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

There are three questions for which I would appreciate a response. See below.

Whilst we accept that an enormous amount of work has gone into producing this options consultation I'm sure you would acknowledge that the average person would find these documents extremely complicated and somewhat difficult to understand.

However, having lived in Rayleigh since 1980 and witnessed considerable growth within the Rochford area as a whole we find options 1 and 2 to be totally unacceptable. I will not list all our concerns and objections since your own CONS for both options speak for themselves.

However Rayleigh itself is choking under the weight of traffic both entering the town and passing through, principally to gain access to the A127. To even consider intensification or extention would be madness. Rochford Council has already allowed considerable development along the A129 to the west of Rayleigh Town, the major area off Rawreth Lane and now a flats development behind Marks & Spencers. Your proposal for the Mill Hall and The Civic Suite sites has quite rightly met with considerable opposition from local residents. Surely that is a clear indicator that Rochford residents do not want further development within Rayleigh. This latter proposal even being within the Rayleigh Conservation Area!

Only this morning I returned on foot from the Rayleigh Wier back into the town along the A129 into the High Street. The traffic was solid and creaping along for the whole distance which further extended into Websters Way. The smell of petrol fumes was considerable and I had to cover my nose for most of the way. The current level of pollution is unacceptable and I even believe these roads have historically failed to meet the required standards for air pollution. The inevitable increase in traffic such centralised development would produce will only exacerbate the problem. I would also mention that we live in Highfield Crescent, very close to Websters Way and [redacted]'s asthma has worsened over the years, I believe as a direct consequence of this increase in traffic.

I also note that "National Policy also requires that Local Plans provide strategies that accommodate unmet need from neighbouring areas". You imply that your plans could help accomodate some of this need. There appears to be no mention of any reciprocal offers or arrangments. Are there any?

As general comment we are not in favour of random piecemeal development and as such options 3 would be by far our preferred choice.

The only development suitable for any form of housing in Rayleigh is the Castle Road waste disposal site which is totally inadequate, causes considerable traffic congestion and should have been relocated years ago.

Given this is a consultation document and emphasises that decisons are yet to be made can you explain why RDC has already embarked on a partnership with Voyage to develop a number of sites within Rochford including Rayleigh Mill Hall and the Civic Suite?

Have contracts been signed by RDC to develop these sites?

I am writing in response to your consultation with regards to development in the area going forward.

I am particularly concerned with regard to 179 Final Viability Report with regards to the field at the bottom of Folly Chase where I live and the addition of Greenacres nursery to the proposals.

I thought the vision statement for Hockley was to maintain ancient woodland rather than destroy it within this development as it is completely abliterated? My understanding was that HC1 Folly Wood has some protection but has the field by the railway line been included in error with regards to biodiversity?

My understanding of previous consideration was that Folly Chase would be used as an exit road??? How is that possible when it is a private road, unadopted and not wide enough?? The only way you could do this would be to compulsory purchase some of our front gardens to widen the road??? There are no paths and I have an oak tree on my border which has a TPO on it.

The completely irony is that when I first moved here and wanted to trim it I was refused (only a trim not a removal!!) by an Arboricultural Inspector as it would spoil the character and amenity of the area and the effect on the tree health and the importance of oak trees in our biodiversity and threatened invertibrates within it. It was decided it would have a negative impact!

This was later overturned as mentioned before I only wanted to trim it!! and at the time the council was considering building 50 houses in the field (later chose Pond Chase).

How are we expected to support a council that dictates on the one hand what I can and cannot do and then turns a blind eye completely contradicting its findings when it suits???

I do not consider 265 houses a small development which is in breach of infill development recommendations.

The drains, I believe, are still not connected to the Pond Chase development so who is responsible for not completing this - the builders?? Surely the council has a responsibility to ensure procedures are followed?

I understand from the Greenacres homeowners they have not put their land forward for development of 40 houses but it has been lumped in with the proposals?? How is that allowed without consultation to the landowners?? It has caused much anxiety and stress to them in addition to the other homeowners in the road.

Again, there is limited access (one car width) to their current premises so does that mean the house at the front would be demolished to provide access??

What about environmental factors and the assessment of the field for protection of wildlife - has this been done for a buffer zone around the mature oaks, and, as previously mentioned, how will you do this around my oak tree as there will not be the room??(see previous biodiversity comments).

I believe there are more suitable sites on the western edge of the plan and other brown field sites not full developed. The bigger developments would have access to better transport links as the current traffic situation in Hockley cannot take any more cars. Strategy Option 3 would be best suited to provide the housing needs if required by government.

I refer to the piece of land off of Folly Chase ( CFS064 ) earmarked for development. My reasons against this piece of land being developed are as follows:-
1. The land is surrounded by three ancient woodlands which would need to be demolished if permission were to be given to housing. In the spring there is an abundance of wild flowers in these woods including many areas of anemonies which grow at the rate of six feet in a hundred years which demonstrates how old these woods are. This is a habitat for many birds bees and butterflies. Can we really justify demolishing years and years of woodland just to line builder’s pockets? There is a suggestion that we should plant trees to save our planet and how can demolishing an old woodland demonstrate this. This is also an area where badgers roam freely at night, there are many sets on the waste land at the back of the new estate off of Folly Lane.
2. Since lockdown we have seen a considerable number of people with or without dogs wandering down our Folly chase for a stroll and into the woodlands surrounding it. The numbers have not decreased as this is now a well known spot for people to walk for exercise and enjoy the flora and fauna,birds and butterflies we still have in this area before it all disappears under the developer’s machinery.
3. During heavy rain this year the field became very waterlogged and the adjoining lane was just a big lake. As the new estate in Folly Lane has had enormous problems with sewerage just how can it be contemplated to add sewerage from another 214 houses when sewerage from the extra 75 houses cannot cope now.
4. The access to the site is very poor. Folly Chase is not wide enough for two cars to pass by. Entry via the Community Centre would lose the grassland surrounding the Community Centre which again is used by walkers, dog training club and the childrens nursery. Access via the school is not safe with small children around.
5. Traffic congestion along High Road is a constant problem, there is frequently long delays if a delivery is made anywhere in the vicinity causing exhaust pollution and that is before all the extra traffic any more houses will generate. Our children are encouraged to walk to school but how many will develop asthma from the constant exhaust fumes that will be generated by more cars stuck in traffic jams.
6. On a general note with future housing development in this area No plans as far as we know have been made to provide new schools, more doctors surgeries and new roads to cope with this influx of people and cars more building will create. As we know from the Hall Road site the builders manipulated the situation flaunting the rules meaning they did not have to provide the schools and doctors surgery as promised. Will the Council ensure that adequate provision is made and that this loophole is not used again?

OBJECTION
What a stupid unthought plan, the infrastructure for start ,would not accommodate for this amount of traffic and people, massed into this area, its is hard to get a doctors appointment when needed, the roads are becoming pot holed, this will create a greater Manchester into what was a village, lots of space up in Norfolk. And if our precious woods disappear, the amount of flooding that would occur because of lack of trees would be devastating. All to do with greedy people wanting money. So yes I object to this stupid project.

I write with reference to the Local Plan being proposed by Rochford District Council.
Having lived in this area now for over 75 years, I have seen the continual destruction of the green belt land being sold off for ill advised development, and sadly this proposed future Local Plan just continues to place the whole area under further extreme development, without FIRST putting in place the very necessary infrastructure that is already overdue and causes more difficulties with inadequate road access, public transport, schools and medical treatment facilities, all of which are either now non existent, or under extreme pressure already.
For many years now there has been a complete decline in the many and varied wildlife and birdlife habitat due to over-development of Green Belt and agricultural land, we have lost many species of birds, grass snakes, newts and other invertebrates and a complete extinction of hedgehogs and slow worms from this area.
Medical facilities have been decimated by the closure and removal of Rochford Hospital together with many of the Health Clinics in this immediate area, placing great pressure on Southend Trust Hospital to the point of near collapse. General Doctor Practice surgeries are so over burdened that appointments are almost impossible to obtain within a two week period already and will only worsen with these extreme development proposals.
The already colossal increase in road traffic within the areas of Ashingdon Road, Rectory Road and the B1013 from Rayleigh through to the A127 at Westcliff, finds gridlock at peak times of morning and evening travel and during school access times. The Rochford Council Planners do not seem to realise that each new home will bring another 3 cars onto the already over stretched road network of the area, with the resultant chaos, jams and loss of working hours, plus the extreme levels of pollution these vehicles engender by stopping and starting within a "tail back", pollution which is very damaging to the local residents health, the adjacent wildlife and vegetation.
The areas adjacent to Clements Hall Centre through to Windsor Gardens and St Marys Church are the lowest in the entire district between Ashingdon Heights, Hall Road (B1013) and Hockley and thus the water fall out from any proposed building will further exacerbate the flooding of the Hawkwell Brook and surrounding fields and all the existing and future housing built near or thereon. Development on this particular area alone will result in chaos with great financial costs as the climate warms and increased flooding occurs. I am old enough to well remember the various flood problems here over many previous winters, which this Local Plan totally ignores when considering opening up land for development under CFS194 / CFS169 / CFS150 / CFS020 respectively.
Overall one readily realises that new housing has to be provided within Rochford District, BUT it has to be sensitively placed in areas of "Brown Field", with good vehicular access, good Public transport, Medical facilities and future flood plain and flooding issues etc very carefully considered and the remedies ALREADY PUT IN PLACE prior to any development being considered or eventually agreed.

