban edge character. The site is assessed as being of medium to low landscape quality, value and sensitivity.
The site is exceptionally well located in terms of access to local bus services. The bus routes serving the subject site are detailed in the table below which illustrates that there are bus stops within 100 metres and 460 metres of the site providing a high frequency of services.
Table 2.1 Local Bus Services
Route Bus Stop Distance from Site boundary
Route 1 (The Renown to Rayleigh via Southend Bus
Station and Hadleigh (A13))
Shoebury
Renown
460m
Route 7 (Rayleigh to Great Wakering via Southend Bus
Station and Hawkwell)
Star Lane 100m
Route 8 ( (Rayleigh to Great Wakering via Southend
Bus Station and Ashingdon)
Star Lane 100m
Route 9 (Rayleigh to Shoeburyness East Beach via
Southend Bus Station and Eastwood).
Shoebury
Renown
460m
2.8 In addition, these services stop at Southend Central Bus Station which is a major public transport hub providing routes across Essex, including routes to Southend and Stansted Airports. An extract
of the local bus routes is shown in Figure 2.1.
[SEE DOCUMENT FOR IMAGE]

Both Routes 7 and 8 can be accessed from Poynters Lane, providing one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at the Renown on Constable Way with both routes each providing five buses per hour in the AM peak.
There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
2.10 The site is also well placed with a large number of local facilities with 1km of the site. These facilities include:
• Asda Superstore;
• Asda Pharmacy;
• Friars Park;
• Friars Primary School;
• St George’s Catholic School
• Convenience Store;
• North Shoeburyness Surgery;
• Eagle Way Surgery; and
• Parsons Barn Public House.
2.11 These local facilities, alongside the local bus services, highlight that the site is well located and
alternatives to car use are practical.

NATIONAL PLANNING POLICY FRAMEWORK
3.1 The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to the subject site.
Plan Led Approach
3.2 The National Planning Policy Framework (referred to herein as “the Framework”) states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
3.3 Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and
enhancement of the natural, built and historic environment. These policies should provide a clear
strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
Green Belt Release
3.4 Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
3.5 Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation and supporting evidence base recognises that RDC
are unlikely to have sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.
3.6 The Framework requires at Para 142 that “Where it has been concluded that it is necessary to release
Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” The subject site benefits from a high frequency bus service which connects this site to the key local centres, and also provides connections to major rail stations in the locality. In this respect the Framework requires that sites such as Tithe Park should be given first consideration for release from the Green Belt.
30 Year Vision
3.7 The Framework requires for large scale developments such as significant extensions to existing
villages and towns ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. The Framework does not define what constitutes a significant extension and thus it is not clear whether the development of the subject site would require a 30-year vision. Given the scale of the proposal and the timescales for delivery, it is
considered that this policy is not applicable in this instance, nonetheless further clarity is expected
from the Government on this policy in due course.
Planning for Education
3.8 The cornerstone of the Framework is the pursuit of sustainable development. The most recent
revision includes reference to UK’s commitment to pursuing the 17 Global Goals for Sustainable
Development in the period to 2030. Goal 4 relates to quality education and ensuring inclusive and
equitable quality education and promotion of lifelong learning opportunities for all.
3.9 In this vein, the Framework highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities in the promotion of healthy and safe
communities. Paragraph 95 states that Local planning authorities should take a proactive, positive
and collaborative approach to meeting this requirement, and to development that will widen choice in education. Local planning authorities should give great weight to the need to create schools through the preparation of plans
HOUSING & EDUCATION NEEDS ANALYSIS
Housing Needs
4.1 In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2 The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
4.3 Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in 10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4 The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. Southend-on-Sea Borough Council have published their Local Plan Consultation ‘Refining the Plan Options’ which confirms that they are unable to meet their full housing needs with an arising shortfall of 3,550 – 4,300 homes over the period to 2040. Given the close relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services
between the two authorities, RDC needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5 Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.
Set against this, the Council’s Housing and Employment Land Availability Assessment considers the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,5001 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short of the District’s
housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
4.7 The table below illustrates that RDC will have a shortfall in the range of 2,700 – 6,300 homes. The
Council is duty bound to test whether there can accommodate this level of development, particularly
in view of Southend-on-Sea’s ability to meet their housing needs.
[SEE DOCUMENT FOR TABLE]
Education Needs
4.8 Iceni Projects has undertaken an assessment of the educational needs provision in Rochford and
Southend-on-Sea.
4.9 Figure 4.2 provides an overview in terms of the geographical spread of the secondary school
provision across the two authorities. As it can be seen, the majority of schools are concentrated to the west and centre of the two authorities, with no schools within 2km of the site and one within 5km.
4.10 There are currently no secondary schools in the southeastern parts of Rochford District to directly
serve settlements in these areas such as Barling, Great Wakering and Little Wakering, indicating that children from these areas would need to travel to facilities in other parts of Rochford or Southend/Shoeburyness. The closest secondary establishment in the southeastern areas is the Shoeburyness High School.
[SEE DOCUMENT FOR IMAGE]

