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

These representations have been prepared by Barton Willmore LLP on behalf of Bloor Homes (the ‘Promoters’). The Promoters have an active interest in a Site at Land North of Rectory Road, Hawkwell, which is identified in the Site Location Plan at Appendix 1.
This Site could provide much needed, deliverable residential development in a sustainable and appropriate location, and is considered suitable for allocation within the Rochford New Local Plan (RNLP).
1.2 This Report is submitted in response to the formal public consultation. Section 2 of this report provides comments on the Spatial Options Consultation Paper (SOCP)(2021); and Section 3 responds to the Integrated Impact Assessment (IIA)(July 2021). These sections
are followed by Section 4, which provides an overview and assessment of the Site which is promoted for development at Land North of Rectory Road, Hawkwell.
1.3 A number of supplementary documents are appended to these representations which are referred to throughout. These include a landscape and visual appraisal (LVA) of the site (Appendix 2) of the site, and an indicative framework layout (Appendix 3). Additional
visuals are also included in appendices 4-9, which provide context and support to the LVA and indicative framework layout. A Transport Appraisal (with associated plans and figures) of the site is included within Appendix 10 confirming its sustainability in transport terms.
A Flood Risk and Drainage report is included within Appendix 11 which demonstrates how any flood risk and drainage matters associated with development of the site could also be addressed

[Due to size of full submission, please refer to attached document, along with individual representations to questions].

Summary and Conclusions:
Overall Bloor Homes is supportive of the proposed approach put forward within the SOCP and IIA documents and it is commended that a positive view is taken with regard to strategy option 4 and higher growth options.
Based on the information put forward within the consultation documents and the supporting evidence base we consider that strategy option 4 and the growth option should be pursued across the district in the interests of planning positively for the most sustainable patterns of growth across the district in its context with surrounding areas.
It is also considered that the Green Belt Study and Landscape Character, Sensitivity and Capacity study papers be immediately reviewed in the context of this to realise positive opportunities for growth particularly in the case of greenfield and green belt sites that may be suitable for release.
Land North of Rectory Road, Hawkwell has the opportunity to deliver on the council’s objectives in a sustainable location in Hawkwell consistent with the approach outlined within strategy option 4. The delivery of the site could contribute to addressing the housing needs of the district and local area whilst securing a new defensible green belt boundary and compensatory improvements, alongside additional public open space,
sustainable transport connections, biodiversity net gains, and sustainable infrastructure. Bloor Homes would also be happy to engage with the council further to discuss this opportunity.

Planning refs. CFS027, CFS098, CFS086 CFS029 & CFS053
Having looked at the Rochford plans for possible development, I was somewhat taken aback at the massive loss of greenspace.

The current infrastructure can barely support the current level of housing, and yet here is a plan to rob us of valuable green space and place even more burden upon the local amenities and services. If additional housing has to be considered, then please brownfield sites ONLY.

Having reviewed the documentation In regards to the new local plan I have a few comments I would like to make.
In general I am not opposed to the building of new homes and all the blue areas put forward are not a surprise. This is a lovely place to live so I understand the appeal for new potential residents but also why so many like myself choose not to leave. I also feel it would create lots of opportunities for current business and the creation of new as time goes by.
Where I am confused is the lack of consultation or information in regards to infrastructure. It is pretty obvious that this area has now become quite saturated by new housing having to use our existing roads. Cherry Orchard was introduced in my primary school years to deal with the growing demand back then and I think it is fairly fair to say this has increased quite considerably 20 years later.
New roads are surely an absolute must (in addition to our current roads being improved). Given the traffic issues posed when developments are in construction new diversions need to be in place prior to commencement.
Surely there is a provision to introduce new routes like the one made in Cherry Orchard to create other means of getting from A-B.
Hockley alone has one way in and two ways out. That is just simply not viable considering the amount of homes being suggested.
Develop new housing if it is required but what’s the plan surrounding this? Where can that information be found? Who is responsible for this?
I feel that more residents would be supportive if it was made clear that things will be made better. More accessible green space will made available within developments, the provisions for flood plains. Rayleigh has experienced Wheatly woods flooding this year and it’s hard not to assume this is because of the new homes close by. Will there be a need for more ponds/reservoirs to deal with the loss of flood plains? If so where will these go? Education and the NHS are other areas which need to be explained. Our schools in Hockley are already at capacity. I find it quite disgusting that children are being taught in portacabins in playgrounds in 2021 and this is accepted to stuff more pupils in beyond the schools actual capacity.
People will naturally fear all the development because the infrastructure is not in place. Everything is running at capacity already so it is difficult not to see this plan in a negative light. There will never be support to meet housing quotas until all aspects of the infrastructure is openly discussed with residents and addressed.

We wish to make the following comments on RDC New Local Plan.
1. It is well known that the Government has set targets for moving to zero carbon housing in this country by 2025. This was being realised in 3 steps firstly in 2010 a 25% improvement was made in the energy/carbon performance outlined in the Building Regulations then secondly in 2013 a 44% improvement was made and finally in 2025 we need to achieve zero carbon. This means that energy needed for heating lighting hot water and all electrical appliances in the house such as TVs and computers must be attained from renewable sources ie no burning of fossil fuels.
The main source of climate change is the human influence for emission of greenhouse gases. The UK produced more than 365 million tonnes of carbon dioxide in 2019. Almost half of these emissions were accounted for in energy use in buildings and more than a quarter came from the energy we use to heat light and run our homes and this does not include the massive amount of emissions produced by manufacturers in the production of most of the current building materials.
A draft Planning Policy Statement was published on climate change which expects Planning strategies to be examined in providing for new homes and it expects that all Local Planning Authorities should have an input in delivering the Governments climate change programme in facilitating any provision of new homes and infrastructure. Local Authorities therefore have a responsibility in leading their communities in dealing with climate change. Therefore the subject of housing supply needs to be looked at alongside the reduction of carbon emissions surely the best way of reducing these emissions is to limit the number of new homes being built and not by increasing the numbers year on year.
2. The NPPF states that developments should be directed away from areas of highest risk of flooding with developments not to be allocated if there are reasonably available sites appropriate for development in areas with a lower probability of flooding. Where development is necessary it should be safe without increasing levels of flood elsewhere.
South Essex Surface Water Management Plan statement includes consideration of flooding from sewers drains groundwater and runoff from land small watercourses /ditches that occurs from heavy rainfall. It appears that none of this was taken into account in the current development in Hullbridge the southern end of which is in the flood plain and should not have been built on. What was originally proposed on this site was the provision of underground attenuation tanks this was subsequently changed to attenuation basins together with an additional basin in the centre of the site which eventually discharges into an existing watercourse in Watery Lane. these basins will no doubt be full for the majority of time especially when calculated for a min of 1 in 1 year annual probability storm together with the amount of additional surface water runoff due to the extra impermeable surfaces from this development especially as DEFRA have now bottled out on introducing Sustainable Drainage Systems SUDS compulsory legislation. Baseline Review for Climate Change Adaption states that in addition to flood risk from tidal sources fluvial systems also pose a risk to parts of the district. The impermeable underlying geology and seasonable wet deep clay soils in the western parts of the district leads to rapid runoff of surface water into local watercourses which inevitably will only get worse with climate change.
3. In connection with Climate Change Mitigation it is stated that it has been demonstrated that Rochford District has a lower per capita transport emissions when compared to Essex as a whole yet BBC Look East recently reported that dangerous levels of nitrous oxide caused by diesel fumes are being found in and around the Rayleigh area. Also in a recent national news report it stated that record amounts of carbon dioxide have been recorded and is on the rise the highest in the past 4 years.
So why are we contemplating building more and more houses on Green Belt land creating more emissions and more traffic adding to this major problem.
4. Regarding Landscape and Historic Environment the NPPF states that Local Authorities planning system should recognise that heritage assets are an irreplaceable resource and preserve them in a manner appropriate to their significance. Again this was totally ignored for the current development striding Rawreth and Hullbridge. As stated in the Archaeological Assessment for this development the Local Authorities archaeological advisor at Essex County Council required archaeological mitigation measures in advance of any development impacts occurring and noted that the historical field boundaries within the site comprise undesignated heritage assets of local significance and recommended that the orientation and preservation of these historic boundaries should be encouraged within the detail of the development proposals. This has not been incorporated within this scheme especially the Ward Boundary between Rawreth and Hullbridge. It is also stated that any new development has potential to lead to incremental changes in landscape and townscape character and quality in and around the district. This includes through inappropriate design and layout.
But once again RDC granted planning Approval for the Hullbridge site which indicated the majority of the future dwellings being 2.5/3storey in an area consisting of mainly bungalows and chalet bungalows.
5. In connection with Population and Communities. Local Authorities should/must ensure that there is sufficient choice of school places which is of great importance. Yet recently at a local workshop meeting in Hullbridge it was pointed out that the local primary school had a few available spaces these children would eventually have to attend the surrounding secondary schools who have all confirmed that they are over subscribed. But according to RDC because these are not actually located in Hullbridge this is not an issue.
6. Regarding Safety Rochford is maintaining that it has a relatively low crime rate and is one of the lowest in Essex. At a recent meeting with the police at the Rochford Parish Rooms the majority of the large number of people who attended all had the same complaint which was that most crimes are not being reported due to the fact that there is hardly any or no response from the police who stated that this was mainly due to severe cutbacks. So the statement made by Rochford cannot be taken seriously.
7. In connection with the Green Belt the Government has stated that the fundamental aim of the Green Belt policy is to prevent urban sprawl by keeping land permanently open the essential characteristics of Green Belts are their openness and their permanence. The majority of this Districts land mass is designated as Green Belt and should only be released under exceptional circumstances. When we recently asked a RDC Planning Officer what is meant by exceptional circumstances he confirmed that this has not been defined. The Green Belt is supposed to serve five purposes 1. To check the unrestricted sprawl of large built up areas 2. To prevent neighbouring towns/villages merging into one 3. To assist in safeguarding the countryside from encroachment 4. To preserve the setting and special character of historic towns/villages 5. To assist in urban in urban regeneration by encouraging the recycling of derelict and
other urban land
RDC have already released large areas of Green Belt for development all over the district. With regard to the New Local Plan the submitted map for the local Hullbridge area shows the majority of the proposed larger sites are Green Belt with the exception of a portion of CFS 100 Brownfield Site being a lorry/heavy goods breakers yard which is obviously highly contaminated.
8. Regarding Health the NPPF states that health and well-being and health infrastructure should be considered in local plans and the NPPG states that Local Planning Authorities should ensure that health and well-being and health infrastructure are considered in local and neighbourhood plans and in planning decision making.
But once again this has been totally ignored by RDC on the western side of the current Hullbridge development site there are three existing Telecommunication Masts.
According to the Guide to Mobile Phone Masts. Independent scientists and doctors these are a major health hazard. Cancer clusters have been found around Mobile Phone Masts up to 400metres from a mast which in this case encompasses the majority of these new dwellings. People living near each other and close to a mast have ended up with rare cancers at the same time as each other. This has been the case in Devon Lincolnshire and Staffordshire. Many doctors are now so concerned that they have all signed petitions to demand that Governments take the health concerns over Mobile Phone Masts seriously.
Forecasts suggest that the number of people aged 85 and over in the District will increase in the future. An ageing population has the potential to increase pressures on healthcare services in the District. We do not agree that any future developments will not as stated will not result in increased pressure on existing primarary healthcare facilities. As stated by the NHS any future developments are likely to have an impact on the NHS funding program and these need to be fully addressed not by just making financial contributions only which in itself does not solve the shortage of doctors nurses dentists hospital beds and appointment times.

As stated above it is shown that RDC have not addressed previously any of the alternatives in terms of major impacts and sustainability especially with the current major development in Hullbridge and we therefore have no confidence that this will change in any future emerging New Local Plan for this District.
RDC need to take into account further carbon emissions overcrowding traffic congestion flooding and further drains on the existing infrastructure.

Listed below are some key issues that we feel need to be addressed in any New Local Plan A. Infrastructure is paramount to all Planning Applications including the provision of all services especially the condition of the existing road network being capable of accepting the increase in traffic numbers. Just providing a new roundabout to provide access to any new large development should not be taken as providing adequate infrastructure as this does not reduce the amount of traffic.
B. The density for outer suburbs should be as stated 20–40 dph with very few apartments and more bungalows. Local Authorities are currently using 30-60 dph which causes more overlooking/overcrowding more 3 storey dwellings and less amenity space. Density should be allocated for actual dwelling plots and should not include open space play areas access roads and space required for attenuation basins which should all be omitted from overall site areas.
C. Approval for development sites that merge with neighbouring villages/parishes especially striding across Ward Boundaries should not be allowed.
D. Brownfield sites are being totally ignored and Local Authorities should not be allowed to re -designate Green Belt without at least applying for a Change of Use in order to for local residents to submit their valid objections.
E. Developers should not be allowed to provide financial contributions for off site provision instead of providing the required numbers of affordable homes.
F. All Local Authorities should ensure that all Planning Applications take into account current Building Regulations for example the style of windows to comply with means of escape ventilation requirements and the use of certain types of external cladding materials G. A minimum number of Lifetime Homes with full wheelchair accessibility should be required to all new developments.
H. All developments should have all required energy generated by on-site renewable and low carbon sources.
I. Not enough amenity space is provided for apartment complexes. Drying areas and bin storage should not be included as part of the amenity space together with balcony areas. Balconies should not be allowed to provide for additional storage and clothes drying.
J. DEFRA should reintroduce Sustainable Drainage Systems SUDs as compulsory legislation to stop flooding.
K. Transport carbon emissions should be taken into account in and around the local areas.
L. Provision of youth facilities should not be by providing football pitches alone.
M. Developers should not be allowed to remove trees and hedgerows prior to the granting of Planning Consent.
N. All developments should be made to comply with their Local Design Guide especially car parking arrangements.
O. All developments should comply with Secure by Design with no back alleys.
P. No Planning Approvals should be granted for any housing development to be constructed near or adjacent to existing Telecommunication Masts.
Q. The awarding of the New Homes Bonus issued to Local Authorities by Government should not be a reason for granting Planning Permission.

Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options (RLPSO) on behalf of Mr G Marshall and in relation to Peggle Meadow, Rochford (‘the Site’).
1.2 The Site has previously been submitted in response to the Council’s the Call for Sites, and is reference CS095 in the Council’s plan-making process.
1.3 Representations were submitted to the Local Plan Issues and Options consultation in 2018 to further promote the allocation of the Site to help meet development needs
through a sustainable, proportionate extension to the south of Rochford, capable of delivering numerous benefits.
1.4 This representation should be read alongside the Vision Document that has been prepared in respect of the development of the Site, and which accompanies the
representations at Appendix A.
2.0 Response to Local Plan Spatial Options Question 4
Q4. Do you agree with the strategic priorities and objectives we have identified?
Is there anything missing from the strategic priorities or objectives that you feel needs to be included?
2.1 We consider that Strategic Objective 1 could be clearer that the provision of homes to meet local needs entails providing housing close to existing communities. As currently drafted, it could be inferred that the priority is working with neighbouring authorities, rather than trying to meet local housing needs and support existing communities within the District per se.
2.2 Providing homes through extensions to existing settlements ensures local residents can remain within their local community and close to family, friends, and other informal social networks that form an important part of everyday life. It also ensures greater choice for
existing residents, and reduce the risk that existing members of the community may have to move elsewhere due to a lack of suitable housing.
2.3 We suggest that Strategic Objective 1 should be amended to:
To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs, through providing homes close to existing communities, utilising previously developed land and working with neighbouring authorities if required.
2.4 In addition, we suggest that objectives of the Local Plan should include to improve the affordability of housing for people of Rochford District.
2.5 The RLPSO notes (page 12) that:
“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times to average
annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”
2.6 We agree that affordability of housing is a very real local concern, and an issue the Rochford Local Plan must seek to address. The most recent data available1
reports that the median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’).
2.7 The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average.
2.8 In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69
– significantly below the District’s 11.57.
2.9 Additionally, and whilst empirical data is currently limited, the longer term impact on housing demand resulting from the Covid-19 pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Early indications
are that there has already been an increased desire to move from more to less urban areas, driven by what has been dubbed the ‘race for space’ – the desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.
2.10 At the same time, the situation has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely anticipated that there will be a degree of return to office-working, it is expected that the need for employees to be physically present within a particular office will be substantially reduced.
2.11 As a consequence, it is anticipated that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London. As a consequence, the area 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 Strategic Objective 3 is proposed to be:
“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 industry will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.
2.16 Development of additional homes in the District will also engender sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of new homes on first occupation, on home set up cost, and on an ongoing basis in local shops and services in the area.
2.17 Conversely, failure to deliver sufficient homes for the District would not only result in a failure to support the local construction industry and failure to realise the potential opportunities outline above, it would also likely significantly deter inward investment by potential employers, if insufficient, affordable accommodation was not available locally to provide a local workforce.
3.0 Response to Local Plan Spatial Options Question 6
Which of the identified strategy options do you consider should be taken forward in the Plan?
Growth of Rochford
3.1 It is important to recognise that Rochford District contains a number of settlements, each with their own character and communities. Whichever growth strategy is ultimately pursued, the Local Plan should ensure a proportionate level of growth is directed to the
District’s various settlements, having regard to their characteristics and sustainability to accommodate additional growth.
3.2 For the Local Plan strategy to be sound, we consider that it will need to direct a relatively large proportion of housing growth to Rochford.
3.3 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, Rochford provides for a wide range of services and business spaces, including a number of specialist employment areas supporting nearby London Southend Airport.
3.4 The RLPSO also recognises that Rochford benefits from good walking access to most services, and that the only parts of Rochford with particularly poor access to services are around Purdeys industrial estate and the residential neighbourhoods of Ashingdon village.
3.5 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.
3.6 It is one of only three settlements in the District that benefits from a railway station.
3.7 In addition, it is also one of only three settlements in the District that benefits from a defined town centre.
3.8 The Local Plan strategy should direct a significant proportion of housing development to Rochford.
3.9 In respect of RLPSO Option 1 (urban intensification) we note that the RLPSO suggests this would involve no loss of Green Belt land, would minimise loss of greenfield, and would deliver 4,200 homes over the next 10 years.
3.10 The RLPSO describes Option 1 as “the minimum expectation of national policy” and states it is “likely to be required within every strategy option”.
3.11 It goes on to state that this option would entail 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).
3.12 The RLPSO suggests that at least 4,200 homes will be built over the next 10 years under Option 1 and that the Urban Capacity Study suggests up to a further 1,500 homes could be built through a mixture of maximising the capacity of planned housing developments and taking a more permissive approach to higher densities in urban areas.
3.13 Whilst elements of Option 1 may be capable of being incorporated into a sustainable strategy for growth, it is clear that Option 1 cannot alone result in a sound Local Plan strategy.
3.14 Firstly, it is important to note that national policy places great emphasis on the need to
significantly boost the supply of housing and to meet local housing needs. Indeed, it is an express requirement of a sound Local Plan (as per paragraph 35 of the NPPF) that it seeks to meet the area’s objectively assessed needs, as a minimum. The RLPSO suggests a need to plan for at least 7,200 additional homes, and Option 1 would fall significantly short of meeting this.
3.15 Secondly, we consider that it is highly unlikely that 4,200 dwellings could be delivered through this option within the next 10 years. Such delivery would equate to an average of 420 dwellings per annum (dpa). The Council’s Annual Monitoring Report 2019/20
states that between April 2010 and March 2020, the District achieved a total of 1,768 dwelling completions – an average of 177 dpa. This figure included homes that had been delivered on large allocations made through the Rochford Allocations Plan, and did not rely solely on redevelopment of previously developed land / urban intensification, yet was still significantly short of delivering 420 dpa.
3.16 Furthermore, the Council’s Annual Monitoring Report 2019/20 noted that of the 347 net dwelling completions achieved in 2019/20, 268 of these were from major schemes. A significant proportion of these were delivered on allocated settlement extension sites in
the adopted Development Plan. It reports that 55% of dwelling completions were on greenfield land and, separately, that only 81 net dwelling completions in 2019/20 were from windfall sites.
3.17 In addition, it must be remembered that there is only a finite supply of previously developed land suitable and viable for residential development, and it is likely that a
significant proportion of this has already been exhausted.
3.18 Thirdly, it cannot be assumed that such a level of urban intensification would be suitable or sustainable. To achieve such a level of urban intensification to deliver the number of new homes that the RLSPO suggests through Option 1 would likely result in densities of development vastly greater than existing, to the potential detriment of the amenity of existing residents and character of the District’s settlements; and / or requiring the
redevelopment of existing employment / retail / community uses for housing, with resultant negative social and economic impacts.
3.19 Fourthly, it is not clear where in the District such intensification / redevelopment of previously developed land would deliver housing, and what spatial distribution of homes this would provide. As noted earlier within this representation, it is important to recognise that Rochford District comprises multiple settlements, each with their own communities, and each with their own needs. Option 1 is unlikely to address such needs, and instead would simply focus housing where there happened to be opportunities to redevelop previously developed land.
3.20 Fifthly, it is unlikely that a strategy reliant on urban intensification / redevelopment of previously developed land will deliver the types of homes required or infrastructure improvements. It is unlikely, for example, that such approach would deliver as many affordable homes as alternative strategies, or be accompanied by any substantial infrastructure improvements, due to the likely limited scale of individual developments and potential viability challenges they would face.
3.21 It is manifestly clear that if the Local Plan is to be a sound plan that meets development needs in a sustainable manner, then it cannot rely wholly on RLPSO Option 1.
3.22 The NPPF confirms (at paragraph 136) that Local Plans are the appropriate vehicle through which to make alterations to the Green Belt boundary. The NPPF also states that such alterations should only be made where exceptional circumstances are fully evidenced and justified; and that strategic policies should establish the need for any changes to Green Belt boundaries.
3.23 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.
3.24 Given the scale of objectively assessed need faced by the District, 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 Rochford Local Plan.
3.25 We also note that there are potential options for the District to explore designation of additional, new Green Belt – land on the eastern side of the District, at Foulness, is very much open and rural in character, and in addition subject to multiple constraints that
make it unsuitable for any significant scale of development. However, this area of the District is not currently allocated as Green Belt.
4.0 Response to Local Plan Spatial Options Question 9
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?
4.1 We agree that the Local Plan should seek to direct development to Flood Zone 1 (land least at risk of flooding from tidal or fluvial sources).
4.2 In doing so, however, it is important that sites, part of which lie in Flood Zone 2/3, but which are perfectly capable of accommodating a quantum of development in Flood Zone 1, are not rejected on flood risk grounds. To do so would be patently unjustified, giving rise, ultimately, to soundness concerns.
5.0 Response to Local Plan Spatial Options Questions 32 and 34
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?
5.1 It is considered that the allocation of additional sites for development gives rise to the potential to make significant enhancements to green and blue infrastructure.
5.2 For example, in respect of proposals for Peggle Meadow, Rochford, and as set out in the Vision Document that accompanies these representations, green and blue infrastructure enhancements are proposed.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
5.3 The development of Peggle Meadow, Rochford (CFS095) gives rise to the potential for green and blue infrastructure enhancements to be delivered, as set out in the Vision Statement that accompanies this representation.
6.0 Response to Local Plan Spatial Options Question 46
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?
6.1 It is critical that the Local Plan seeks to direct sufficient growth to the District’s various
settlements such that inter alia local services and facilities can be sustained and supported.
6.2 We consider that the Local Plan should seek to support and enhance the vitality and vibrancy of the District’s town centres; and to sustain village and neighbourhood centres.
6.3 It should be recognised that towns such as Rochford contain smaller neighbourhood centres, as well as a town centre, and that these often perform an important function for the local community which planning should seek to support.
6.4 The town centre and neighbourhood centres both have important roles in such settlements, and the Local Plan should look to support both. In respect of South
Rochford, for example, it is considered that the Local Plan should seek to ensure that neighbourhood shopping along Southend Road is sustained, as well as acting to
enhance the vitality of the town centre. Support for both is not mutually exclusive – the direction of growth to South Rochford can help support local neighbourhood shops, as well as the town centre.
7.0 Response to Local Plan Spatial Options 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?
i. Housing
7.1 The Site (CFS095) is considered suitable, available and achievable for residential development in a highly sustainable location for additional growth, and without
undermining the strategic purpose of the Green Belt. This is discussed in further detail in response to this question.
7.2 In addition, the Vision Document for Peggle Meadow that accompanies this representation (Appendix A) details the sustainability and deliverability of the Site for
housing, and demonstrates how a high-quality development will be delivered on the Site.
South Rochford as a location for growth
7.3 The adopted Core Strategy (2011) identifies Rochford as a tier 1 settlement, noting that it is a local centre. Rochford is one of the largest settlements in the District and is home to a range of services, facilities, employment opportunities, and is well served by public transport. It clearly represents a sustainable location to which a proportion of the District’s growth should be directed.
7.4 The general location South Rochford was considered through the Council’s previous Local Development Framework process and Core Strategy as a general location for growth.
7.5 The Council’s reasons for rejecting South Rochford were set out in the Core Strategy Sustainability Appraisal Addendum (2011) and were as follows:
“Location 2 [South Rochford] was not selected as it has the potential to engender coalescence with Southend, performed less well in sustainability terms compared with
West Rochford and would be less likely to deliver community benefits than development in South East and East Ashingdon”.
7.6 It is important to note that these concerns related to the general location of South Rochford, and not to any specific site.
7.7 The other reason to reject South Rochford as a general location was not that it was an unsustainable area for growth per se, but rather there were other areas that were considered more sustainable.
7.8 Firstly, it should be recognised that these areas have subsequently been developed, or their development is already been accounted for, and that there is still an outstanding need for housing.
7.9 Secondly, since adoption of the Core Strategy, Rochford District – jointly with Southendon-Sea Borough Council – adopted the London Southend Airport and Environs Joint Area Action Plan (JAAP). The JAAP directs significant employment growth and
infrastructure improvements into the area commensurate with the general location of South Rochford.
7.10 In addition, a railway station has been delivered at London Southend Airport. This is accessible from a number of locations within South Rochford, and significantly enhances the sustainability of this area for growth.
7.11 Having regard to the above, it is clear South Rochford is considered a sustainable location for growth.
Peggle Meadow (CFS095)
7.12 Peggle Meadow, Rochford is site reference CFS095 in the Council’s current plan-making process.
7.13 It is located off Southend Road, at the southern end of Rochford. Peggle Meadow is a mall site on the edge of an existing urban area, with development immediately to the north and west.
7.14 The Site measures c.3.9 ha, is mostly grassland, resembling a horse paddock, and contains several storage sheds no longer in use.
7.15 Historically, the land was farmed as market gardening. However, it has not been in productive use for c.25 years and has been uncultivated during this time. The land is not currently in use and, indeed, is no longer viable for agricultural use.
7.16 The Site is located to the south of Rochford, and is subject to a significant degree of containment due to the existing residential development immediately to the north and west; and watercourses and their accompanying dense vegetation to the south and east.
Views into and out of the Site are very much restricted.
7.17 The Site is close to the District boundary with Southend Borough Council, with Warners Bridge Park to the south providing a substantial and robust green buffer between it and the built form of Southend-on-Sea.
7.18 Arable fields are located to the east of the site, though it should be recognised that the Site does not project any further eastwards than the existing built form to the north of the Site.
7.19 There are a range of shops, services and facilities within close proximity to this Site.
7.20 As set out in the Vision Document (Appendix A) that accompanies this representation,
the Site is within walking distance to a range of facilities, services, public transport connections, and employment opportunities; and benefits from excellent access to rail
and bus services, providing sustainable links to larger centres.
7.21 A retail park including both convenience and comparison shops is located approximately 400m from the site – well within walking distance. Additionally, a neighbourhood shopping parade is located to the north of the Site, and also within walking distance.
7.22 London Southend Airport and Southend Airport railway station (which provides links to Southend, Rochford centre, and London Liverpool Street), are located opposite the site and within walking distance.
7.23 In addition to being accessible to future employment growth at London Southend Airport, the site is well located in relation to existing employment areas at Temple Farm Industrial Estate and Purdeys Industrial Estate.
7.24 The Site is accessed via Southend Road – which provides a direct connection with Southend to the south; and Rochford town centre to the north, negating the need for vehicles travelling from the site to either of these centres to navigate through existing residential areas / the non-strategic highway network within the District.
7.25 Development of the Site is presents a number of opportunities, which are discussed in details within the Vision Document. In summary, these opportunities / benefits of the Site’s development include:
 Creation of a more robust and defensible Green Belt boundary.
 Minimal impact on the Green Belt, and would not engender coalescence.
 Landscape enhancements.
 Provision of homes in a location well related to facilities, services and employment opportunities; and with excellent accessibility to public transport services.
 Enhanced sustainable transport links for the wider area.
 Avoidance of impact on the District’s local highway network.
7.26 In relation to the Site’s ability to deliver improved sustainable transport links to the benefit of the wider area, the cycling and walking charity, Sustrans, have confirmed they expressly support development of the Site due to the sustainable transport
improvements it will enable. A copy of Sustrans’ letter is provided as Appendix B. We consider this is a factor that should be afforded significant weight in favour of the Site’s allocation.
7.27 Further to the Site’s excellent accessibility to public transport services (including rail and bus) it is important to note that the NPPF states:
“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”. (Paragraph 142, emphasis added)
7.28 The Site has been considered by the Council through its Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017) (as site referenceCFS095).This noted that the Site is not subject to any constraints that would prohibit its development.
7.29 The SHELAA (2017) considered the Site’s proximity to educational facilities; healthcare facilities; open space / leisure facilities; retail facilities; public transport facilities; and existing residential areas. Against all of these, with the exception to education, it found that the site’s proximity was ‘good’.
7.30 In respect of proximity to education it was rated as ‘medium’.
7.31 In respect of proximity to education, we note that the SHELAA (2017) does not consider that this renders the site unsuitable, but would nevertheless wish to emphasise that the Site is in close proximity to Southend Road along which run regular bus services which
connect the site to a number of schools (and, considering accessibility beyond educational facilities, to the town centre).
7.32 The SHELAA (2017) acknowledged that the vast majority of the Site is within Flood Zone 1 – land least at risk of tidal or fluvial flooding. Development of the site can be delivered without residential development taking place within Flood Zone 2 or 3.
7.33 The Site has been subject to a Flood Risk Assessment (July 2020), provided as Appendix C to this representation. Key conclusions of this Flood Risk Assessment include:
 All proposed dwellings will be located within Flood Zone 1. NPPF states that all uses of land are appropriate in this zone and the Sequential Test has been applied within
the site boundary and can be deemed as being passed.
 All built development and SUDS features will be located outside of the design climate change (35%) 1 in 100 year floodplain and climate change (65%) 1 in 100 year floodplain.
 Proposed dwellings will be set above the extreme climate change 1 in 1000 year flood level.
 Safe access/egress can be achieved during the peak of the event.
 It is considered that there is a low risk of groundwater flooding.
 There is a very low to high risk of surface water flooding which will be mitigated by ensuring that the proposed dwellings are set above the flood depth. 7.34 The SHELAA (2017) confirmed that the Site can be delivered without requiring significant infrastructure upgrades.
7.35 Vehicular access to the site can be achieved, as confirmed through an Access Appraisal
that has been undertaken, and previously submitted to the Council.
7.36 There are no physical constraints that prohibit the development of Peggle Meadow for housing.
7.37 The SHELAA (2017) concluded that the Site’s suitability for development will be dependent on a Green Belt assessment.
7.38 Subsequently, the Council published the Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’).
7.39 The Green Belt Study (2020) suggested that development of the Site would result in ‘moderate-high’ level of harm to the Green Belt.
7.40 Within this study, the Site forms a small part of the a larger parcel that was assessed as P65.
7.41 The Green Belt Study (2020) concluded that Parcel P65 makes a strong contribution to purposes 1, 2, 3 and 5 of the Green Belt (to check the unrestricted sprawl of large builtup areas; to prevent neighbouring towns merging into one another; to assist in safeguarding the countryside from encroachment; and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land). It concluded that it makes a weak contribution to purpose 4 (to preserve the setting and special character of historic towns).
7.42 It is important to recognise the need to treat the results of any assessment of a larger parcel with caution when seeking to apply them to a smaller site within such a parcel. Clearly, smaller sites within a larger parcel may make a different level of contribution to the purposes of the Green Belt, and the harm their development may cause to the purposes of the Green Belt may well be different to that of the larger parcel in which they
have been incorporated for the purposes of assessment. 7.43 A note provided by the Local Plan Examination Inspector to Welwyn Hatfield Borough Council in relation to its Local Plan and the approach to the review of the Green Belt underlines this issue, stating:
“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).
7.44 As such, it is imperative to consider the Site itself: its contribution to the purpose of the Green Belt, and the extent of any harm to the purposes of the Green Belt that its development would entail.
7.45 In addition, case law confirms that in considering whether exceptional circumstances apply that justify alterations to the Green Belt, it is necessary to not only consider the potential harm to the purposes of the Green Belt development would engender, but also the degree to which such harm could be mitigated. The Green Belt Study (2020) fails to consider potential mitigation measures, and this will be something that the Local Plan
will need to consider.
7.46 A Green Belt Report (2020) has been prepared and submitted previously to the Council, and provided again as Appendix D to this representation. In addition, a site-specific Landscape and Green Belt Statement (2021) has been undertaken by James Blake Associates and provided as Appendix E.
7.47 As these studies confirm, when one looks at the Site in detail, it is clear that it only make a limited contribution to the purposes of the Green Belt.
7.48 The Landscape and Green Belt Statement (2021) considered the Site specifically, and in detail. In relation to Purpose 1 of the Green Belt (to check the unrestricted sprawl of large built up areas) it noted that the Site is located in close proximity to the built up area of Rochford and would not result in encroachment. Rather, its development would result in limited ‘infill’ of the previous brownfield land. It also noted that the Site is well contained by strong physical features including the built-up area of Rochford, the Prittle Brook and the Harp House Ditch. Overall, it concluded the Site was of low importance to Purpose 1 of the Green Belt.
7.49 In relation to Purpose 2 (to prevent neighbouring towns merging into one another) the Landscape and Green Belt Statement (2021) found that the Site is physically and visually separated from Southend and as such would not result in any physical or visual
encroachment. Furthermore, it noted that Warners Bridge Park provides a gap between Rochford and Southend which is of substantial permanence, and that the gap which exists now between the two settlements will exist to no greater or lesser degree whether or not Peggle Meadow is developed. It concluded the Site is of zero importance to Purpose 2.
7.50 Regarding Purpose 3 of the Green Belt (to assist in safeguarding the countryside from encroachment), the Landscape and Green Belt Statement (2021) found that the Site is well contained by strong man-made features to the north and west, and and dense and mature green infrastructure to the east and south. It also noted that the proposed strategic green infrastructure will provide further containment. As the Landscape and Green Belt Statement (2021) noted, it is also relevant that the Site has a degraded / neglected character. It concluded that the Site is of low importance to Purpose 3 of the
Green Belt.
7.51 In relation to Purpose 4 (to preserve the setting and special character of historic towns) the Landscape and Green Belt Statement (2021) concluded that the Site is not considered to form part of the landscape setting of a historic town, nor does it impact on any Conservation Areas or Listed Parks and Gardens. It went on to conclude the Site is of zero importance to Purpose 4.
7.52 In summary, the Landscape and Green Belt Statement (2021) provided by James Blake Associates concludes the Site is of low importance to Purpose 1 and Purpose 3 of the Green Belt, and of zero importance to Purpose 2 and Purpose 4. It provided clear and
robust justification for reaching such conclusions.
7.53 In respect of the need to consider the potential to mitigate impacts on the Green Belt in addition to considering a site’s contribution to the purposes of the Green Belt, it is relevant to note mitigation measures are proposed as part of the development of the
Site.
7.54 These include enhanced landscaping to reinforce the existing mature vegetation towards the southern boundary; and a loose-grained layout of dwellings towards the south and east of the Site (proposed to take a traditional form, and will be a scale and massing
which reflect the existing residential development in the locality, in order to minimise visual impact).
7.55 Additionally, and still in relation to the issue of Green Belt, the NPPF states that where Green Belt is released to meet development needs, as well as prioritising locations close to public transport links, plans should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. The PPG3
sets out the compensatory improvements that strategic plan-making authorities should seek to deliver in the event that it is necessary to release land from the Green Belt. These include the following:
 New or enhanced green infrastructure;
 Woodland planting;
 Landscape and visual enhancements (beyond those needed to mitigate the immediate impacts of the proposal);
 Improvements to biodiversity, habitat connectivity and natural capital;
 New or enhanced walking and cycle routes; and
 Improved access to new, enhanced or existing recreational and playing field provision.
7.56 A number of such compensatory improvements can be delivered through development of the Site. 7.57 In terms of new or enhance green infrastructure, in addition to the enhanced landscaping that is proposed, the proposed development also incorporates the creation of a new public open space to the north of the Site. This will also provide a recreational benefit.
7.58 Through development of the Site, ecological benefits will be delivered, with ecological enhancements to be delivered as part of the additional landscaping enhancements,
SuDS and open space provision.
7.59 In terms of cycle and pedestrian link enhancements, the Site represents a unique opportunity to deliver a cycle link which the Core Strategy (2011) promoted.
7.60 This link is discussed further within the accompanying Vision Statement, and to reiterate,
is supported by Sustrans.
7.61 This link will facilitate a safe and attractive pedestrian and cycle access to Warners
Bridge Park, Temple Farm Industrial Estate, and to Southend-on-Sea more generally,
for existing and future residents of Rochford.
7.62 It should be noted that this new link will also provide a safe and convenient pedestrian / cycle access for existing and future residents of Rochford to recreational facilities and playing fields at Warners Bridge Park.
7.63 The ability of the Site to deliver the above compensatory measures called for by national
guidance in instances where land is removed from the Green Belt, are factors which weigh very much in favour of removing this Site from the Green Belt.
7.64 The Site is clearly a suitable and sustainable site for residential development, and one through which a number of additional benefits, in addition to the provision of housing, can be delivered.
7.65 Turning In relation to deliverability, the Site is not subject to any legal or ownership constraints to its delivery for housing, and is being actively promoted for development by the owner. It is an available and achievable site for residential development, in addition
to being a sustainable one.
7.66 A Landowner’s Vision Statement has been prepared by the landowner, and accompanies this representation as Appendix F. This sets out the landowner’s desire for an exceptionally high quality development at Peggle Meadow, to provide a legacy for this Site, which has been in his family’s ownership for generations.