I am writing to you in response to the publishing of the New Local Plan. I am compelled to conclude that Rochford Council’s approach to this proposal is deeply cynical. The scale of the proposals is enormous, but yet this plan is invisible on the council home page and takes some persistence in navigating through various pages to find it. Some of the proposals, such as concreting over Belchamps appear so far-fetched that they are being proposed knowing that they will be sacrificed to placate the public and get some of the proposals through. Also lacking is why this enormous development is needed? (A very obvious omission). I suspect that the very large number of sites have been chosen to make it difficult and time consuming to object.
I will therefore select a few sites which present the same negative outcomes. These sites are:
CFS074, 020, 150, 169, 194, 045 and 064
All of the sites give us more of the following outcomes:
1/ More traffic onto the B1013, an already congested road
2/ No infrastructure to support walking and cycling
3/ More pollution and a decrease in air quality
And less of the following:
a/ green corridors and wildlife habits
b/ footpaths, so vital for mental health in recent times
c/ More flood risk in many of them
I have lived in Hockley for 30 years and have noticed a diminution in the quality of life in the local area which has felt increasingly suburban in nature. The large increase in population has not been accompanied by any increase in amenities.

Thank you for making the Local Plan and Spatial Options available on the internet and for the extensive detail included. It's taken me a while to get to examine the contents and would like to respond to proposals to develop land surrounding my family home. I am concerned by the scale of possible development all across the Rochford area, but there are two sites that will directly and adversely affect my family and I.

Of course I understand that Government policy will force significant development within the area, but I am writing to highlight issues with developing the sites of CFS064 and CFS264 and to ask that they be removed from the Plan and any subsequent consultation stages. Site CFS064 is special and should be protected in accordance with RDC's own objectives.

I list my concerns as follows:

Access to the sites CFS064 and CFS264

I live on Folly Chase, I was born here more than 50 years ago and it's been my parents only marital home in their 56 years as husband and wife. As I look at the plans it seems the only access to both sites would be through the Chase, which for many years was an unmade road off a country lane. Folly Lane is no longer a quiet road - it's a busy rat-run, with large trucks, coaches and even buses forcing their way through a narrow thoroughfare. The new housing developments in Pond Chase and Church Road has seen the speed of traffic rise dangerously. Increased building in Hullbridge, poor access on the B1013 from Rayleigh to Rochford - with drivers avoiding the often log jammed A127 - means this is now a busy road and the only direct way Hullbridge to Hockley. Car are often parked in dangerous positions on both sides of the road and it's worse when parents are dropping children at Hockley Tennis Club. Traffic goes too fast and often cut the corners of the 90 left - 90 right and 90 left bends those of us looking to pull into Folly Chase are in jeopardy at times. The roads are broken and in disrepair fallowing the construction of Pond Chase Nursery.
Any more development will just make all of this worse - if even the small site is green lit that will mean another 60 cars using the road - not to mention extra the delivery traffic.

Our road is maintained by residents and is incapable of handling construction traffic or the eventual increase in residential access traffic. It leads to a footpath, popular with dog walkers taking them into Bluebell Woods (aka Folly Wood) designated Ancient Woodland, carrying HC1 Wildlife Site designation. It's all part of the "6,320km Public Rights of Way (PRoW) in Essex - one of the most extensive networks in the country" according to the ECC website. And the Rochford District Council website highlights that "Hockley" is a member of the Parish Paths Partnership Scheme, which is an initiative introduced by Essex County Council in conjunction with The Countryside Agency to assist parish councils to maintain, develop and promote their local footpath network."

Folly Chase has no surface drainage features, no run off into gullies or gutters. There are no footpaths, and no room to build them as the roads about 9 feet wide at its narrowest point, so cannot support two way traffic. The infrastructure for housing water, and gas supplies is not far beneath the surface and any increase in heavy traffic will almost certainly damage these as they are vulnerable.

Anglian Water had serious concerns about the strain on the current sewerage systems in the area and the Pond Chase development created serious issues contributing to the ill health of several residents on the road. The complete system now cross to Folly Chase from Pond Chase, across to the field that is site CFS064 to the Hockley Community centre and has already caused significant sinking of our road surface. The nearby development in Church Road has also had significant sewage and surface water issues and any further development adding onto the existing surface water and sewage infrastructure will only increase the pressure on existing infrastructure, potentially to the point of failure, with significant public health concerns.

Folly Chase is Private Road with an undefined Public Footpath running down it. Ownership of the road isn’t registered and absent any contrary evidence each land owner owns up to the mid- point of the road. There are some private rights of way that have been established by usage and by deed, but it is apparent that the ownership issue is complex and fragmented and that my discussions with many residents shows the large majority would be unwilling to enter into any negotiation to depart from current use and access.

With specific reference to site CFS064

This land abuts the full length of our back fence, we have all manner of wild life that comes into our garden from here including newts, common lizards and adders (a protected species) as well as bats, and dragonflies.
I note that the land is Metropolitan Green belt land and have read that such land can only be developed for ‘Exceptional circumstances’ as detailed in the Planning Policy Guidance Note 2 (PPG2). It also says in paragraph 143 that "Inappropriate development is by definition harmful to Green Belt’’ and in Paragraph 145 is says ‘’A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are;


• Agriculture and Forestry.
The outline proposal is for residential development thus condition is not satisfied. Indeed any development would actually be in direct opposition to this as the land is already prime agricultural arable land and is actively farmed.

b. Essential facilities for outdoor sport and recreation.
The site already includes a football pitches at the Community Centre, the Community Centre itself and is widely used for walking, dog walking, running and cycling. The outline proposals would diminish the provision of outdoor sport and recreation and this condition cannot therefore be satisfied by any housing development.

c. and d. Limited extension and/or alteration of existing buildings.
Other than the Community Centre there are no existing buildings within the site. The Community Centre itself still has a long unexpired lease and development of it fails the test above in any case. This condition cannot be fulfilled

e . Limited Infilling.
The Local Plan allocation site reference 179 states that the land could be used for up to 265 dwellings. This is anything but ‘limited’ and this condition cannot be fulfilled

f. Limited affordable Housing
Again the size of the potential development is anything but limited. Condition cannot be met.

g. Limited infilling or redevelopment of previously developed land.
This land has not been previously developed and condition cannot be met.

Paragraph 136 of the National Planning Policy Framework lays out that ‘exceptional circumstances’ must be met for any consideration of changing existing Green Belt boundaries.

Paragraph 137 specifically states that ‘’the…authority should be able to demonstrate that it has examined all other reasonable options for meeting its identified need for development. …..and whether the strategy…. Makes as much use as possible of suitable brownfield sites and under-utilised land’’

All the above suggests the site cannot be considered any further for housing development as to do so contravenes existing Metropolitan Green Belt legislation so it must be removed from the development plan.


Local Wildlife Sites and Incorrect identification of their proximity to the site CFS064.
An additional contravention of Policy to the Green belt restrictions is that the site is in ‘close proximity’ to 3 Local Wildlife Sites (LoWs) namely, Betts Wood, Folly Wood and Hockley Hall-South Wood. These are all designated a minimum of HC1 (ancient Woodland) and have further designations. Folly Wood occupies most of the southern boundary of the site, Betts Wood most of the eastern boundary and Hockley Hall-South Wood circa half of the northern boundary. It should be noted that there is a strip of woodland joining Folly Wood and Hockley Hall-South Wood along the entire western perimeter and this may mean that these two LoWs are in fact one larger site. It is important to point out that the Site Allocation Assessment Criteria fails to mention the ‘close proximity’ of the LoWs and that it is vital that this is noted by RDC. This omission must render the Site Allocation Assessment as invalid, and that the site should not have passed the first stage consultation as a consequence.