The spatial coverage of the various Rochford secondary establishments indicates that settlements located in the south east of the District (e.g. Great Wakering and Little Wakering), are currently situated on the edge of King Edmund School’s catchment area. This could lead to potential difficulties for residents of these areas and their children to access secondary school facilities. In addition, the site falls within the Shoeburyness High School catchment area.
4.2 The Department for Education provides the latest school performance tables through the Find and
compare Schools Tool.
In Rochford, the King Edmund School, which is closest to the Site has a rating of Well below average (-0.79). The performance of the school in terms of Grade 5 or above in English & maths GCSEs is lower than national averages. There is thus a qualitative issue regarding
the choice of good quality schools for residents living in the Rochford and the south-eastern part of Rochford District.
4.3 Moreover, in Southend-on-Sea the Shoeburyness High School ranks at below average; as does the
Southchurch High School. The school’s performance in terms of Grade 5 or above in English & Maths GCSEs is lower than Southend-on-Sea and national averages.
4.4 There are currently no specific Special Education Needs & Disability (SEND) facilities within
Rochford, with some of the mainstream schools in Rochford offering special education needs settings
for limited number of pupils. While there are limited facilities in Southend the school performance of
SEND schools is poor when compared to authority and national averages. There is thus a qualitative
issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District
EVIDENCE BASE & TECHNICAL ASSESSMENTS
5.1 The purpose of this section is to consider both the evidence prepared by RDC to date in so far as it
relates to the subject site and also to consider the technical reports prepared by our client in order to
inform the plan making process and assist the Council.
5.2 In this section we provide an overview of the Rochford Site Appraisals Paper, along with the Green
Belt and Landscape assessments undertaken by RDC.
5.3 Our client has undertaken the following technical reports in respect of the site –
• Green Belt & Landscape Assessment
• Flood Risk Assessment
• Agricultural Land Assessment
• Minerals Assessment
• Ecological Assessment
• Highways, Public Transport & Connectivity Analysis
• Community Infrastructure Audit
• Education Needs Assessment
5.4 In the interests of ensuring these representations are as concise as possible it is not intended to submit these technical reports with the submission, with the exception of the Green Belt and landscape assessment prepared by CSA, rather we will provide an overview of the key findings. We would be pleased to share these reports with the Planning Authority at the appropriate juncture.
RDC Site Appraisals Paper
5.5 The Site Appraisals Paper (SAP) forms an assessment of land being promoted for development in
the District, providing a technical understanding of the sustainability of different sites to inform future
decisions about development as part of the Council’s emerging Local Plan. The Council have stated that it is not the purpose of the SAP to arrive at a list of preferred sites, nor ‘select’ a list of final sites for allocation. The site selection process could logically follow as a next stage.
5.6 The assessment has not flagged any significant issues to hinder the development of Tithe Park (minus being a GB site). Using this assessment potential concerns from the Council regarding development on this site could include the site being Grade 1-3 agricultural land and a minerals safeguarding area. Our client has commissioned technical assessments in relation to these issues which are summarised further below.
5.7 A key issue that needs to be clarified is that the RDC analysis is incorrect in relation to bus frequency which states “The Site is between 400m and 800m from a bus stop however, no bus services received at stops within 400m”. This is an error and needs to be clarified to ensure the site benefits from the correct scoring when assessed against other sites. As detailed above at section 2, the site is within 100 metres of bus stops served by Routes 7 and 8 which provide one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at
The Renown on Constable Way, 460 metres from the site, with both routes each providing five buses per hour in the AM peak. There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
5.8 The sustainability of the locality is raised due to the lack of access to major facilities such as a secondary school. However, it is recognised the scale of the site is capable of delivering services such as a school which the subject site could facilitate.
5.9 No notable constraints in terms of site conditions have been identified, there is also a lack biodiversity
and ecology features on the site. Also, the sites close proximity to the strategic road network and suitable vehicular access being possible from a private road are considerations in favour of development on this site.
[SEE DOCUMENT FOR TABLE]