Ref. CFS027
CFS098
CFS029
CFS053

NO to any proposed planning on greenbelt land.

Proposal Objection
Site No CFS141 – 231 houses proposed (fields at Stewards Elm Farm)
Site No CFS072 – 167 houses proposed (field to the right looking up Cagefield Rd)
Site No CFS073 – 74 houses proposed (field on the left looking up Cagefield Rd)
Site No CFS113 – Mill Lane – 39 houses proposed
Site No CFS114 – Behind the Cherry Tree – 39 houses proposed
Having found it very hard to navigate your Spatial Options website in order to object (not everyone is IT literate enough to understand your objection site……but many residents are of the opinion that was precisely the intention!) I though it best to email my objections to your proposals to build on the above listed sites

I am sure by now you have heard all the obvious objections…..yes, our homes are built on an existing flood plain. Therefore to any sensible thinking person, it would be extremely unwise to build anything further on it. The farmers help to minimise risk during bad weather with double ditches etc to help run off and the open land around us helps too as the rate of water soak up is 20 times what it would be if the area was built on.

However, the Environmental Report released only this week should give us all cause to rethink how we are doing things. The sea and river levels are predicted to rise over the next two decades, making living in coastal or river flood plains even more risky. Large scale weather events resulting in flooding are set to become more and more frequent (our own summer so far being an obvious sign and set to get worse) and the only defence we have against our homes being destroyed in the future, is the large expanses of open land around us. Take that away and you leave us and any future residents open to disaster, huge insurance bills and misery

The contractors are only interested in buying cheap agricultural land, throwing up as many houses as possible and making as much money as possible. The councils priority appears to be fulfilling Government housing quotas however they possibly can, with the Government giving little thought to the disastrous impact heir actions may have on the people that already live here….places that they themselves have never visited, don’t live in and are just a blue patch on their map

Our way of life is simple, with no amenities or frills but our community is strong, historic and beautiful and we are very proud of our roots here which for many of us go back over generations. The information you have for us seems very inaccurate. Even your documents covering the 1-5 ratings for access to facilities out here is wrong, with Primary school rating as a 4 (good) Anyone who knows this village well would know we have one primary school….difficult to access unless you drive and with the capacity for only 84 pupils and already has 95!!! Just how many of these 550 homes are likely to have children wanting to go to an already over subscribed village school!!!!

I could go on listing the ways in which this proposal is utter folly and how your rating system is inaccurate but I think the Council is well aware
I would urge you therefore to look to build on more suitable sites, brown sites, old commercial sites and spend money on getting old unoccupied property up to scratch and inhabited. Building on Greenbelt should always be prohibited lest this “green and pleasant land” become nothing more that concrete. Leave the Ward Council some credibility with its voting public

I am writing to express my concerns regarding the proposed plans within the Spatial Options Consultation 2021. The plans for additional housing developments will further reduce the green spaces locally and infringe upon greenbelt land.
A brief word about the consultation itself; while the documentation has been made available and residents have been informed, I do not believe that it is presented in a manageable or accessible format. There is a plethora of information the questionnaire is very long, and the language used is formal, wordy, and fairly technical in nature. I expect that despite many residents having concerns many will not respond as they will see it as too time-consuming and impenetrable.

An uncertain future
Given the upheaval caused by the pandemic this is probably not the time to make firm plans for the next 20 years. We have been going through a period of huge change. The way we work and live are likely to be affected for some time to come, some changes will be permanent with more people working from home some or all the time. In turn this means that the use of office and retail space will change significantly. More people are moving towards online shopping and gradually retailers are improving the online shop experience. These changes are likely to free up space for redevelopment of existing office and retail space into residential use. I believe that rather than building on green field sites we should consider a more conservative approach to wait to see whether the effects of the pandemic mean that existing sites can be redeveloped. Once the green field sites have been used, they are gone. Furthermore, the pandemic has highlighted the need for areas of nature for recreation and health. It can surely not be wise to shrink these areas while adding to the population? This cannot have a positive effect on the health and wellbeing of the local population.

Local character, Historic Towns
The character of the local area is being gradually eroded with the green spaces between towns such as Rochford, Hockley, and Rayleigh dwindling. If the proposed blue sites on the interactive map https://rochford.opus4.co.uk/ you have provided were to be used for development the area is close to becoming one large conurbation. Thus, the towns will lose their character and simply become areas within a larger whole.

Greenbelt
There are many proposed sites that appear to sit within, or directly on or adjacent to the boundaries of Metropolitan Green Belt land. These appear to include, CFS07L, CFS027, CFS053, CFS160, CFS134, CFS002, CFS045, CFS251, CFS074, CFS082, CFS078, CFS080, CFS081, CFS135, CFS064, CFS264, CFS040, CFS160, CFS105, CFS024. Moreover, some of these sites would appear to involve building within Marylands Nature reserve in Hockley (CFS024) or within Hockley Woods (CFS160) or next to the boundary of Betts Farm ancient woodland and Folly Wood (CFS064). This would obviously cause immense damage to the natural environment, loss of ancient woodland and potential loss to rare species. Even if the woodland itself is not built upon the disruption to the site while building work is taking place and the loss of linking areas of open land will have a detrimental effect on the woodland environment, causing fragmentation. Studies done by charities such as The Woodland Trust state that inappropriate development of land adjacent to woodland can cause chemical pollution, disturbance to wildlife, fragmentation, introduction of non-native plants and other negative cumulative effects. Please see: Threats to woods and trees - Woodland Trust
I would draw your attention to the following paragraph within The National Planning Policy Framework revised 20th July 2021.
“13. Protecting Green Belt land 137. The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence. 138. 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”
And
“Proposals affecting the Green Belt 147. Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances”
Within The draft vision for Rochford in 2050 Strategic Priority 5 is “Making suitable and sufficient provision for climate change mitigation and adaptation, conservation and enhancement of the natural and historic environment, including landscape”. I believe the plans for housing developments within the green belt will directly obstruct this priority.


Congestion, Pollution, Gridlock
An area of huge concern amongst residents is the effect of all the additional traffic created both during the building of new developments and once built from the increased traffic caused by increased population. Infrastructure in the local area is woefully insufficient already. The B1013 links Rochford, Hawkwell, Hockley and Rayleigh. Greensward Lane and Ashingdon Road link to this road. Should further housing be added to the area the pressure on these roads will be immense. There will be further delays, additional pollution, and road traffic accidents. There is already severe traffic especially at peak times along these roads. One small accident can cause gridlock. Rochford District Council is fully aware of these issues as they have been raised time and time again by residents.

In conclusion I implore you to consider carefully the impact of further residential developments on the infrastructure, character, and green field sites of our area. Examine meticulously the emerging trends due to the effects of the pandemic and our increasing dependency on information technology and take a far more conservative approach to the management of our open spaces.

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

Critical Drainage Risk
3
Green Belt Harm
1

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



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

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

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

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

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

I am writing to provide a response of behalf of East of England Ambulance Service NHS Trust (EEAST) in relation to the consultation on the Rochford Local Plan Spatial Strategy Options and to confirm our commitment to working in partnership with the Council and Mid and South-East Essex Sustainability and Transformation Partnership (MSE) (and any successor organization) to jointly plan the necessary infrastructure to help local community in Rochford prosper.
As part of joint health working, EEAST agree and support the points made by MSE in their separate response to the Strategic Objectives for Rochford.
As both a health partner and an emergency service, EEAST would hope to engage with the Council as the Integrated Development Plan is developed as a supporting document to the 2050 Rochford Local Plan. EEAST would request any developments adopt the jointly created emergency services Design Guide for Essex details can be found using the attached link: Engaging with the Emergency Services | Essex Design Guide (https://www.essexdesignguide.co.uk)
We welcome further discussions with the Council around how we collectively can mitigate the cumulative impact of housing and infrastructure developments across health services serving Rochford and where appropriate the surrounding area. Every effort is made to EEAST’s request for developer contribution is tailored to each individual development, or where less than 50 dwellings in each development, group of developments.

EEAST are in the process of developing an evidence-based formula to identify the impact of population growth for housing and infrastructure developments on ambulance services. This will include key projects to enable delivery of our services due to population growth on housing developments, nursing and care homes or over 55 developments. EEAST together with MSE would welcome further discussions around how the infrastructure impact of the Borough’s 2050 Local Plan can be collectively addressed and support net Carbon Zero, to deliver BREEAM Outstanding sustainability standards.

EEAST’s Estates Strategy (2020-2025) summary position is to provide cost effective and efficient premises of the right size, location, and condition to support the delivery of clinical care to the community served by the Trust. A range of national initiatives are underway aimed at improving performance and sustainability within the NHS across wider urgent and emergency system in all six counties along with Local Authorities and Councils, Universities, military establishments, and private providers of ambulance services. Addressing these changes requires the Trust to develop revised operating models and strategies for all aspects of its services, including operational support services such as the Estates Service. A key component of this process has been to establish the Trust’s future Operating Model and to commence planning for the resulting transformation of support services. Expansion to the existing Make Ready Hub and Spoke network will be required to meet the growing demographics.
Each Hub will have a network of Spokes termed Ambulance Station Response Posts (ASRP), tailored to meet service delivery and patient response specific to their local area. Other infrastructure developments such as road and rail also impact on EEAST as an emergency services provider, with requirements to meet nationally set response times.
The spoke network is determined by the changes to infrastructure and changes to local population health care needs through patient flow modelling and subsequently EEAST staffing requirements. The aim is to create demand-centric and agile spokes which are adapted to activity requirements (both permanent and temporary workforce requirements during significant infrastructure development construction periods) as these change over time.

Current East of England Ambulance Stations close to Rochford

Spokes can be made up of:
• Ambulance Station Reporting Base - 24/7 permanent reporting base for staff and primary response location for one or more vehicles
• Ambulance Station Response Post - primary response location which includes staff welfare facilities
• Standby Location - set in strategic locations where crews are placed to reach patients quickly. Facilities used by staff are provided by external organisations to EEAST.
The resulting estate configuration which consists of a network of up to 18 ambulance Hubs. Each Hub will incorporate:
• A make ready center from which the Make Ready Service is delivered
• Workshop facilities providing service, maintenance, and repair services for operations vehicles within the local spoke network, including Patient Transport Service (PTS) vehicles
• Consumable product stores, with stock-levels maintained on a just-in-time basis by direct supplier delivery
• Some Hubs will operate additionally as the bases for certain corporate, administrative and support services
• PTS facilities incorporated into the operational estate, primarily at the Hubs.
In addition, across the Trust’s region there are:
• Two Hazardous Area Response Team (HART) bases, located to best support the major airports within the Trust’s region
• A Trust HQ co-located within operational premises
• A regional training school providing staff professional training, co-located with driver training and supported by up to two satellite professional training locations plus general training facilities at each of the Hubs
• A fleet logistics center at one of the Hubs’, incorporating a 24-hour fleet logistics call-center
The Rochford area is covered by the Southend Hub which forms one of the 18 Make Ready Hubs across the region.
EEAST estates and development plans consider growth in demographics of population changes and therefore any increase in requirements to meet these changes will require modelling to account for the required increased workforce, equipment and vehicles. EEAST are currently participating in a service review to better understand what resources are needed to meet patient demand.

Acute, Mental Health, Social and Out of Hospital Services
As Integrated Care Systems deliver hospital services reconfiguration and transformation into new models of care, this means ambulance services will be impacted by:
• Ageing population and greater number of people living with long term conditions – creates greater demand on both emergency and commissioned patient transport services.
• An increased need for emergency ambulance services to deliver more out of hospital care, such as by expanding their “hear and treat” and “see and treat” services.
• Development of centralised care Hubs, such as vascular and stroke networks, may lead to increased conveyance times, but with improved outcomes for patients.
• Changes to discharge care models are likely to increase the number of patients discharged with more complex needs and are likely to require increased levels of care during transportation as well as effective and timely handover of care.
• Focusing on improvements to acute and ambulance service diagnostic and digital connectivity.
The provision of health and social care services out of hospital care into community and social care via diagnostic hubs and community locations will require changes to patient transport services.

Assessment of Rochford Local Plan 2050 Spatial Strategy Options

This section provides further assessment of the impact of each of the proposed options on EEAST Emergency Ambulance Services across the Spatial Options Consultation Paper 2021 and the likely mitigations to be considered as part of the Infrastructure Delivery Plan next year.

STRATEGY OPTION 1: Urban Intensification

Existing planned housing developments, including sites with planning permission, existing allocated sites and urban developments, involving around 4,200 new homes of which at least 800 will be affordable. Support utilisation of existing site and urban developments with provision of at least 800 affordable homes.

In relation to ambulance services providing support to this population growth, wherever possible this would be incorporated into existing ambulance Hubs or response posts, however this may not be possible and additional response or stand by posts may be required or relocated. This may be in larger primary care premises or jointly located with fire and police or other potential solutions.

EEAST would request any developments adopt the created principles in Essex: Engaging with the Emergency Services Essex Design Guide.

Potentially a further 1,500 homes by allowing higher density developments in urban areas and on existing allocations. As above
Existing planned employment developments, including sites with planning permission and existing allocated sites, involving a minimum of 120,000 m2 of permissioned employment space, including new high quality space at Airport Business Park and Michelin Farm As above
Capacity improvements to existing schools and healthcare centres, new onsite open spaces and sports facilities Any new health/medical premises would ideally provide the opportunity to explore an ambulance response post at this location including a suitable fast charging EV connection.

Potential requirement for financial contributions from developers.
Limited opportunities to deliver transformational new infrastructure as many of the developments would fall below the 50-home threshold to contribute to new infrastructure The combination of a number of small developments (<50 dwellings) affects ambulance service provision and consideration is requested to enable financial contributions from developers is assessed on a block basis to enable expansion or introduction of new response posts to retain the nationally mandated response times
Option 1 Urban Intensification EEAST does not have any particular preference for each sub-option, as any development option requires consideration of the suitable location of ambulance response and/or standby posts in order to meet the needs of the patient population growth which will impact on our ability to achieve national response times.

Our main consideration is the ability to access financial contributions from developers to support the expansion or relocation of ambulance stations/reporting/response and/or standby posts
Total 4,200 + 1,500 dwellings

STRATEGY OPTION 2: Urban Extensions
Option 2a: Focused on main towns
Option 2b: Dispersed to all settlements based on Settlement Hierarchy

An additional 3,000 – 5,000 homes relative to Option 1 of which at least 1,000-2,000 would be affordable Support utilisation of existing site and urban developments with provision of at least 1,000 – 2,000 affordable homes.

In relation to ambulance services providing support to this population growth, wherever possible this would be incorporated into existing ambulance Hubs or response posts, however this may not be possible and additional response or stand by posts may be required or relocated. This may be in larger primary care premises or jointly located with fire and police or other potential solutions.

EEAST would request any developments adopt the created principles in Essex: Engaging with the Emergency Services Essex Design Guide.

Up to 3 new primary schools, new medical facilities, open spaces, employment areas and transport connections Any new health/medical premises would ideally provide the opportunity to explore a response post at this location including a suitable fast charging EV connection.

Potential requirement for financial contributions from developers.

Opportunities to support rural services by directing some growth to villages with rural shops, schools or community facilities We support rural growth combined with regular appropriate public transport arrangements to support people getting to work/recreation/use of community facilities

The combination of a number of small developments (<50 dwellings) affects ambulance service provision and consideration is requested to enable financial contributions from developers is assessed on a block basis to enable expansion or introduction of new response posts to retain the nationally mandated response times.
Option 2a: Focused on main towns

Option 2b: Dispersed to all settlements based on Settlement Hierarchy
EEAST does not have any particular preference for each sub-option, as any development option requires consideration of the suitable location of ambulance response and/or standby posts in order to meet the needs of the patient population growth which will impact on our ability to achieve national response times.

Our main consideration is the ability to access financial contributions from developers to support the expansion or relocation of ambulance stations/reporting/response and/or standby posts
Total between 3,000-5,000 dwelling with 1,000 – 2,000 affordable

Option 3: Concentrated growth
Option 3a: Focused west of Rayleigh
Option 3b: Focused north of Southend
Option 3c: Focused east of Rochford

An additional 3,000 – 5,000 homes relative to Option 1 of which at least 1,000-2,000 would be affordable Support utilisation of existing site and urban developments with provision of at least 1,000 – 2,000 affordable homes.

In relation to ambulance services providing support to this population growth, wherever possible this would be incorporated into existing ambulance Hubs or response posts, however this may not be possible and additional response or stand by posts may be required or relocated. This may be in larger primary care premises or jointly located with fire and police or other potential solutions.

EEAST would request any developments adopt the created principles in Essex: Engaging with the Emergency Services Essex Design Guide.

Up to 1 new secondary school, 3 new primary schools, new medical facilities, open spaces, employment areas and new link roads Any new health/medical premises would ideally provide the opportunity to explore a response post at this location including a suitable fast charging EV connection.

Potential requirement for financial contributions from developers.
Greater opportunities to attract Government investment into existing and new infrastructure as part of the Thames Estuary Growth Area. Support growth opportunities
Greater opportunities to work with Basildon, Castle Point, Essex and Southend Councils to co-ordinate funding towards transformational transport infrastructure projects such as a new inter-urban rapid transit system or new link roads EEAST as an emergency service needs to be aware of and involved in transformational infrastructure projects as during the construction phase this may impact on our ability to achieve national response times.

Infrastructure changes also impact on any commissioned Patient Transport Services to ensure timely delivery and collection of patients for their appointments to acute hospitals/diagnostic hubs or other out of hospital services
Opportunities to deliver the eastern extent of the South Essex Estuary Park forming a new coastal country park in the east of the District Support opportunities to improve health and well -being of residents and visitors to the area
Option 3a: Focused west of Rayleigh

Option 3b: Focused north of Southend

Option 3c: Focused east of Rochford
EEAST does not have any particular preference for each sub-option, as any development option requires consideration of the suitable location of ambulance response and/or standby posts in order to meet the needs of the patient population growth which will impact on our ability to achieve national response times.

Our main consideration is the ability to access financial contributions from developers to support the expansion or relocation of ambulance stations/reporting/response and/or standby posts
Total between 3,000-5,000 dwellings with 1,000 – 2,000 affordable

Option 4: Balanced Combination
No sub-options

An additional 3,000 – 5,000 homes relative to Option 1 of which at least 1,000-2,000 would be affordable. Support utilisation of existing site and urban developments with provision of at least 1,000 – 2,000 affordable homes.

In relation to ambulance services providing support to this population growth, wherever possible this would be incorporated into existing ambulance Hubs or response posts, however this may not be possible and additional response or stand by posts may be required or relocated. This may be in larger primary care premises or jointly located with fire and police or other potential solutions.

EEAST would request any developments adopt the created principles in Essex: Engaging with the Emergency Services Essex Design Guide.

Up to 1 new secondary school, 3 new primary schools, new medical facilities, open spaces, employment areas and new link roads. Any new health/medical premises would ideally provide the opportunity to explore a response post at this location including a suitable fast charging EV connection.

Potential requirement for financial contributions from developers.
Greater opportunities to attract Government investment into existing and new infrastructure as part of the Thames Estuary Growth Area Support growth opportunities
Greater opportunities to work with Basildon, Castle Point Essex and Southend Councils to co-ordinate funding towards transformational transport infrastructure projects such as a new inter-urban rapid transit system or new link roads EEAST as an emergency service needs to be aware of and involved in transformational infrastructure projects as during the construction phase this may impact on our ability to achieve national response times.

Infrastructure changes also impact on any commissioned Patient Transport Services to ensure timely delivery and collection of patients for their appointments to acute hospitals/diagnostic hubs or other out of hospital services
Opportunities to support rural services by directing some growth to villages with rural shops, schools or community facilities. We support rural growth combined with regular appropriate public transport arrangements to support people getting to work/use of community facilities

The combination of a number of small developments (<50 dwellings) affects ambulance service provision and consideration is requested to enable financial contributions from developers is assessed on a block basis to enable expansion or introduction of new response posts to retain the nationally mandated response times
Opportunities to deliver the eastern extent of the South Essex Estuary Park forming a new country park in the east of the District Support opportunities to improve health and well-being of residents and visitors to the area
Option 4 Balanced Combination EEAST does not have any particular preference for each sub-option, as any development option requires consideration of the suitable location of ambulance response and/or standby posts in order to meet the needs of the patient population growth which will impact on our ability to achieve national response times.

Our main consideration is the ability to access financial contributions from developers to support the expansion or relocation of ambulance stations/reporting/response and/or standby posts
Total between 3,000-5,000 dwellings with 1,000 – 2,000 affordable

We hope this information provides a useful indication of the expected impact on health services for East of England Ambulance Services on the proposed Spatial Strategy Options set out in the Local Plan 2050 consultation document. We look forward to working with the Council, Mid Essex STP, police and fire colleagues throughout the development of the Local Plan 2050 and associated Infrastructure Delivery Plan.