The ’Buffer Zones’ that would be required at the perimeter of the LOWs and around the mature veteran Oak trees within the site would reduce the available land suitable for development significantly and render the site uneconomic.

The LoWs mentioned above, and the immediate surrounding environment, including the field detailed in site CFS 064 support a rich and varied population , indeed such woodland is recognized as providing the most diverse and important habitats in the UK and is already limited to just 550,000 Hectares across the entire UK.

When I was a little girl I used to play in "the big field" and in the gloaming of summer would watch the glow-worms in the grass by Folly Woods. The LoWs assessments do not detail many resident species but it's not only the glow worms that the children growing up here see on their walks. We have grass snakes and slow worms as well as adders and very cute common lizards. There are frogs, toads, smooth Newts, great Crested Newts. I have seen badgers, foxes, muntjac deer and even a very fast weasel! There are nesting buzzards, sparrow hawks, merlin, tawny owls, little owls, nightjar, blue tits, great tits, long tail tits, robins and wrens, coal tits, willow warblers, chiff chaff, blackcap, blackbirds, thrushes, goldfinch, greenfinch, chaffinch, yellowhammer, tree creeper, nuthatch, swallow, swift, house martin. In the trees of the ancient woodland we have many corvid including crow, jackdaw, Magpie, Jay, Rook, then there's the Coot, Moorhen, Cuckoo, dunnock and sparrows and when it's cold fieldfare, lapwing, and redwing shelter and rest. Goldcrest, Great Spotted Woodpecker, Green Woodpecker, Lesser Spotted Woodpecker, Grey Heron, Pied Wagtail, Grey Wagtail, House Sparrow, Kestrel, Linnet, Nightingale, Meadow Pipit, Skylark, Starling have all been seen here as the seasons change. And we all love the bats so their must be a colony making their home within Folly and/or Betts Woods. There's rich flora, including wild honeysuckle, wood anemones and the bluebells, all with the many variety of beetles, spiders and Wood Ant colonies.

They live happily undisturbed amongst brambles, oak, hornbeam, holly and Ash trees around the Ancient Woodland and on arable farmland. They require free movement between sites and the field, and the large mature Oaks within it, provide essential movement corridors between the three identified LoWs sites. Any development in the field in the centre of these three LoWs can only have a massive detrimental effect on the population, and the existing richness and diversity proves this is a site that should be preserved, not destroyed. Consideration for development must cease forthwith.

The ’standing advice’ of the Government in this regard is found within Natural England and Forestry Commission guidance ( https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences). Standing Advice is a ’Material planning consideration’. Ancient Woodllands have equal protection in the National planning Policy Framework.


I have been shown RDC’s own statements regarding potential development within the Local Plan document. The plan clearly states that one of it’s key objectives is ‘’for meeting future needs (including housing….). It will also identify areas for protection, such as sites that are important for wildlife and open space.’’ The RDC have failed in their policy objective and in following correct process that there is a failure to even identify the proximity of the LoWs detailed above in the Site Allocation Assessment Criteria. So this site really should not be considered for development - instead it should be listed for protection in accordance with the Local Plan objectives - taken off the development plan and placed in a protection plan.

Infrastructure- both sites

I've mentioned my concerns about local road issues - I haven't added my worries about the times ambulances take to get to our road and then back to Southend hospital (While it continues to have an A+E unit).
I have also explained how inadequate drainage and sewerage is in the area but we have to also address the pressure local services are already straining under. If both sites are green-lit hundreds more people (and children) will be looking for places in our local schools, GP surgeries, dental surgeries and nurseries. The bus service is infrequent and expensive, and speaking as a cyclist the roads are too narrow for safe transit for younger riders. I want proper cycle ways but where are they? And where would they realistically go? The B1013 cannot cope with the current traffic let along increased pressed form increased housing.

Reduction of Quality Arable farming land-CFS064
I am concerned the Plan may well reduce the acreage available for arable farming. What measures have the council made to ensure we have sufficient acreage available for farming use to enable us to keep feeding ourselves?

Impact on the landscape and community
Any development at site CFS064 will be detrimental on the environment, biodiversity and the visible appearance of the site. The visual impact will destroy the character of the site and its surroundings and the increase in population and traffic would destroy the culture of the existing community within Folly Chase.

Spatial Options Document 2021
Whilst I agree with the Vision Statement for Hockley as detailed in the SOD I cannot see how the proposed development sites would achieve the stated vision. Surely any further development would conflict with the entire Vision Statement, other than the one regarding affordable housing, but as we have seen on numerous occasions building more houses does not link directly to improved affordable housing allocations as builders charge increasingly higher prices. Surely a Central Government led policy on house pricing/profits is the answer?

Q58e asks re the significance of the ‘local green spaces’ but makes no mention of the Local Wildlife Sites. These should be equally regarded and are very significant. I have heard that CFS064 could be considered for re wilding. If so, with it’s close proximity to LoWs it could become an education centre or Country park, accessible to many by foot and cycle. It therefore does need protecting form development as it would help increase the land locally t comply with the Vision Statement and improve the environment and bio diversity for the benefit of the local community.

More Suitable Sites
My introduction acknowledged the need for some developments to comply with Government policy. There is a consensus that Hockley itself cannot cope with more development in the immediate vicinity but the Plan includes sites on the western fringes of the district that are clearly more suitable with better access, room to provide additional social infrastructure as well as housing, better transport and potential for more transport hubs, and would keep the majority of traffic away from the existing overly congested community of Hockley and Hawkwell.

Conclusion
I ask that sites CFS064 and CFS264 be removed from the next stage. They are simply not suitable.

Having studied the Local Plan at length and the recently published Spatial Options pages on your website I feel I have to respond. Whilst I have wider concerns than those regarding just the two sites above I think it is to be accepted that due to Government policy significant development has to happen somewhere within the boundaries of RDC. My purpose in writing this response , however, is to advise the council of specific issues affecting the two specific sites identified in the header and to request their removal from the Plan and any subsequent consultation stages. Indeed not only should site CFS064 be removed from the development pan, it should be earmarked for protection in accordance with RDCs own objectives detailed within the plan.

My concerns are as detailed below

Material Planning Concern regarding Access-re sites CFS064 and CFS264
The only apparent access to both sites appears to be via Folly Chase, a small unadopted road off of the already congested and unsuitable Folly Lane. Folly Lane itself has seen an unreasonable increase in traffic as it is used to access the recent new housing developments in Pond Chase and Church Road as well as the previously existing housing estate. It is now seeing additional increases in traffic flow caused by the significant housing development in Hullbridge as it is the only direct two way road access from Hullbridge to Hockley. The road is frequently difficult to get through with parked cars along both sides and heavier traffic flows in both directions. This is not helped by it’s layout with three 90 degree bends and one c 45 degree bend along its relatively short length. These bends are difficult for larger traffic, especially the type of traffic used in construction, and a drain cover on one bend is broken several times a year by lorries having to ride up on to the kerb in order to get around the bend. Generally the speed of the ‘through’ traffic is too high and I have witnessed many near misses on the bends as vehicles either cut the corners or are forced to breach the centre of the road due to parked cars. A serious head on accident is now inevitable down this road, and the prospect of further development off of it will make matters even worse as the scale of the housing for the two sites identified in the plan would equate to approximately another 500 cars using Folly Lane just to access the developed sites. This would likely equate to an average of approximately 1000 to 2000 extra car movements a day on a road that is already inadequate.

A far as Folly Chase is concerned it is so limited in its capacity that it simply cannot be deemed suitable for access for either construction traffic or the eventual increase in residential access traffic. The Chase is not a through road, terminating at a footpath leading into designated Ancient Woodland, carrying HC1 Wildlife Site designation. Folly Chase has no significant base as it was unmade until the 1980s. The current road has been constructed and maintained by the Folly Chase Road Frontagers Committee on behalf of residents. A layer of bitumen and gravel was utilised over a thin layer of type 1 hardcore that is sufficient for the low traffic flow associated with 25 houses and no through access, but will simply not support construction traffic or the flows commensurate with the potential development. The road itself has no surface drainage features, gullies, gutters or drains so all water runs over the surface to the bottom of the road. There are no footpaths, nor is there space to construct footpaths and is approximately only 9 feet wide at its narrowest point and cannot support two way traffic. The existing housing water, and gas supplies are very shallow beneath the surface and any increase in heavy traffic will almost certainly cause collapse of these and there are numerous points where the existing sewage pipes cross the road, again, at a very shallow depth and would be extremely vulnerable to increased traffic flows.