Green Belt & Landscape Assessment
5.10 The Council’s Green Belt assessment considered that release of the site from the Green Belt would result in a high level of harm to the Green Belt purposes. The study noted its potential role in maintaining separation between Great Wakering and Southend-on-Sea, and in preventing sprawl and countryside encroachment. The assessment did however acknowledge that the parcel was contained by development on two sides and that Poynters Lane would be a stronger Green Belt
boundary than the current one. Moreover, the Council’s evidence base identified that the majority of site falls within medium-high capacity area to accommodate development.
5.11 CSA Environmental have undertaken their own independent review of the site’s contribution to the
green belt, attached at Appendix 2 of these representations, and found that “development of the Site could provide a logical planned extension, which would effectively infill an area of land at the north eastern edge of Shoebury. It would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, which would form a robust
and consistent boundary to the redefined Green Belt. There would be some reduction in the
separation between Southend-on-Sea and the smaller settlement at Great Wakering, however a clear visual and physical break would remain”.
5.12 This area is assessed generally as being of medium to low landscape quality, value and sensitivity. The is consistent with the Council’s published Landscape Character, Sensitivity and Capacity Study.
5.13 Views towards the Site from the surrounding area are limited, due to its proximity to surrounding
urban development. There are filtered views from the rear of properties which lie adjacent to the Site, and from the open space at Friars Park. There are also views from Poynters Lane, and from the footpaths which cross the farmland at the edge of Great Wakering.
5.14 The site’s performance against the first four Green Belt purposes is summarised in the table below.
Table 5.2 Assessment of the Site against the four Green Belt purposes
[SEE DOCUMENT FOR TABLE]
In light of the above, it is considered that the Council should assess the green belt contribution of
this site independent of the wider area, and thus will reach similiar conclusions as the CSA Environmental analysis.

Education Needs Assessment
5.16 An Education Need Assessment has been prepared by Iceni Projects with the key findings –
• The demographic analysis shows an expected notable increase in the population of secondary school age over the next 6 years to 2027;
• By 2027, the school age population is expected to increase by 2,200 – 2,600 pupils in Rochford and Southend;
• Estimated there is a residual shortfall of approximately 880 to 1,280 places for both Rochford
and Southend when considering school age population increase and planned provision;
• Moreover, the closest schools to these areas (in both Southend and Rochford) are currently
performing poorly, with below average performance when compared to local authority and national averages;
• Lack of good quality secondary school provision in the area for residents to easily access;
• Beyond 2027, the demographic analysis indicates that additional need could be generated as
family housing is delivered and attracts enhanced in-migration to Southend and Rochford. A total population of secondary school age children (relative to the 2020 baseline) of between 2,000 –
3,000. This implies an additional need of up to 400 pupils relative to that to 2027.
5.17 There is currently capacity deficit in the Special Education Needs and Disability (SEND) facilities
closest to the Site. Moreover, the school performance of SEND schools within both Southend-onSea and Essex is poor when compared to authority and national averages. There is thus a qualitative issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District.
Community Infrastructure Audit
5.18 A Community Infrastructure Audit was also prepared by Iceni Projects, which presents an overview of current community facilities and services in the area where the Site is located. This assessment came to the conclusion the Local Impact Area where the site is located is considered to have a good range of community facilities. There is capacity in most existing facilities including sport and openspace, health care facilities and community facilities. However, it is likely that local education facilities
to experience some deficits if additional population is introduced into the area. The Report also identifies there is a shortage of allotments and young people’s provision in the District, therefore development on this site could address this need.