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

1.0 Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options (RLPSO) on behalf of Countryside Properties and in respect of Land at Pulpits Farm, Hockley.
1.2 The Site has previously been submitted in response to the Council’s Call for Sites, and is reference CFS263 in the Council’s plan-making process (although also referred to as Site 272, in the Council’s Green Belt Study (2020))
1.3 This representation should be read alongside the Vision Document that has been prepared in respect of the development of the Site, and which accompanies the
representations as Appendix A.
2.0 Response to Local Plan Spatial Options Question 4
Q4. Do you agree with the strategic priorities and objectives we have identifies? Is there anything missing from the strategic priorities or objectives that you feel
needs to be included?
2.1 We suggest that improving the affordability of housing for local people in Rochford District should form an objective of the Local Plan.
2.2 As the RLPSO rightly recognises at page 12, housing affordability is a particularly issue within the District.
2.3 ONS data on the affordability of housing reports that in 2020 the median house price was 11.57 times the median gross annual workplace-based earnings. The affordability of housing has worsened significantly in recent years, and is substantially worse than the
national average.
2.4 Without an increase in housing supply, we consider there is a very real risk that it will only worsen.
2.5 Not only do current projections suggest increased housing need in the District, but the longer term impact of the Covid-19 pandemic may well place additional pressure on Rochford’s housing market and affordability of homes for local people.
2.6 Early indications are that there has already been an increased desire to move from more to less urban areas, due to a combination of a desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas; and people considering it less critical to live very near their place of work, given the increase in home working within a number of employment sectors.
2.7 This is of particular relevance to Rochford District, given that 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.
3.0 Response to Local Plan Spatial Options Question 6
Which of the identified strategy options do you consider should be taken forward in the Plan?
3.1 We consider that a balanced approach that includes direction of a relatively significant proportion of the District’s housing needs to the higher tier settlements (including Hockley) would be the most appropriate strategy, for the reason set out below.
Strategy Option 1 – Urban Intensification
3.2 The RLPSO states that this option would entail 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). It is suggested this would involve no loss of Green Belt land, would minimise loss of greenfield, and would deliver
4,200 homes over the next 10 years.
3.3 The RLPSO describes Strategy Option 1 as “the minimum expectation of national policy” and states it is “likely to be required within every strategy option”.
3.4 We agree that it would be consistent with national policy to seek to promote the redevelopment of appropriate previously developed land to help meet development needs. However, we consider that a strategy which were to rely purely on this to meet development needs would be ineffective, unsustainable, incapable of meeting development needs in full as required by national policy, and result in a Local Plan that would be inherently unsound.
3.5 The National Planning Policy Framework (NPPF) confirms (paragraph 35) that one of the requirements of a sound Local Plan is that it seeks to meet the area’s objectively assessed development needs in full. The NPPF also emphasises the Government’s objective to significantly boost housing land supply (paragraph 60).
3.6 However, the RLPSO acknowledges that Strategy Option 1 would fall significantly short of meeting local development needs in full. Not only would this render the plan unsound and contrary to the NPPF, but it would likely result in significant negative social and economic impacts locally.
3.7 In any case, we consider that a yield of 4,200 dwellings over 10 years through urban intensification to be unfeasibly optimistic.
3.8 To achieve this quantum, it would be necessary to sustain an average of 420 dwellings per annum (dpa) over a 10-year period. The Council’s Annual Monitoring Report 2019/20 states that between April 2010 and March 2020, the District achieved a total of 1,768 dwelling completions over this particular 10-year period – an average of just 177 dpa. Furthermore, the delivery of these 1,768 dwellings was not solely through urban
intensification, but also included allocations made through the Rochford Allocations Plan (2014). There is of course only a finite supply of previously developed land that is
suitable and viable for residential redevelopment, and it is considered that much of this has likely already been exhausted, particularly given the emphasis placed by national and local policy on utilising such sites.
3.9 In addition to Strategy Option 1 being unlikely to deliver anywhere near the number of new homes needed in the District, we would also question the appropriateness of such a strategy in any case. To make a meaningful contribution to housing needs over the
plan period, this strategy would likely require development at a significantly greater density than existing development in the District. Not only could this be harmful to the character of the District’s residential areas, but it may also result in loss of amenity for existing residents.
3.10 Furthermore, it is unclear if this approach would deliver the types of homes required where they are required in the District. Such a strategy is, for example, unlikely to deliver a high proportion of family homes.
3.11 For the above reasons, we do not consider that Strategy Option 1 is capable of resulting in a sound Local Plan and should be discounted.
Strategy Options 2, 3 and 4
3.12 Given Strategy Option 1’s inability to result in a sound Local Plan, this leaves Options 2, 3 and 4 as potential strategies.
3.13 Strategy Option 2 is to focus on urban extensions, with Option 2a entailing focussing such growth on the District’s main towns; and Option 2b dispersing to all settlements based on the settlement hierarchy.
3.14 Through Strategy Option 2 sustainable sites could be utilised at the edge of settlements, which should include Hockley, to deliver a range of housing developments, including the provision of much needed housing in the short term. This option provides flexibility to utilise smaller sites to deliver homes earlier alongside larger sites to meet the overall housing need.
3.15 We consider that Strategy Option 2b should include growth to Hockley, given that it is a top tier settlement in the adopted Development Plan’s settlement hierarchy.
3.16 In relation to Option 3, this suggests focussing 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 short term and do not require
significant infrastructure improvements) and in a range of different locations that reflect the fact 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.
3.17 The outcome of the Uttlesford Local Plan Examination provdes a warning regarding the dangers of over reliance on large strategic growth sites to meet housing needs. Recommending the submitted plan be withdrawn due to soundness issues, the Inspectors concluded:
“In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could
deliver homes in the short to medium term and help to bolster the 5 year [housing land supply], until the Garden Communities begin to deliver housing. This would have
the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing”. (Paragraph 114 of Uttlesford Local Plan Examination
Inspectors’ letter of 10 January 2020)
3.18 This does not of course mean that the strategy cannot include strategic growth allocations, only that if it were to, they would need to be accompanied by a range of other small and medium sized sites.
3.19 Strategy Option 4 entails a mix of the other options, and rightly recognises that the alloction of strategic growth sites and the allocation of urban extensions are not mutually exclusive. We consider this option does have particular merit, and it is notable that it was scored positively by the Integrated Impact Assessment (IIA) in relation to its social, economic and environmental impacts. This option will still allow for current housing
needs to be addressed in the short term, as the Local Plan is required to; as well as enabling provision of strategic allocations if so wished. It will also allow for proportionate growth to be directed to the District’s various communities through settlement extensions, including Hockley – something which we consider is essential for the Local Plan to do if it is to deliver sustainable development.
Hockley
3.20 We consider that, in order for the Local Plan’s spatial strategy to promote sustainable development, to be justified, and to be capable of being found sound, it will be essential for it to direct a proportion of the District’s growth to Hockley.
3.21 Hockley / Hawkwell is identified as a Tier 1 settlement in the current Development Plan, i.e. one of the settlements considered most sustainable to accommodate greatest levels of growth.
3.22 Notwithstanding this, the District has experienced considerably less housing development since adoption of the Core Strategy than the other two Tier 1 settlements.
It is recognised that this is in part due to aspirations for the redevelopment of the town centre not being realised, as conditions have changed; and also partly due to constraints to the settlement’s growth as a result of Hockley Woods and the Upper Roach Valley Special Landscape Area to the south. Nevertheless, there are opportunities to deliver sustainable extensions to the existing settlement, particularly located away from the
more sensitive areas to the south.
3.23 Hockley is an established, vibrant community with a long history. It is important that planning helps support and enhance the vitality of the community, including by directing future growth to the settlement.
3.24 The RLPSO recognises that housing affordability and availability are key issues in Hockley. The Local Plan represents an opportunity to help address this issue, by
directing additional housing to this location. Conversely, failure to direct sufficient housing to Hockley is likely to result in housing becoming increasingly unaffordable for
local people. It is manifestly clear that if the Local Plan is to be a sound plan that meets development needs in a sustainable manner, then it cannot rely on RLPSO Option 1.
Alterations to the Green Belt boundary
3.25 It is evident that the District’s Green Belt boundaries will need to be amended in order to meet development needs and provide a sound plan for the future of the District.
3.26 The NPPF confirms (paragraph 140) that Local Plans are the appropriate vehicle through which to make alterations to the Green Belt boundary.
3.27 The NPPF (paragraph 140 again) also states that such alterations should only be made where exceptional circumstances are fully evidenced and justified.
3.28 Exceptional circumstances are not defined in national policy or guidance.
3.29 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.
3.30 The District is subject to an acute local housing need. The existing Green Belt boundary
is drawn tightly around the District’s existing settlements, and opportunities to meet development needs are severely restricted without alterations to the Green Belt
boundary.
3.31 Given the scale of objectively assessed need faced by the District, 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 Rochford Local Plan.
4.0 Response to Local Plan Spatial Options Question 29
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?
4.1 We agree that the Local Plan should seek to protect areas of locally important wildlife. Furthermore, we consider it should seek to deliver ecological gains.
4.2 However, the designation of such sites must be justified by robust evidence.
4.3 The 2018 Local Wildlife Review suggested a new Local Wildlife Site (R41) which
incorporates some of what is currently Local Wildlife Site R24, along with additional land to the west of this, including part of the Land at Pulpits Farm (CFS263 (‘the Site’).
4.4 The evidence for designating such additional land as a Local Wildlife Site is unclear.
4.5 It is not clear from the 2018 Local Wildlife Site Review what particular characteristics of the land forming part of CFS263 proposed to be designated as a Local Wildlife Site justify this land’s designation as such.
4.6 There is no evidence that a detailed survey of the Site was undertaken as part of the 2018 Local Wildlife Site Review that could justify its inclusion within a Local Wildlife Site.
4.7 The Site has been subject to an ecological constraints and opportunities survey, undertaken in 2020 by qualified specialist ecological consultancy, Southern Ecological Solutions.
4.8 This survey identified that the Site comprises habitats of varying value to biodiversity, with the most suitable habitat at the Site’s boundaries in the form of hedgerows, mature trees, rough grassland margins and watercourses. However, there was nothing to suggest that the Site merits any form of designation for its ecological value.
4.9 A copy of this initial survey is provided as Appendix B to these representations.
4.10 It is not the case that evidence must be provided to set out why the Site should not form part of the Local Wildlife Site. On the contrary, if this land is to be designated as a Local Wildlife Site, it is incumbent upon the Council to provide robust evidence justifying this.
4.11 We do not consider the Site merits designation for its ecological value, and would object to any proposals to do so. However, we do recognise that parts of the Site are of
ecological value. As part of the development of the Site, existing ecological features would be retained and, where practicable, enhanced.
4.12 It is important to recognise that development of land often has the potential to engender ecological benefits, and that would be the case in the development of site CFS263.
5.0 Response to Local Plan Spatial Options Question 58
Q58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing?
5.1 We agree with the vision for Hockley as proposed by the RLPSO.
5.2 In particular, we very much support the objective of improving housing affordability in order to ensure that local first-time buyers can afford to live locally.
5.3 If this vision is to be realised, it will be imperative to provide a sufficient number of new homes for Hockley, and of a variety of types and tenures, to meet all of the community’s needs.
Q58b. With reference to Figure 46 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Hockley and Hawkwell?
i. Housing
5.4 Land at Pulpits Farm (CFS263, ‘the Site’) is suitable, available, and achievable for residential development as a sustainable extension to Hockley. The Vision Document
which accompanies this representation (Appendix A) sets out details regarding the Site’s ability to sustainably deliver a high-quality development.
5.5 The Site was considered through the Council’s Strategic Housing Land Availability Assessment (SHELAA) (2020). The SHELAA (2020) considered the Site’s suitability in relation to a multitude of constraints, including policy, environmental, ecological, heritage
and physical constraints. In respect of the Site and potential constraints, this assessment concluded:
“Green Belt site that is currently in mixed use with residential and ancillary outbuildings, with some vacant grassland. There is an existing access with no
fundamental constraints to redevelopment of the site” [Emphasis added].
5.6 In summary, the only constraint to the Site’s development identified was its location within the Green Belt in the current Development Plan – a policy constraint.
5.7 In addition, the SHELAA (2020) assessed the Site’s suitability in terms of its accessibility to local services.
5.8 In relation to accessibility alone, it stated:
“There are two bus stops within c 0.3km of the site, however these are served by only two bus routes (No7/18). A private road connects the site to Greensward Lane, a C road which traverses the centre of Hockley before connecting to the wider strategic road network”
5.9 In addition to the points made within the SHELAA (2020) we would add that the Site is c.12 minutes walking distance from Hockley railway station. When considering
accessibility of this Site, and its appropriateness for allocation, this is clearly a key consideration.
5.10 In particular, it is important to note that the NPPF instructs Local Planning Authorities to prioritise sites that have good access to public transport when considering release of Green Belt to meet development needs. At paragraph 142 of the NPPF it states:
“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 previouslydeveloped and/or is well-served by public transport”.
5.11 The Green Belt is drawn tightly around the existing extent of residential development in Hockley. As noted in our response to Question 6, Hockley is clearly a sustainable location to accommodate a proportion of the District’s housing needs, and furthermore it is important that the vitality of Hockley be supported through the direction of sustainable growth to the settlement. It will be necessary to direct some growth to Hockley in order to ensure a sound Local Plan that delivers sustainable development, and to deliver this it will be necessary to alter the existing Green Belt boundary. In making such a revision, sites such as CFS263 which have good access to public transport should be prioritised for residential allocation.
5.12 The SHELAA (2020) considered the Site’s proximity to local services and stated: “A primary school sits c 1km to the east of the site, with a secondary school c 0.6km
to the west. A garden centres [sic] sits within C 0.3km of the site with a small number of shops along Greensward Lane”.
5.13 We consider the above significantly understates the range of local services and facilities that are in proximity to the Site.
5.14 In particular, the SHELAA (2020) appears to have overlooked that the Site is adjacent to
a GP surgery.
5.15 The Site is also well located in relation to a range of other services, facilities, employment opportunities and centres. As set out in the Vision Document that accompanies this representation, the following can be reached without use of a car within the following
journey times:
Walking:
Bus stop 1 minute
Greensward Surgery 1 minute
Greensward Academy Secondary School 5 minutes
Hockley Railway Station 12 minutes
Plumberow Academy Primary School 15 minutes
Convenience retail (Co-Op, Spa Road) 15 minutes
Hockley Post Office 15 minutes
Eldon Way 15 minutes
Approximate centre of Hockley Town Centre 17 minutes
Bus:
Approximate centre of Hockley Town Centre 5 minutes
Rochford Town Centre 14 minutes
Rayleigh Town Centre 16 minutes
Train:
Southend Victoria 27 minutes
London Liverpool Street 60 minutes
5.16 In 2014, sustainable transport charity Sustrans estimated that school traffic contributed,
nationally, to 24% of all traffic at peak times. The accessibility of both primary and
secondary schools from the Site without reliance on a car, and the potential to avoid
additional traffic that might be otherwise generated, is considered to be a factor which
weighs significantly in favour of utilising this Site to help meet housing needs.
5.17 The principal constraint to the Site’s development is that it is currently within the Green Belt.
5.18 In terms of the Site’s contribution to the purposes of the Green Belt, it is relevant to note that is an edge-of-settlement Site, the character of which has been influenced by adjacent residential uses to the north, west and south. The Site is subject to a degree of containment provided by existing features, and its development would not give rise to unrestricted urban sprawl. On the contrary, it would allow for a new, robust Green Belt
boundary to be implemented.
5.19 The Council’s Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’ concluded that the western portion of the Site could be developed with only moderate harm to the Green Belt. This is before mitigation measures are factored in (which case law suggests must be considered in determining whether exceptional circumstances apply), and once potential measures are
accounted for (such as provision of landscape buffers) it is considered that the Site’s development would not undermine the strategic purposes of the Green Belt.
5.20 Use of the Site to provide market and affordable homes would result in a number of social, economic and environmental benefits, as set out within the Vision Document
(Appendix A). These include, in summary:
 Market and affordable homes to help meet acute local need;
 Highly accessible Site, with opportunities for future residents to access services and facilities without use of a car;
 Efficient use of land which lacks environmental constraints, reducing pressure to develop more sensitive sites to meet needs;
 Provision of variety of public open space across the Site, including informal open space, ponds, structural landscaping for wildlife;
Increased expenditure within the local area, supporting jobs and helping sustain local facilities and services;
 Creation of direct employment during construction, as well as indirect employment related to the supply chain;
 Landscape and ecological enhancements as part of development;
 Development within a location that will help sustain the vitality of Hockley Town Centre.
5.21 It is important that where Green Belt is released for housing, the Council can have confidence that such land will be delivered and contribute to meeting needs.
5.22 In addition to being suitable and sustainable, the Site is also available and achievable for residential development.
5.23 The Site is not subject to any legal or ownership constraints to development.
5.24 The Site is being actively promoted for development by an established housebuilder with a track record of delivery. The Council can be confident that the Site will be deliver, and through a high-quality development, if allocated through the Local Plan.
6.0 Comments on Integrated Impact Assessment
Assessment Framework
6.1 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 identity.
6.2 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?
6.3 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.
6.4 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 These representations have been prepared by Pegasus Group on behalf of Penland Estates Limited in respect of their land interests in Rochford District Council (RDC).
1.2 These representations are submitted in response to the current Rochford Local Plan Regulation 18 ‘Spatial Options' consultation, which sets out the different growth
strategy options that could be pursued by the Council in the emerging Local Plan. The evidence base accompanying the Spatial Options document includes a Site Appraisal Paper which identifies the suitability of potential sites for allocation, including Penland Estate Limited's interests at:
• Site Reference CFS190: Land South of Pooles Lane, Hullbridge
1.3 The purpose of these representations is primarily to respond to the questions raised by the consultation to ensure there is a sound basis for emerging policies, as well as to support the most sustainable growth options of those set out in the consultation. These representations also confirm the deliverability of the above site and the exceptional circumstances in support of a minor revision to the Green Belt alongside the provision of a site-specific policy that allocates Land South of Pooles Lane, Hullbridge, for residential development in the emerging Local Plan. The representations are supported by high-level technical assessments and an indicative Framework Plan.
1.4 These representations should be read in conjunction with the enclosed high-level technical assessments and an Illustrative Framework Plan, which explain further
the opportunities available to create a high-quality and sustainable residential development with the ability to contribute positively towards the District’s significant housing needs.