The recent adjacent Pond Chase development has well known problems with regards to access to sewerage, and whilst this is now complete and running it should be noted that the bored line of drains that traverse the bottom of Folly Chase from Pond Chase, across to the field that is site CFS064 to the Hockley Community centre have already caused significant sinking of our road surface. The nearby development in Church Road has also had significant sewage and surface water issues and any further development adding onto the existing surface water and sewage infrastructure will only increase the pressure on existing infrastructure, potentially to the point of failure, with significant public health concerns.

Folly Chase is Private Road with an undefined Public Footpath running down it. Ownership of the road isn’t registered and absent any contrary evidence each land owner owns up to the mid- point of the road. There are some private rights of way that have been established by usage and by deed, but it is apparent that the ownership issue is complex and fragmented and that my discussions with many residents shows the large majority would be unwilling to enter into any negotiation to depart from current use and access.


Green Belt- ref site CFS064
The land in question forms part of the Metropolitan Green belt. Such land can only be developed for ‘Exceptional circumstances’ as detailed in the Planning Policy Guidance Note 2 (PPG2), and states in para 143 that Inappropriate development is by definition harmful to Green Belt’’ and in Para 145 that ‘’A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are’’ ;


a. Agriculture and Forestry.
The outline proposal is for residential development thus condition is not satisfied. Indeed any development would actually be in direct opposition to this as the land is already prime agricultural arable land and is actively farmed.

b. Essential facilities for outdoor sport and recreation.
The site already includes a football pitches at the Community Centre, the Community Centre itself and is widely used for walking, dog walking, running and cycling. The outline proposals would diminish the provision of outdoor sport and recreation and this condition cannot therefore be satisfied by any housing development.

c. and d. Limited extension and/or alteration of existing buildings.
Other than the Community Centre there are no existing buildings within the site. The Community Centre itself still has a long unexpired lease and development of it fails the test above in any case. This condition cannot be fulfilled

e . Limited Infilling.
The Local Plan allocation site reference 179 states that the land could be used for up to 265 dwellings. This is anything but ‘limited’ and this condition cannot be fulfilled

f. Limited affordable Housing
Again the size of the potential development is anything but limited. Condition cannot be met.

g. Limited infilling or redevelopment of previously developed land.
This land has not been previously developed and condition cannot be met.


Paragraph 136 of the National Planning Policy Framework lays out that ‘exceptional circumstances’ must be met for any consideration of changing existing Green Belt boundaries. Paragraph 137 specifically states that ‘’the…authority should be able to demonstrate that it has examined all other reasonable options for meeting its identified need for development. …..and whether the strategy…. Makes as much use as possible of suitable brownfield sites and underutilized land’’

From the above it is clear that the site cannot be considered any further for housing development as to do so contravenes existing Metropolitan Green Belt legislation. The site should be removed from the development plan.


Local Wildlife Sites and Incorrect identification of their proximity to the site CFS064.
An additional contravention of Policy to the Green belt restrictions is that the site is in ‘close proximity’ to 3 Local Wildlife Sites (LoWs) namely, Betts Wood, Folly Wood and Hockley Hall-South Wood. These are all designated a minimum of HC1 (ancient Woodland) and have further designations. Folly Wood occupies most of the southern boundary of the site, Betts Wood most of the eastern boundary and Hockley Hall-South Wood circa half of the northern boundary. It should be noted that there is a strip of woodland joining Folly Wood and Hockley Hall-South Wood along the entire western perimeter and this may mean that these two LoWs are in fact one larger site. It is important to point out that the Site Allocation Assessment Criteria fails to mention the ‘close proximity’ of the LoWs and that it is vital that this is noted by RDC. This omission must render the Site Allocation Assessment as invalid, and that the site should not have passed the first stage consultation as a consequence.

The ’Buffer Zones’ that would be required at the perimeter of the LOWs and around the mature veteran Oak trees within the site would reduce the available land suitable for development significantly and render the site uneconomic.

The LoWs mentioned above, and the immediate surrounding environment, including the field detailed in site CFS 064 support a rich and varied population , indeed such woodland is recognized as providing the most diverse and important habitats in the UK and is already limited to just 550,000 Hectares across the entire UK.
The LoWs assessments do not detail many resident species but the following can/have been found in and around these sites and the site in question; Grass snakes, Adders, Slow Worms and Common Lizards , Common Frogs, Toads, Smooth Newts, Great Crested Newts, Badgers, Foxes, Muntjac Deer, Buzzards, Sparrow Hawks, Merlin, Tawny Owls, Little Owls, Nightjar, Blue Tits, Great Tits, Long Tail Tits, Coal Tits, Willow Warblers, Chiff Chaff, Blackcap, Blackbirds, Song Thrush, Goldfinch, Greenfinch, Chaffinch, Yellowhammer, Nuthatch, Swallow, Swift, House Martin, Crow, Jackdaw, Magpie, Jay, Rook, Coot, Moorhen, Cuckoo, Dunnock, Wren, Fieldfare, Lapwing, Redwing, Goldcrest, Great Spotted Woodpecker, Green Woodpecker, Lesser Spotted Woodpecker, Grey Heron, Pied Wagtail, Grey Wagtail, House Sparrow, Kestrel, Linnet, Nightingale, Meadow Pipit, Robin, Skylark, Starling and significant numbers of unidentified bats over the field and in the gardens of Folly Chase at night suggest a colony within Folly and/or Betts Woods. Rich flora, especially Bluebells and significant insect species including Wood Ant colonies.

This incredibly diverse range of species rely on the tree and plant species found in Ancient Woodland and on arable farmland. They require free movement between sites and the field, and the large mature Oaks within it, provide essential movement corridors between the three identified LoWs sites. Any development in the field in the center of these three LoWs can only have a massive detrimental effect on the population, and the existing richness and diversity proves this is a site that should be preserved, not destroyed. Consideration for development must cease forthwith.

The ’standing advice’ of the Government in this regard is found within Natural England and Forestry Commission guidance ( https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences). Standing Advice is a ’Material planning consideration’. Ancient Woodllands have equal protection in the National planning Policy Framework.


We draw attention to the RDC’s own statements regarding potential development within the Local Plan document. The plan clearly states that one of it’s key objectives is ‘’for meeting future needs (including housing….). It will also identify areas for protection, such as sites that areimportant for wildlife and open space.’’ The RDC have failed in their policy objective and in following correct process that there is a failure to even identify the proximity of the LoWs detailed above in the Site Allocation Assessment Criteria.
Rather than the site be considered for development, we have shown that it should be identified for protection in accordance with the Local Plan objectives and that it should be removed from the development plan and placed in a protection plan.

Infrastructure- both sites
I have detailed my concerns above regarding the inadequate infrastructure in respect of local roads, access and drainage and sewerage. In addition it is quite clear that other local services are already struggling and would simply be unable to cope with an increase in the local population of approximately 1000 people based on the estimated development potential of the two sites. Local schools, GP surgeries and wider health care have been under significant pressure for many years. Limited local car parking inhibits local trade ( it should be noted that there are several sites used for car parking included in the site allocation potentially limiting it further) and the main Southend/Hockley/Rayleigh Road is far too frequently jammed back to Hawkwell and Hambro Hill. There is no room for dedicated bus lanes or cycle lanes along this main corridor so whatever thoughts there may be regarding increasing public transport usage or cycling are simply pie in the sky and not feasible. The main road simply cannot cope with any more traffic arising from increased housing.

Reduction of Quality Arable farming land-CFS064
I am concerned the Plan may well reduce the acreage available for arable farming. What measures have the council made to ensure we have sufficient acreage available for farming use to enable us to keep feeding ourselves?

Impact on the landscape and community
It is clear that any development at site CFS064 would have a significantly detrimental effect on the environment, biodiversity and the visible appearance of the site. The visual impact will destroy the character of the site and it’s surroundings and the increase in population and traffic would destroy the culture of the existing community within Folly Chase.

Spatial Options Document 2021
Whilst I agree with the Vision Statement for Hockley as detailed in the SOD I cannot see how the proposed development sites would achieve the stated vision. Surely any further development would conflict with the entire Vision Statement, other than the one regarding affordable housing, but as we have seen on numerous occasions building more houses does not link directly to improved affordable housing allocations as builders charge increasingly higher prices. Surely a Central Government led policy on house pricing/profits is the answer?