Highways, Public Transport & Connectivity
5.19 Iceni Projects undertook an initial Transport Assessment on the Site. The Assessment investigated
a number of potential options for the Poynter Lane / Star Lane Priority Junction to ensure sufficient capacity at this junction when the site is developed. The transport study demonstrates that there are a range of options in order to enhance Poynter Lane / Star Lane Priority Junction which include a new roundabout or a signalised junction.
5.20 There are currently no pedestrian frontages along Poynters Lane, but there are number of other
Public Rights of Way (PRoW) in the vicinity of the Site, including a pedestrian link to Great Wakering.
Local roads are commonly used by recreational cyclists albeit there are no formal cycle routes in the vicinity of the Site. There may also be an opportunity to improve recreational footpaths along the site boundaries to provide purpose-built routes to nearby local amenities.
5.21 As detailed above, the Site is also located in proximity to a number of bus routes in the vicinity of the
Site, serving routes across Essex including Southend and Stansted Airport. The nearest bus stops are located on Poynters Lane and Constable Way and there are up to 13 buses per hour available to residents at the Site which provide access to local train stations and major employment hubs.
Given its proximity to a number of local amenities combined with good connectivity to the public transport network, sustainable transport modes are considered feasible in this location.
Agricultural Land Assessment
5.22 An Agricultural Land Classification and Soil Resources Assessment has been prepared by Reading
Agricultural Consultants. This report set out the findings from an assessment of the Agricultural Land
Classification (ALC) and soil resources by means of a detailed survey of site and soil characteristics.
5.23 15.7 hectares (46%) of the site was identified as Grade 2 soil quality ‘Grade 2 is very good quality
agricultural land, with minor limitations which affect crop yield, cultivations or harvesting. The level of yield is generally high but may be lower or more variable than Grade 1’.
5.24 18.5 hectares (54%) was identified as Grade 3a ‘land has moderate limitations which affect the choice of crops, timing and type of cultivation, harvesting or the level of yield, it is subdivided into Subgrade 3a, which is land is capable of consistently producing moderate to high yields of a narrow range of arable crops or moderate yields of a wide range of crops’.
5.25 The majority of the district comprises Best and Most Versatile Agricultural Land. It is clear that there will be a loss of BMV as part of RDC meeting their local housing needs. On this site, there is no Grade 1 and the majority of the land is Grade 3a. The benefits of the proposed development outweigh any minor harm as a result of the loss in this respect.

Ecological Assessment
5.26 An Extended Phase 1 Habitat Survey was undertaken by Derek Finnie Associates in July 2021. The
Site was found to comprise a single arable field under a bean crop. On the northern, eastern and southern boundaries, outgrown, semi-mature hedgerows are present. There are no ecological constraints to developing the Site, with ample potential in any future landscape design to provide a net biodiversity benefit.
Minerals Assessment
5.27 A Minerals Assessment of the site was undertaken by Tetra Tech Environment Planning Transport Limited, this assessment concluded the majority of the site has previously been worked for minerals.
5.28 The report identifies that a small proportion of the site, approximately 5 hectares, are potentially still
suitable for mineral extraction, however it is not possible to state with any great level of certainty that mineral extraction could take place. Having found that the majority of the site has already been worked it is not considered that, in the case that any underlying economically viable minerals are proven, that this should be of any detriment to the site’s ability to be developed.
5.29 The site is of such a size that it would be possible to phase the development to incorporate the recovery of any minerals, sand or gravel in a timely manner. It is considered that the recovery of any sand and gravel could have sustainability benefits for the site. Depending on the quality of any resource that was proven, the sand and gravel could be used within the site’s construction.
Flood Risk Assessment
5.30 A Flood Risk and Drainage Note was prepared by Waterman to appraise the flood risk and drainage
opportunities and constraints at the Site. The key conclusions from this assessment are set out as, the EA Flood Map for Planning shows that the majority of the Site is located within Flood Zone 1, indicating a low risk of flooding from tidal and fluvial sources (less than 1 in 1,000 annual probability of river or sea flooding). Based on the proximity to the sea, it is understood that any flood risk to the Site would originate from tidal sources. The Map also indicates the majority of the Site is at ‘very low’
risk from flooding from surface water. There have been no recorded groundwater flooding incidents at or within the vicinity of the Site. The risk of flooding from artificial sources and sewers has also been assessed and is considered to be low.