2. SPATIAL OPTIONS DOCUMENT
2.1 This section responds to questions posed by the Spatial Options consultation that are relevant to Penland Estate Limited's interests in Rochford.
Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
2.2 The technical evidence that has been prepared and is yet to be prepared by the Council is supported as being required to inform the production of a sound Local
Plan in accordance with the provisions of the National Planning Policy Framework (NPPF 2021).
Q2. Do you agree with our draft vision for Rochford District?
2.3 Penland Estates Limited considers that the Draft Vision for Rochford District Council provides a sound basis for preparing a spatial strategy. Land to South of Pooles Lane, Hullbridge, will deliver upon the draft vision of Rochford District by providing a high-quality, well-designed development in a sustainable location with good
access to services and facilities which will foster vibrant and healthy communities.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
2.4 Penland Estates Limited broadly agree with the importance of adopting a range of separate visions for each of the District's settlements to help apply the district-wide vision and objectives at more localised settings. Nevertheless, there is likely to be considerable cross-over between the specific visions for individual settlement, and
as such, the benefits of this approach might not be fully realised.
2.5 Furthermore, this is likely to be quite a time-consuming exercise for the Council's Planning Policy Team to create separate visions for each of the District's
settlements. The Draft Local Development Scheme (2021-23) anticipates that the Local Plan could be submitted to the Secretary of State for independent
examination by Spring 2023, thus providing a short timescale to prepare and submit the emerging Local Plan. Therefore, it is considered that the resource of the
Planning Policy team is likely to be better deployed in other more pressing aspects of the emerging Local Plan process.
Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?
2.6 The Spatial Options document identifies five ‘Strategic Priorities.' Strategic Priorities one (meeting the need for homes and jobs in the area) and five (making suitable and sufficient provision for climate change mitigation and adaptation, conservation, and enhancement of the natural and historic environment, including landscape) are of particular interest to our client's site.
2.7 Our client is promoting Land South of Pooles Lane, Hullbridge, for the allocation of residential development through the emerging Rochford District Council Local Plan (RDCLP). It is estimated that the site is capable of delivering up to 226 new homes towards meeting the housing need target for the RDCLP. In addition to delivering much-needed market and affordable housing, the site will deliver upon the draft strategic priorities of the RDCLP as follows:
2.8 Meeting the need for homes (Strategic Priority 1 and 2) – Penland Estates Limited prides itself on working with developers that deliver well-designed, highquality, and sustainable homes for all to enjoy. Any scheme delivered on the site would provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include affordable housing provision which would be tenure blind in terms of design and well-integrated into the scheme to enhance social cohesion and generate community spirit. It is agreed that the
delivery of new homes sufficient to meet local housing need should be assigned great importance.
2.9 Climate change (Strategic Priority 5) – Any scheme would provide modern high-quality living with housing that meets the latest Building Regulation requirements in respect of energy and water consumption. In addition, the site is located in a highly sustainable settlement, within walking distance of a range of shops, services and pre and primary schools. The site’s location and proximity to
the local service provision in Hullbridge would assist in reducing travel by car and thus assist in reducing carbon emissions.
2.10 Natural environment (Strategic Priority 5) – Any scheme brought forward would aim to achieve a net gain in biodiversity through the retention, protection and enhancement of any on-site habitats, provision of extensive new public open space and high-quality landscaped areas. Existing vegetation at the site would be retained and enhanced through new planting to enhance the potential for habitat creation. In addition, drainage attenuation basins, required as part of the surface water drainage strategy, offer further potential to boost on-site biodiversity.
2.11 Furthermore, whilst the site is currently located in the Green Belt, the evidence provided in our representations and accompanying Green Belt Appraisal demonstrate that the site performs poorly against the five purposes of Green Belt as set out in the NPPF and is capable of coming forward for development without unduly damaging the integrity of the Green Belt. The evidence gathered by the Council clearly illustrates that the District's housing need cannot be sufficiently met
through urban and previously developed land only. Some release of Green Belt land in appropriate locations should be recognised as being necessary where 70% of the
District is designated as Green Belt. The release of Green Belt sites such as Land South of Pooles Lane, Hullbridge, will allow the continued sustainable growth of existing settlements, and would be consistent with the NPPF.
2.12 Historic environment (Strategic Priority 5) – The evidence provided in our representations, the accompanying Heritage Appraisal (see attached at Appendix A) and the Council's Initial Heritage Assessment of Submitted Sites (October 2020)
demonstrates that the site does not adversely impact any nearby heritage assets either directly or indirectly.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
2.13 The Options Spatial Paper includes a draft settlement hierarchy based on the 2021'Settlement Role and Hierarchy Study,' which uses various factors (including population size, availability and range of services and transport accessibility) to assess the relative sustainability of the District's multiple settlements.
2.14 The Adopted Core Strategy (2011) categorises Hullbridge (and Great Wakering) as a second-tier (out of four) settlement, where there is considered to be a more
limited range of services and access to public transport is judged to be relatively poor. The Spatial Options paper shifts Hullbridge into tier three (out of four) of its
draft settlement hierarchy. This appears to be due to the sub-division of Tier 1 of the Adopted Core Strategy into Tier 1 and 2 of the draft settlement hierarchy, with
Rayleigh remaining in Tier 1 and Rochford (including Ashingdon) and Hockley (including Hawkwell) shifting down into Tier 2 2.15 In addition to Hullbridge, the new proposed Tier 3 includes Great Wakering and
Canewdon. Penland Estates Limited, as outlined below, considers that Hullbridge is better related to the Tier 2 settlement of Hockley in terms of access to services,
population, geographical size, and transport accessibility, compared to the Tier 3 village Canewdon:
2.16 Population – according to the Parish Council website, Hullbridge's population is approximately 7,300, which is markedly greater than that of Canewdon (Tier 3) at circa 1,100. The other Tier 3 settlement of Great Wakering (including Little Wakering and Barling) has a similar population to Hullbridge at circa 7,200.
However, it is recognised that Hullbridge has a growing population, particularly through strategic allocations, such as the 500 unit Lower Road development in southwest Hullbridge (adopted Policy SER6 – South West Hullbridge). It is also anticipated that Hullbridge's population will continue to grow through strategic
allocations in the emerging Local Plan, given the sustainability of the settlement and its ability to support continued growth. This means that the population of
Hullbridge is anticipated to move closer to the suggested Tier 2 population threshold of 10,000.
2.17 Access to public transport – Hullbridge is serviced by the frequent no. 20 bus route operated by Frist Group (every 30 minutes between 7.00 to 21.00 Monday
to Saturday) to Southend via Rayleigh, where wider connectivity into London via the Greater Anglia train service is available. Great Wakering is similarly wellconnected as Hullbridge to public transport links; however, Canewdon is only serviced every two hours by the 60 bus route to Southend via Rochford. It is
recognised that neither Hullbridge nor Great Wakering includes rail links, as available in the Tier 2 settlements. Nevertheless, the frequent bus journeys to these rail station destinations from Hullbridge (and Great Wakering) provide accessible sustainable transport options for residents of these settlements.
2.18 Range of services and facilities – the village of Hullbridge has a good range of services and community facilities capable of meeting the everyday needs of
residents. These include three convenience stores, a dentist, GP surgery, library, pharmacy, a pre-school and primary school and public houses, fast food outlets
and restaurants. In comparison, Canewdon does not possess any such range of services facilities, with only a primary school, a convenience store, and a public
house. Great Wakering has a few more facilities, including a primary school, medical centre, and pharmacy and two public houses, albeit not to the extent found
in Hullbridge.
2.19 It is recognised that Hullbridge does not include a secondary school. Nevertheless, the no. 20 bus route provides a regular service (every 30 minutes) to the
settlements of Rayleigh and Hockley, which contain secondary schools as well as higher order retail services.
2.20 Access to jobs – several small-scale businesses are positioned around Hullbridge and at the various facilities and services mentioned above, which could
accommodate some local employment opportunities. It is considered that such employment opportunities would not be available at the Tier 3 settlement of Canewdon.
2.21 On the above basis, it is considered that the range of existing services and facilities available in Hullbridge mean that the village is better related to Tier 2 of the
settlement hierarchy than Tier 3. It is important that the Council has due consideration of the sustainability of Hullbridge when determining what level of growth is appropriate. The designation of Hullbridge as a Tier 3 settlement should not in itself be taken as a reason for allocating a certain level of growth. This is especially important as the Spatial Options document recognises that Hullbridge (and Great Wakering) are larger settlements than Canewdon; the scale of new
growth that would be appropriate for the settlements would therefore differ.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
2.22 Penland Estates Limited strongly agree with the identification of a housing requirement of 7,200 homes based on the standard method, which is in accordance
with paragraph 61 of the NPPF. The acknowledgement that this housing requirement forms the minimum housing needs for the District is also strongly agreed with; the Council must explore all opportunities available to accommodate additional growth above the minimum requirement and take on unmet need from neighbouring authorities that are constrained in the level of housing growth they are able to deliver.
2.23 The Spatial Options Document recognises that there is potential for Rochford District to accommodate unmet need from neighbouring authorities. The District's
neighbours are burdened with constraints to identifying sufficient land for housing, such as significant areas of Green Belt land which envelops existing urban areas
and areas of high flood risk. The authorities located within the same housing market area as Rochford have also struggled with maintaining sufficient levels of housing
delivery, further highlighting the importance of this matter. We therefore consider it to be highly likely that there will be unmet need arising from neighbouring authorities. In particular, early evidence issued for the Southend-on-Sea Local Plan preparation has indicated that Southend will require some of their housing requirement to be delivered in Rochford District (Issues and Options consultation,
April 2019). It is therefore vitally important that Rochford District pursues a growth strategy that includes a buffer in excess of the minimum housing required to meet local needs.
2.24 On the basis of the above, Growth Option 1 should be discounted as the strategy would not secure the level of housing required to meet the identified minimum
housing requirement. A sound Local Plan could not therefore be produced following this strategy.
2.25 Of the remaining options which would deliver sufficient housing growth, Penland Estates Limited is strongly supportive of Option 2 (Urban Extensions), particularly Option 2b 'Urban extensions dispersed to settlements based on hierarchy.'
2.26 Firstly, it is recognised that Rochford District Council have had a historic record of housing under-delivery, which in 2020 resulted in the Council having to publish a
Housing Delivery Test Action Plan as their 2019 Housing Delivery Test (HDT) was calculated at 77%. The 2020 Action Plan noted that the delayed delivery of several
strategic sites was a key factor. In particular, this was due to prolonged landowner and developer negotiations, delays at the planning application stage, and the time
taken to discharge pre-commencement conditions. The growth strategy for the Local Plan should therefore limit any over-reliance on large-scale strategic urban
extensions for delivering the required amount of housing.
2.27 Consequently, our client considers that the Council should identify available and deliverable small and medium-sized sites (10 and 1,500 homes) dispersed to
settlements based on hierarchy. This approach would be consistent with Paragraph 69 of the NPPF (2021), which states that "small and medium sized sites can make
an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly." The delivery of sites at this scale also helps to
ensure sustainable growth can take place across the District in a dispersed manner that allows all settlements to grow organically. 2.28 The NPPF allows for revisions to be made to the Green Belt boundary through the
Local Plan process where there are exceptional circumstances. As explained earlier, release of Green Belt land is required if the Local Plan is to deliver sufficient housing to meet the local housing needs for the District. This forms the exceptional circumstances required for the release of land from the Green Belt in appropriate locations. The delivery of small and medium-scale sites released from the Green Belt, such as Land South of Pooles Lane, will also play an important role in the Council meeting their five-year housing land supply as required by paragraph 68 of the NPPF.
2.29 Land South of Pooles Lane, Hullbridge, is available and deliverable within the Local
Plan period and should be considered further by the Council. Secondly, Option 2b will support existing services by directing further growth to villages like Hullbridge to support the vitality of local services. This approach is consistent with NPPF 79 of the NPPF (2021), which outlines that "planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services."
Consequently, sites in sustainable locations with good access to a range of services and facilities (generally Tier 2 and 3 settlements) should be selected to ensure the
sustainable and effective growth of settlements across the District.
2.30 The Council's Settlement Role and Hierarchy Study assesses the relative sustainability of individual settlements by considering its 'completeness'. The
theory is that the more services a place has, and the easier to access those services are, the more complete that place is. The 'completeness' assessment is shown in
the form of a heatmap, and for Hullbridge, this is shown on Page 82 of the Spatial Options Paper. Land to the South of Pooles Lane adjoins the north-eastern
settlement boundary of Hullbridge, which benefits from a 'walking completeness score' of between 11 and 13, which is the highest score in Hullbridge and is in the
second-highest category overall.
2.31 This is because the north-eastern section of Hullbridge includes Hullbridge preschool and Riverside Primary School, Hullbridge Community Centre, and a bus stop providing a frequent bus service to Southend and Rayleigh (one bus every 30 minutes). These services and facilities are less than a five-minute walk from Land
to the South of Pooles Lane. Additional services and facilities, including convenience stores, a dentist, GP surgery, library, pharmacy, and other fast food outlets and
restaurants, are within a 10-minute walk from the site. By affording sustainable levels of growth to sites such as these, it will assist in safeguarding existing services, public transport links and infrastructure which local people currently rely upon and support vibrant rural communities.
2.32 For the reasons set out above, Penland Estates Limited strongly supports the pursuance of Growth Option 2b, with concentrated growth dispersed to settlements based on hierarchy. This includes allocating growth in high performing and sustainable Tier 3 settlements, such as Hullbridge.
Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
2.33 Penland Estates Limited supports the Council's ambition of ensuring future growth takes place in a manner that is aligned with the national objective of transitioning towards a zero-carbon economy. Penland Estates Limited intends to work with developers that will create high-quality, energy-efficient buildings, which could
incorporate energy generation and conservation technologies, in line with the Council's strategy to reduce carbon emissions.
2.34 Notwithstanding this, there needs to be a balancing act in order to meet this target against the need to deliver a viable scheme. It is clear that further consideration is
required regarding the expected capital uplifts in the emerging Local Plan to ensure that energy efficiency is considered alongside viability. In doing so, the guidance
should consider the Government's figures in their Draft Future Homes Standard which will be in place by the time homes allocated by the new Local Plan are likely to be built. Any policy brought forward on this matter should therefore be supported by appropriate evidence that has investigated potential impacts on viability. The policy itself should include wording to reflect the importance of considering the overall viability of a scheme when determining the application of energy efficiency
initiatives over and above that required by Building Regulations
Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?
2.35 The Council should be consistent with the Government's Draft Future Homes Standard that proposes to remove the ability of local planning authorities to set higher energy efficiency standards than those in the Building Regulations. This is because the Government considers the situation confusing, particularly as the application of energy efficiency standards across local authority boundary lines often means that homes need to be built to different technical specifications. This inconsistency creates inefficiencies in supply chains, labour and potentially the quality of outcomes.
2.36 Nevertheless, Future Homes Standard outlines that changes to the Building Regulations are expected to mean that between 75- 80% fewer carbon emissions
are released into the atmosphere from new development compared to ones built to the 2013 Part L requirement. Requiring new developments to achieve energy
standards higher than the proposed changes to the Building Regulations would need robust evidence identifying the need for such a requirement.
13. How do you feel the plan can help to support the local generation of lowcarbon and renewable energy? Are there locations where you feel energy generation should be supported?
2.37 The Council should promote the idea of the Local Plan supporting renewable energy developments by designating appropriate locations within the District for lowcarbon and renewable energy generation projects. The Council could consider a
'call for sites' process for potential low carbon and renewable sites submitted by landowners, site promoters or developers. The Council could then assess the suitability of submitted sites using relevant criteria.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
2.38 Penland Estates Limited broadly supports the principles contained in the draft place-making charter, which sets out a number of key principles for how new
development is expected to be delivered in a way that contributes positively to their setting and wider environment. In taking this charter forward however, it should be made clear what weight will apply to the principles contained in the charter at the development management stage, as well as how the charter will interface with development management policies.
2.39 Penland Estates Limited prides itself on working with developers that deliver welldesigned, high-quality and liveable schemes for all to enjoy. Place-making and
creating a sense of identity is at the heart of the scheme design shown on the enclosed Development Framework Plan (see attached at Appendix B), with a
consideration of the opportunities and constraints of the site (see plan attached at Appendix C). New dwellings would be modern but sensitively designed to complement the character of the local area, and public open space would be delivered to a high standard to stimulate on-site recreation and interaction between residents. The development would be a positive and environmentally friendly place to live, work and play.
Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
2.40 The production of new design guides, codes or masterplans alongside the new Local Plan could provide applicants with clarity about design expectations at an early stage. However, there are two important considerations to take into account.
Firstly, site-specific design guidance is likely to be useful only in cases where the development proposed is at a strategic scale or there are unique constraints which
design guidance would help to overcome. For the majority of small and mediumscale development, development management policies relevant to urban design and placemaking are sufficient in securing a high-quality design.
2.41 Additionally, the production of design guidance requires time and staffing resources. The Council should consider the level of detail required in a design code
and the possible impacts of delays due to detailed discussions and negotiations between applicants regarding a scheme's compliance with a design code. Given the Council's historic under-delivery of strategic housing sites, which has in part been attributed to delays at the planning application stage, it is considered that with the preparation of design guides and masterplans is likely to slow housing delivery rates further if required for all sites.
2.42 The suggestion that design guidance is produced alongside the Local Plan preparation would also potentially delay the Local Plan process; which would mean further delaying the delivery of much-needed homes, given the delays experienced in the Local Plan process thus far. It would also require developers to invest in upfront work with no certainty that their particular site would be allocated in due course.
2.43 As such, Penland Estates Limited considers the preparation of design codes, guides or masterplans should be limited to large-scale strategic sites or sites with particularly complex delivery strategies only. All other developments can be brought forward appropriately without specific design guidance, as development
management policies related to design will ensure the correct design principles are followed.
4 Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing?
2.45 Penland Estates Limited recognises the importance of providing a mix of homes to meet the identified local housing needs. Option 2 is supported as providing a logical and flexible approach to ensuring that each new development provides a mix of housing that is appropriate to its location, taking into account all relevant sitespecific factors. This would ensure schemes can provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include an element of affordable housing provision which would be tenure blind in terms of design and be well integrated into the scheme to enhance social cohesion and generate community spirit.
Q31. Do you consider net gains for biodiversity are best delivered on-site or offsite? Are there specific locations or projects where net gain projects could be delivered?
2.46 National guidance outlines that biodiversity net gain can be achieved on-site, offsite or through a combination of on-site and off-site measures. Schemes should come forward with the aim of achieving a net gain in biodiversity through the retention, protection and enhancement of any on-site habitats, provision of extensive new public open space and high-quality landscaped areas wherever
possible. However, the option of achieving net gain through off-site contributions or habitat creation should not be discounted, as there may be site constraints such
as viability which limit a site's ability to provide net gain on-site.
2.47 Existing vegetation at Land South of Pooles Lane site would be retained and enhanced through woodland belt planting to enhance the potential for habitat creation, as shown on the illustrative Development Framework Plan (Appendix B). In addition, surface water detention basins, required as part of the surface water drainage strategy, offer further potential to boost on-site biodiversity. All opportunities will therefore be taken to enhance the biodiversity of the site.
Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?
2.48 National policy outlines that strategic plans should take a strategic approach to green and blue infrastructure to help promote active and healthy lifestyles, combat climate change and alleviate air quality issues. Well-designed green infrastructure can provide a sustainable alternative to car use through a connected network of
public rights of way and greenways. Proposed option 3 is supported, as the delivery of new and enhanced green infrastructure on new development sites will assist in
creating an improved network of green infrastructure throughout the District.
2.49 In reference to Option 2b ('Urban extensions dispersed to settlements based on hierarchy'), the Council should select sites that are in close proximity to the existing and proposed green and blue infrastructure networks to ensure that future residents have a sustainable alternative to car use. Land to the South of Pooles Lane is located within the Option 2b strategic area, and there is an existing 'secondary greenway' (ref PROW 287_6) approximately 300m to the east of the
site, running in a north-south direction as indicated on Figure 32 of the Spatial Options Document. To the north, this greenway connects to a network of existing and proposed coast paths along the River Crouch, which is less than a 5-minute walk from the site. To the south, this 'secondary greenway' connects to a network of primary greenways circulating Hockley.
2.50 The Land South of Pooles Lane, Hullbridge, promoted by our client Penland Estates Limited, is well placed to encourage a shift away from the private car. As shown by the submitted Framework Plan, any development at the Pooles Lane site will integrate into the existing highway network by providing vehicular, pedestrian and cycle access points. The Council's Site Appraisal (2021) recognises the accessibility of the site to existing walking and cycling infrastructure, as Land South of Pooles Lane (ref CFS03) is scored at level 5 (highest category), as the site is within 400m of an existing cycle or footway.
2.51 In contrast however, the Site Appraisal (2021) scores the site at level 2 for accessibility to public rights of way (the second-lowest category), as there are
adjudged to be no PROWs with 400m. However, a PRoW (ref 287_12) does indeed run along part of the site's eastern boundary, as indicated on the submitted Framework Plan and connects to the 'secondary greenway' (ref PROW 287_6), further to the south. Future residents of the site will significantly benefit from the existing and proposed green and blue infrastructure, which is directly connectable from the site. This inaccuracy within the Council's site assessment should be rectified to correctly reflect the sites accessibility in all ways, including to the PRoW network.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?
2.52 There is the potential for new development to contribute towards the upgrade and maintenance of existing facilities. Penland Estates Limited would welcome the opportunity to engage with the Council and local stakeholders in Hullbridge to understand local community needs.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
2.53 In reference to Strategy Option 2b ('Urban extensions dispersed to settlements based on hierarchy'), the Council should support sites that can help improve open space or sports facility accessibility or provision. This would be in line with proposed option 4 for meeting open space needs through the Local Plan, which proposes requiring new developments to provide on-site open space or contribute towards improving existing recreational facilities.
2.54 Land South of Pooles Lane is located in the Option 2b settlement of Hullbridge. As identified in the 2009 Rochford District Council Open Space Study, Hullbridge has deficits against the local minimum standards of natural and semi-natural greenspaces (-2.05ha), amenity green space (-0.11ha) and children's play space (-0.01ha). Incidentally, Hullbridge has the second-highest deficit in the District for the provision of natural and semi-natural greenspaces. The provision of sports facilities is 0.53ha above the local minimum standards. It is recognised that the Open Space Study informing the evidence base is slightly dated. Nevertheless, it is
expected that the settlement's deficits (or low provision levels) of semi-natural greenspace and amenity green space, and children's play space are likely to still
exist in the village.
2.55 Taking this information into account, Land South of Pooles Lane has the potential to provide around 3ha of open space throughout the site, serving a range of
different purposes. Open space will be landscaped with a variety of natural and semi-natural areas, such as new woodland belt planting and mixed grassland areas
to promote biodiversity. Circular walking routes are provided, integrated into the wider network of public rights of way in the area. A centrally located locally equipped area for play (LEAPS) can also be provided. The open space would be delivered to a high standard to stimulate on-site recreation and interaction between residents. The development would be a positive and environmentally friendly place to live, work and play.
2.56 Land South of Pooles Lane achieves the highest score for access to public open space in the Council's Site Appraisal (2021) paper, given that Hullbridge Playing
Field is located directly opposite the site. Hullbridge Playing Field contains various existing sports facilities, including a BMX track, skate park, basketball court, sports pitch, as well as play equipment. Furthermore, Hullbridge Yacht Club, located on the River Crouch, is less than a five-minute walk, providing future residents with a wider range of sports and leisure facilities. The Council should consider allocating sites, such as Land South of Pooles Lane, in the emerging Local Plan that are well placed to provide accessible open space and sports facilities, either on-site or within
close walking distances.
Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
2.57 Paragraph 104 of the National Planning Policy Framework (NPPF) identifies that transport issues should be considered from the earliest stages of plan-making,
which includes opportunities to promote walking, cycling and public transport. The importance of encouraging a shift towards more sustainable modes of transport is
recognised as this will assist in reducing climate change and congestion levels on roads.
2.58 The four options set out in the Spatial Option document are considered to be logical approaches to take in addressing transport and connectivity issues. The Rochford Local Plan should also promote sustainable forms of transport by allocating housing sites in sustainable locations in established settlements which possesses good quality public transport links, including; bus services, footways and cycleways. The preparation of an Infrastructure Delivery Plan or Cycling Delivery Plan would provide clear evidence of the infrastructure improvements that may be required to further support and achieve sustainable development.
2.59 The Land South of Pooles Lane, Hullbridge, is exceptionally well placed to encourage the shift away from the private car. As shown by the submitted
Framework Plan (Appendix B), any development at the Land South of Pooles Lane site will integrate into the existing highway and pedestrian infrastructure by
providing vehicular, pedestrian and cycle access points in appropriate locations. 2.60 By utilising the proposed access points, residents of the scheme will have
convenient and sustainable access (via walking or cycling) to education, a range of shops, and services capable of serving their day-to-day needs. The public transport links available to residents of a scheme at Land South of Pooles Lane are summarised in the schedule below. Access to these services could be further
improved through new development resulting in an increased level of users.
Public Transport Links
Bus stops outside Riverside School, Ferry Road:
No 20 bus service from Hullbridge to Southendon-Sea via Rayleigh:
Monday to Saturday- every 30 minutes
between 7.00 to 21.00, and hourly between
22.15 and 23.15
Sundays- every 30 minutes between 9.00 to
21.30
(0.3km – to bus stop, 3-10 minute walk)
Hockley train station,
Station Approach Hockley SS5 4BG
(6.2 km, 19 minute cycle, 10 minute car)
Rayleigh train station, 1 Castle Dr, Rayleigh, SS6 7HT
5.1 km
(18 minute cycle, 9 minute car,15 minute bus)
Q60a. Do you agree with our vision for Hullbridge?
2.61 Penland Estates Limited broadly support the draft vision of Hullbridge becoming self-sufficient and accessible by sustainable means and to make the most of its location by opening up its coastline as a more attractive and usable space for both residents and visitors. Any development should respond to meeting the housing needs of local residents, and it should be acknowledged that the aims of meeting housing needs and Hullbridge becoming self-sufficient are interlinked. The growth of service provision would be supported by new housing and new customers, which would encourage new businesses as well as support the vitality of existing
businesses.
2.62 The vision currently references the need to provide suitable housing for the elderly, which our client supports. However, the vision should be expanded to incorporate
the needs of young families and parishioners seeking local and affordable housing to ensure a diverse and sustainable settlement can be maintained.
2.63 Land South of Pooles Lane would seek to provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include
a provision of affordable housing which would be tenure blind in terms of design and be well integrated into the scheme to enhance social cohesion and generate
community spirit.
Q60b. With reference to Figure 48 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
Housing [market, affordable, specialist, traveller, other]
Commercial [offices, industrial, retail, other]
Community infrastructure [open space, education, healthcare, allotments, other]
Other
2.64 As mentioned in answer to question 6 above, Penland Estates Limited supports Growth Strategy Option 2b. This strategy would provide new development in
sustainable locations across the settlement hierarchy, of a scale that is suitable to the services provision in the relevant settlement. Land South of Pooles Lane (ref
CFS190), promoted by Penland Estates Limited to provide a medium-sized housing scheme, is exceptionally well placed in this regard. It would adjoin the north-western boundary of Hullbridge and lead to the natural extension of this sustainable settlement. The site is incredibly well related to existing services as illustrated on
the walking completeness score replicated below. Development of the site offers the potential to increase permeability within this part of the village, improving
access for existing residents located north of Pooles Lane. 2.65 This accessibility has been reflected in the Council's Site Appraisal Paper (2021), which aims to provide an indication of the relative sustainability and suitability of potential housing sites. For example, the site scores in the highest accessibility (category five) for access to a primary school (less than 400m), a bus (more than 10 bus services provided per hour within 400m), and walking and cycling infrastructure (less than 400m from existing footway and cycle paths). This assessment is strongly supported as reflecting the location of the site in relation to services and facilities, as illustrated in the summary table below.
[see document for table]
2.66 However, the site scores poorly in the following categories: green belt impact (level two), agricultural land classification (level one), access to a train station (level one), access to a secondary school (level one), town centre (level one) and employment site (level one). Additional information is outlined below to provide a more robust assessment of the site's credentials against its poorly performing categories from the Site Appraisal Paper and demonstrate the deliverability of the site.
Green Belt
2.67 Given the extent of the Green Belt across the District and drawn tightly around sustainable settlements such as Hullbridge, it is vital that specific parcels of Green
Belt land adjacent to settlement boundaries are subject to a detailed Green Belt review process. Notwithstanding its Green Belt designation, this land will often provide a sustainable location for growth by virtue of its proximity to the local service provision and public transport links. We consider that this is the case of Hullbridge, where our client is promoting Land South of Pooles Lane, Hullbridge.
Indeed, this is recognised in the Rochford District and Southend-on-Sea Borough Joint Green Belt Study (February 2020) undertaken by the Council, which at paragraph 3.9 states that the most sustainable sites for allocation may be located in areas that make a strong contribution to Green Belt purposes.
2.68 As explained earlier in these representations, the exceptional circumstances required to justify the release of land from the Green Belt are considered to exist
by virtue of the evidence base demonstrating there is insufficient non-Green Belt land available to accommodate the growth required during the Local Plan period. Paragraph 130 of the NPPF readily acknowledges that the plan making process can incorporate the review of existing Green Belt boundaries in exceptional
circumstances. Penland Estates Limited believe that exceptional circumstances exist to warrant such a review and consider that a modification is required in order
to deliver economic and housing growth which is recognised by the Government to be of national and potentially international importance.
2.69 Central to this review should be an assessment of specific parcels of land with development potential against the five purposes of Green Belt as set out in the
NPPF. Sustainable sites for housing growth which are found to not contribute to the five purposes of the Green Belt should be released and subsequently allocated for
development. It is strongly contested that this is the case for the Land South of Pooles Lane. The evidenced and justified release of this land from the Green Belt will allow development to come forward which will meet the objectives of achieving sustainable development as set out in paragraph 8 of the NPPF and assist in
delivering growth of regional and national importance.
2.70 In respect of Land South of Pooles Lane, an independent Green Belt Assessment of the site has been commissioned. The Assessment, produced by Pegasus Group, is appended to these representations (Appendix D). The Green Belt Assessment draws on the recently published Green Belt Study (February 2020) but applies a
finer-grain assessment in order to provide a comprehensive and robust, yet concise
assessment. The conclusions in respect of Land South of Pooles Lane contribution to the Green Belt purposes, is outlined below:
• Purpose 1: To check the unrestricted sprawl of large built-up areas. Site Contribution is assessed as Low/weak.
• Purpose 2: To prevent neighbouring towns merging into one another. Site Contribution is assessed as Low/Weak.
• Purpose 3: To assist in safeguarding the countryside from encroachment. Site Contribution is assessed as Moderate.
• Purpose 4: To preserve the setting and special character of historic towns. Site Contribution is assessed as Low/Weak.
• Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Site Contribution is assessed as n/a.
2.71 The detail underpinning the above listed conclusions is evidenced in the Pegasus Group report. In light of the specific assessment against each Green Belt purpose,
the Green Belt Appraisal provides an overarching conclusion which confirms that Land South of Pooles Lane provides a low contribution to the NPPF Green Belt
purposes. In respect of bringing forward development at the site, the Appraisal concludes that:
2.72 “the Council agree that there are exceptional circumstances to justify the release of land from the Green Belt to accommodate development needs, then the Green Belt land immediately around Hullbridge – the site, would be suitable for such release.”
2.73 It is strongly recommended that the Council review the Green Belt Assessment alongside the other submitted evidence from their Site Appraisal Paper and Green
Belt Review study. The results of the Green Belt Assessment have strongly influenced the formulation
of the Framework Plan, in particular with regard to the incorporation of landscape mitigation measures. These take the form of a substantial landscape buffer along
the length of the eastern boundary, which will comprise new woodland planting and will integrate with and enhance existing vegetation. The landscaping strategy for
the site will aid in creating a strong defensible Green Belt boundary, as well as create a scheme that responds sensitively to the countryside character, with a soft
transition from built development to rural countryside.
Agricultural Land Classification
2.74 The Site Appraisal Paper (2021) scores Land South of Pooles Lane (ref CFS190) level one (the lowest category), as the majority of the site is adjudged to contain Grade 1-3 agricultural land (best most versatile or BMV). The other sites in Hullbridge also mostly score level 1, with a few scoring level 2 (i.e. any part of the site contains Grade 1-3 agricultural land). The assessment is based on Natural England Agricultural Land Classification mapping. However, the Natural England maps' scale is intended for strategic use and is not sufficiently accurate for the assessment of individual fields. Given that the site is currently used for arable grazing, it is unlikely that the land will be classified as BMV agricultural land.
Nevertheless, it is clear that the loss of some agricultural land will be necessary if Hullbridge is to continue growing in a sustainable manner. The sites available for
development in this area are of a similar agricultural value, and it is considered the benefits of sustainable development would be sufficient to outweigh the loss of
agricultural land.
Drainage
2.75 The site is located within Flood Zone 1 (lowest risk) as defined by the Environment Agency. The site is therefore considered sequentially preferable for residential development in flood risk terms.
2.76 The score of level two for 'critical drainage risk' appears to have been informed by a high-level review of the surface water flood risk for the site. Mapping on the
Environment Agency long term flood risk website illustrates that the majority of the site is in an area of low or very low surface water flood risk. There are small,
localised areas of medium and high surface water flood risk, associated with low spots within the site or near watercourses. 2.77 This is a matter that can be suitably addressed through any future planning application, which would be supported by a surface water drainage strategy
incorporating Sustainable Urban Drainage Systems (SuDS). The Framework Plan which has been produced has been informed by a high-level Flood Risk and
Drainage Constraints Plan (Appendix E) which illustrates how surface water flood risk can be appropriately mitigated through the inclusion of detention basins in
appropriate locations. The location and design of the basins will be subject to further detailed drainage assessment, however it is considered that a scheme can
be designed that effectively mitigates the risk of surface water flooding.
Access to a train station
2.78 The nearest train station to Land South of Pooles Lane (ref CFS190) is located in Rayleigh approximately 5.2km, which is just over the 5km threshold for a level one score. However, the assessment should take into account where opportunities exist for linked trips via other sustainable modes of transport such as by cycle or public
bus. Land South of Pooles Lane is located less than two minutes' walk from the nearest bus stop, where there is a frequent bus service (every 30 minutes) to Rayleigh railway station, with the journey taking approximately 15 minutes (including walking to the bus stop). This provides a very sustainable option for future residents of this site, and the Council should consider this factor when
assessing the site's sustainability.
Access to secondary school
2.79 It is recognised that Hullbridge does not include a secondary school, and as a result, the site scores level one in the Site Appraisal Paper. However, as mentioned above, the frequent no. 20 bus route (every 30 minutes between 7.00 to 21.00 Monday to Saturday) between Hullbridge and FitzWimarc School, in Rayleigh takes
approximately 15-20 minutes. This is considered to be an acceptable distance for secondary-aged pupils who often travel by bus, bike or even train to get to school.
The Council should therefore consider the accessibility of secondary schools by modes of public transport when assessing the relative sustainability of a site.
Access to a town centre
2.80 The nearest town centre of Rayleigh is around 6.2km from Land South of Pooles
Lane (ref CFS190), which is therefore within level one threshold, as the site is more than 2.3km from the town centre. However, it should be recognised that Hullbridge
contains a range of services, which could be found on a high street, with three convenience stores, medical centre, a pharmacy and other facilities. These services
are therefore capable of supporting the day-to-day needs of residents within Hullbridge, limiting the need to travel beyond the village on a frequent basis.
2.81 The site is also less than two minutes' walk from the nearest bus stop, where there are frequent bus services (every 30 minutes) to Rayleigh town centre, with the
journey taking approximately 15 minutes. This provides a very sustainable option for future residents of this site. Furthermore, due to the impacts of the COVID-19
pandemic, there has been a greater focus on online retail shopping; thus, it is considered that the 2.3km threshold is unjustified adopted by the Site Appraisal Paper, particularly where residents of Land South of Pooles Lane could either access retail facilities by public transport or online.
Employment site
2.82 The nearest designated employment (Imperial Park) area is 4km from Land South of Pooles Lane in Rayleigh, which is just over the level one threshold of 2.3km.
However, this employment site can be accessed by frequent bus service (every 30 minutes), with the journey taking approximately 20 minutes, providing a
sustainable option for future residents of this site. The Council should also consider the impact of the COVID-19 pandemic with increased levels of working from home
practices when considering the relevant proximity of employment sites.
Conclusion
2.83 Penland Estates Limited consider that Land South of Pooles Lane, is suitable, available and achievable for development, taking into account the evidence that it
has prepared to support the site’s promotion so far. The site should be allocated in order to achieve a sustainable and deliverable development strategy for Hullbridge,
consistent with the Local Plan strategy as a whole.

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

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

Q2. Do you agree with our draft vision for Rochford
District? Is there anything missing from the vision that
you feel needs to be included? [Please state
reasoning]
Mostly. Although you have not included enough information on how you might achieve housing for
the hidden homeless or those on low incomes, schemes to allow the elderly in large houses to be able
to downsize or how you plan to provide suitable commercial units of varying sizes, to allow businesses
to up or downsize into a suitably sized premises without them needing to relocate into another area.
No provision for emergency housing.

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

Q4. Do you agree with the strategic priorities and
objectives we have identified? Is there anything
missing from the strategic priorities or objectives that
you feel needs to be included? [Please state
reasoning]
No comments.

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

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

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

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

Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating
development away from areas at risk of flooding and
coastal change wherever possible? How can we best
protect current and future communities from flood
risk and coastal change? [Please state reasoning]
Yes. You must ensure the district has a suitable plan to protect not only the towns and village communities, their houses and businesses but also the natural areas as well. The district needs adequate defences to limit flooding in all areas, protecting people and wildlife. Maybe these could be incorporated in the “natural” landscape theming so as to deflect any water away from these areas.
New developments not only need to address their carbon footprint but also the design of the housing they build so that they limit flood damage; raised floors, bunded gardens etc.
The plan must include or identify a flood plane that is protected from development.

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

Q11. Do you agree we should require development to
source a percentage of their energy from low-carbon
and renewable sources? Are there other opportunities
in the district to supply low-carbon or renewable
energy?
Yes.
New developments should be able to source some or all of their energy from renewable sources.

Q12. Do you agree we should require new development to achieve energy efficiency standards higher than
building regulations? What level should these be set
at? [Please state reasoning].
Yes. The Town Council believes that you should aim to achieve a higher standard if possible and
encourage developers to put forward new ways of achieving this. You must plan for future generations and should not be stuck in the past. Why go for minimum standards? Always aim higher! Keep the technology under review to capitalise on new development.

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

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

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

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

Q17. With reference to the options listed above, or your
own options, how do you feel we can best plan to
meet our need for different types, sizes and tenures of
housing? [Please state reasoning]
By working closely with planners and developers, as well as different charities and communities,
residents and businesses. You will then get a better understanding as to what you need and what will
be achievable.

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

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

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

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

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

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

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

Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new
employment facilities or improvements to existing
employment facilities?
Option 3 could deliver new opportunities for employment as it would be a new site completely. Industrial units of various sizes, with room for expansion plus retail, hospitality and other employment could be included in the criteria for the development.
Q26. Are there any particular types of employment site or
business accommodation that you consider Rochford
District is lacking, or would benefit from?
Environmental services - woodland conservation and management. (We need to find funding for this
as it is important!) HGV training school and modern transport training. Improve manufacturing base.
Q27. Are there other measures we can take through the
plan to lay the foundations for long-term economic
growth, e.g., skills or connectivity?
Better road networks, gigabit broadband and Wi-Fi. Apprenticeships or training for all ages with jobs
at the end of training. CCTV where appropriate.
Q28. With reference to the options listed above, or your
own options, how do you feel we can best manage the
Airport’s adaptations and growth through the
planning system? [Please state reasoning]
No comments.
Q29. Do you agree that the plan should designate and
protect areas of land of locally important wildlife
value as a local wildlife site, having regard to the Local
Wildlife Sites review? Are there any other sites that
you feel are worthy of protection? [Please state
reasoning]
Yes. You should conform to and improve existing RDC policies for protecting wildlife areas. Everyone should be doing all in their power to protect wildlife sites. All wildlife is important and has been neglected, sites have been slowly lost over the years. Wildlife now enters suburban areas as their own habitats have diminished and they can no longer fend for themselves adequately from nature. Badgers and hedgehogs as well as rabbits, frogs, newts, voles and shrews are declining and are seldom seen apart from dead at the roadside. Bat numbers are declining as their habitats are lost. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was.
Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. You mention that Doggett Pond no longer meets the standard but are there no steps to improve its status instead of dismissing it? It is obviously an important site for the wildlife in that area. To lose it would be to our detriment. You should be looking at creating new sites with every large housing
development, and protecting them to improve our district and our own wellbeing. Private households should not be allowed to take over grass areas and verges or worse, concreting the verges over for parking and cost savings. These areas, although small are still areas for wildlife. Bees and butterflies are also in decline, as are
the bugs which feed our birds. The plan should create new wildlife meadows to encourage the pollinators in order to future proof our own existence. You should be exploring smaller sites that could be enhanced, managed and protected to give future generations a legacy to be proud of.
Q30. Do you agree that the plan should designate and
protect areas of land of locally important geological
value as a local geological site, having regard to the
Local Wildlife Sites review? Are there any other sites
that you feel are worthy of protection? [Please state
reasoning]
Yes. The plan must protect them for future generations and teach our children their history and importance so that they can continue to keep them safe.
Q31. Do you consider net gains for biodiversity are best
delivered on-site or off-site? Are there specific
locations or projects where net gain projects could be
delivered?
On site. You can then assess in real time and sort out any issues you would not have known about off
site.
Q32. With reference to the options above, or your own
options, how do you feel we can best deliver a quality
green and blue infrastructure network through the
plan? [Please state reasoning]
You need to retain what we already have by ensuring the necessary links are in place to join as many as possible, and ensuring that public rights of way are not blocked by land owners and are kept free from debris. You also need to assess some paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look into offering this in the larger spaces. For example, a small toilet block and hand washing facilities in the car park. Obtaining funding from new developments that can enhance existing areas as
well as providing new spaces and facilities. The sites should be well-maintained.
Q33. Do you agree that the central woodlands arc and
island wetlands, shown on Figure 32 are the most
appropriate areas for new regional parklands? Are
there any other areas that should be considered or
preferred? [Please state reasoning]
They are a step in the right direction, but you need to assess periodically in order to be able to add further links to any new parkland that may be created in the future. The map is unclear as it does not show exact routes. There is a large open space to the South West of Rayleigh (on the border), South of Bardfield Way and The Grange/Wheatley Wood, which could be enhanced. Existing sites must be retained
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new
strategic green and blue infrastructure? [Please state
reasoning]
Enhancing existing areas and ensuring developers include green space and recreational facilities
within their developments. A new, separate development would be able to deliver this within their plan layout. Ensuring there are suitable links, access and footpaths. Making sure some of these footpaths are maintained and accessible for the disabled.
Q35. With reference to the options above, or your own
options, how can we address the need for sufficient
and accessible community infrastructure through the
plan? [Please state reasoning]
Assess the shortfall of facilities and networks before plans are approved so that adequate planning
and funding can be secured before any building takes place.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or
improved community infrastructure? [Please state
reasoning]
A new town would have this infrastructure built into its plans. Funding for improvements must otherwise come from developers if an area is already overpopulated.
Q37. Are there areas in the District that you feel have
particularly severe capacity or access issues relating to
community infrastructure, including schools,
healthcare facilities or community facilities? How can
we best address these? [Please state reasoning]
Rayleigh is overcrowded; it has a road network no longer fit for purpose, some schools are near to capacity, it is difficult to obtain a GP or dental appointment. There is little to no disabled play areas or play equipment. There are always issues with waste collections, drain and road cleaning and verge trimming. The District Council does not have the staff to deal with all these issues. The council should either build another waste recycling site, or develop a better waste collection program which allows extra waste to be collected next to the bin. The current recycling site at Castle Road is no longer
capable of expanding to meet the needs of an ever-growing population. The plan should also identify
a site to accommodate commercial waste facilities to stop fly tipping.
Q38. With reference to the options above, or your own
options, how do you feel we can best meet our open
space and sport facility needs through the plan?
[Please state reasoning]
Improve what we already have. The tennis courts on Fairview Park needs improvement. Safeguard our open spaces to protect wildlife and recreation. Develop different types of sporting facilities. We need to offer free recreation.
Q39. Are the potential locations for 3G pitch investment
the right ones? Are there other locations that we
should be considering? [Please state reasoning]
All-weather facilities should be considered
Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should
be considering? [Please state reasoning]
They look suitable. They will probably need funding.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver
improvements to open space or sport facility accessibility or provision?
A new development would be able to deliver this in their plans or fund improvements for existing facilities in line with national strategy and requirements.
Q42. Are there particular open spaces that we should be
protecting or improving? [Please note, you will have
an opportunity to make specific comments on open
spaces and local green spaces in the settlement
profiles set out later in this report]
The sites will be specific in each parish. You must protect all of these recreational spaces and improve them, if necessary. Once lost to development, they can never come back.
Q43. With reference to the options listed in this section, or your own options, how do you feel we can best
address heritage issues through the plan? [Please
state reasoning]
You should reassess the planning policies regarding alterations made to the buildings on the heritage
list, especially those in conservation areas. There have been a few occasions where buildings of “interest” (or other) have been altered, and that places in conservation areas have been allowed canopies, shutters and internal illumination of signage without challenge. Any building work should be sympathetic to the area and you should require corrections to unauthorised changes, even if they
have been in place for some time. Shop fronts are huge areas of uninteresting glass with garish colours. No objections are raised to signage and advertising that is out of character with a conservation area in a heritage town. Ensure statutory bodies are consulted and heeded.
You should take effective actions to manage the footways, ‘A’ boards and barriers are obstructions to
those with impaired sight or mobility.
Q44. Are there areas of the District we should be
considering for conservation area status beyond those
listed in this section? [Please state reasoning]
You should not take areas of precious woodland to make way for housing. Sites within the existing Rayleigh Conversation Area should not be considered