Q58e asks re the significance of the ‘local green spaces’ but makes no mention of the Local Wildlife Sites. These should be equally regarded and are very significant. I have heard that CFS064 could be considered for re wilding. If so, with it’s close proximity to LoWs it could become an education centre or Country park, accessible to many by foot and cycle. It therefore does need protecting form development as it would help increase the land locally t comply with the Vision Statement and improve the environment and bio diversity for the benefit of the local community.

More Suitable Sites
My introduction acknowledged the need for some developments to comply with Government policy. There is a consensus that Hockley itself cannot cope with more development in the immediate vicinity but the Plan includes sites on the western fringes of the district that are clearly more suitable. The following sites CFS146,147,167,144,168,145,137,055,121 all have far easier access, being close to A127 to London/Southend, A13 to London/Kent and A130, and room to provide additional social infrastructure as well as housing, better transport and potential for more transport hubs, and would keep the majority of traffic away from the existing congested community of Hockley and Hawkwell, and prevent a commensurate increase in pollution, noise and general inconvenience. Because these are bigger they could also attract government funding for local improvement.



Conclusion
As can be seen form my concerns detailed above , sites CFS064 and CFS264 should be removed form the next stage. They are simply not suitable when there are many more sites which would ‘score’ much better under a wide range of development considerations.

Thank you for your time in reading our response

Dear Councillor Simon Wooton,

I hope you are well and a belated congratulations for being voted in leader of Rochford District Council last July.

I purposely write to you as a person of leadership for my area and with genuine interest of your views, given someone in your position will naturally do your very best to put resident interests (amongst other things) at the heart of everything.

I’m namely reaching out to you in relation to the identified or proposed plans for new housing development.

Before I go on, I feel for integrity I should briefly introduce myself and explain what has compelled me to write to you. I’m Jason McGinley, a 47 year old who moved to the Hawkwell area back in 2002/3, I am married, have 3 children (mostly grown up now) and have my Dad living close by. The reason I moved here was to find more space, tranquility, good schooling and the green space. The pace of life here back in 2002/3 was much slower and quieter than I was used to but was just what we looking for, and we integrated quickly and very much appreciated the qualities of local community life and living.

I’m not a man of erratic views or knee-jerk decisions and want for nothing in the main. However, I’ve found myself thinking over the last few years that perhaps it’s time to move on to somewhere which offers what we found here back in 2002/3. The area in ‘some’ ways has developed out of all recognition and has become an area with different dynamics, with seemingly many more people and car traffic and now feels quite claustrophobic and restrictive – feelings which my last area were reminiscent of.

So with introductions out the way, I understand plans seem to include over 6,200 houses across 6 sites with others involved in addition. I’m also mindful of the considerable amount of new housing already developed over last number of years and observe just from them along, a distinct lack of new supporting services / shops / road access - notwithstanding the impact to existing services in the surrounding areas. Specifically on the ‘past’ element effect, I’ve tried not to use the roads at all during weekends due to the traffic congestion stress it brings to me on a personal level.

Before I try to summarise business type reasons of concern, I’m conscious that this type of issue is 1 of many part of the bigger plan you’re responsible for. I also understand that for every past there’s also a present and a future, which requires a lot of balancing, thought and change, Having said all that, I do think there’s a lot of overlap across multiple touch-points, including decision making, and for that reason I’d like to really ‘pick-your-brains’ on the wider view and challenges or pressures you have to factor in to decisions.

For me it’s crucial to understand and differentiate between the directives you’re working to against viable options specific to our district – I’m sure this is something that most residents would have empathy on too?

On the ‘overlap’ I referred to, budget is a big one, as is climate and environment, younger generation, core services and local business. Being in business myself, naturally I can see benefit from creating efficiencies and making strategic decisions which embed and have sustainable impact. Personally I have lots of ideas around both, and am more than happy to impart these as part of resident feedback – should there be good reason to.

I genuinely am really interested to hear the challenges for our district and how you have to balance and manage these as part of a local and central Govt plan, including any personal thoughts presuming you’re a local resident too.

Back to the new housing point, the main aspects of concern or interest are:

1) Road traffic and lack of road infrastructure to deal with this – personally speaking, I can’t even see or understand how implementing new road space will even impact or help with this issue, for example the road in and out of Rayleigh through to Rochford and beyond just can’t cope anymore and neither would the main roads like A127 – we’re simply at ‘tipping point’.
Beyond the local access, those outside our district would find it near impossible to access what our area has to offer without extreme delay or difficulty.

2) Lack of new support services and shops / or impact to existing – such as supermarkets, doctors, hospitals, dentists, car parking, park space, exercise space, public transport and public houses. I often find which situations like this, you hear about conceptual ideas and promises without analysis of numbers before/future and real thought to how this will truly affect these things without having those who work or live on the ground in or near these things.

3) Population – whilst this relates to points 1) and 2) coming back to the qualities and dynamics the area offered back in 2002/3 versus what it’s like now, it just seems that there’s now too many people for what the area can deal with. I’m inclusive but this is something different to simply preferring it less busy.

4) Air pollution / Climate / Environment – for me this all overlaps and whilst more housing will bring more diversity, I just cannot see how for any of these points we will be in a better position ‘locally’, rather the opposite. Any statistical development analysis over last 5 or 10 years would be useful, against what locally and centrally we’re trying to achieve in this space and how more housing will align to the ambition.

5) Green Space / Flooding – again I think this overlaps. Much of the local beauty and attraction is the green space and all that it offers for wildlife and people alike, yet we keep taking it up more and more with concrete. Additionally, the flooding aspect as result and impact to utility service disruption i.e. blockage/flooding. To me this is alarming from both a future risk point of view and personal experiences namely from blocked drains causing both flooding and polluted flooding (from faeces) – which has become much more frequent. Ultimately I presume this is a shared risk for local Council services, budget and disruption too.

6) Youth – there seems to have been a lack of Council driven effort to generate new ideas or services which positively engage youth and the younger generation. This is an aspect I’ve spoken about for years too. There seems to be a whole range of opportunities but possibly a lack of budget, insight or plan to develop it. Additionally, it seems we now live in a world of such heavy compliance / regulation / and process, that bringing these types of things to life take extraordinary time and cost with incredible inefficiency – making them then quite un-attractive to take up. Also getting the right people involved is crucial to success.

7) Crime – I really don’t know the statistics here but do know on experience that it has become a much more frequent occurrence in recent years versus when we first move here. As result, I’m keen to hear what is planned in this regard if thousands of new residents arrive?


I recently saw a Rochford District Council report from 2018 on additional dwelling plans between 2010 – 2025, and attach a screen shot below. In reflection my immediate thoughts were:

• Planned 3,750 dwellings in a 15 year period (2010-2025) versus:

now in 2021 adjusted plans suggest ‘additional’ 6,236 dwellings across 6 sites alone, which seems a huge uplift in comparison?

• How policy can change from 1 year to another completely affecting previous plans
• What additional new dwellings have been developed in the interim period 2018 – 2021
• There were 33,600 dwellings in 2011, how many are there in 2021
• The 2021 Census doesn’t seem to be accessible yet?

I also found a Population chart (per below) which whilst has steadily grown from 2002 – 2018 by 7,656, it seems comparatively fair in relation to new dwellings, which using the above chart (from 2018) of 3,750 new dwellings there were 3,887 additional in population. One could suggest then, that this was driven mainly be ‘new housing’ more than anything else?

I remain interested in your response but for completeness and timing have also copied in the ‘SpatialOptions’ team. Please let me know if you prefer to arrange a face-to-face meeting as part of any response, or, feel free to call me too.

I am sending you a letter with our responses to the questions relevant to the Croudace development in Rochford. I have also attached a copy of the area Croudace propose to build on in relation to Question 57b. I hope you find these comments constructive and informative.