THE ALLOCATION OF TITHE PARK FOR HOUSING & COMMUNITY
INFRASTRUCTURE
Spatial Strategy
6.1 RDC propose to take a positive approach to growth locally, helping to create a more inclusive housing
market, avoiding the emergence of housing-related issues including homelessness and concealed
households. A number of strategy options have been identified in the Local Plan Consultation that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
6.2 These representations support growth in the Great Wakering area and more generally to the east of
Rochford. In terms of spatial options, Option 2 seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns or villages. The development of the subject site would accord with Option 2b: Urban extensions dispersed to settlements based on hierarchy. Essentially our client’s preference is Option 4: Balanced
Combination, which proposes growth in terms of urban intensification, urban extensions and concentrated growth. It is considered that this is the only way that the Council will be able to meet their housing needs in the future through a range of growth options which deliver homes and infrastructure in tandem.
6.3 The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive contribution to housing delivery in the early years of the Local Plan.
6.4 The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary and SEND education facilities in this locality and also can also perform a role in the delivery of green and blue infrastructure.
Delivery of Homes & Community Infrastructure
6.5 The Consultation states that new development can also deliver community infrastructure stating that “It is therefore important that new growth is not simply seen as creating additional demand for community infrastructure but also as one of the most effective tools at creating additional supply”. The proposal at Tithe Park will deliver up to 525 homes, and also facilitate the provision of a
secondary school including scope for SEND and enhance connections between Southend and the
River Roach.
6.6 The Rochford Consultation is clear that while the Wakerings and Barling has a good range of core
facilities, these only serve local residents and ‘most town-scale facilities, such as a secondary school and large-scale job opportunities, are absent’. The Consultation further notes that ‘The population of the Wakerings and Barling skews slightly younger than the District average which may generate additional demand for housing and jobs in coming years’.
6.7 The proposed development comprising of new homes, provision of land for the delivery of a
secondary school and scope for SEND and open space is designed to be locally-responsive and aimed at meeting the ongoing needs of local residents. The nature of the development and the site location will ensure that the development of this site does not impact on the character of the existing settlements.
Design Principles
6.8 The proposal provides for landscape lead scheme which seeks to strengthen and enhance the
character of the area. The key design principles include :
• Residential development to be focused on the western and central parts of the Site, in close proximity to existing residential land uses.
• New pedestrian / cycle connections to connect into the adjacent residential areas and to Friars Park to integrate the proposals with the existing urban area at Shoebury;
• New planting and open space alongside the northern boundary with Poynters Lane to soften views of the new homes from the north and to provide a robust edge to the redefined Green Belt;
• Potential secondary school and SEND site and associated playing fields to be located to the east; and
• Existing rights of way to be retained and enhanced within green routeways.

CONCLUSION & RESPONSE TO QUESTIONS
7.1 In conclusion, and to summarise the main issues pertaining to these representations, a response to
the relevant questions relating to this site are set out below -
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
7.2 Our client fully supports the delivery of the South Essex Estuary Park, however the current location
and extent of the park needs to be reconsidered. At present, the entirety of the subject site is indicated as a Regional Park. If this position were to be maintained the site will not deliver any new homes or education facilities. It also would not provide publicly accessible open space as the site would remain in private ownership. Therefore, it is considered that to facilitate the delivery of the
parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach, this site should be allocated for housing and community infrastructure. Our client welcomes the opportunity to engage with the Council and their consultant team to ensure the design of the proposals maximises the potential of the Park and ensures it is deliverable.
Q59b. With reference to Figure 47 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of the Wakerings and Barling?
i) Housing [market, affordable, specialist, traveller, other]
ii) Commercial [offices, industrial, retail, other]
iii) Community infrastructure [open space, education, healthcare, allotments, other]
iv) Other
7.3 As detailed in these representations, it is considered that the subject site should be allocated for
housing and community infrastructure comprising a secondary school. In addition the development
of this site will enhancement green and blue infrastructure including an extension to Friars Park.
7.4 The Consultation details a vision for the Wakerings and Barling which highlights that more services
need to be developed to reduce its reliance on neighbouring towns and ensure villages should have
become more self-sufficient when it comes to homes, jobs and community facilities, including education.
7.5 The Educational Needs Assessment clearly demonstrates that there is a serious shortfall in
Secondary School and SEND provision in the vicinity of Great Wakering and the local area.
Furthermore, the limited provision that does exist in the area is poor performing. This proposal will enable the delivery of a new school which will meet existing and future needs of the locality. This would be of major benefit to the local community. The allocation of this site will also facilitate the delivery of the parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach.
Conclusion
7.6 Our client fully supports the Council in the preparation of a new Local Plan for Rochford in order to meet local needs and address current deficiencies in the District. The allocation of this site in a highly sustainable location, on land which has a limited contribution in landscape and Green Belt terms will assist the Council in meeting their strategic priorities. This site has the potential to deliver up to 525 homes, facilitate the provision of a Secondary School including scope for SEND provision and
contribute towards the delivery of blue and green infrastructure.
7.7 We welcome the opportunity to discuss the emerging Local Plan preparation and the Council’s proposals for this site in further detail.

Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
We feel strongly that a local highways study needs to take place. The document only refers to a study of the main roads in the south Essex infrastructure position statement. This states in 4.2.4 that much of the main road network which leads to our district is operating at, or near, capacity in peak periods.
We cannot understand why Rochford District Council (RDC) would base its planning upon the 2025 flood risk area when developments could reasonably be expected to be in place for more than 100+ years. All evidence from the IPCC and other scientific institutions demonstrate that global sea level rise is a real and presently accelerating threat. In addition, the British Geological survey shows that the Eurasian tectonic plate is tilting along an axis between the Wash and the Bristol Channel, this means that Essex is sinking at a rate of 0.4 to 0.7mm per year (ref. research carried out at Durham University and published in the Journal ‘GSA Today’). These projections are not the worst-case scenario, and the sea level rise could be much worse if climate change continues raising temperatures beyond 1.5 degrees centigrade.
The map generated by Coastal Climate Central for 2050 shows that all of the promoted sites to the west of Hullbridge will be in the flood risk area, and that those to the North East of Hullbridge are also in the flood risk area. RDC needs to ensure that no site at risk of flooding by 2050 is developed.
The Coastal Climate Central 2050 map shows large part of Rochford including Hullbridge below flood levels:
https://coastal.climatecentral.org/map/15/0.6252/51.6246/?theme=sea_level_rise&map_ type=year&basemap=roadmap&contiguous=true&elevation_model=best_available&fo recast_year=2050&pathway=rcp45&percentile=p50&refresh=true&return_level=return_ level_1&slr_model=kopp_2014

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


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


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


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


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

Q5. Do you agree with the settlement hierarchy presented?


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


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

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

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

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

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

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


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

Spatial Themes

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


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


Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?
We agree that it is imperative that both flood risk and coastal change should be central to any development plans going forward; for us in Hullbridge, many of the proposed sites to the west of the existing settlement are projected to be deep within flooding territory by 2050, as are numerous ones in the east as well. With 2050 now less than three decades away, and no sign of any imminent alteration in the path of climate change, development in any of the areas identified to be in potential flood plains today and in the near future must not be considered.


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


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


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


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


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


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

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


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

Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas?
Yes, these should be settlement specific, to allow for the maintenance of the integrity and specific characteristics of each area, sufficiently detailed to avoid confusion, and widely distributed.

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


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

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

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


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

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

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

Housing for All

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


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

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

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

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


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

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


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

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


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

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

Employment and Jobs

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


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

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

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

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


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

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

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


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

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

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

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


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

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


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

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

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


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

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

Biodiversity

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


YES

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

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

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


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

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

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

Green and Blue Infrastructure

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


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

Q33. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?


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


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

Community Infrastructure

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


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

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

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


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

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

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

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


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

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

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

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


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

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


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

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


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

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


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

Heritage

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


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

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


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


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

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


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

Town Centres and Retail

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


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

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

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


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

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

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

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


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

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


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

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

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


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

Transport and Connectivity

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


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

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


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

Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [walking, cycling, rail, bus, road etc.]
Improvements to existing road networks. Large scale bypass schemes, such as the “Southend Outer” bypass would be unacceptable because of the hugely detrimental impact on the Green Belt and its physical and natural environment.
Small low top busses to link smaller communities with larger ones. Trams not a viable option for the more rural areas as roads are too narrow and winding; additionally, would increase congestion on existing roads.
Improvements to the cycle path network, extending and linking the network as and where appropriate and safe.