Q45. Are there any buildings, spaces or structures that
should be protected for their historic, cultural or
architectural significance? Should these be considered
for inclusion on the Local List of non-designated
assets? [Please state reasoning]
Yes there are many sites of historic importance which should be included.
Q46. With reference to the options listed above, or your
own options, how do you think we can best plan for
vibrant town centres in Rochford, Rayleigh and
Hockley? How can we also ensure our village and
neighbourhood centres remain vibrant? [Please state
reasoning]
You can only have a vibrant town centre if there are shops to go to. If these units are subsequently changed to residential then our town centres will be fractured and uninviting. The new Use Class E will mean it will be even more important for the council to protect our retail outlets. You need to work actively with premises owners in order to assist in the re-letting of any empty shops. Maybe
offer a reduced rent to new businesses as a start-up scheme. You could contain this as a “local”
business only – allowing the entrepreneurs in the Rochford District a chance to showcase their
businesses. You also need to be able to negotiate with the owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows, perhaps photos of the old towns or useful information, to make them more attractive. Explore business rates levies. Any plan should be reviewed frequently; at least every 5 years
It is a well-documented fact that independent businesses have done better than large chains during Covid as they are able to diversify at short notice. RDC need to incentivise new small or micro businesses into our town centre, either through grant support or another mechanism. Occupied premises create employment, increase footfall and reduce vandalism. Landlords should be engaged with to ensure quick turn-arounds, or for more flexible lease agreements where for example a new
business can take on a shorter lease to test the market.
Good public transport links are crucial for our villages, neighbourhoods and town centres.
Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make?
[Please state reasoning]
Yes
Q48. With reference to Figures 38-40, do you agree with
existing town centre boundaries and extent of
primary and secondary shopping frontages in
Rayleigh, Rochford and Hockley? If not, what
changes would you make? [Please state reasoning]
Yes.
Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary
shopping frontages within those centres? If yes, what
uses should be restricted? [Please state reasoning]
Yes. A mix of retailers is essential as a lack of variety will eventually kill off the high streets. We need to have a balance of outlets that keep the area viable as you would lose the vibrancy you are hoping to achieve.
Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved
retail and leisure services in the District? [Please state
reasoning]
Unfortunately, there has been a tendency to switch from commercial outlets to residential, where smaller retail areas have been sold off and housing development has been allowed. In a new development there would be scope to add a small, medium or large retail precinct, depending on the development size. Retail parks, leisure areas and outlets are proving in many cases, the preferred option for consumers, normally as a result of having everything in one place, free on-site parking and maximum choice. We feel that some of the sites, whilst not suitable for large housing developments, may be suitable for something of this type. It would create much needed employment, opportunity and tourism for the
area.
Q51. With reference to the options above, or your own
options, how do you feel we can best address our
transport and connectivity needs through the plan?
[Please state reasoning]
The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. The existing paths need updating and attention
Q52. Are there areas where improvements to transport
connections are needed? What could be done to help
improve connectivity in these areas?
More work needs to be done on the A127 and The Carpenters Arms roundabout. The feeder lanes
proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions is
now essential as this is a bottleneck. Hockley needs another access. Connecting the cycle ways into a
cycle network as part of the plan.
Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new
transport connections, such as link roads or rapid
transit? What routes and modes should these take?
[Walking, cycling, rail, bus, road etc.]
As the preferred strategy option is 3b, this could create opportunities for improved links to Southend. You should also consider more and smaller buses to link the towns and villages. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a
complete review of sustainable transport.
Q54. Do you feel that the plan should identify rural
exception sites? If so, where should these be located
and what forms of housing or employment do you feel
need to be provided? [Please note you may wish to
comment on the use of specific areas of land in the
next section]
This may be a suitable option for a retirement village that could be restricted to single storey dwellings only, and could include community facilities such as convenient store, community centre and so on.
Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities?
[Please stare reasoning]
Better public transport and sustainable transport links.
Q56.
a. Do you agree with our vision for Rayleigh? Is there
anything you feel is missing? [Please state reasoning]
The plan is adequate so far is it goes, but you have more work to do. You must plan for a reduced volume of traffic and air pollution. More attention is needed to initiatives that design-out crime and fear of crime, and this needs to be functional, sustainable and viable. The Draft Vision Statement ignores the over-development, the lack of infrastructure and facilities we already suffer. Indeed, Rochford District Council’s stated aim within their Asset Strategy and the plans of other Public Service providers is to reduce facilities in the Town further. This is at the same time as demand is growing from a sharply increasing population. This is particularly relevant for the growing elderly population. This will make the next 25 years very challenging.
1/ Cycling infrastructure and other sustainable transport methods should be prioritised over a carcentric highway use. We regret we do not because it is unrealistic, our response must be to inject a note of realism looking forward based on RDCs policies and past action. This goes to the heart of the new Local Plan.
We regret a realistic Vision Statement based on the current trajectory of further development recommended in the Draft Local Plan will be rather more dystopian. We could see a Rayleigh chocked by traffic. Although pollution should decrease with electric vehicles the advent of driverless vehicles, both domestic and commercial, servicing an ever-expanding population could result in gridlock. Pollution will increase from fossil burning home heating systems in many of the new homes. Failure to support public transport will inevitably maroon older residents in their homes far from those few
facilities and shops that remain in our town centre.
Public services offered by police and council (most likely giant unitary council catering for half million people based far away in an urban area), will seem very distant to most people. Most of the green open spaces not in public ownership, also some that are publicly owned, will be built on and have disappeared by 2050. Many public facilities and local public service providers will be taken away and sold off to property developers. The town centres will cease to be the shopping and social areas we know today as a result of Council plans and changing shopping habits. Rayleigh retail business will have closed and online and out of town retail parks will prosper with their free parking facilities. In the same way that London boroughs developed through the decades and centuries, the traditional housing we know today, with private gardens will be replaced by blocks of flats with large vehicle parking areas with recharge points.
2/ Another vision could be forged with the right policies in an enlightened Local Plan. RDC could opt for a garden village settlement away from all the Districts Towns and villages. Rayleigh like other towns that have suffered from overdevelopment in recent decades and should be protect from large scale private development during the forthcoming Plan Period. Only development or local needs should be permitted. Local facilities like Mill Hall would be saved and car parking retained and made
cheaper to assist local town centre business to survive what will be a challenging period. Secondary
shopping facilities in Rayleigh would be supported and encouraged with public finance where required. Public transport would be supported and encouragement, especially when given for children to reach school without parents’ vehicles. Renovation and refurbishment of historic buildings with modern green energy would be promoted over demolition and intensification. Public services would be encouraged to return/expand to Rayleigh, in existing buildings like Council Offices, Police Station and Library etc. The town centre should be the heart of our community not just something you drive
through to reach somewhere else. This could be our vision and our aim for the future.
b. With reference to Figure 44 and your preferred
Strategy Option, do you think any of the promoted
sites should be made available for any of the following
uses? How could that improve the completeness of
Rayleigh?
Balancing access against increased congestion will be the issue for a lot of the sites in Rayleigh. If you keep adding small developments to the boundaries of the town, it will overcrowd existing houses and add to urban sprawl.
i. Rayleigh has taken the brunt of development without significant infrastructural improvement.
ii. Commercial [offices, industrial, retail, other]
Commercial development should be supported in town centres, secondary shopping facilities and on approved industrial estates (the latter should not become retail / entertainment locations and residential development should not encroach on them to avoid conflict). Community Improvement Districts should be established
iii. Community infrastructure [open space, education, healthcare, allotments, other]
Community infrastructure should be preserved and extended. Access to town centres and secondary
shopping by bicycle and foot should be made easier and safer.
c. Are there areas in Rayleigh that development should
generally be presumed appropriate? Why these areas? [Please state reasoning]
No. Large scale residential development in Rayleigh should be resisted in the new Local Plan. So called
windfall development should be incorporated in the overall development targets thereby reducing
large scale development.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Conservation areas and green belt and sites subject to the exclusion criteria on the call for sites should be protected. Proposed sites within Rayleigh and on the Western side should not be considered for development. Only an infrastructure plan would provide evidence that the chosen sites are sustainable in the long term, and greenbelt and environmental policies should be adhered to in relation to open spaces on the edge or within the town.
e. Do you agree that the local green spaces shown on
Figure 44 hold local significance? Are there any other
open spaces that hold particular local significance?
All green spaces, no matter how small, hold some significance, especially to those who use them for
recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets
Q57.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Hockley Wood
Q58.
a. Do you agree with our vision for Hockley and
Hawkwell? Is there anything you feel is missing?
[Please state reasoning]
Yes. Insofar as it relates to Rayleigh.
Q58.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
As Hockley Woods is the largest remaining wild woodland in the country you should be doing
EVERYTHING you can to save it from development, either adjacent to or close by. You should also actively be adding to it by planting more trees to future proof its existence and status. You must protect any thoroughfares that access Hockley Wood.
Q60.
a. Do you agree with our vision for Hullbridge? Is there
anything you feel is missing? [Please state reasoning]
Yes. Insofar as it relates to Rayleigh.
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Anything too close to the river due to flood risk.
e. Do you agree that the local green spaces shown on
Figure 48 hold local significance? Are there any other
open spaces that hold particular local significance?
[Please state reasoning]
All green spaces, no matter how small, hold some significance, especially to those who use them for
recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the
Governments home building targets
Q63.
a. Do you agree with our vision for Rawreth? Is there
anything you feel is missing? [Please state reasoning]
Yes. Insofar as it relates to Rayleigh.
c. Are there areas in Rawreth that development should
generally be presumed appropriate? Why these
areas? [Please state reasoning]
d. Are there areas that require protecting from
development? Why these areas? [Please state
reasoning]
Protection needs to be given to development that change the dynamics of the village and those areas that border Wickford. There needs to be a significant amount of green belt land left to separate the two areas to prevent urban sprawl. Rawreth Lane gets heavily congested at peak times, and with Wolsey Park still not complete this is likely to increase. If there is an accident or breakdown on the road network, it has a huge knock on through Rayleigh and the surrounding areas and Watery Lane isn’t a reliable back up for when there are issue. Therefore, further development on the boundary or
otherwise could be detrimental to not only local residents but the wider District too. RDC should be supporting farmers wherever possible to continue to grow their crops in the district and protect suitable farm land in the area. We do not want to lose the local producers

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

1.0 Summary
1.1 These representations have been prepared on behalf of Crest Nicholson in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the “Site”) for consideration in the Rochford District Council (“RDC”) Spatial Options Local Plan (“the emerging Plan”) consultation of September 2021. Appendix 1 contains a Site Location Plan which shows the extent of the
boundaries of the Site.
1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council’s local housing need. The Vision Statement in Appendix 2 of these representations contains an indicative masterplan layout which has been led by an assessment of the constraints and opportunities.
1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full identified housing need. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council’s proposed settlement hierarchy.
1.4 Crest Nicholson is an award-winning national housebuilder with the means, experience and proven
track record to deliver sustainable development in partnership with RDC, so the residential
development of the Site would be ensured if it is allocated in the emerging Local Plan.
1.5 We support the identification of Rayleigh as the single Tier 1 settlement at the top of the proposed
hierarchy.
1.6 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. This is the minimum number of homes that needs to be planned for and it is clear that neighbouring Southend Borough Council will need support from Rochford District Council to deliver its housing need.
1.7 We support Spatial Options 2 and 4 insofar as they are relevant to the growth of Rayleigh and development of suitable available deliverable sites in sustainable locations that would enhance the completeness of Rayleigh, such as the Land at Lubards Lodge Farm.
1.8 We consider that Lubards Lodge Farm should be allocated for housing, with supporting community
infrastructure. The accompanying Vision Statement confirms that there are no overriding technical constraints to development, specifically in respect of landscape, highways, drainage, ecology and utilities. The Vision Statement demonstrates how a masterplan could deliver a balanced new community in the region of 500 new homes in this sustainable location, together with a new home for Rayleigh Boys and Girls FC, a new Country Park, integrated water management systems and
enhanced pedestrian and cycle links to the existing surrounding area.
1.9 We look forward to working with RDC, relevant stakeholders and the local community to help deliver our vision for Land at Lubards Lodge Farm.

2.0 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?
1.1 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.
1.2 Rayleigh is identified as the Tier 1 settlement and we consider this is entirely appropriate in light of its significantly larger population than any other settlement in the district, and that it contains by far the widest range of local and regional services. It would therefore be appropriate for a large proportion of the District’s growth to be directed to Rayleigh.

Spatial Strategy Options
Question 6 – Which of the identified strategy options do you consider should be taken forward in the Plan?
2.1 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 isnecessary to support economic growth, infrastructure improvements or address the needs arising
from neighbouring authorities.
2.2 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.
2.3 In light of our comments above, this option must be ruled out as it fails to meet the needs of Rochford district, let alone neighbouring areas.
2.4 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 2 insofar as it is relevant to the larger scale urban extensions proposed in Rayleigh.
2.5 Option two is split into two sections. Section 2a focuses urban extensions in main towns. Option 2b looks to deliver a hybrid approach whereby the larger urban extensions would be focused on the main towns including Rayleigh, whilst some of the residual urban extension growth would be dispersed to other lower order settlements based on the hierarchy.
2.6 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 Rayleigh. 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.
2.7 Insofar as this option is relevant to Rayleigh, we support the proposals in Option 2a to direct growth to suitable deliverable sites in and on the edge of Rayleigh.
2.8 Insofar as it is relevant to Lubards Lodge Farm, we would be supportive of Option 2b provided that large scale growth is not directed towards the lower order settlements at the expense of the most sustainable and deliverable sites in Rayleigh, including Lubards Lodge Farm.
Strategy Option 3 - Concentrated Growth – we do not support this option.
2.9 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 large scale (but not strategic scale) sites, such as the Site at Lubards Lodge Farm.
2.10 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.
2.11 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 2.12 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 Rayleigh.
2.13 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.
2.14 This Option also provides good opportunities for sustainable growth within Rayleigh with an appropriate scale of development based on the settlement hierarchy. This option is not restrictive on the location or scale of development.
2.15 Based on the response set out above we are supportive of Options 2 or 4 insofar as they direct
proportionate levels of growth to the higher order settlements in the hierarchy, including Rayleigh.
Our support for either of these two options is conditional on the proposed allocation of the Site at Lubards Lodge Farm, which is suitable, deliverable and sustainably located.

Planning for Complete Communities
Question 56a – Do you agree with our vision for Rayleigh?
2.16 Yes, we agree with RDC’s vision for Rayleigh. We note that the Vision Statement says that Rayleigh should be a “thriving town with a wide range of shops and services”, vibrant town centre, functional and reliable transport system with all residents living within walking distance of a local green space. It should provide for a diverse range of housing and job opportunities
meeting the needs of all in the community, whilst retaining its strong historic and cultural character.”
2.17 The best way of ensuring this vision is realised is by allocating significant land for residential development on the edge of Rayleigh. Land at Lubards Lodge Farm is capable of providing development of a scale to support the vitality of the town centre, the local bus routes, providing for diverse range of housing and retaining the town’s strong historic and cultural character.
2.18 Significant new housing growth in Rayleigh, through the allocation of greenfield land, is the only way of ensuring this.

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? How could that improve the completeness of Rayleigh?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
2.19 Yes, we consider that the Lubards Lodge Farm site, which forms a part of site CFS164 (excluding the brownfield land in CFS164 which falls outside of the control of Crest Nicholson and is not associated with these representations), should be allocated for housing, with supporting community infrastructure including a Country Park and a new outdoor sports area. The
release of this site from the Green Belt would accord with the settlement hierarchy, and Spatial Options 2 and 4. It is suitable, available and deliverable within the Plan period. Crest Nicholson has the means, experience and track record to deliver the development.
2.20 To deliver the necessary level of housing growth identified for the Plan period it will be necessary for RDC to focus its attention on the allocation of a large-scale greenfield site(s) on the edge of the higher order settlements in the district, including the single Tier 1 settlement – Rayleigh. The Site is one of only a small number of large-scale sites on the edge of Rayleigh and, because it is unconstrained and accessible, in light of RDC’s housing need and that Rayleigh is the only Tier 1
settlement, it therefore naturally means that the Site should be allocated for housing development through the Local Plan. The extract from Figure 44 below exemplifies this.
2.21 The proposed development onsite is market led residential housing, with supporting community
infrastructure including a new country park and onsite high-quality playing pitch provision for outdoor sport. As the Land at Lubards Lodge Farm is a greenfield site, it can accommodate a policy compliant quota of affordable housing and a package of proportionate infrastructure
provision only a greenfield site of this size within the sole control of a major national housebuilder could deliver. This is extremely important if RDC wants to realise its planning policy objectives by delivering healthy balanced communities with a range of supporting infrastructure, access to local employment opportunities, provision of public open space, biodiversity net gain and an enhanced new home for Rayleigh FC back in Rayleigh, where the Club belongs. This is unlikely to be possible on smaller scale allocations because they would be unable to deliver transformational infrastructure. It would be undeliverable on strategic scale allocations because the extent of funding required to deliver the necessary infrastructure would be likely to have significant impacts
on the ability to deliver on other planning policy objectives, such as affordable housing provision.
2.22 Taking account of the above, there are few comparable alternative suitable sites in Rayleigh that
are capable of delivering what is proposed by Crest Nicholson at Lubards Lodge Farm. For ease of reference an extract from Figure 44 of the consultation document showing the range of sites put forward for development around the edge of Rayleigh is shown below.
[see attached document for map]
Above: Extract from Figure 44 of the consultation document showing the promoted sites around Rayleigh in blue.
Land at Lubards Lodge Farm is available and deliverable
2.23 Lubards Lodge Farm is in single ownership and is wholly within the control of Crest Nicholson. Crest Nicholson’s due diligence to date suggests that there are no reasons why development of the site could not be delivered. This is further demonstrated under the technical sub-headings as set out in the accompanying Vision Statement.
2.24 Crest Nicholson has been building new homes for over 50 years and is firmly established as a leading developer with a reputation for creating vibrant sustainable new communities. Crest Nicholson’s contribution to the built environment has been recognised with a strong of awards, including The Queen’s Award for Enterprise in Sustainable Development. This award is testament to Crest’s continued emphasis on producing high quality developments that champion the very best principles in sustainability. More recent awards include winning Sustainable Housebuilder of the Year at the Housebuilder Awards 2016, and Large Housebuilder of the Year in 2015.
2.25 The Site is therefore available and deliverable.
Land at Lubards Lodge Farm is suitable
2.26 The Site is a suitable location for development, is free from constraints and is unencumbered in all respects. This is demonstrated in the accompanying Vision Statement prepared in support of these representations. To supplement this assertion, we have extracted the Appraisal for the wider CFS164 site from the Site Appraisal paper in RDC’s evidence base – see below.
[see attached document for table]
Above: extract from RDC’s Site Appraisal paper for CFS164 Lubards Lodge Farm
2.28 Against the assessment criteria in the Site Appraisal paper, site CFS164 scores comparatively well against other Rayleigh sites. It is noted as being developable (subject to policy) and deliverable for housing and/or commercial development. We agree with this assessment, as there are no overriding constraints to development. Similarly, the site is attributed high scores (4 or 5 out of 5, i.e. well performing) against most of the assessment criteria, including flood risk (the site is within Flood Zone 1) air quality, various forms of utility infrastructure, access to transport options and facilities. This all corroborates with the evidence contained within our accompanying Vision Statement for the development of the Site.
2.29 The Appraisal attributes scores of 1 out of 5 (i.e. worst performing) against the Green Belt and Agricultural Land Quality measurements. In respect of Green Belt harm, we must draw to RDC’s attention two matters in particular that must be noted in order for these “issues” to be properly viewed in context:
● It is inevitable that the development of any greenfield Green Belt site would cause harm to the Green Belt. Any harm to the Green Belt arising from development needs to be balanced against RDC’s need for new homes, which cannot be delivered wholly on brownfield land in
the district because there are not enough previously developed sites.
In accordance with NPPF guidance and established case law1, where exceptional circumstances for the release of Green Belt land are justified, it is necessary to consider,
amongst other factors:
− Whether the Plan could achieve sustainable development without the use of Green Belt land,
− Whether the nature and extent of Green Belt harm would be minimised through the site selection process by selecting sites that contribute the least to Green Belt purposes, and
− The extent to which consequent impacts on the purposes of the Green Belt may be ameliorated or reduced to the lowest reasonably practicable extent, through the redefinition of the Green Belt boundary via physical features that are likely to be permanent, and through scheme design. The extent of harm to the Green Belt, by reference to the Appraisal paper’s score for the Site, is therefore not in itself a reason to discount it from consideration.
● The Appraisal for the CFS164 site considers the Site in its entirety. It should however be noted that the Green Belt Review Stage 2 assessment for CFS164 splits the site into two distinct assessment parcels, identifying that the south-eastern part of the assessment parcel has a lower Green Belt sensitivity. An extract from the site assessment is shown below.
[see document for image]
Above: Green Belt Review Stage 2 assessment – CFS164 is split and assessed as two parcels
Against the south-eastern half of the assessment area for CFS164, the Green Belt review identifies that “release of the land in the southern and south eastern Moderate-High corner of the assessment area up to and including the developed site 163 is significantly more contained by urbanising development. Consequently its release would have a more limited impact on adjacent Green Belt land. Whilst it would lead to the breaching of a strong
boundary along Rawreth Lane, development has already taken place to the north of this road to the west and east of the parcel.”
It is demonstrated that a blanket assessment of the site in its entirety does not accurately reflect the way in which the impact of development could be ameliorated by a reduced development coverage. Added to this, NPPF paragraph 143f) states that when defining Green Belt boundaries, plans should “define boundaries clearly, using physical features that are readily recognisable and likely to be permanent”. We consider that any residual harm to the Green Belt can be addressed through masterplanning and landscape mitigation. Crest
Nicholson has the means, experience and track record to ensure this. Indeed, the southeastern parcel within CFS164 broadly corresponds with the masterplan proposals we have put forward within our accompanying Vision Statement. This can be refined as necessary in
due course, should RDC consider it necessary to do so.
2.30 Taking account of the above, it is considered that harm to the Green Belt caused by the development of the Site can be appropriately mitigated. We look forward to working with RDC to ensure that effects can be minimised in this respect.
2.31 The Site Appraisal identifies a high degree of harm under the Agricultural Land Quality criteria. However, as with the Green Belt matter, the Paper identifies at paragraph 70 that the nature of the District has “a relatively scarce supply of brownfield land” which means that if the district’s identified housing need is to be met in full, greenfield land would need to be released. It is
therefore inevitable that some “best and most versatile” agricultural land would need to be lost if RDC wishes to achieve wider sustainability objectives, in accordance with the Strategic Objectives and the draft Vision for Rayleigh. We consider that there are therefore sustainability factors that would outweigh the loss of BMV land.
2.32 Taking account of the above, we consider that the Site is entirely suitable for development. Land at Lubards Lodge Farm would enhance the completeness of Rayleigh
2.33 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”.
2.34 The supporting text to the Draft Vision statement for Rayleigh says that “as can be seen from the
completeness mapping, Rayleigh benefits from a good standard of walking access to most dayto-day services. The areas of Rayleigh with the best walking access to services are around its town centre, with other strong areas to the west along London Road. Overall, even those parts of Rayleigh outside of the walking catchment of services benefit from good levels of access overall,
particularly along the spines of Rawreth Lane, Hockley Road and Eastwood Road” [Bidwells emphasis]. This is shown on the Completeness map for Rayleigh, an extract from which is shown below
[see document for image]
Above: extract from the consultation document’s Completeness map of Rayleigh
2.35 Lubards Lodge Farm is well located to enable sustainable transport choices and is within a 10-
minute walk of the following local facilities:
● Asda supermarket;
● Down Hall Primary School;
● St Nicholas C of E Primary School;
● Sweyne Park Playground;
● Employment uses at Lubards Farm to the north; and
● Rayleigh Leisure Centre.
2.36 Land at Lubards Lodge Farm is comparatively closer and more accessible to Rayleigh town centre than other large-scale sites on the edge of town and therefore offers better opportunities to make use of sustainable forms of travel. It offers the opportunity to strengthen the existing bus route along Hullbridge Road, together with potential to enhance existing non-frequent public
transport along Rawreth Lane thereby bringing enhancing the sustainability and accessibility to
residents of the existing community, as well as future residents.
2.37 Completeness benefits would not only be limited to walking and public transport options. The provision of cycle routes in Rayleigh is currently limited, however, several proposed routes are identified in the Rochford District Cycling Action Plan (published by Essex County Council in 2017) but which do not yet appear to have been taken forward. These include Proposed National
Cycle Route 135 passing the Site along Hullbridge Road and Rawreth Lane, and an extension of an existing route along Priory Chase to Rayleigh Rail Station via St Nicholas Church of England School and The Sweyne Park School (proposed route IDs 24 and 23). These are shown on the Cycling Acton Plan map extract below
[see document for image]
Above: extract from the Rochford Cycling Action Plan
2.38 Cycle routes would be provided within the development, and there is the potential to connect to
these proposed routes and contribute to improvement works to facilitate a safe route to local schools and the rail station. Provision of connections from the Site into the existing and future planned cycling infrastructure offers further potential to enhance the completeness of Rayleigh.
A new home for Rayleigh Boys and Girls FC
2.39 Rayleigh Boys and Girls Football Club has been running since 1976 and is regarded by the Essex Football Association as the largest youth football club in Essex with more than 65 teams, 12 of which are Girls teams. It is the aim of the Club to promote a safe Environment for Children of all ages to learn, develop and enjoy playing football. Despite the Club’s key role in the community, with player registrations increasing year on year, it has been very difficult for the Club to secure match-day (grass) and training (all-weather) pitches locally due to the lack of available land and funding.
2.40 The Club relies on the dedication of volunteers to organise the rental of pitches, many of which have limited facilities and require long journeys outside of Rayleigh for the children, for example the Chichester Ground in Rawreth which is only accessible by car. To-date the Club does not benefit from any form of building or clubhouse to manage operations from and allow teams and their families to interact before/after matches.
2.41 The proposals for a sustainable neighbourhood at Lubards Farm provide a unique opportunity to accommodate new training and match day pitches, and a permanent new facility in Rayleigh that the Club can finally call home. Not only would there be significant benefits for the Club’s 800+ players and families, but the facility could also be available during weekday school hours for the wider Rayleigh community (including local schools) who currently do not benefit from an allweather pitch, despite being the largest town in the District. Crest Nicholson specialises in delivering community-led, high quality new homes and is proud to be working with the Club to inform the proposals from the outset.
Lubards Lodge Farm would deliver green and blue infrastructure
2.42 There is an opportunity to incorporate managed green infrastructure to the north of the site in the
form of a Country Park, to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised.
2.43 As the Site is currently private land it does not benefit from the same potential that its allocation for
residential development would bring in this regard.
2.44 Within the rationale provided by the South Essex Green and Blue Infrastructure Study, the Country Park established in the north of site would become a multifunctional greenspace with areas of high value habitats as well as recreational areas. The park would include a range of circular walks and dogs-off lead areas as well as public rights of ways connections to adjacent greenspace. The Country Park would integrate SuDS and swales within habitat links to create well-connected
wetlands. There are opportunities to maximise connectivity with adjacent habitats. Enhanced habitat connectivity will be created through strengthened linkages and ‘stepping-stone’ areas across the site; for example, grassland, hedges and other linear features, and water features. The proposals will maximise connectivity for species such as bats with the adjacent golf course and priority habitats to southeast (woodlands) and west.
Land at Lubards Lodge Farm benefits from recently delivered highways improvements
2.45 A new 3-arm compact roundabout has been built in the location of the former mini roundabout between Rawreth Lane and Hullbridge Road, directly adjacent to the south-eastern corner of the Site, where there is the opportunity for the Site’s vehicular access to be taken from.
2.46 Financial contributions towards the cost of improvement works were secured by Essex County
Council to build the roundabout to relieve congestion at the local bottle neck. Work was commenced in January 2021 and was completed in the summer of 2021.

I have just looked into the above document. Firstly I would like to start by saying that the vision statement for Hullbridge should’ve been put together by Hullbridge, as this in no way reflects the Hullbridge community and what there vision for Hullbridge is!
I do not feel that Hullbridge is a candidate for Yet even more housing development. Hullbridge is already trying to deal with the impact of approx 500 new homes which has had an impact on traffic in and out of the area and affecting local amenities.
I am also concerned that the proposed areas within Hullbridge listed are on Green belt land which is going to hugely impact natural habitat and wildlife whilst posing a flood risk to an area which is already a flood plane. Since moving into the area a year ago the impact of the ongoing new builds has already had ongoing effects with travelling in and out of the area whilst causing the water pressure to be low. I do not feel that having even more development to this area would be beneficial for anyone and feel that there are alternative areas which would be better suited and not have such a negative impact to neighbouring areas.
West of Raleigh would be a much better option to build in one location whilst enabling residents easy access to commute whilst providing amenities in the area to cope with the increasing population.

I felt it necessary to email in with my concerns after hearing of the new local plan. It concerns me that you are proposing to build yet more houses within a village that is already suffering from the already increase in property that is currently being done. The roads are constantly gridlocked and there is concern of flooding with the natural flood drainage being turned into yet more houses. Your vision for Hullbridge does not reflect local residents vision at all.
>
> Would it not be more appropriate to increase housing in Raleigh west ( one of the proposed sights) where you would be able to increase amenities along with the population. This would also give residents a more sufficient commute when using public transport i.e trains, buses.
> This would also be less of an impact on habitat.
>

Re: Spatial Options consultation – Eastwood Nursey’s, Eastwood Road, Rayleigh Essex. CFS127

I refer to your spatial options consultation document in which the Local Planning Authority are seeking views that will form the basis of the Local Plan going forward to 2040.

I would be grateful if your office would kindly note that this practice acts on behalf of Mr Barrie Stone, the landowner of the above site.

The purpose of this letter is to assist the Local Planning Authority with its consultation process and provide additional information which may assist officers of the council when reviewing individual sites which are most appropriate for residential development. There does appear to be a number of errors within the site assessment already conducted by the Local Planning Authority. This letter along with the additional reports that have been undertaken will provide some assistance.

Firstly, my clients fully endorse the Local Planning Authority’s interim policies with regard to sites that are identified as brownfield, part brownfield, and contaminated land should be brought forward for development first. This of course follows government guidelines and recent appeal decisions that have been issued by the Planning Inspectorate.

In the case of the above site, this has a long history of various mixed uses on the site including commercial, retail, light industrial, residential and sui generis uses. Many of the uses operate under a lawful use category having been in operation prior to the 1st of July 1948. Crucially, there is a statutory grant of planning permission here, in acted by virtue of the 1947 Planning Act.

In essence, the fallback position on this site is that the total site area can be used as a scrap yard without the consent of the Local Planning Authority. Please note as per 1985 caselaw, an abandonment use cannot occur with a statutory grant of planning permission.

In addition, there is substantial built form on the site, along with large areas of concrete hardstand; therefore the site complies with the National Planning Policy Guidance, annex one in terms of previously developed land.