Spatial Options Consultation

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]
We agree with the draft vision for Rochford District, especially in relation to the delivery of high quality homes supported by accessible and responsive services and facilities, creating healthy and sustainable communities.
Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included? [Please state reasoning]
We agree with Strategic Priority 1, Objective 1, facilitating the delivery of high quality and sustainable homes that meet your local community needs. Whilst we agree that previously developed land should be an important part of meeting needs for development, the council needs to be realistic about how much of the district’s need for development can be accommodated on previously developed land.
We agree with Strategic Objective 2 of Priority 1 which states that Rochford need to plan for a mix of homes to support current and future residents. It is important that the council take into account the types of dwellings required when allocating sites, considering the likely sizes and types of dwellings likely to be accommodated on any given site. Sites such as that at Hall Road, Rochford, being promoted by Croudace, offers an important opportunity to provide a diverse portfolio of housing, addressing the affordability issue that Rochford currently struggles with. From 2016-2019 Rochford only delivered 677 of the 876 new dwellings set out in the housing delivery test (2020). This rate of delivery also falls short of the South Essex Strategic Housing Market Assessment of May 2016 and June 2017 which stated that between 331 and 361 new dwellings should be delivered per annum up to 2037.
We agree with Strategic Objective 6 of Priority 1 which states that the council want to ensure that all new homes “are built to the highest attainable quality, design and sustainability standards”. Croudace prides themselves on the quality and design of the housing they build and we are certain we will meet the council’s standards for development.
We agree with Strategic Objective 11 of Priority 3 which wants to encourage sustainable travel within the district such as walking and cycling. Croudace’s two sites, CFS081 and CFS082 at Hall Road in Rochford, are within walking distance of Rochford town centre, encouraging residents to walk or cycle to the town centre. This factor should be given significant weight when appraising possible Greenfield and green belt releases.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required? [Please state reasoning]
We agree with the settlement hierarchy presented as we think it is reasonable to have Rayleigh, the largest town should be at the top of the hierarchy with Hockley and Rochford in tier 2 and the smaller settlements in the tiers below.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan? [Please state reasoning]
Of the identified strategy options we believe Option 2b should be taken forward by the Plan. Option 2b would see urban extensions dispersed to settlements based on hierarchy. We agree that spreading the housing supply across a number of builders is the correct and less risky strategy and means that more housing can be delivered sooner, relieving Rochford of its affordable housing supply shortage. We believe that some of the better sites for sustainable development are within the greenbelt so as Option 2b states, some Green Belt land will need to be released. Option 2 would deliver 3,000 – 5,000 more dwellings than Option 1, which already delivers 3,000 – 5,000 homes, with 1,000 – 2,000 of these new houses being affordable, giving a potential total of 10,000 new houses of which 4,000 are affordable houses. We believe this is the correct solution to solving the affordable housing issue in Rochford. As stated in the 2021 draft Local Plan for Rochford, for every 10 additional homes the local community sees the benefit of creating or sustaining 9 local jobs and bringing in £250,000 in additional local spend from new residents.
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]
For residential development, the Planning Practice Guidance (paragraph 012) is clear that any energy performance standard required by a local policy should not exceed the equivalent of Level 4 of the Code for Sustainable Homes. The building regulations remain the most straightforward way of the country as a whole meeting the challenge of climate change. The Government is working on its Future Home Standard for significantly reducing the carbon emissions of homes, with a challenging but achievable timetable for introduction over the period to 2025. Local policies on the subject can add value where there is a locally-specific justification or opportunity, but the council needs to be clear that the policies it proposes on this front are justified, will add value, and will be capable of implementation without creating substantial duplication of work for both council and applicant that is more simply administered through the building regulations system.
Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas? [Please state reasoning]
The plan should include a place-making charter that informs relevant policies. However, the same principles should not apply everywhere in the district because some policies would not be relevant in a residential development for example.
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]
The principles set out in the draft place-making charter are commendable but it is important that the Council set out in policy what they require regarding place-making in the district. These policies will have to be financially budgeted for and may slow down development.
Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
It would not be necessary to create new design guides, codes or masterplans alongside the new Local Plan as this would create an additional burden on the council and potentially delay the release of the new Local Plan. Any design guides, codes or masterplans could be created once the new Local Plan was published.
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]
The best method to ensure Rochford Council can deliver different types, sizes and tenures of housing is to allocate different types of sites to be available for builders to buy. Ranging from brownfield sites in urban areas to Green Belt land being released for new housing developments, making available different types of sites will ensure a mix of housing types, size and tenure are built. It is also important to take into account when creating policy regarding the development of housing that the demand for different type, size and tenure will fluctuate as the demographic and requirements in relation to services of the district change. For this reason, it is important that some flexibility be designed into the policy when determining what size, type and tenure of housing is to be built on a site and that this be determined when the application is received taking into account the current local housing context. With regard to affordable housing, we expect the council to calculate how many affordable houses they need for a given period so as to not slow down the application process with lengthy negotiations. We also want to raise the issue of all the other policy measures and building regulations that builders have to comply with when assessing the number of affordable houses that need to be built, and taking into account the financial feasibility of these requirements.
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]
For Sites CFS081 and CFS082 at Hall Road, Rochford, Strategy Option 2b would be suitable for the specific housing approach which would see a mix of 1 to 4 bedroom houses built on these parcels of land. The suitable housing tenure for these sites would be a mixture of owner occupation and affordable houses falling under affordable rented tenure and intermediate (shared ownership) homes. What is required to meet the housing needs in these areas are an increased land supply to provide more housing for Rochford. Rochford has become one of the most unaffordable district counties in the country, with house prices increasing by 70% in the past 15 years. The 2016 and 2017 South Essex SHMA calculated that Rochford district council needed to build at least 360 houses for the next 20 years, however, Rochford currently build on average 166 new houses per year, which falls below the government requirement set out in the SHMA. If Rochford continue to undersupply new dwellings, housing-related issues such homelessness and concealed homes, where young people are forced to stay or move back in with their parents longer than they would want to, will become an increasing issue within the district.
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]
By providing well designed, high quality and affordable housing Rochford will be able to attract more potential workers and businesses to the district and prevent young people moving away from the area in search of affordable housing. This will ensure a stable and able work force whilst also providing jobs to the local population during the construction period of the new dwellings.
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?
The foundations of long-term economic growth is through having affordable housing young people can afford. This will decrease the likelihood that they will move away, taking their skills with them, whilst also attracting potential businesses to the area to provide services. Providing this housing will also create new jobs during the construction phase which can up-skill workers over a prolonged period of time.
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?
We believe net gains for biodiversity are best delivered off-site. This ensures there are no unforeseen costs during a development and we believe it is more beneficial to the environment to have biodiversity in specific areas than have it spread through developments.
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]
We think the best plan to ensure Rochford’s town centre remains vibrant is through option 6, specifically providing sustainable connections from any large-scale new housing development to Rochford town centre. Building new housing developments within a 20 minute walk of the town centre is a method of providing sustainable connections to existing town centres, and sites CFS081 and CFS082 fall within these parameters. Additionally, providing accommodation for more residents will provide greater footfall to the businesses within the town centre, further sustaining the services and employment opportunities for Rochford district.
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]
We agree with your vision for Rochford and Ashingdon, however, the allocation for housing has not been covered. Providing new housing will support Rochford and Ashingdon’s town centre business and provide more sustainability to services.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other
We believe that site CFS081 and the eastern part of CFS082 (as shown on the attached plan) should be made available for housing market falling under Strategy Option 2b. This could improve the completeness of Rochford and Ashingdon by providing the required ‘critical mass’ in terms of housing density for additional services such as a more frequent bus services or an additional bus stop on the proposed site. This will improve the site assessments access to a bus service from a 1 to a 5 and improve the access to bus services assessment. Site CFS082 is missing from Figure 45 when it is included on the Interactive Consultation Map. We propose to build on half of the total site, preventing Rochford and Hawkwell coalescing and retaining and protecting part of the metropolitan green belt. With these two sites combined, over 600 houses could be delivered for Rochford, which would provide three main benefits. The first benefit would be to local businesses, as an increasing population would bring additional income to the business, which would allow local businesses to grow. The second benefit is that with an increasing population, other firms would view the district as a viable location to establish themselves in, further increasing employment opportunities in the district and providing more services to the area. The third benefit would be Rochford and Southend Borough District would avoid housing-related shortage issues such as homelessness and concealed households. Building more housing would also prevent young people moving away in search of housing they can afford, preventing an ageing demographic which would present its own challenges to the district.
Q57c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
Sites CFS081 and the Eastern half of site CFS082 should be presumed appropriate for development as they are within sustainable walking distance to Rochford town centre, and therefore offer a highly sustainable way of accommodating the housing needs of the town, a factor which we believe has been given inadequate weight in the council’s published site assessments. As well as meeting housing needs, building these developments would provide jobs over the construction period and prevent homelessness and concealed households becoming an issue within the district. These developments would also increase footfall for local businesses, making local businesses more sustainable, and potential businesses seeing Rochford as a viable area to locate their business. These factors bring the added benefit of greater sustainability to the local businesses and employment opportunities to the wider community.
We acknowledge that sites CFS081 and the eastern half of CFS082 are currently in the green belt. As we are only proposing building on the eastern part of site CFS082, the green belt harm assessment should be re-examined for this site to ensure that it has been fairly appraised relative to all other sites being considered. Limiting development to the eastern part of CFS082 reduces the potential harm caused to green belt purposes, preventing Rochford and Hawkley merging into one another in line with paragraph 138 subsection b of the 2019 NPPF.
The recent development of 620 homes to the east of sites CFS081 and CFS082 has demonstrated that growth of Rochford town in this direction can be successfully accommodated. There is a strip of land along the western edge of that development which remains designated as green belt, providing public open space. We believe the council needs to assess sites CFS081 and CFS082 (east) in light of the fact that the open space there is now not countryside, but is meeting the open space needs of the urban area. If sites CFS081 and the eastern part of CFS082 were to be released from the green belt they would effectively continue the urban area around this open space.
We also question the impact on Built Heritage assessments for sites CFS081 and CFS082 labelled at 1 and 2 respectively. We can only conclude that this low score is due to the nearby Pelham’s Farmhouse, which is a grade II listed building. However, on a site the size of CFS081 there is scope to plan the open space on site so as to minimise direct impacts which may arise to that heritage asset.
We question the assessment for site CFS081 in regards to the access to bus stop being scored at 2. CFS082 assessment scored a 4 and we propose linking the two sites allowing site CFS081 better access to bus stop services, and the area is closer on foot to the town centre. CFS081 and the eastern part of CFS082 are also large enough that they would reasonably be expected to make contributions toward new bus stops and improving bus services. We would also like the access to bus services re-appraised if were given permission to develop on the two sites as the increase in population density may provide the ‘critical mass’ to make the sites viable for the Rochford SS4 1NL bus service to come more frequently then it currently does. This would improve the appraisal score and make the development more sustainable.
The access to secondary schools for site CFS081 is appraised at a level 4 whereas site CFS082 is appraised at the lowest level of 1. With these two sites side by side, with access to the same road network as each other, we question why site CFS082’s access to secondary schools was appraised so low. If needs be, we can provide a financial contribution to a local secondary school to improve the facilities and size of the local secondary school.
We would like the access to town centre for site CFS082 to be reappraised as it is only a level 1 whereas site CFS081 is appraised at a level 4. With the two sites being developed on, a pathway through site CFS081 could be created for site CFS082 allowing it better access to Rochford town centre. The two sites fall within a 20 minute walk of Rochford town centre which should mean the appraisal for site CFS082 is higher.
We also question the appraisal for the access to employment site for site CFS082 at level 2 when CFS081 is appraised at level 4. With both sites having access to the same road network, these appraisals should be the same. We also question if the town centre has been considered as an employment site as it often is a major source of employment within a town. The town centre is only a 15 minute, 1 mile walk away or a 3 minute drive so the access to employment site for site CFS082 should be appraised higher.
We question why both sites CFS081 and CFS082 are appraised at levels 3 and 2 respectively for distance to strategic road network when both have access to the A127 being only 6 minutes away and 2 miles in distance via Cherry Orchard Way.
We would also like the appraisal for access to train services for site CFS082 to be reappraised as site CFS081 is appraised at level 3 whereas the former is at level 2. Through the development, site CFS082 will have access to Rochford train station like site CFS081. Rochford station is only a 15 minute walk or 3 minute drive away from the sites, at a distance of 1 mile from both sites. We therefore argue that the appraisal for access to train services for both sites should be higher.
We would also like the appraisal for site CFS082 proximity to water apparatus to be reassessed as it is a level 1 whereas neighbouring site CFS081 is appraised at a level 5. The River Roach does flow south of both sites and there is Rochford Reservoir only 1 mile away.
The assessment for Critical Drainage Risk for site CFS082 can be improved from a level 2 with implemented drainage systems for the proposed development.
We also question the level two assessment of impact on Ancient Woodland for site CFS082 being at a level 2 when the site is currently used as an agricultural field with no Ancient Woodland currently existing on the site. Site CFS081 with no ancient woodland on it as well was assessed at level 5 for impact on Ancient Woodland.