Green Belt and Rural Issues

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


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

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

Planning for Complete Communities

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


N/A


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


N/A


Q56d. Are there areas that require protecting from development?


N/A


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


N/A

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



N/A

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


N/A


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


N/A


Q57d. Are there areas that require protecting from development?


N/A



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

N/A

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

N/A

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

N/A

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


N/A

Q58d. Are there areas that require protecting from development?


N/A



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


N/A


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

N/A

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


N/A




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


N/A





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


N/A


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


N/A


Q60a. Do you agree with our vision for Hullbridge?


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

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

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


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

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


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

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


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

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


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

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


N/A


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


N/A


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


N/A


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

N/A

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

N/A



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


N/A


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


N/A


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

N/A



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

N/A



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


N/A





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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A

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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A






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


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

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


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

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


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

Create a Country Park to the west of Hullbridge.

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

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

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

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


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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

CRITICAL REVIEW: New Local Plan - Spatial Options Document 2021

Dear Sirs,
I am writing in response to the Councils call for responses to their, "Spatial Options Document 2021".

In summary, as a local resident of Rayleigh since 1964 and a local resident of Hockley since 1985 the Council's plan falls far short of expectations. There have been a number of similar planning documents since the turn of the century. And at each consultation the Council has failed to address the concerns of residents about infrastructure. In particular, the total absence from the Plan of any facts published by infrastructure providers for the provision of improvements. You will be all too familiar with Resident's frustration and anger with the Council and with Councillors that this continuing omission is causing.
The "Spatial Options Document 2021" is no different to its predecessors in this regard. In her reply to me dated 21 June 2021 regarding concerns I have with the apparent "creeping house building" in our district, Acting Managing Director, Angela Hutchings, says, "... that each of these infrastructure providers will have their own strategy for improving infrastructure provision in the area that, whilst informed by the Council's Local Plan, are functionally independent documents." This might well be the case, but it does not take a rocket scientist to draw from these documents and pull together a meaningful spatial options plan for sustainable house building in our district.

I challenge Ms Angela Hutchings to re-issue the Plan and to include a meaningful review that shows the provision of infrastructure improvements AND in addition, that said improvements are in "lock-step" with house building.

Furthermore, a re-issued Plan must include a clear Council policy on how they will control house builders from this moment forwards. Thus far the Council have failed to earn the trust of local residents in this regard. The Hall Road development being a case in point. Going forward the Council and Councillors must be totally transparent with Residents on how they will achieve this.

Mr Mark Francois, MP shares similar concerns. In February 2018, (at the time of the last Plan consultation,) my neighbour Mr Layzell wrote to him expressing concerns about the "New Local Plan." In reply, Mr Francois included a copy of his letter to the then Managing Director, Mr Scrutton, in which he agrees with local residents that a plan for 7,500 new homes was probably too much for the district to bear. And that among a number of well made points Mr Francois expressed the view that,

"... experience shows that house builders who develop in the district tend to do so at a considerable profit ... house builders need to be firmly held to account [on adequate contributions ... to the local community] and that the Council should be robust in ensuring that profitable house builders make sufficient and timely contributions to the extra infrastructure that will be required by the developments they create."

Another issue I have with the contents of the Plan document can be found under the Chapter called “Community Infrastructure”. The introduction contains a link to the Council’s “Infrastructure Position Statement.” Expecting to be taken to a paragraph outlining the Council's approach, one is instead taken to a 100 page document (issued in 2019.)

I persevered and dipped into the section about roads but was disappointed to read that it only talks about issues at a high level. But not about local pinch points such as the Spa round-a-bout, or how Essex Highways propose to improve it and our “B” roads that are already at full capacity during peak times each day!

A more general concern about the Plan document is simply the daunting size of it and therefore the Council's failure to provide guidance notes to residents. All we received was an e-mail and/or a card through the door inviting us to review the document at https:// Rochford.oc2.uk.

In addition, the e-mail and/or card does not highlight the importance of the Council's interactive map and what it contains. I was fortunate to receive a copy of "Item 8" of the Planning Policy Committee agenda for the 23 June 2021. The introduction to "Site Appraisals" was informative.

The whole issue of development is a very important one to the local residents and our quality of life. I look forward to receiving your response to the consultation exercise in due course.