Although the site is currently identified within the Rochford District Local Plan as Green Belt, it must be a matter of common ground that the site does not meet the objectives of the Green Belt which are as follows:

Green Belt serves 5 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.

In view of the site not meeting any of the above Green Belt criteria, the Local Planning Authority are encouraged to remove this site from the Green Belt.

With regard to other areas that have been highlighted within the initial assessment, my clients have already conducted extensive survey work which have included highways, ecology, flood, and strategic drainage, all of which have concluded there are no issues of concern, and these have been confirmed by statutory consultees.

In terms of sustainability, the site is highly sustainable being on a major bus route and within a five-minute walk of a major food store, A primary school is a 15-minute walk and secondary education is within easy access. In addition, Rayleigh town is also within easy reach either by bus or by walking. The site is also well served by open space and parks are within a 5-minute walk.

Development delivery has been mapped out by my clients with a delivery partner and end user already on board. Therefore, delivery of this much needed housing could be delivered within two years.

planning applications for consideration
I understand that there are multiple sites which are being considered for housing development in the area. Given the overwhelming recent evidence of climate change and it’s impact on the global environment, could you please advise whether the developers of these large scale building sites will be compelled to ‘up their game’ in respect of green initiatives (with the aim of delivering carbon neutral or very low carbon housing, heat pumps rather than traditional boilers, high performance insulation and glazing, electric car charging points, etc.)?

A friend of mine purchased a new home in the Folly Gate development and she is now in the process of selling it; the surveyor has identified multiple issues (which should, she hopes, be covered by the new build guarantee), however it is apparent that this development (and I suspect many) was put up cheaply with the minimum regard to quality and likely just enough regard to environmental impact in order to pass planning and building control regulations.

Whilst central government may be lagging behind in their attempts to tackle climate change, it would be good to know if the local council are demanding higher standards for new builds which might otherwise need retro fitting at a later date (creating more manufacturing impact), or worse still, they are still considered ‘acceptable’, when they could have been built to better standards in the first place, developments which lead the way in green credentials, and something which the local council can be proud of.

I have just reviewed your interactive map and I am appalled by the clear documenting to any developer in the country to ride in and apply to build all over any tiny bit of green space we have in rochford.

Rochford has always been semi-rural as a district, particularly in areas such as Stambridge. I am so disappointed to see every field that a house could be squeezed onto, is highlighted and offered up as a potential to be developed.

I understand you have targets and that sites should be offered before they are taken by central government, but we cannot turn England into concrete city.

There is already uproar about the potential (and likely) development off of ashingdon road, rochford itself cannot withstand such proposals (roads, doctors, dentists, schools) and overdevelopment is looking to be a real issue.

Surely having over 1000 holes built (hall road + ashingdon road) in such a short space of time should be enough! Leave rochford alone for 10 years, the poor animals and our environment! It’s devastating.

My husband and I would prefer no further houses were built in or around Hullbridge as the road infrastructure will not meet traffic demand, we have already noticed the impact of traffic delays with current new builds.

The only strategy option would be
3. Build all housing in one location west of rayleigh, north of southend's or east of rochford.

Proposed building in Rochford Hawkwell and Rayleigh
Dear Planning

We are so unhappy with the proposed large scale housing developments.
Having lived in Hockley for over 35 years we have certain seen it grow. But enough is enough, the area can not take anymore traffic.

Let’s keep our wonderful town and villages as they are.

Introduction

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

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

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


Comments on the Consultation itself

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

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

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

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


District Profile

Population Statistics = a strange change of approach.

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

Presenting a confusing and contradictory picture

I found your approach here very confusing.

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

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

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

Use proper hard credible metrics

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

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

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

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

A suggested alternative

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

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

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

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


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


Spatial Strategy Options

Option 3a = the best strategic solution

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

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

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

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

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

Option 2 is tactical not strategic

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


Spatial Themes - suggested additions

Waste and Recycling

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

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

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

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


Digital Infrastructure

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

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

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



Green Belt Policy

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

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

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


Bio-Diversity

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


Spatial Themes - Flood Risk

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

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

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


Transport and Connectivity

Public Transport

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

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

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

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

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

Walking

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

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

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


Conclusion

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

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

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


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

Electronic Car Charging

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

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

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

This will present the District with significant Planning challenges:

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

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

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

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

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

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

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

My main comments are:-

No new housing should be built on green belt land, we need to protect our environment and the lungs of the area and not turn it into a concrete jungle, use brown fields site only, any housing plans should not be pushed through against the local residents wishes and more notice must be taken of objections and people’s views unlike now.

I live in Hullbridge and your proposed housing sites will make the “village” a town, this is unacceptable for the following reasons :-

Hullbridge is a one road village, Lower Road is already at full capacity particularly at school times and the morning and afternoon rush hours, to get access onto the road from a side road you take your life in your hands, there are 40 ft, artic lorries using a road which is totally unsuitable, especially considering the amount of cyclists using it now which is being encouraged by central government to reduce car movements, so will only increase as would car movements should housing stock increase in the area.

Watery Lane is a road which again is totally unfit for purpose with more minor accidents than almost anywhere else, Hullbridge road has improved with the new roundabout at Rawreth Lane although I reserve judgement until the rest of the houses already planned for the area are complete but any slight problem, an accident or road works it becomes a total nightmare with traffic virtually making Hullbridge impossible to get to or leave, with emergency vehicles stranded.

One of the proposed areas for new housing is Pooles Lane, how anyone in their right mind can even consider this or propose this I do not know, the road between the Community Centre and Tower Park entrance is effectively a one lane road with a blind bend, unfortunately some drivers appear to have developed eyesight that allows them see round bends and to go round the bend at speed, many near misses everyday here, I stood watching this piece of road for just under half an hour one day 3 weeks ago, in that short period 7 vehicles mounted and drove along the footpath, I cannot imagine how many a day there are.

Other as important reasons that new housing should not be considered apart from roads are :-

Schools, where are the increase in pupils of any age going to school, the schools are at full capacity now, education is vital and any young person should not have to travel for a long period to be educated especially on grid locked roads.

Medical facilities are over stretched and at breaking point, Southend Hospital Group cannot cope now, so after any development in other areas or any future planned development have the possibility to cause mayhem, it will not handle the increase in population.

Hullbridge Riverside Medical Centre is a very good practice but with standards reducing with appointments very hard to get, this will get worse once the houses already being built locally and are full of people the practice will be under even more pressure so how will they cope with any further increase, they will not, lives will be put at risk especially with an aging population as Hullbridge.

I feel that other questions in your plan have been adequately answered by our parish council response.

Please find below our objections to the local plan proposed sites CFS023 and COL38. I have submitted parts of these answers on your online gateway, though the forms are not clear over whether it should be a support, objection or comment, based on how the questions are worded, particularly when one question asks multiple things.
We would also like to make it known that Strategy option 3 would be our prefered solution to the local plan. It provides large scale development that would have the space to fit in the new infrastructure, such as schools, doctors and shops. The areas would be planned into an effectively blank canvas allowing the best chance to build sustainably, rather than trying to force additional housing onto infrastructure that's only just coping with current demand. The proposed sites have good links to the major roads e.g. A127 to provide transport to employment areas.

Site reference: CFS023
Firstly, Site CFS023 (Land north and east of Malvern Road) should be protected from development as developing on this piece of land will have detrimental and irreversible effects to the adjacent ancient woodland; your own site survey scores it at a 1 (worst performing site) in regards to ancient woodland. Your vision statement for Hockley / Hawkwell is about “making the most of its access to ancient woodland”, clearly recognising the importance of protecting our ancient woodland, including Beckney woods.
The government’s own gov.uk website (https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences#assess-the-impacts) states that developments nearby ancient woodland can have the following affects:
• reducing the amount of semi-¬natural habitats next to ancient woodland
• increasing the amount of pollution, including dust
• increasing disturbance to wildlife from additional traffic and visitors
• increasing light or air pollution
• increasing damaging activities like fly-¬tipping and the impact of domestic pets
• changing the landscape character of the area
All of the above would affect the ancient woodlands of Beckney woods, and the vast range of ancient trees and other flora and fauna that inhabit it. Any increased pollution to the area would damage the wonderful bluebells and wood anemones in Beckney woods.

In the Hockley/Hawlkwell area Beckney woods is one of only 2 ancient woodlands; therefore it is not unreasonable to protect Beckney woods by choosing other sites for housing developments which are not adjacent to ancient woodlands, therefore ancient woodland ecosystems would not destroyed.

The Woodlands Trust is actively working to save ancient woodlands and ensure appropriate buffering land is in place, therefore we have informed them of your proposal, as the site is one of the last remaining greenbelt strips connecting Beckney Woods to the surrounding areas.

The proposed site is an important animal and insect habitat in its own right. Many different birds of prey use the green belt as a hunting ground, meaning there is numerous small prey animals that call the site home. Snakes are known to live on the site, while bats can be seen most evenings, so they must roost nearby. Foxes and badgers have also been sighted on the proposed site, as have both Spotted and Green Woodpeckers. We would be able to provide photographical evidence of these, if required.
Furthermore, there are other reasons in addition to the site being adjacent to ancient woodland that make Site CFS023 inappropriate for development.
This is green belt land, and should not be built on. Why make policy changes on protected sites, when others are suitable instead. Your own survey ranks development on the site as the most damaging to green belt land. There is a lot of trees on the site itself, which would have to be felled; again this is indicated on your survey as having a big impact on protected trees.
The proposed access to this site (Harrogate Drive) is currently single lane track and is not suitable for the additional traffic 139 houses will bring. It is unclear what land would be used to widen this road to make it suitable as there are already houses either side of this unmade track/road. Additionally, your site survey highlights that the development is no where near any parts of the strategic road network, and while reasonable access to Greensward Lane for a bus stop, it has very poor access to bus services.
While the proposed site may have a low flood risk itself (as it is on the crest of a hill, with pretty steep terrain), if it was to be developed there is a real risk that the extra water that will no longer soak into the ground (due to a large amount of new pavements, roads, driveways and the houses themselves) will cause surface flooding issues to those houses beneath in Malvern Road. Many of the houses in Malvern Road already have issues with such flooding. The site itself also scores poorly for critical drainage risk.
Malvern Road already suffers with weak water pressure, which will only be exacerbated by further housing development.
I would also like to question how the proposed site has received a 5 for topography, as it is literally on the crest of a hill, with a steep West to East gradient. I would like any planning officer / councillor to walk the length of the site and not comment on the height change.
Access to local primary and secondary schools may be good, as they are physically within walking distance, but from their Ofsted reports, they do not have the capacity to support the additional housing you are suggesting in the area. Surely picking a larger site, where developers would have to provide facilities, such as schools and doctors, would be a smarter choice by the council. Leading on from this, the road infrastructure in the local area is already struggling to meet demand, in particular on Greensward Lane under the railway line where a large bottleneck forms as there are no alternative routes through.

Site reference: COL38
Site COL38 (Former Park) should also be protected from development as this Park is a well-used amenity to the current residents of Hockley and the surrounding areas. It is used as an access point to Beckney woods, as well as a popular spot for dog walkers and ramblers. This has previously been recognised by Mr Martin Elliott following an inspection in 2014 that concluded there is a public right of way through this land. Regardless of how well used this piece of land is, it is our understanding that this land is on peppercorn rent to Ashingdon parish council; from when the lease started in 2000 it had to be used as a play area for at least the next 100 years. Because of these reasons site COL38 should be excluded from consideration from the local plan.

I have read with concern the possible future sites for building in and around great Wakering and out towards Shopland and Sutton Road.

Wakering is one of the only remaining villages in this part of Essex and those that live here enjoy the village community because of the way of life. i feel that this is slowly being eroded and will affect the health and well being of the residents detrimentally. More housing will also increase crime.

There are also surface and tidal issues to consider here and further building will increase the risk of flooding. There are several sights near to creeks which would put any development itself at risk of flood. With climate change this is likely to be an increased risk anyway and our drainage system cannot cope as it is.

New homes rarely bring more or improved infrastructure. This area is a peninsula with only 2 roads in and out. Residents have to travel to work as there is no transport links by way of station or public transport to support this. Traffic is already at a standstill at times. It only takes one lorry parked in the road for a delivery to bring gridlock. In addition many of the roads are rural and the fact is that the majority or road accidents happen on rural roads. Any further increase in traffic will increase accidents. We already have one new housing development with access via a country lane. Not a road... as not even wide enough for central white lines. Lorries etc on this road accessing the new site will make this lethal.

We struggle already for children to get places in the local schools and the doctors surgery is under immense pressure. 30 years ago, with far fewer residents, we had 4 doctors. We now have three.

I am therefore opposed to any of the sites in the consultation to be considered for future building as I do believe that building in condensed areas goes against both the environment bill and the goal of carbon neutrality.

If new houses are really needed, this is not the area to build in and add to the congestion, destruction of the environment, biodiversity and our wildlife.

Although I do not like the option of new garden villages to the west of the area, this may be the only way forward as it will ensure that the infrastructure is put in place.

My thoughts and definite objections particularly to plot cfs057 plus all others affecting great wakering

The lack of infrastructure,is by far the biggest issue, doctors unable to cope, school over overflowing, no areas for children to play .

In addition only 2 roads in and out if this area so in event if an emergency evacuation of the village,this would cause severe issues and probable deaths .

flooding, both surface and tidal issues, I can’t even pave my driveway without special permission yet you want to cover acres in buildings patios and access roads

the environment bill, with climate change will only get worse the drains can’t cope as it is .

People live in a village community because of the way of life. So health and well-being will be detrimentally affected. We chose to buy in a village not a town .

The Impact on the environment will be highly detrimental to the biodiversity and wildlife. Without bees we will not survive !!!

The increase in traffic will increase accidents. This area is a peninsula-people have to travel to work. No nearby station or public transport to facilitate this.

For these reasons I am totally against any of the proposed plots being agreed for future building within great wakering and would strongly suggest looking at building a purpose built town towards Rayleigh which has the space and capacity to support new homes and custom infrastructure

EXECUTIVE SUMMARY.
GROWTH SOUTH EAST OF ROCHFORD & NORTH OF SOUTHEND.

Bellway Strategic and Cogent Land LLP, on behalf of the landowners, welcomes the identification of growth
on land South East of Rochford and North of Southend (Strategy Option 3b) in the Rochford District Council
(RDC) New Local Plan: Spatial Options Consultation Paper 2021. The delivery of this growth option will
unlock a new generation of highly sustainable communities that meet housing, employment and qualityof-life needs, while promoting innovation. Bellway Strategic, have acquired the subject landholding from
Cogent Land, and are committed to working collaboratively with the Council, key stakeholders and the
existing community to create an exemplar new community which sets the benchmark for development in
the region and for future generations.
Option 3b should be the priority location for strategic growth within the emerging Local Plan and is
fundamental in delivering RDC’s strategic priorities. This proposal will deliver the step change RDC is looking for to address the housing crisis in the District, along with ensuring the District keeps apace with the Thames Estuary objectives reinforced through the South Essex authorities partnership. Critical to this change in approach is delivering large scale strategic concentrated development in one location and moving away from solely ‘bolt-on’ schemes that fail to deliver the much-needed infrastructure and the benefits for the existing community. This aligns with the Framework which
identifies that in delivering large numbers of new homes significant urban extensions are preferrable
provided they are well located and supported by the necessary infrastructure (including a genuine choice of transport modes). Through existing characteristics in terms of the site’s location on the edge of Rochford and adjacent to Southend Airport, along with proposed infrastructure enhancements, the proposal will satisfy the Framework in this regard crucially ensuring that people have the choice to walk, cycle and access reliable and frequent public transport.
RDC need to find a solution to deliver housing in the short term, in addition to planning for the medium- and long-term. In terms of developing balanced growth across the Plan period, our client endorses Strategy Option 4: Balanced Combination - supporting the delivery of a blend of sites which will ensure the Council can meet their identified housing needs across the Plan period. The preferred strategy will involve making best use of urban capacity (Option 1), building the identified growth option on land south east of Rochford and north of Southend (Option 3b) and a number of smaller urban
extensions (Option 2).
The Council’s previous engagement with local communities has identified the need for improvements
to services and utilities, supporting local employment opportunities, development of sustainable transport options, and improvements to strategic infrastructure as key community concerns. Option 3b will deliver a range of major new infrastructure, including highways improvements, investment in community infrastructure including schools, health centres, the eastern extent of the South Essex Estuary Park, along with sporting facilities and will provide substantial investment in the public realm.
This proposal has the potential to enhance and diversify employment and business opportunities in the local area, enabled by access to high-speed broadband. The scale of development and variety of uses presents opportunities to coordinate energy generation, and to achieve net-zero carbon.

Strategy Option 3b – South East of Rochford & North of Southend will deliver:
Sustainable Communities
New villages within Rochford which respond to the landscape and the morphology of existing settlements

New Homes for Rochford
4,600 homes in total, with 1,850 homes by 2040

Meeting Local Affordable Housing Needs
Deliver c. 650 affordable homes by 2040 (35%) and 1,600 affordable homes in total

Strategic infrastructure improvements delivered alongside growth
Improved eastern access to London Southend
Airport Rail Station, Temple Farm and Purdeys
Industrial Estates, and address congestion pinch points including Bell House Junction, Priory Crescent and Warners Bridge.

Job Creation & Employment Land
Deliver c. 11 ha of employment land concentrated in close proximity to existing employment to the south east of Rochford / Southend Airport; together with enhanced
digital connectivity to support home working

Benefits for Existing Residents
Enhanced transport and social linkages to existing villages in Rochford

Genuine choice of transport modes
New green, sustainable transport corridors providing a link between the two train lines (Southend Airport and Thorpe Bay)
Encourage cycling and walking by designing 15-minute neighbourhoods and ensuring high-quality cycle networks to serve existing and future communities.

Community Infrastructure
Delivery of two new primary schools, healthcare and community services in the Local Plan period;

Green & Blue Infrastructure
Utilising the unique natural assets for the benefit of existing and future residents including delivering the eastern extent of the South Essex Estuary Park forming a new coastal country park in the east of the District

Environmental Benefits
Retention and enhancement of historic woodlands and the identification of locations for new woodland for greater biodiversity and wildlife, rewilding, green infrastructure corridors, private food growing and vertical
farming will add to the Biodiversity Net Gain

Tourism Strategy
Harness the untapped potential of Rochford as a tourism destination

Climate Change
Be carbon neutral by 2040 and achieve netzero carbon emissions by 2050 through a host of measures including building design and specifications and encouraging growth of active travel

01. INTRODUCTION & SITE CONTEXT
1.1. Iceni Projects on behalf of Bellway Strategic and Cogent Land wish to submit representations to the Rochford District Council New Local Plan: Spatial Options Consultation Paper 2021. Bellway has acquired an interest in land south east of Rochford / north of Southend and is actively engaged with key stakeholders to bring forward growth in this location, incorporating a mix of uses including housing, community, health and employment uses through the plan-making process. Cogent Land have been promoting the subject site for sustainable growth for almost two decades and wholly support the preparation of the new Rochford Local Plan.
1.2. Bellway Homes is one of the UK’s leading home builders. Bellway began as a small family business in
1946 - with a passion for building exceptional quality homes in carefully selected locations, inspired by the needs of real families. Bellway has grown from a local family firm into one of the country’s leading residential developers. Bellway have this year been awarded 5 star builder status by the Home Builders Federation for the fifth year running.
1.3. The designs of Bellway homes and construction techniques blend tradition with innovation, creating
well-built homes with modern living standards. With a reputation for high quality developments in prime locations, Bellway Homes strive to create sustainable new developments. The homes are designed with more than seven decades of experience and craftmanship, to create a new generation of properties that meets the aspirations of today’s homebuyers. Bellway homes
feature exterior finishes that reflect the character of the local neighbourhood with an enhanced specification, both inside and out.
1.4. The extent of the land under the control of our client within the RDC boundary is detailed in Appendix 1. The landholding lies to the north of the A13 and A1159, with London Southend Airport & Rail Station and Sutton Road sitting to the west. Temple Farm and Purdeys Way employment area, as well as employment opportunities associated with the Airport, are closeby. The River Roach lies to the north and is designated as a Site of Special Scientific Interest, a Special Area of Conservation and Special Protection Area.
1.5. In addition, our client has interests on adjoining land to south which falls within the Southendon-Sea Borough Council boundary. Given that the landholding straddles both Council boundaries the conceptual design studies undertaken to date have considered the land holistically, as many of the Council’s evidence base documents have also done. In this respect, these representations should be read alongside the Potential Growth Options in Rochford and Southend, Proof of Concept, 22.07.2021 attached at Appendix 2. Nonetheless for the purposes of this Local Plan and ensuring the Rochford Local Plan can be found sound in its own right, these representations
focus on the land within Rochford and the proposals that can be delivered within this Local Plan.
1.6. These representations will demonstrate that Bellway, and their appointed consultant team, have prepared a vision for this location to deliver positive growth for the District which will be sensitively designed to connect with the surroundings, will foster social and economic relations with the existing communities, will contribute towards biodiversity net gain, minimising carbon
emissions and protect the environment.
1.7. These representations are structured as follows:
ƒ Section 2 details the main policies contained within the National Planning Policy Framework including the support for large scale growth options and the required approach for plan making in releasing land from the Green Belt;
ƒ Section 3 summarises regional matters in respect of the Association of South Essex Local Authorities, the preparation of a Joint Strategic Plan and the Thames Estuary Growth Commission;
ƒ Section 4 assesses RDC’s housing and employment needs;
ƒ Section 5 considers the strategic matters in Local Plan making;
ƒ Section 6 details the key findings from the RDC landscape impact and green belt evidence base;
ƒ Section 7 sets out the vision for land south east of Rochford and north of Southend;
ƒ Section 8 provides a response to the relevant questions raised in the consultation; &
ƒ Section 9 in conclusion details the economic benefits of Option 3b to Rochford District.

02. NATIONAL PLANNING POLICY FRAMEWORK
2.1. 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 Option 3b.
PLAN LED APPROACH
2.2. The National Planning Policy 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:
ƒ meet the development needs of their area;
ƒ align growth and infrastructure;
ƒ improve the environment;
ƒ mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
2.3. This element of the Framework and specifically how the proposal at South East of Rochford and North of Southend will assist the Council in delivering a sustainable pattern of development is considered in detail at Section 5 of these representations.
2.4. 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.
LARGE SCALE GROWTH
2.5. The most recent revisions to the Framework include the requirement:
‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’.
2.6. This is applicable in respect of the current proposal at Option 3b and is detailed in full at Section 7 of these representations.
2.7. The Framework at para 73 considers that

“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). Working with the
support of their communities, and with other authorities if appropriate, strategic policy-making authorities should identify suitable locations for such development where this can help to meet identified needs in a sustainable way”. (Our emphasis)

This is key in Rochford as acknowledged in the Spatial Options Consultation, that the only way to deliver the Council’s strategic objectives such as addressing current infrastructure deficits is through large scale growth. Growth of a strategic scale will ensure that the housing numbers are delivered but also that the necessary infrastructure, including transport, is delivered alongside
the new homes.
2.9. The Framework advocates that in identifying suitable locations for such development, strategic policy-making authorities should consider a host of factors which are detailed in the table below, alongside a review of the relevant features of growth at South East of Rochford and North of Southend. The policy requirements set out in para 73 of the Framework provide the basis for
assessing the potential and suitability of growth in south east of Rochford and north of Southend.

[See attached document for table format]
Table 2.1 Review of Spatial Option 3b against the criteria set out in Para 73 of the Framework
Para 73 NPPF – Criteria for Large Scale Growth
[followed by] Assessment of Growth Option – South East of Rochford and North of Southend
a) consider the opportunities presented by existing or planned investment in infrastructure, the area’s economic potential and the scope for net environmental gains

The site’s location on the edge of Rochford and Southend, and adjacent to Southend airport offers a
major opportunity for inward investment which can
be maximised through growth in the right locations.
At a regional level, Rochford’s location within the
Thames Estuary Growth Corridor, along with the
proximity to London and the Lower Thames Crossing
makes this area an economically competitive area
attractive to inward investment. The development
of this region is a national priority as reaffirmed in
the Government’s Response to the Thames Estuary
Growth Commission.
Moreover, planning for growth at scale will leverage
investment in order to deliver new and upgrade
existing infrastructure in the district. Given the extent of land under the control of Bellway it is considered that significant environmental enhancements can be achieved.

b) ensure that their size and location will support a sustainable community, with sufficient access to services and employment opportunities within the development itself (without expecting an unrealistic level of self-containment), or in larger towns to which there is good access;
The proposals provide for four distinct neighbourhoods which are specifically designed to be of a scale so that they are self-sufficient in terms of local services centred on the principle of 15-minute neighbourhoods. There is a swathe of land close to the airport and the existing industrial estates identified for employment uses, and in
addition each neighbourhood will include local employment.

c) set clear expectations for the quality of the places to be created and how this can be maintained (such as by following Garden City principles); and ensure that appropriate tools such as masterplans and design guides or codes are used to secure a variety of well-designed
and beautiful homes to meet the needs of different groups in the community;
Design is key in order to deliver upon the vision of
creating high quality aspirational housing which benefits from the unique location of the site. The Growth Option 3b will be based upon a holistic masterplan framework which establishes a range of different character areas and is genuinely landscape led.
The proposal will deliver a range of housing to achieve diversification in accordance with the recommendations of the Letwin Review including:
ƒ Differing Tenures - Affordable homes; including
affordable rented housing will be provided alongside affordable home ownership on each phase.
ƒ House type and size – Within each phase a broad
range of house types and sizes will be delivered.
ƒ Housing for specified groups and custom build – older people’s housing and plots sold for custom or self-build for individuals on Rochford’s self-build register will also be delivered. Student accommodation will also be explored.

d) make a realistic assessment of likely rates of delivery, given the lead-in times for large scale sites, and identify opportunities for supporting rapid implementation (such as through joint ventures or locally-led development
corporations)
The footnote (37) linked to this policy states ‘The
delivery of large scale developments may need to extend beyond an individual plan period, and the associated infrastructure requirements may not be capable of being identified fully at the outset. Anticipated rates of delivery and infrastructure requirements should, therefore, be kept under review and reflected as policies are updated’

The main factor influencing delivery rates will be the
delivery and funding of infrastructure. There are
significant infrastructure requirements needed in order to deliver growth in the District which will have implications on the housing delivery rates. Bellway are keen to collaborate further with the Council in this respect in order to establish the funding and timing of infrastructure which will address existing congestion issues in Rochford and the environs and unlock growth to the east.

e) consider whether it is appropriate to establish Green Belt around or adjoining new developments of significant size.

As detailed in the illustrative concept plans, the proposals will be designed based on defensible boundaries, logically defined by the landscape framework

VITALITY OF RURAL COMMUNITIES
2.10. The updated Framework at Para 79 states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities.
Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.
2.11. There are a range of existing rural communities in the vicinity of the proposed growth option. The emerging Masterplan and all future proposals will ensure that the character and identity of these existing settlements is retained, while also delivering new infrastructure and services which will be of benefit to the established rural communities. These existing communities do not currently have a genuine choice in terms of travel option, with the private car for many people the only form of transport available. The Local Plan, and the proposals for large scale growth, have the potential to address this through substantial investment in public transport in the district.
2.12. 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.
2.13. 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 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.

DUTY TO COOPERATE
2.14. The Framework restates that planning authorities are under a duty to cooperate with each other, and with other prescribed bodies, on strategic matters that cross administrative boundaries.
Strategic policy-making authorities should collaborate to identify the relevant strategic matters which they need to address in their plans. Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively
prepared and justified strategy. It is evident that there has been close collaboration between RDC and SSBC in the preparation of the evidence base supporting the Local Plans to date which is welcomed.
2.15. In particular, joint working should help to determine where additional infrastructure is necessary, and whether development needs that cannot be met wholly within a particular plan area could be met elsewhere. In order to demonstrate effective and on-going joint working, strategic policymaking authorities should prepare and maintain one or more statements of common ground, documenting the cross-boundary matters being addressed and progress in cooperating to address these.
2.16. The Framework at para 128 requires Planning Authorities to prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences. Design guides and codes provide a local framework for creating beautiful and distinctive places with a consistent and high quality
standard of design.
2.17. National policy in respect of design has been detailed further at Para 129 of the Framework which
states that:
“Design guides and codes can be prepared at an area-wide, neighbourhood or site specific scale, and to carry weight in decision-making should be produced either as part of a plan or as supplementary planning documents. Landowners and developers may contribute to these
exercises, but may also choose to prepare design codes in support of a planning application for sites they wish to develop”.
2.18. The requirement for design codes is considered at Section 8 of these representations.

03. REGIONAL POLICY MATTERS – CONTEXT FOR GROWTH.

INTRODUCTION
3.1. The Association of South Essex Local Authorities entered into a Memorandum of Understanding (January 2018) setting out their commitment to build on the existing strong foundations of cooperation developed through the Duty to Cooperate, and within the wider context of the South Essex 2050 Ambition to move to a more formal approach to strategic planning. This will
be developed through a ‘portfolio’ of plans, with a Joint Strategic Plan (JSP) setting out strategic spatial and infrastructure priorities that are of mutual benefit, prepared alongside a suite of ‘local delivery plans’ to manage delivery within each of the local planning areas. As detailed at Figure 6 of the RDC Spatial Options Consultation, the South Essex Plan is a non-statutory Framework which sits above the Rochford Local Plan.
3.2. The JSP will provide the ‘effective strategic planning mechanism’ to ensure compliance with the requirements of the Duty to Cooperate, with the existing joint work, evidence base and shared governance through ASELA demonstrating that cooperation is proactive, positive and ongoing.
There is a clear commitment to meeting the full housing needs across the sub-region. ASELA have confirmed that they are committed to work collectively in the interests of South Essex detailing that the “joint spatial plan will provide a strong framework to build on and deliver the sound individual local plans and provide the future strategic context for them”.
3.3. The ASELA Productivity Strategy provides a framework for addressing some of the challenges
across the region, outlining that the future of work is changing and higher-skilled, knowledgebased work will drive future economic activity. It sets out opportunities to attract, retain and develop highly skilled knowledge workers, including through skills development; encourages B2B collaboration and development of local supply chains; and identifies opportunities to use data and leverage connectivity to grow the economy through both growth of indigenous SME businesses and attracting inward investment. It emphasises the importance of town centres as centres for economic activity which offer a rich social experience and space for interaction and can accommodate a range of economic activities.
SOUTH EAST ESSEX STRATEGIC GROWTH LOCATIONS ASSESSMENT 2019
3.4. RDC, SSBC and Castle Point Borough Council (CPBC) have worked together to consider potential spatial options for future strategic scale residential development, jobs and supporting infrastructure. The South East Essex Strategic Growth Locations Assessment has considered and assessed six broad locations of undeveloped land adjoining the built-up area of Southend and considered their potential to accommodate strategic scale development of approximately 6,000 – 8,000 homes, together with employment and supporting infrastructure. The report
considered six broad locations, Sectors A-F and identified that only Sector D has the potential to
accommodate strategic scale development. Option 3 b sits within the Sector D area.
3.5. The Plan’s evidence thus identifies Sector D – land north of Fossetts Farm, Garon Park and Bournes Green Chase - as the only area in Rochford which adjoins Southend’s urban area which offered the potential for strategic scale development. This area was found to have the least environmental constraints. The landscape was found to be of medium sensitivity, and development
would need to have regard to this as well as listed buildings and heritage assets in the area.
3.6. The Assessment found that significant investment in public transport, road and cycling infrastructure would be needed to support sustainable development. This included congestion concerns along the A127 and at Warners Bridge. It found synergies with nearby employment locations and existing recreational resources including around Garons Park. Major development would need to avoid coalescence with Rochford and maintain a buffer to the villages of Barling, Little Wakering and Great Wakering to the east.