I would like to add, that if we do not keep our open green spaces, families will have less space to walk, picnic, and to find a way of enjoying our natural world, you have to consider quality of air as more cars will flood the roads, and climate change, the more nature walks
that are built on, the more chance of flooding too. I once again say, this is a stupid plan over populating this area. Please leave Woods, and places of enjoyment alone. Lots of land in Norfolk, to build villiages.

Firstly the Consultation Process. The volume and format of information contained in the consultation was difficult to access and view online. It was difficult to understand the context of the consultation and RDC are not reaching residents who have no internet. It is also very difficult to cross reference when trying to write a response.

In my opinion the most important factor is that Infrastructure needs to be addressed before more housing is added to the area - This is a key concern for residents exacerbated by the volume of recent and proposed development causing additional pressure on roads, education, social services, health facilities and local employment opportunities. In particular our roads and cycle paths are in a very pitiful state of repair and are only likely to worsen with significant further development. The main route, the B1013 is already at full capacity and we the residents have concerns with traffic volumes causing severe Jams, increase in road noise and pollution combined with the very poor state of the roads with potholes etc

The Infrastructure Funding Statement states all financial and non-financial developer contributions relating to Section 106 conditions should be completed but this has not always been the case and is not the case when larger sites are split up. This was evident at the Hall Road development that promised a school and and doctors both of which were promised but not delivered

Open Spaces - The value of our open spaces and the issues with climate change have become a priority. The use of empty buildings and Brownfield sites should be evaluated first and consideration should be given to identifying an area where a discrete garden village with appropriate infrastructure, separate from current settlements, could be created. Prime examples of such working developments include Chelmsford Beaulieu Park and the South Woodham Ferrers development. I believe that approach is much better that the “Pepper Pot” approach in that it does not give residents a clear picture of the local area erosion of space and general slow increases of population that lead to an adverse effect on local infrastructure.

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

The proposal for development on land at Belchamps, CFS074, is particularly worrying due to the lack of open space for activities available to youngsters and community groups in the Rochford District. The site has been a very valuable well used resource and it is important this is retained for our future generations.

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

I consent. To my name and comments being added to the Councils consultation database and understand anonymous comments cannot be accepted.
I would like to be added to the council planning list and consent to my data being stored and processed for the purposes of receiving planning updates by email

Objections to over development
Last week we received a flyer from the Rochford District Residents. I put it to one side with a view to 'read it later'. But what a horrifying read! The list of sites being considered for more housing is crazy.

The subheading 'Infrastructure First' is an understatement. I am aware of the Bloor Homes plan for 660 houses off the Ashingdon Road. But, the other proposed sites 4447 off Brays Lane, 498 near Mount Bovers Lane, 801 near Rectory Road to name but a few. The Ashingdon Road CANNOT take any more traffic and the B1013 gets very heavily congested at times. The Hall Road part of the B1013 has no public transport and the local doctors surgery in Back Lane is stretched as it is.

PLEASE, PLEASE, PLEASE what can be done to stop all this over development? Redevelop, renew the historic town of Rochford putting funds into maintaining the buildings, green spaces, roadways etc not BUILD BUILD BUILD. It will ruin Rochford and all the surrounding villages as traffic will be unavoidable, air quality will be poor and flooding will be on the increase. It should be a quaint little market town with independent shops and cafes encouraged NOT as an outlet for London housing.

Hello in response to the consultation paper I have the following comments/concerns

In response to Q6 I object to further development within Rayleigh (maximising development density under Option 1, Urban extensions under options 2a and 2b)

- The infrastructure will not support further development. In the 3 years I have lived here I have seen a marked increase in traffic and congestion. Rayleigh will become a gridlock preventing access in/out the district
- Further development will erode the remaining historic character and appeal of the town.
- Quality of life is reduced - noise, pollution, congestion , associated social issues that the town was not developed or designed for
- It will have the opposite effect - more densely populated developments will be a dissentive in attracting people into the District to live or visit
- I strongly believe Options 3a and 3b should be considered. introducing a fit for purpose and favoured Garden village, collaborating with our neighbours . This can be introduced with due consideration and sympathetic to the surrounding environment

In general I believe the consultation underrepresents the lack of infrastructure investment needed or how it is constrained possible under options 1 2a, 2b.Or take into account the negative impacts have on circa 40% of the districts population

Q56d I believe that areas adjacent to Rayleigh Mill i.e Mill Hall should not be developed/redeveloped. Reasons similar to above . Centralised congestion, erosion in the quality of historic features. Reduction in public amenity (Mill hall) contrary to planned increases in population and desire to attract in population. Rayleigh town centre then becomes at risk of having no heart or attraction .