SOUTH ESSEX STRATEGIC GROWTH LOCATIONS STUDY 2020
3.7. The 2020 South Essex Strategic Growth Locations Study1 reinforces the findings of the 2019 study, which has undertaken a strategic review of land availability and development constraints across South Essex and considered potential locations where urban extensions and new settlement-scale growth could be explored. This Study has assessed the potential for urban extensions to each of the District’s main settlements - Hockley, Rayleigh and Rochford – as well as Southend; together with the potential for new-settlement scale growth north-east of Southend and at Fairglen where the A127, A13 and A130 join.
3.8. The Study shows that transport infrastructure capacity is a particular constraint to growth at a sub-regional level with a highways network largely at capacity at peak times. An appropriate response to this is to locate growth at accessible locations, preferably where there is fixed public transport and this is a key component of the ‘sequential approach’ adopted in the Study to identifying potential locations for strategic scale growth. The Study includes an assessment of the relative accessibility of different options, having regard to proximity to major routes and local congestion; and public transport accessibility. Hockley scores poorly, and Rayleigh is moderate in this respect; while Rochford and Southend together with the potential for strategic growth south east of Rochford are identified as having good accessibility. Fairglen is identified as having very poor accessibility by public transport currently and would require delivery of a new station to support strategic development.
3.9. The Study concludes that the best scope in the medium term is for strategic growth at Southend North East and West Horndon. This reflects the less constrained nature of these locations relative to other areas considered and the greater potential for sustainable access even in the short to medium term. This issue of sustainable access is critical given the constrained nature of the existing highway network in South Essex and the fact that strategic growth must have viable non-car access. There are however still significant challenges in these locations, including the requirement for substantial supporting infrastructure and further studies are required.

GOVERNMENT RESPONSE TO THE THAMES ESTUARY 2050 GROWTH COMMISSION 2019
3.10. In the Budget 2016 the Government asked the Thames Estuary 2050 Growth Commission to set out an ambitious vision and delivery plan for North Kent, South Essex and East London. The Thames Estuary 2050 Growth Commission published their report on 25th June 2018. In the response published on the 25th March 2019, the government welcomed the Commission’s vision, and sets out national commitments to the Thames Estuary.
3.11. The government’s response is a clear demonstration of the commitment to growth in the Thames Estuary and identifies that this is a national priority which is of importance to all of the United
Kingdom. The response acknowledges the tremendous potential of the Thames Estuary to power growth for the benefit of local communities and the entire country. It highlights however that the region does not fully deliver on its great potential and “A bolder approach is needed to realise this vision and the potential of the region”.
3.12. In addition, the Government agrees with the Commission that the scale and pace of delivery will need to increase to meet demand for housing across the Estuary. The report further states that the Government is prepared to offer bespoke support through initiatives such as housing deals, to support those places willing to be ambitious in their approach to building more homes.
Government would expect places across the region might want to go further in order to take account of higher demand and fully enable them to meet their economic growth ambitions.
3.13. This report wholeheartedly confirms the Government’s commitment to this region. The Local
Plan has the opportunity to utilise this support from a national level to ensure that the region fulfils its full potential in terms of new homes and jobs through a plan-led approach. This is an unprecedented opportunity for the region and RDC must capitalise on this to ensure they fulfil their ambitions.
3.14. Rochford is located within the South Essex Foreshore, and within this context the Commission’s
vision for the area is :
“The rich patchwork of places which form the South Essex Foreshore will be celebrated. Empowered by a statutory Joint Spatial Plan the area will go beyond ‘business as usual’. Locally driven town centre transformation will help create lively places that people choose to work, live, learn and play in. These policies and local initiatives will see development unlocked, postindustrial landscapes restored, and the filling of empty business spaces to create a thriving and
creative economy”.
3.15. This vision aligns with the positive approach outlined in the RDC Spatial Options which states that “The scale of housing growth required in Rochford presents opportunities to do things very differently and harness much greater investment in infrastructure than has been possible before”

04. REGIONAL POLICY MATTERS – CONTEXT FOR GROWTH.
Current Situation
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.
Future Housing Needs & Supply
4.3. Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040 in RDC. 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. The emerging evidence provides a strong indication that SSBC will not be able to meet its development needs for housing and employment in full within its borough boundaries.
Southend has a constrained supply of land which also limits its ability to deliver family housing.
Given the close-relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services between the two authorities, the Council 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.

[SEE ATTACHED DOCUMENT FOR ORIGINAL DIAGRAM OF ROCHFORD HOUSING CRISIS]
- Average house price in Rochford 2021: £426,000 (12% increase since 2020)
- House price growth 2011-21: £136,000
- House prices 11.5 times average earnings. Amongst the least affordable areas in the country
- Average rents grown 18% over last 5 years
- 1,000 households awaiting affordable housing in 2021 (grown by 20%)
- Average housing delivery 205 dwellings per annum (2011 – 2021)

4.6. In this respect, the Planning Practice Guidance provides clarification on the standard method
reiterating that it provides the minimum starting point and details the circumstances actual housing need is higher than the standard method indicates, stating:
Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in
place to promote and facilitate additional growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground.
3.7. 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 4,500 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.
[SEE ATTACHED DOCUMENT FOR TABLE COMPARING LAND SUPPLY TO HOUSING NEED]

4.8. Available and suitable land for housing in Rochford is scarce, with the majority of open land being
designated as Metropolitan Green Belt, extending from London across the South Essex subregion. Significant parts of the District are also protected for their ecological value, landscape value or because they are at risk of flooding.

ECONOMY
4.9. As with many other areas across the country and internationally, Rochford’s economy has been harmed by the Covid-19 pandemic. The Local Plan needs to set out a strategy for economic recovery.
4.10. Prior to the pandemic, the evidence pointed to :
ƒ a relatively modest-sized economy with 29,000 workforce jobs based in the District (2018).
ƒ The percentage of jobs available per resident is much lower than the national average, leading to a greater reliance on out-commuting for our residents and leakage of spending and investment
ƒ Significant out-commuting of residents to work, totalling over 14,000 people per day in net terms, both to surrounding employment centres such as Southend and Basildon and to London.
ƒ Self-employment had been growing, reaching almost 16% of working-age residents.
ƒ Local employment opportunities were focused more towards lower paid/skilled roles, with the proportion of residents with NVQ 4+ skills (equivalent to degree level) below the regional average, and an under-representation in higher value-added sectors borne out in average earnings for those employed in the District which were around 7% below the East of England average.
OFFICE AND INDUSTRIAL ACTIVITIES
4.11. The 2017 South Essex Economic Development Needs Assessment (EDNA) identified a need for 27 ha of employment land across Southend and Rochford to 2036. Quantitatively it identified sufficient supply to meet this. The evidence base will need to be updated to reflect changes in economic circumstances and the longer plan period. However it is likely that some additional
employment land provision is needed in the local area to support growth in local SME businesses in manufacturing, construction, trades and related sectors including in providing grow-on space; and to contribute to addressing the significant out-commuting from the District. National planning policy and guidance is clear that both quantitative and qualitative factors should be
considered in considering employment land provision.
4.12. The Covid-19 pandemic and associated lockdowns have ushered an unprecedented change in the way people work, almost overnight. The Local Plan needs to facilitate these changes by providing opportunities to work more locally for those that might have historically commuted out to work, and ensuring high quality broadband infrastructure is in place.

[See document for original diagram re benefits of meeting housing need]
- Delivering affordable housing
- Family housing for local people
-Supporting the local economy
- Supporting funding and delivery of infrastructure
- Supporting town centres
- Supporting public services

RETAIL AND LEISURE
4.13. Rochford District’s main retail provision is within the centres of Rayleigh, Rochford and Hockley.
However, none of these are major classified centres and Rochford achieves a very low market share of retail provision in comparison to the rest of South Essex. In particular, retail expenditure for comparison goods is generally lower in the District than it is for convenience goods, demonstrating that residents will often do their regular shopping (such as food) more locally but travel to other commercial centres, such as Southend, for comparison retail shopping such as for household items, electrical goods and clothes.
4.14. The Retail and Leisure Study Update 2014 recommended that the District seek to increase the
market share of comparison retail to a minimum maintain market share in South Essex. The South Essex Retail Study 2017 sets out that the District would benefit from further retail provision to promote sustainable shopping patterns, with retail provision aligned new housing growth.

E-commerce had been growing before the pandemic, but Covid-19 is likely to have accelerated this, and this is a particular challenge for the District’s town centres which therefore need to evolve. Housing growth within the District together with an evolution of the town centres’ offer will be important to supporting the vitality and viability of the District’s town centres.
TOURIST ECONOMY
4.15. The tourism economy in Rochford District is currently underdeveloped – there is a lack of infrastructure such as quality accommodation, restaurants and cafes, visitor attractions and activities. The District has a distinctive character – it benefits from a world-class natural environment with internationally significant estuaries, namely the Crouch and Roach and an extensive coastline, including the RSPB’s Wallasea Island Wild Coast Project. These geographical features give rise to the potential to explore opportunities to promote tourism, particularly a green tourism offer. Rochford also has a range of heritage assets with untapped potential.
4.16. The Tourism, Leisure and Recreation Strategy for South Essex 2020-2038 sets a vision “to make South Essex a renowned major tourism destination comprising a corridor of quality interrelated tourism, leisure and recreation attractions. An expanded visitor offer will
encourage people to stay and enjoy our culture, resorts, countryside, market towns and coastline. In turn this will add to the area’s vibrancy and make us a more attractive place to live, work and start up a business”.
4.17. It identifies that there are some structural weaknesses that exist, such as the lack of a ‘stand out’
single attractions. A key conclusion that is drawn is that there is a number of exciting and attainable opportunities which can be the focus of future strategic action. This would help the area to bounce back from Covid-19 and reposition the area in the domestic visitor market.
4.18. There is a clear opportunity for the District to increase the value of the tourism economy over the
Local Plan period in the following ways:
ƒ increasing visitor spending by providing high-quality facilities and attractions and supporting infrastructure;
ƒ increasing the number of linked trips to Southend and other locations in South Essex;
ƒ converting a proportion of day trippers into overnight stays;
ƒ increasing the share of holiday makers as opposed to people visiting friends and relatives;
ƒ Capitalising on the ‘staycation’ market;
ƒ capturing the untapped potential of the district’s assets, including the historic environment, the countryside and coast; and
ƒ developing the business tourism offer and overseas visitors to capture this higher value market segment linked to London Southend Airport.
4.19. The Tourism, Leisure and Recreation Strategy for South Essex outlines objectives to provide a planning framework to facilitate development, including co-ordinating the development of appropriate Local Plans that support the development of tourism, leisure and recreation. The preparation of the Rochford Local Plan provides an appropriate basis for achieving this.

ECONOMIC POTENTIAL OF OPTION 3B
4.20. Our economic analysis points to the following opportunities:
ƒ The local economy across Southend and Rochford is structured around the delivery of goods and services to local people and visitors. The economic strategy for the Option 3b will tie into this, and deliver job opportunities in everyday services, health and education on site, but also recognise and encourage spending from residents on shops and services in Rochford Town Centre.
ƒ Southend Airport is also an important local employment driver in the medium-to-long term,
with potential growth of both direct jobs on site and in the supply chain and aviation-related activities in the surrounding area. There is a good spatial relationship to this.
ƒ The scale of the development opportunity provides an opportunity for transformational change and can act as a major economic driver in its own right. The scheme will support sizeable population growth creating demand for goods and services within the local economy. It can
deliver employment in traditional employment space, support home-based working, and create/support employment opportunities in health, education and local services.
ƒ If the scale of development is comprehensively considered, there is a strategic opportunity to shift the skills and jobs profile towards higher value-added activities. Delivery of high-quality housing, with space to work, and better employment opportunities have the ability to attract higher paid/ earning individuals to avail of the benefits of coastal life.
ƒ Self-employment in the area is high and has been growing. There are many small business and self-employed enterprises in the area. The office market is focused on local SME occupiers.
Local centres within the scheme should be designed in a way in which they can accommodate flexible workspace in local work hubs which can cater for local micro-businesses, can provide workspaces for people that might commute into London less or who work principally at/ hear home. Provision of high-quality broadband and telecommunications infrastructure will also be key to supporting this and facilitating the growing trend in home working. As working patterns change as a result of Covid and technological improvements, there is a major opportunity to create an attractive residential environment with local workspace which responds to this.
ƒ There is a concentration of industrial space in the area with low current vacancy levels. There is a strong relationship between the site and existing key employment and industrial sites in the local area, including Purdeys Industrial Estate, Temple Farm, Stock Road, Rochford Business Park and the Airport Business Park. There are opportunities to deliver high quality connections to these.
ƒ The development offers potential to help diversify the area’s visitor / tourism offer and to increase tourism spend, including in exploring the potential of the River Roach, provision of a high-quality hotel and/or visitor resort offer.
ƒ There is a good opportunity to deliver different types of housing, including: family housing both market and affordable, specialist/ embryonic sectors, Build to Rent, third age living including a range of care products and the self-build sector. Diversity in the housing offer, and recognition of the relative role of growth here vis-à-vis what is delivered within the urban area (focused more on higher density / smaller units), is important to supporting overall housing delivery rates, a balanced population profile and attracting higher skilled/ earning households.

05. STRATEGIC MATTERS IN LOCAL PLAN MAKING.
5.1. The Framework at para 11 requires Plans to 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:
1. meet the development needs of their area;
2. align growth and infrastructure;
3. improve the environment;
4. mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
5.2. This section of the representations considers these strategic matters in a Rochford context and considers how growth on land south east of Rochford and north of Southend will assist RDC in delivering a sustainable pattern of development.
MEETING THE DEVELOPMENT NEEDS OF THEIR AREA
5.3. RDC propose to take a positive approach to growth locally, help 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 that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
5.4. These representations wholly endorse Strategy Option 3: Concentrated growth » Option 3b: Focused north of Southend which lies within our client’s land interests. It is not purported however that this strategy will meet Rochford’s full housing need over the lifetime of the Plan, thus Strategy Option 4: Balanced Combination is the preferred approach. The Consultation states that
Option 4 could make best use of urban capacity (Option 1), building one or two large growth areas (Option 3) and a number of smaller urban extensions (Option 2).We support Option 4 which will provide a varied supply of sites to make the local housing market as diverse as possible delivering a range of choice and competition to the market, thus offering the greatest chance that housing will be consistently delivered over the whole plan period. Crucially the Plan needs to incorporate large scale strategic growth, as a Local Plan strategy that relies solely on smaller sites, or sites spread more evenly through the District will not have the potential to fund new infrastructure and provide betterment to the current challenges facing the District.
5.5. It is submitted that in order to deliver the ambitions of the Local Plan, large scale growth focused in one location as per Option 3b is required. Strategic growth at this location is embedded within the evidence base which supports this Local Plan including the South East Essex Strategic Growth Locations Assessment (2019) and the South Essex Strategic Growth Locations Study (2020).
5.6. Option 3 b is the only option which will:
ƒ Provide the “critical mass” needed to secure transformational new infrastructure to mitigate the impact of future development and critically to address the chronic congestion currently experienced within the District
ƒ improve affordability
ƒ address the decline in home ownership
ƒ support a sustainable shift towards higher wage/skilled jobs.
5.7. The Government have also been clear in their funding decisions that they will help fund infrastructure
where it is supporting their growth ambitions. Option 3b will make a substantive positive contribution to the Government’s ambitions for growth across the Thames Estuary Area. The Government’s Response to the Thames Estuary Growth Commission (HM Government, March 2019) states that it will support regeneration and growth within the area through a range of measures, including negotiating Housing and Infrastructure Deals with groups of ambitious local authorities. Option 3b provides the greatest potential to capture funding through such deals.
ALIGN GROWTH AND INFRASTRUCTURE
5.8. The Council’s previous engagement with local communities has identified the need for improvements to services and utilities, supporting local employment opportunities, development sustainable transport options, and improvements to strategic infrastructure as key community concerns alongside concerns regarding the number of homes. Strategic growth provides an
opportunity to address these issues. The vision for land south east of Rochford and north of Southend is that the development brings positive benefits to all residents including through the delivery of new infrastructure for sport, recreation and leisure; the provision of new high quality employment opportunities; and in supporting the delivery of strategic transport infrastructure which helps to improve accessibility across the area including addressing existing congestion bottlenecks in Southend and Rochford and delivering new high quality public transport links and opportunities for walking and cycling.
5.9. The Planning Practice Guidance requires Authorities in Plan-making to set out a positive vision for the area, but the plan should also be realistic about what can be achieved and when. This means paying careful attention to providing an adequate supply of land, identifying what infrastructure is required and how it can be funded and brought forward. A collaborative approach is expected to
be taken to identifying infrastructure deficits and requirements, and opportunities for addressing
them. In doing so they will need to:
assess the quality and capacity of infrastructure, and its ability to meet forecast demands.
Where deficiencies are identified, policies should set out how those deficiencies will be addressed; and
ƒ take account of the need for strategic infrastructure, including nationally significant infrastructure, within their areas.
5.10. The government recommends that when preparing a plan strategic policy-making authorities use available evidence of infrastructure requirements to prepare an Infrastructure Funding Statement. Where plans are looking to plan for longer term growth such as significant extensions to existing villages and towns, it is recognised that there may not be certainty and/or the funding secured for necessary strategic infrastructure at the time the plan is produced. In these circumstances strategic policy-making authorities will be expected to demonstrate that there is a reasonable prospect that the proposals can be developed within the timescales envisaged.
Our client is keen to work with the Council and their appointed consultants in respect of the infrastructure requirements for growth Option 3b to accommodate future growth, and crucially ensuring betterment for the existing residents in the district.
Genuine choice of transport modes
5.11. Rochford’s peninsula location creates issues for connectivity with relatively limited sustainable travel options available, particularly north-south, leading to notable congestion along key roads. Given the existing level of traffic within the District and how this affects the road network, future strategic highway decisions and plans must consider how changes in working habits and future technology can help promote innovative but realistic transport solutions.
5.12. It is essential that public transport connections to the stations and key employment locations in the sub-region are improved to provide realistic and viable option to residents from commuting and other journeys. This can help reduce congestion. In addition, whilst there are a number of existing cycle routes within the District, these routes are often found in isolation. Whilst there are routes along Ashingdon Road, Hall Road and Cherry Orchard Way, these are not continuous. Future investment should look to ensure integration and improvement of existing cycle routes where possible and ensure cycling is considered as a key mode of travel from the outset.
5.13. The District cannot however be considered in isolation and the continued expansion of development in the adjoining Southend Borough has led to an increased propensity for vehicles to find alternative routes to the A127 (A1159), often resulting in growing pressures on Rochford’s own network. The Authorities will need to work collaboratively to address these issues - ensuring
unnecessary trips on the network are removed and essential trips are accommodated along appropriate existing or new infrastructure.
5.14. The concept of ’15 minute neighbourhoods’ can help to achieve this. These are based on ensuring that residents to access the majority of their day-to-day needs – such as everyday shops, schools, medical facilities, pubs, cafes and leisure opportunities - within a 15-minute walk or cycle. This has been shown to build sustainable communities and reduce private car use throughout the world.
5.15. Future communities proposed on land south east of Rochford and north of Southend will be designed to encourage cycling and walking by promoting 15-minute neighbourhoods and ensuring high-quality cycle networks are provided to link up with both existing communities’ and other future communities. This integration is key to help promote active travel. For locations and routes where high levels of cycle use are expected, green corridors for example, we will look to promote segregated spaces for other cyclists and pedestrians to ensure safety and encourage active travel.
5.16. Consideration will also be given to how other forms of powered micro-mobility can be promoted such as, e-scooters or powered skateboards. The Council is keen to lead the way with new technological solutions and ensure developments have electric charging for not only for
vehicles, but the bicycle, moped and e-scooters. This might include a new e-scooter and e-bike hire scheme in Rochford and Rayleigh which could take the form of autonomous e-scooters, improving the efficiency of their operation.
A New Travel Corridor Network
5.17. A key constraint that is recognised in the transport evidence is that despite the sustainability imperative to reduce car use, local people continue to use their car for short journeys and tolerate the time lost in congestion. It appears there is a general resident’s desire locally to continue using their cars for most journeys and expected new infrastructure that supports it.
5.18. The local network is currently congested. Access by car is broadly restricted geographically to the west along the A13 and A127. Once these routes penetrate the borough boundary, they quickly become congested. This has resulted in rat-running, even for local journeys. Capacity improvements have taken place along the A127 which include improvements to Progress Road, Kent Elms, Tesco roundabout and Cuckoo Corner. Works are currently underway at the Bell House Junction. The distribution of employment zones in the area has contributed to congestion and created a poor environment for pedestrians and cyclists.
5.19. Rochford is formed of a number of towns, villages and standalone employment locations. Improving the east-west connections will not only help those leaving the District as part of their commute but will also ensure that existing businesses within the District are seen as viable
locations for employees.
5.20. It is also important to optimise the opportunities associated with London Southend Airport as an
economic driver and a rail station. It is essential that surface access and access to both the local and strategic highway network is improved. By doing this, the Airport can help support economic growth in both the district and the wider South Essex area. To help achieve this access to the station from the east will be required.
5.21. Strategy Option 3b will deliver strategic infrastructure improvements alongside growth including improved eastern access to London Southend Airport Rail Station, Temple Farm and Purdeys Industrial Estates, and address congestion pinch points including Bell House Junction, Priory Crescent and Warners Bridge. Strategic growth will enable the delivery of a new green, sustainable transport corridor providing a link between the two train lines Southend Airport and
Thorpe Bay.
5.22. If strategic growth is delivered between Southend and Rochford, changing the design characteristics of infrastructure from what has previously been provided is key to delivering a solution that fits both travel behaviours now and in the future. Through a forward-thinking
approach we ensure that any hard infrastructure provided in the District cannot only make use of new technologies as they become available but are also not held back by building solely for the problems at the time. For example, in the short term, a green corridor could be formed of a
two-lane dual carriageway. However, as working behaviours move towards a more home-based approach or as more local employment opportunities become available, the need for two-lanes will be reduced. As such, one lane in each direction could be converted to a bus lane.

IMPROVE THE ENVIRONMENT
5.23. In the recently updated Framework, the environmental objective wording has been strengthened
with a requirement to ‘protect and enhance’ the environment and ‘improve biodiversity’. The key issue for consideration is crucially how the proposals will protect and enhance the environment.
5.24. By way of context, over 70% of Rochford is designated Metropolitan Green Belt with over 15%
protected for its biodiversity value. The subject landholding south east of Rochford and north of Southend lies within the Green Belt but is not covered by any statutory environmental designations. The River Roach lies to the north and is designated as a Site of Special Scientific Interest, a Special Area of conservation and Special Protection Area; with land in this northern
part of the area falling within Flood Zones 2 and 3.
South Essex Estuary Park
5.25. The RDC Open Space Study 2020 revealed that the current quantity provision of all open spaces in the District is at 8ha per 1,000 people. This falls below the Fields in Trust benchmark. This provides a further opportunity for the new Local Plan to address this shortfall of which the proposals for the South Essex Estuary Park are integral to.
5.26. The South Essex Strategic Green and Blue Infrastructure Study (2020) was prepared on behalf of
ASELA and sets out a vision for green and blue infrastructure across South Essex and provides high-level objectives, strategic opportunities and policies driven by a co-ordinated approach.
The Study defines an integrated green and blue network, that will provide multiple benefits and which merits prioritisation and significant investment as well as defining a spatial arrangement to create the South Essex Estuary Park (SEE Park) - a network of green and blue assets across the
region. Growth Options 3 b have the potential to deliver the eastern extent of the SEE Park.
5.27. Figure 5.1 extracted from the Green and Blue Infrastructure Study shows indicative opportunities
which could help to deliver a regional green and blue infrastructure resource. Island Wetlands is identified as one of these landscapes, as shown below, which extends from Wallasea Island to Southend. Initiatives around Wallasea Island will create a large wetland nature park, with designated areas accessible to people. The southern part of the park shown - closer to Southend – indicates the potential for the creation of green corridors linking urban areas, the countryside and coast and
providing much needed green open space for existing and future residents. The proposal could contribute towards delivering these ambitions. The ambitions for the green and blue infrastructure need to be aligned with the growth options to maximise the benefits that can arise.
5.28. Figure 5.2 details our interpretation of the ambitions for the parkland and how the strategic blue and green infrastructure will influence the design of the growth option south east of Rochford and north of Southend.
Figure 5.1 Sub-Regional Green and Blue Infrastructure Study – Indicative Opportunities [SEE DOCUMENT FOR MAP]
Biodiversity Net Gain
5.29. The proposals will maximise opportunities to enhance and protect local ecosystems and green
infrastructure will be exploited to achieve a minimum 10% biodiversity net gain. This will ensure that biodiversity is improved across the District through new development, minimising incumbent losses and restoring ecological networks.
Figure 5.2 Indicative proposals for strategic green and blue infrastructure on land east of Rochford and north of Southend [SEE DOCUMENT FOR IMAGE]
MITIGATE CLIMATE CHANGE AND ADAPT TO ITS EFFECTS
Active Travel
5.30. It is no secret that the emissions generated by fossil fuel-based vehicles are contributing climate change. The Local Plan should guide development and investment in the District to supports the Government’s target of reaching net-zero carbon emissions by 2050, as well as the Association of South Essex Local Authorities (ASELA) aim to be carbon neutral by 2040. To help meet these targets, Rochford must show leadership in promoting the use of electric cars and buses to its
residents and encouraging growth of active travel.
5.31. We are also on the brink of a new transport revolution, with numerous technologies coming forward - in both the short, medium and long term - each having their own impact of personal travel options. It is therefore important to consider how travel will change over the plan period. In recent years, many residents have commuted to work 3-5 days a week using a fossil fuel burning vehicle, however, by the end of the plan period, residents might only commute to work twice a week (with a 60% reduction in capacity demand); use electric vehicles, which could in time be self-driving; or make use of a high-quality public transport option. It is clear that the technological and transport solutions to accommodate likely travel behaviours at the start of the plan will not match those at the end of the plan in 2040. Getting this aspect of future development wrong could lead to large roads being built that are far too big for the expected travel patterns at the end of the plan period and we are left with huge barriers, severing communities unnecessarily.
Building Design
5.32. The National Housing Federation states England’s homes produce more carbon emissions every year than all the country’s cars thus decarbonising housing is an urgent priority. At a building level, this means designing buildings with highly efficient building fabric to reduce demand for energy and associated energy bills. Bellway’s homes will aim to be fossil fuel free where possible, using
innovative and renewable forms of energy production and storage to make the most of the UK’s increasingly decarbonised electricity supply.
5.33. Building homes with a ‘fabric first’ approach means high levels of insulation, reduced air permeability and reduced cold bridging, and uses passive design to retain heat within buildings by minimising losses to the outside. This is the basis of the PassivHaus scheme, which has been shown to result in homes with very low levels of energy demand due to good passive design to minimise heat loss. The benefits of this approach to design include low heating bills, reduced risk of obsolescence, not
having to retrofit to improve insulation levels and homes that are futureproof.
5.34. Where appropriate, waste heat from industrial processes can provide heating for new and existing homes, making the most of our existing energy resources. Opportunities to partner with industry to generate renewable electricity at scale on suitable sites across the District will also be explored, meeting wider climate change objectives and providing an income to the Council.
Alternative Fuels
5.35. There are opportunities to make use of sustainable hydrogen, either for building heating or vehicle
transportation. Hydrogen has the potential to partially replace natural gas within our existing gas infrastructure. Although the majority of current hydrogen production methods are not sustainable, the growing levels of renewable electricity in the national grid mix will mean that sustainable hydrogen can be produced more widely in suitable locations throughout the country.
Lifestyle
5.36. New and innovative technology will play its part in helping to decarbonise Rochford. However we also need to help our residents to live more sustainably, by demonstrating that sustainable lifestyles lead to better quality of life. By encouraging people to participate in active travel, walking and cycling where possible, residents will see benefits to their health and wellbeing. Local air quality will be improved. Our roads will be safer. We will get to know our neighbours better.
5.37. Taking account of the District’s rural character, consideration can also be given to the use of land for sustainable food production. This could vary from the provision of allotments by residents to grow their own food to the use of new, innovative farming techniques, such as vertical farming which maximises food production on a smaller footprint.

06. LANDSCAPE & GREEN BELT EVIDENCE BASE.
6.1. In order to meeting minimum housing needs, RDC will need to release land from the Green Belt.
Rationale for Strategic Green Belt Release
The evidence base indicates that Strategic Green Belt release is required through the preparation of Rochford’s Local Plan as:
ƒ Meeting development needs is an important component of achieving sustainable development – the key aim of the planning system. The evidence shows that this cannot be achieved across the sub-region without reviewing Green Belt boundaries. The aim of Green Belt policy is not to restrict meeting development needs. It is to direct development to sustainable locations;
ƒ Green Belt release is required to meet the identified local need for market and affordable housing and improve housing affordability, a key feature of Government policy, as well as to deliver family housing – the need for which is not being met through urban sites in the sub-region;
ƒ Strategic growth is required to support economic recovery and sustainable economic growth – key policy ambitions at a national, sub-regional and local level. It will support growth in the workforce, attract skilled workers and attract higher paid employment
opportunities as identified in the ASELA Productivity Strategy.
ƒ The evidence base identifies key infrastructure deficiencies. Strategic growth will support the funding and delivery of strategic infrastructure including transport infrastructure to promote more sustainable travel and address existing congestion.
ƒ It is appropriate that consideration is given to meeting unmet need from Southend in locations which have a strong spatial and functional relationship to in a context in which there are strategic constraints to development at a sub-regional level.
6.2. The Joint Green Belt Study (February 2020), covering Rochford and Southend, assesses the
performance of Green Belt land in meeting the purposes of Green Belt. The strongest performing Green Belt is land within the Upper Roach Valley between Rayleigh, Thundersley and Southend. Only small areas of land on the urban fringe are identified as having a low performance against Green Belt purposes. These areas of land alone will not provide sufficient land to meet development needs;
indicating a need to consider land with one or two strong ratings against Green Belt purposes.
6.3. The south-eastern part of the Green Belt – adjoining the urban boundary with Southend - has two strong ratings, which is likely a reflection of its purpose to prevent urban spawl. It should not be assumed that a site that weakly contributes to the Green Belt is automatically a good candidate for development, nor that a site which strongly contributes to the Green Belt is automatically a poor candidate for development. In making decisions regarding Green Belt release, performance against
Green Belt purposes however needs to be considered alongside wider factors which influence what
constitutes sustainable development – including access to services and employment opportunities.
The purpose of Green Belt is to support sustainable patterns of development.
Figure 6.1: Green Belt Performance – Southend and Rochford
[see attached document for map]
6.4. The area south-east of Rochford which has been identified as a potential strategic growth location falls into parcels AA153-AA158 of Stage 2 of the Green Belt Study. In most scenarios, these parcels are considered to have a high harm if they were to be released from the Green Belt.
There are however some scenarios where if certain smaller parts of this wider area were released, the harm would be reduced to moderate-high. This would only be the case if these smaller parcels were released in isolation.
6.5. Whilst the ideal would be to minimise harm to the Green Belt, it may be that the most sustainable
locations for development will result in high harm to the Green Belt. Conversely, the release of Green Belt land likely to result in low harm may not be appropriate or sustainable. In each location where alterations to Green Belt boundaries are being considered, planning judgement will be required to establish whether the sustainability benefits of Green Belt release and the associated development outweigh the harm to the Green Belt designation.
ROCHFORD AND SOUTHEND LANDSCAPE CHARACTER, SENSITIVITY AND CAPACITY STUDY (2020)
6.6. The Landscape Character, Sensitivity and Capacity Study prepared for Rochford and Southend sets out the value and sensitivity of landscape character areas in the two LPAs and their potential capacity for development to inform strategies for the area.
6.7. The majority of the land at the strategic growth location Option 3b is within the Coastal Farmland Landscape Character Type, specifically parcel C5 (Stonebridge). The landscape value, sensitivity along with the landscape capacity and recommended development scale are detailed in the table below. The Study identifies that this land parcel had medium to high
capacity for development.
Figure 6.2 Landscape Capacity extracted from the RDC Landscape Character Study
[see attached document for map]

[SEE ATTACHED DOCUMENT FOR TABLES DETAILING LANDSCAPE CHARACTER ATTRIBUTES]

07. THE VISION FOR LAND SOUTH EAST OF ROCHFORD / NORTH OF SOUTHEND.

CONTEXT
7.1. The RDC Spatial Option Consultation identifies a number of strategy options that could form the basis of the plan’s approach to growth over the next 20 years and beyond. These representations endorse Strategy Option 3: Concentrated growth » Option 3b: Focused north of Southend.
7.2. As detailed in these representations, Option 3b is required in order to deliver the ambitions of the Local Plan with large scale growth focused in one location which will provide a sufficient critical mass in order to deliver the required infrastructure for the District. Strategic growth at this location is embedded within the evidence base which supports this Local Plan including the South East Essex Strategic Growth Locations Assessment (2019) and the South Essex Strategic
Growth Locations Study (2020).
7.3. This location provides the opportunity to deliver strategic development at scale which includes new homes and employment land, new strategic transport infrastructure, local services and associated community facilities and additional open space and recreational facilities. The strategic rationale for growth is to:
ƒ Contribute to meeting the strategic housing need for market and affordable housing in Rochford and also potentially unmet needs from Southend in a location close to where the need arises;
ƒ Locate growth at a sustainable location close to the concentration of existing employment opportunities at and around London Southend Airport, Temple Farm and Purdeys Industrial Estates, Fossets Way and Gardon Park, to reduce the need to travel and achieve a high
proportion of travel by sustainable modes;
ƒ Provide strategic scale development where housing can be brought forward alongside local employment opportunities, schools, healthcare facilities, local shops and services in line with the principles of 15 minute neighbourhoods in order to reduce the need to travel;
ƒ Deliver concentrated strategic growth which reduces the scale of incremental growth of the District’s existing towns and villages which can place pressure on their local infrastructure and adversely affect their character;
ƒ Enable strategic infrastructure improvements alongside growth including improved eastern access to London Southend Airport Rail Station, Temple Farm and Purdeys Industrial Estates, and address congestion pinch points including Bell House Junction, Priory Crescent and
Warners Bridge.
Figure 7.1: Land South East of Rochford & North of Southend Broad Location for Growth
[SEE ATTACHED DOCUMENT]
THE VISION
7.4. There are a number of themes which have informed the vision for the subject site -
ƒ A sequence of new neighbourhoods – the proposals include four individual, future facing neighbourhoods in Rochford, which contain mixed-use neighbourhood centres and the key community infrastructure and services required to support residents needs and reduce the need to travel, that can be brought forward alongside one another with a distinct identity and character. The character of these neighbourhoods can vary and respond to their location – with new hamlets and villages within Rochford which respond to the morphology of settlements in the area.
ƒ A Connected Place – the neighbourhoods will be physically connected by new green, sustainable transport corridors which also provides a link between the two train lines (Southend Airport and Thorpe Bay) and encourage sustainable transport choices. Proposed infrastructure will also help redress existing capacity constraints on the highways network.
Digital infrastructure is also at the forefront of the strategy to deliver connectivity. The proposals will help to deliver new strategic infrastructure which addresses existing congestion issues along the A127 and A1159 Eastern Avenue;
ƒ A Place with Identity – the proposals seek to identify and establish a character that draws from that of the surrounding context and is informed the existing site features. This involves drawing out local character and distinctive features associated with the area. .
ƒ A Working Place – the proposals are underpinned by an economic strategy to help transform the profile of the local economies, by attracting a more highly skilled demographic looking to locate here as a lifestyle choice, supported by employment floorspace provision.
7.5. This vision reflects the new requirement introduced through the Framework for larger scale developments ‘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 draft policy demonstrates the level of growth that is anticipated during this Local Plan (up to 2040) and also considers the longterm potential of this growth option up to 2050 and beyond. The emerging Masterplan has been
designed as such to allow for the delivery of individual villages which can all be connected in time but equally allowing for the villages to be independent in their own right with sufficient services and infrastructure to meet their needs without reliance on future growth to deliver infrastructure.
DRAFT POLICY: LAND SOUTH EAST OF ROCHFORD & NORTH OF SOUTHEND STRATEGIC
ALLOCATION
Land south east of Rochford, east of London Southend Airport and north of Eastern Avenue is allocated as a cross-boundary strategic growth location with potential to deliver around 10,000 homes on land in both Rochford District and Southend-on-Sea. Mixed-use development is
envisaged to deliver a minimum of 4,600 homes in Rochford District together with necessary community, employment, transport, green and blue infrastructure; of which approximately 1,850 dwellings are expected to be delivered in the plan period to 2040.
Development should include:
ƒ Housing - a minimum of 4,600 homes in Rochford District to including market and affordable housing, specialist housing for older persons, and self- and custom-build homes;
ƒ Employment – around 11 ha of employment land to include provision for flexible commercial floorspace or workspace hubs (Class E) within neighbourhood centres and industrial land located east of London Southend Airport; together with infrastructure to support home working;
ƒ Social and community infrastructure – including provision for local shops and services, multi-use community space, health and education infrastructure to be structured around 15 minute neighbourhood principles;
ƒ Enhanced transport infrastructure – including high quality bus services to key employment locations, town centres and rail stations, high quality infrastructure for walking and cycling and strategic highways infrastructure to enhance east-west connectivity and mitigate impacts.
Development should include a buffer to prevent coalescence with and maintain the separate identities of the settlements of Great Wakering, Little Wakering and Barling.
To guide development a Framework Masterplan SPD should be developed jointly with the Councils, local community, site promoters and infrastructure providers to ensure the comprehensive integrated development of land in both Rochford and Southend and to coordinate the delivery of infrastructure. This Masterplan should include:
ƒ A Green and Blue Infrastructure Strategy providing a coordinated framework for provision of publicly-accessible formal and informal open space, play space and other sport and recreational facilities and provide new green corridors linking the Southend Urban Area to
the River Roach.
ƒ A Transport and Movement Strategy which should prioritise cycle and pedestrian movements and public transport through development of a comprehensive pedestrian and cycle network including green sustainable transport corridors providing links to major trip generators and London Southend Airport Rail Station and linking the two rail lines; and wider measures to promote sustainable travel. The Strategy should address the
phasing of development with highways improvements necessary to mitigate the impacts of development.
ƒ A site-wide Energy Strategy detailing how the range of land uses and associated infrastructure across the masterplan will combine to achieve a site-wide net-zero carbon target. The scale of development and variety of uses presents opportunities to coordinate energy generation, transference and consumption, together with carbon sequestration to achieve net-zero carbon.
ƒ Infrastructure Delivery Plan - to coordinate the funding and delivery of development and on- and off-site infrastructure and addressing long-term stewardship of community infrastructure
Planning applications for development should be accompanied by a Phasing Strategy addressing the phasing of development and infrastructure; and a Sustainability Strategy outlining measured to be taken to achieve a net zero carbon development, high quality
digital connectivity, biodiversity net gain and to future proof development to achieve long-term sustainability.
Figure 7.2: Concept Masterplan for Land South East of Rochford & North of Southend
[SEE ATTACHED DOCUMENT]

CONCEPT MASTERPLAN
7.6. The ambition is to deliver a sequence of new ’15 minute walkable neighbourhoods’ with local services and a strong character and identity set within a high quality green network which connects Southend’s existing urban area and the new areas of growth through to the River Roach, whilst protecting important Estuary and wetland environments, historic environments and biodiversity. We want to deliver a vibrant place to live, work and visit which successfully integrates and improves coastal, rural and urban environments, delivers family housing in strong local communities and helps to deliver transformational change and growth in the local economy and new strategic infrastructure.
7.7. This approach embraces environmental, climatic, technological, social and economic resilience, aiming to futureproof the development and provide flexibility to accommodate design changes resulting from new ways of living, working and playing.
7.8. Considering the scale of the site and potential growth that can be accommodated in this location, it is anticipated that the scheme will be built out over many years. In order to provide a high-quality built environment that caters for the needs of people both now and in the future, it is necessary to develop a set of key framework principles that will underpin every masterplan
developed for the site.
7.9. Incorporated within this approach are a number of key factors that are certainties given current national policy objectives and personal lifestyle choices. Other factors are less clear, and a flexible approach will therefore have to be adopted to ensure the masterplan is capable of adapting to changing technology and trends as it is developed.
7.10. The certainties the masterplan will have to accommodate include;
ƒ Being digitally connected with high-speed internet access
ƒ Being ready for the net-zero carbon economy
ƒ Being socially connected
ƒ Being mobile

PHASING
7.11. The following section of these representations detail the key phases to the proposed growth option on land southeast of Rochford and north of Southend. It should be noted that these options are indicative only at this stage and we welcome the opportunity to develop these proposals in further detail with the Council, key stakeholders and the local community.
Figure 7.3 – Potential Phasing Sequence for Land at South East of Rochford and North of Southend [SEE ATTACHED DOCUMENT]
Early phase : 1-5 years. (Phase 2b)
ƒ East of Southend Airport: 1050-1100 dwellings, a primary school, a local centre including health uses and 10.35Ha of flexible employment land.
Middle phase : 6-15 years. (Phase 3b)
ƒ North west of Garon Park: 710-770 dwellings, a local centre including a small employment hub and health uses.
Late phase : 16-30 years (Phase 6a, 6b & 8)
ƒ (6a and 6b) Southwest of Little Wakering: 2,000 – 2,100, a primary school and a local centre including a small employment hub and health uses.
ƒ (8) West of Little Wakering: 850– 900 dwellings, a primary school and a local centre including a small employment hub and health uses.
KEY DESIGN ATTRIBUTES - EARLY PHASE : 1-5 YEARS. (PHASE 2B)
East of Southend Airport: 1050-1100 dwellings, a primary school, a local centre including health uses and 10Ha of flexible employment land.
ƒ To provide a new east-west transport link in the location of Warners Bridge next to the Airport.
ƒ To provide a new junction to allow Temple Farm and Purdeys Indus¬trial Estate vehicles to pass
through the area without impacting residential areas
ƒ To allow the continuation of the east-west transport link as a green corridor public transport route eastwards
ƒ To provide easy walking and cycling access to support the vitality of Rochford Town Centre
(1.2miles convivial walk)
ƒ To provide a mixed-use village core with school, shops, health care and village square
ƒ To provide flexible expansion space for Temple Farm employment area and in close proximity to the new east-west transport link and railway bridge.
ƒ To provide the first phase of a wider community park that will in¬crease biodiversity along Prittle Brook to Sutton Road
Figure 7.4 – Early Phases of Strategic Growth with Rochford District Council
[SEE ATTACHED DOCUMENT]

KEY DESIGN ATTRIBUTES - MIDDLE PHASE : 6-15 YEARS. (PHASE 3B)
North west of Garon Park: 710-770 dwellings, a local centre including a small employment hub and health uses.
ƒ To allow the continuation of the east-west transport link as a green corridor public transport route eastwards
ƒ To respond to the existing planning proposals for the Fossetts Farm area including the masterplan for Southend Football Stadium, the Homes England residential area of Prittlewell Camp and the Fossetts Way East residential area.
ƒ To provide highway connections from the east-west transport link to Fossetts Way and Eastern Avenue (A1159) allowing stadium traffic additional access opportunities.
ƒ To provide early access from Fossetts Way B&Q roundabout across Garons Park established access. This would allow the east-west transport link to be delivered as early infrastructure whist the opera¬tional needs of Garon Park and Golf Course continue without interruption through the development process.
ƒ To provide bus connection to Shopland Road, Stonebridge and The Wakerings.
ƒ To provide the second phase of a wider community park that will increase biodiversity along the brook to Shopland Road
Figure 7.5 – Middle Phase of Strategic Growth with Rochford District Council [SEE ATTACHED DOCUMENT]
KEY DESIGN ATTRIBUTES - LATER PHASE : 16-30 YEARS (PHASE 6A & 6B)
(6a and 6b) Southwest of Little Wakering: 2,000 – 2,100, a primary school and a local centre including a small employment hub and health uses.
ƒ To allow the continuation of the east-west transport link as a green corridor public transport route westwards and southwards.
ƒ To reserve land for a future phase secondary / academy school (a separate 9.45Ha parcel of land).
ƒ Integrate the farms and small holdings of: Barrow Hall Farm, Abbotts Hall Farm, Oldbury Farm, Morley Nurseries.
ƒ Integrated the setting of Stonebridge village.
ƒ To provide the third phase of a wider community park that will in¬crease biodiversity along the brook to Shopland Road.
ƒ To allow for not less than 450m off-set distance to properties of Little Wakering.
ƒ To retain the existing water reservoir for agricultural use Figure 7.6 – Later Phases of Strategic Growth with Rochford District Council [SEE ATTACHED DOCUMENT]

KEY DESIGN ATTRIBUTES - LATER PHASE : 16-30 YEARS (PHASE 8)
West of Little Wakering: 850– 900 dwellings, a primary school and a local centre including a small employment hub and health uses.
ƒ To allow the continuation of the east-west transport link as a green corridor public transport route westwards and southwards.
ƒ To integrate a reconfigured golf course that will sit within Rochford and Southend.
ƒ Integrate the farms and small holdings of Beauchamps.
ƒ Integrated the water bodies serving surrounding farmland.
ƒ To provide additional bus corridor south to allow access to Garons Park sports and leisure uses.
ƒ To provide extensive landscaped community parkland.
ƒ To ensure the setting of the village is not visually intrusive on the landscape
Figure 7.7 – Later Phases of Strategic Growth with Rochford District Council [SEE ATTACHED DOCUMENT]

08. RESPONSE TO QUESTIONS RAISED IN THE CONSULTATION.

Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help
guide decision-making? [Please state reasoning]
8.1. Yes, we agree that a range of separate visions for each of the settlements is a helpful guide to decision making. In any event a separate vision will be required for the growth areas as required in the recently updated Framework which stipulates that for larger scale developments ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. A draft vision for South East of Rochford and North of Southend is
detailed at Section 7 of these representations.

Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing
from the strategic priorities or objectives that you feel needs to be included? [Please state reasoning]
8.2. We support and endorse the five main strategic priorities set out in the Consultation, which are follows:
ƒ Meeting the need for homes and jobs in the area
ƒ Making suitable and sufficient provision for retail, leisure and other commercial development
ƒ Making suitable and sufficient provision of infrastructure for transport, telecommunications,
waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat)
ƒ Making suitable and sufficient provision of health, security, community and cultural infrastructure and other local facilities
ƒ Making suitable and sufficient provision for climate change mitigation and adaptation, conservation and enhancement of the natural and historic environment, including landscape
8.3. These form the foundation for the Local Plan in which all growth options should be tested against to ensure that future development will deliver the strategic priorities and objectives of RDC.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan? [Please
state reasoning]
8.4. These representations wholly endorse Strategy Option 3: Concentrated growth » Option 3b: Focused north of Southend which lies within our client’s land interests.
8.5. It is submitted that in order to deliver the ambitions of the Local Plan large scale growth focused in one location as per Option 3b is required. Strategic growth at this location is embedded within the evidence base which supports this Local Plan including the South East Essex Strategic Growth Locations Assessment (2019) and the South Essex Strategic Growth Locations Study (2020).
8.6. Option 3b is the only option which will:
ƒ Provide the “critical mass” needed to secure transformational new infrastructure to mitigate the impact of future development and critically to address the chronic congestion currently experienced within the District
ƒ improve affordability
ƒ address the decline in home ownership
ƒ support a sustainable shift towards higher wage/skilled jobs.
8.7. It is not purported however that this strategy will meet Rochford’s full housing need over the lifetime of the Plan, thus Strategy Option 4: Balanced Combination is the preferred approach. The Consultation states that Option 4 could make best use of urban capacity (Option 1), building one or two large growth areas (Option 3) and a number of smaller urban extensions (Option 2).We support Option 4 which will provided a varied supply of sites to make the local housing market as diverse as possible delivering a range of choice and competition to the market, thus offering the greatest chance that housing will be consistently delivery over the whole plan period. Crucially the Plan needs to incorporate large scale strategic growth as a Local Plan strategy that relies solely on smaller sites, or sites spread more evenly through the District will not have the potential to fund
new infrastructure and provide betterment to the current challenges facing the District.

Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and
renewable sources? Are there other opportunities in the District to supply lowcarbon or renewable energy?
8.8. Bellway have committed that all new homes will be ‘zero carbon ready’ by 2025 and net zero by 2050 as part of the Future Homes Task Force road map published in July 2021 entitled The Future Homes Delivery Plan. The headline goals include:
ƒ homes that are zero carbon ready and sustainable by 2025
ƒ production and construction methods that are net zero and sustainable by 2050, with substantial progress by 2025 and 2030;
ƒ businesses operations that are net zero by 2050 with a 50% reduction by 2030.
8.9. The roadmap sets a series of goals and milestones that need to be met along the way, incorporating government policies such as the Future Homes Standard and Biodiversity Net Gain.
8.10. The proposals on the subject site afford the opportunity to provide an exemplar new community
which sets the benchmark for development in the region and for future generations in terms of the low carbon / renewable energy. Our client is keen to explore the potential to set up a Rochford Energy Supply Company and how this could be achieved.

Q14. Do you consider that the plan should include a place-making charter that informs relevant policies?
Should the same principles apply everywhere in the District, or should different principles apply to different
areas? [Please state reasoning]
8.11. Yes, a charter should be included to ensure relevant place-making principles are applied to
different areas. The land in the Roach peninsula is precious, unique and has great potential for combining new neighbourhoods within an important landscape setting. It is a land asset that will require careful decision making and one that will enhance the legacy opportunities for the Council.
8.12. Our intention is to develop a long-term vision and planning strategy for the site, rather than to identify immediate development opportunities. We therefore have the opportunity to lay down the foundations for future plans. A charter can help this. With such a long term project, it can allow for changing stakeholders over many years to ensure greater consistency to long term goals.
8.13. Our approach will necessarily be ambitious, complex and multi-faceted. It will be a collective
endeavour from many and over many years. The charter can inspire each and every one involved. It can serve as a benchmark and help guide decision-making, particularly at those moments when what appears urgent in the short term, threatens to overshadow what its truly important in the long term.

Q16a. Do you consider that 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? Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting? [Please state reasoning]
8.14. We support the preparation of design codes. Design codes provide briefing for consistency, from
site wide to detailed design. As such, each phase will require its own design code and each time a phase is complete, a review of the completed phase will inform the production of the design code for the following phase.
8.15. Typical content of a design code shall include -
ƒ Movement strategy where appropriate
ƒ Access and street hierarchy where appropriate
ƒ Landscape and open space strategy
ƒ Land use and mix
ƒ Density
ƒ Heights
ƒ Number of homes
ƒ Identity and character of buildings and public spaces
ƒ Employment

Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new
employment facilities or improvements to existing employment facilities?
8.16. Development of Land at east of Rochford and North of Southend and Rochford provides major
opportunity to:
ƒ Support workforce growth in the area
ƒ Attracting new employers –who will come because there is a large labour force in the catchment area, and it has some capacity within it.
8.17. In the absence of such growth, there are structural challenges which will loom large: with a growing elderly population which creates costs for the public sector –including in health, social care, pensions etc –but a declining number of people and businesses which are contributing to this through taxation. With an ageing population, housing growth is going to be important to
supporting the local economy and ensuring that local businesses can find staff over the mediumand longer-term.
8.18. The scale of growth envisaged at Option 3b is a potential major economic driver in its own right. As with other development schemes, it will support growth in the population which supports employment in consumer-related sectors (as well as supporting the construction sector over a sustained period).
8.19. In addition, it also provides the opportunity to transform the area’s wider investment appeal by
improving the skills profile through diversifying the housing offer and delivering family housing with space to work in an attractive residential environment with access to the coast, countryside and local facilities together with local work hubs which offer facilities. A lifestyle offer which attracts higher skilled residents can over time improve Southend and Rochford’s skills profile and
investment offer to businesses.
8.20. In an environment in which we are seeing shifts in how people work –and will no doubt see shifts in the sectoral structure of the economy –the potential for a high quality lifestyle, at a location which is well connected (to London and other parts of Europe) is one of the important ways in which Rochford can stand out.
8.21. Self-employment is significant and has been growing in the district. There is potential for further
growth in this area, and a need for infrastructure to support this. With changes in how we work, some of those who currently commute out to higher paid jobs elsewhere may spend more time working at home or locally. The digital infrastructure (and potentially some local workspace) is needed to support this.
8.22. There will still be jobs in schools, education, local shops and services. Development on land at Southend and Rochford will support jobs in these areas. There will also still be jobs in offices, on industrial sites and at Southend Airport.
8.23. Mixed-use development is envisaged in all neighbourhoods, which includes provision of flexible
commercial space in neighbourhood centres as well as delivery of the technology infrastructure to support home-working and home-based businesses.
8.24. In addition to this, provision of over 10 ha of employment land is envisaged in on the western side
of the site, providing opportunities for both growth of SMEs and for grow-on space for existing
businesses in Southend and Rochford.
8.25. Equally, this large area of employment land could provide the right location for a Southend University Hospital Relocation subject to wide ranging consultation. This new location could serve Rochford and Southend as it is halfway between the two town centres. A&E Blue light routes would also be more rapid as they could rely on the new sustainable transport corridor and avoid congestion.

GREEN AND BLUE INFRASTRUCTURE
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure? [Please state reasoning]
8.26. As detailed in these representations, the ambition is to deliver a sequence of new ’15 minute walkable neighbourhoods’ with local services and a strong character and identity set within a high quality green network which connects Southend’s existing urban area and the new areas of growth through to the River Roach, whilst protecting important Estuary and wetland
environments, historic environments and biodiversity. We want to deliver a vibrant place to live, work and visit which successfully integrates and improves coastal, rural and urban environments, delivers family housing in strong local communities and helps to deliver transformational change and growth in the local economy and new strategic infrastructure.
8.27. It is considered that that new strategic green and blue infrastructure is essential in order to create the community envisaged in this location. We support the delivery of the South Essex Estuary Park and The Island Wetlands. In order to ensure these landmark green and blue infrastructure projects can be delivered this will need to be balanced with the Council meeting their strategic needs. The provision of growth in southeast of Rochford and north of Southend will enable investment into strategic green and blue infrastructure projects in the location. We welcome the opportunity to work with the Council in terms of the extent and location of the green
and blue infrastructure.
OPEN SPACES AND RECREATION
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?
8.28. A critical aspect in delivering a new community such as that proposed at Option 3b will be the
delivery of high quality public open space. The initial design work has considered green fingers separating the series of neighbourhoods as illustrated at Figure 5.2. Our client is keen to work with the Council to explore how the proposed scheme can contribute towards and assist in the delivery of the South Essex Estuary Park. Moreover, the proposed is of such a scale and critical mass that
will ensure each neighbourhood provides generous public open space and sports facilities.

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? [Please state reasoning]
8.29. Rochford is identified as one of the top five local authorities in England as having heritage potential as defined by the Heritage Index 2020. This means that the District has untapped heritage potential and suggests that local heritage is a further asset for consideration to achieve the goal to grow the tourism economy. There is an opportunity through delivering growth in the district to celebrate the heritage assets of Rochford.
8.30. The Thames Estuary 2050 Growth Commission aims to utilise opportunities in existing sectors,
environmental assets and planned development to create a ‘tapestry of productive places’ along a global river. These assets present an opportunity to support the attractiveness of Rochford as a place to live, work and visit, and contribute to the potential for growth of the tourism economy in the District.
TRANSPORT AND CONNECTIVITY
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.]

8.31. We are on the brink of a transport revolution as a result of both technological advances and changes to social behaviour. For example, new technologies such as autonomous vehicles can help improve traffic flow or reduce the need for car ownership and changes in working habits may allow more people to work from home or closer to home. Both of these, when added to numerous other changes, will reduce the need and size for large highways infrastructure projects which will
cost large sums of money and have ecological impacts and may be over designed for behaviours in 20-30 years.
8.32. The scale of Option 3b is such that development in this area will deliver significant enhancements to public transport which will not only serve future residents but crucially provide local services to the existing community.
8.33. We need to ensure that high-quality public transport options are available for those that need
it, for example, high-quality dedicated bus services linking major growth locations in the Plan to local train stations ensuring that a realistic low carbon option for travel. The availability of highquality options for travel by sustainable modes must be key to encouraging people to leave their cars behind.
8.34 A Transport and Movement Strategy will be prepared for the proposals which will prioritise cycle and pedestrian movements and public transport through development of a comprehensive pedestrian and cycle network including green sustainable transport corridors providing links to major trip generators and London Southend Airport Rail Station and linking the two rail lines; and wider measures to promote sustainable travel. The Strategy will address the phasing of development with highways improvements necessary to mitigate the impacts of development.

Q65b. With reference to Figure 53 and your preferred Strategy Option, do you think any of the promoted
sites should be made available for any of the following uses? How could that improve the completeness of
Sutton and Stonebridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
8.35. As detailed in the submitted proposals it is envisaged that this area south east of Rochford and north of Southend could be developed for a new growth location which will deliver a range of services and community infrastructure to serve the future residents and also due to the close proximity to the existing settlements of Stonebridge and Sutton will serve the existing community. The Masterplan has been designed to ensure that the existing settlements retain their own identity as proposed in the Draft Vision, however residents of these places should have greater access to services close at hand, including by sustainable means.

09. ECONOMIC BENEFITS TO ROCHFORD
OF OPTION 3B

This infographic provides an overview of the economic benefits that could be delivered through the development of a minimum of 4,600 dwellings together with approximately 11ha of employment space, as well as education, community and healthcare uses within Rochford District. The proposed expansion is expected to deliver a range of economic benefits during both the construction and operational phases which will make a positive contribution to the local economy.
[see document for full infographic]
the construction phase benefits:
Injection of private sector investment
Supporting direct construction jobs
Supporting indirect jobs in the supply chain
Contribution to Economic Output (GVA)

the occupational benefits
First Occupation Expenditure up to £25.4m
Resident Expenditure c.£131.7m
Direct operational employment 5,900
Direct operational employment 6,700
Indirect operational employment 1,700

the fiscal benefits
Business Rates £4.2m
Council Tax £9.6m
New Homes Bonus £26.5m

We have attended a consultation and studied the map with all the blue planned farm fields for housing.
There seem to be an awful lot of planning . I know people need somewhere to live .
But the environment is important too.
To reduce the amount of housing I suggest The council should talk about the environmental impact this will have on our area.
With 600 houses come 600 cars or a lot more .I live in a close with 8 houses And 14 cars.
I also think we should do lots more to encourage people to cycle.
A stripe on a pavement like in Ashingdon road is not good enough. It's dangerous for the children walking to Holt Farm school.
There should have been a proper distinguished border The pavement was wide enough to do that
Hall road could have a cycle path Behind the trees Not just a stripe on the road .
Ironwell lane could be made into bridle path one side cycling path next to it At the moment Ironwell can not be used if it rains a lot.
So my opinion is Reduce the amount of housing .Spend the council TAX The council receives from all the houses already build on saving the enviroment
By providing alternative transport To reduce the amount of cars
By providing proper cycling routes Especially to schools .And providing convenient public transport.

CFS260F BARLING ROAD
AGAINST ANY FORM OF HOUSING DEVELOPMENT IN GREENBELT/FARMERS FIELDS

I am writing to raise my concerns over the level of development which is currently being undertaken in areas of Essex Green Belt . Also planning proposals for thousands of housing in the near future on Greenbelt. At the moment the infrastructure to allow for the traffic to move freely has been compromised already. You cannot leave the house without getting stuck in traffic near Rayleigh Weir, bottle neck by Hadleigh, queuing at the Southend underpass and A127 by Priory Park. The housing estates which have recently gone up at Star Lane, Barrow Hall, Hullbridge, Rawreth have not taken into account the existing Schools or Doctors Surgeries. None of the developers have contributed into building new schools or clinics to allow for patients from the new housing estates to be serviced.

I fully understand the farmers cannot make ends meet if they find farming unprofitable. With Brexit and recent lockdown, there needs to be more UK farming so we can be self sufficient should the need arise that we cannot fulfil consumer needs in this country from the EU. Once you have built on all the farming land, we will be totally reliant on food supplies coming from abroad, which will cost more and will damage the environment.

The country roads in Barling Magna and Wakering do not even have curb sides so how would more traffic which will be generated by more housing cope? This would mean carving up more greenbelt for bigger roads and there will be no countryside left. Should the housing behind Daws Heath go ahead, how will Rayleigh Weir cope? It will be at a standstill. The offices which were once by Victoria Avenue have been developed into flats which is a very good idea, not using our precious greenbelt.

Even if you build on brownfil sites, where will all the extra traffic go? All these people moving down to the South East will have no Hospital to go to or doctors surgeries to register at as we are overloaded already.
Any intelligent person can see already the roads cannot cope and will get worse.

Also there was some talk of a Marina at Shoebury East Beach, Southend seafront is already at a standstill with traffic and I cannot see the traffic being diverted through Southend. Please do not make Rochford a City.

Please, please do not let our GREENBELT go to greedy developers who probably do not live in Essex and consider the future implications should these sites be built on.