In addition I believe that Brookland Park warrants recognition/ongoing maintenance support as a small but significant open space . It offers an appreciation of wildlife features close to the town and nearby schools

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

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

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

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

Site reference: CFS023

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

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

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

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

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


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

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

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

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

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

Dear Sirs
I understand it is important that there needs to be development to meet Government targets.
But I do not believe the constant in-filling of existing communities is the right way to achieve this objective. By so doing the strain on the infrastructure becomes even greater when it is already at an unsustainable level in terms of traffic, medical facilities and schools. For instance the almost daily traffic queues through Hockley and Rayleigh will get considerably worse with any housing development to the East of the district. The piecemeal development also means that the developers have no obligation to make meaningful improvements to the infrastructure.

It would be preferable to build the housing required in one location to the west of the district.
The sites suggested in the spatial plan are much better sites with better access and less impact on the existing infrastructure and the communities of Hockley, Rochford and Hullbridg. Specifically those sites which are close to the A130, Rawreth Lane and London Road and that have the space for large development, additional social infrastructure and transport links. Specifically the sites CFS055, 121, 137, 144, 145, 146, 147, 167, 168. These are all on the Western edge of the district and would therefore protect the existing communities and infrastructure in Rochford, Hockley, Hullbridge etc. from increased through traffic and pollution and would not put further stress on these villages infrastructure including roads, schools, doctors, etc.

In terms of the local plan I have particular reservations with regard to CFS064 and CFS264 with which I am familiar. My concerns are:-

· That access to the sites is very limited, specifically that using Folly Chase, a privately owned and un adopted road that is too narrow, has no footpaths and the residents have ownership rights. The ability to make any adaptions would involve the destruction of numerous trees with preservation orders including ancient oaks.
· It would impact adversely upon the footpaths which are located within these sites and which have proved invaluable during the pandemic for not only exercise but also the mental well being of the local population.
· there is no public transport access to these sites
· Drainage – this has already been an issue with the lack of sewerage connection at Pond Chase and already inadequate fall/capacity to take waste away without any further development
· Elements are within the Green belt and should not be harmed.
· The effect on the Environment and its biodiversity. Specifically, the threat to Ancient Woodland at Folly Wood, Betts Farm Wood and the wood in the North of the Field.
· The effect on the existing Wildlife ‘corridors’ (specifically the badger setts), and the further fragmentation of wildlife habitats by future development.
· My understanding is that should the plan be adopted at site (previously designated Site 179) now CFS064 this would conflict with RDC policy on promoting and preserving Biodiversity
· Removal of valuable quality agricultural land
· Having reviewed the site appraisal paper for Hockley and Hawkwell and the various levels assigned to each criteria I seriously doubt whether any detailed site visits have been made and proper due diligence carried out.

Given the announcements that have been made that there are pending changes of Government legislation relating to planning, I recommend that any further action on the Local Plan is suspended until such legislation is passed, otherwise there is a real risk of wasting a lot of tax payers money on further consultation/planning etc. that may subsequently be prevented or altered by policy changes.
To Conclude
To meet the housing needs all housing should be built in 1 of the 3 locations which have been identified. (Option 3 on the consultation document).
In addition CFS064 and CFS264 should be removed from the next stage of the plan.

Seetec – Introductory Comments
With our head office in the Rochford district, we are one of the UK’s largest employee owned businesses, employing over 2,000 people and committed to building our history of service.
We help people in the UK and Ireland to increase their social and economic stake in society. We do this by providing skills, training and support services that people need to reach and exceed their ambitions, creating positive change for the communities we serve
Our aim has always been to change lives for the better. Founded more than 35 years ago as a small charity, we first taught IT skills to 30 unemployed young people at a former primary school in Hockley. From these humble beginnings, we now help hundreds of thousands of people find work, learn new skills and take ownership over their lives.
We understand the needs of the people we support. As employee owners, we now want to drive further improvements and continue to generate enduring positive outcomes for the people and communities we service.
As a B-Corp organisation we are business committed to social value by reducing inequality, working toward lower levels of poverty, a healthier environment, stronger communities and the creation of high quality jobs with dignity and purpose.
We care passionately about the District, its environment, open spaces, heritage and sustainable living. Our business has made a long term contribution to the District and this response is intended to reflect our on-going ambition to make Rochford district a first class place for health & wellbeing, work, learning and leisure. The choices the Council makes over the next 35 years will be key to this ambition.

Consultation Representations
Our responses and representations to the questions from the above consultation are set our below. We have replied to some specific questions and used cross references where appropriate to avoid duplication.
• Introduction
o
 Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
Agree
 Q4. Do you agree with the strategic priorities and objectives we have identified?
Agree
• Strategy Options
 Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
We prefer taking forward Option 4 Balanced Combination with the following comments, preferences and concerns regarding risks.
In general, the preference is for a ‘selective’ ‘Strategy Option 4’ approach by combining Strategy Option 1 Urban Intensification; Option 2 Urban Extensions and Option 3a Concentrated Growth in the west of Rayleigh. This would need to be in specific sites and it will be easier to quantify for housing targets if we were to identify sites that we would not support.
We would not support Option 3b North of Southend and 3c Focused East of Rochford and the land allocations from Rochford to Hockley in the 2017 Strategic Housing and Employment Land Availability as well as some other sites in Lower Hockley and Rayleigh. These are transport infrastructure and risk related objections whilst there are others that negatively impacting heritage, character and setting.
The specific areas of allocations of concern are listed below:
CFS035 land west of Rochford hall 1.25 hectares
CFS041 Lee valley farm 2.54ha
CfS074 land south of Mount Bovers Lane 14.22ha
Cfs077 land north of Great Wheatley’s Road 7.5ha
CFS084 land south of hall road 7.16
CFS085 land west and north of Hall Road 2.22
CFS087 land between Western Road and Weir Farm Road 3.08
CFS121 land north of A127 38.48
CFS150 land on the north side of Victor Gardens 1.73
EXP12 land adjacent 44 Great Wheatley Road 0.12
These will exacerbate the B1013 ‘rat run’ causing huge congestion and comprised emergency evacuation with the potential risk of:
• global warming repeating ‘1950’s scale flooding’ in South East Essex,
• nuclear contamination (Bradwell) and
• airport / rail disaster.
Any development must be matched by adequate transport solutions. Until this document is available then it is difficult for consultees to make informed representations and the Council to make evidence based decisions. The whole approach is somewhat ‘chicken and egg’. The transport solution should be the first document given the historic challenges and earlier consultation responses. Once this is available, the context of spatial options can be evaluated on sound evidence as community and population safety will be of paramount concern.
Assuming there is no radical bypass, which we would not support anyway given the intrusion into Crouch Valley conservation, solutions must be found to the key rail bridges and Rayleigh Weir underpass. These are high risk pinch points for local population and egress in particular:
Rochford Bridge / Hall Road
Hockley Bridges (Greensward Lane & Church Road)
Rayleigh station (London Road)
A127 Weir underpass
As a minimum, solutions must be found to these bottle-necks - widening the bridge underpasses, flyovers etc. If certain developments were to go ahead, flooding and the increased congestion of Options 3a, 3b and the proposed allocations along B1013 will potentially lock-in and lock-out population from their homes, shops, work and living in safe communities.
• Employment and Jobs
 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?
Any growth must be contingent on the transport infrastructure comments in this representation, without this future growth is limited. In addition, it is important for quality of living that night flights are stopped and pollution and noise controls are enhanced.
• Green and Blue Infrastructure
 Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?
We refer you to our comments and sites outlined at Q6.
• 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?
Remove allocations that threaten the key heritage sites in the District e.g. CFS035, CFS084, CFS085
 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?
Grade 1 Rochford Hall and setting.
Rochford Conservation Zone
Crouch Valley
• Town Centres and Retail
 Q48. With reference to Figures 38, 39 and 40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
As regard Hockley town centre we have previously stated our preference to develop an imaginative town setting that brings Hockley Woods into the town e.g. shop ‘timber’ facades, woodland street furniture etc thus celebrating the setting of Hockley in its ancient woodlands and Spa.
• Transport and Connectivity
• We refer you to our responses under Q6 and Q28

 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?
We refer you to our responses under Q6 and Q28
 Q52. Are there areas where improvements to transport connections are needed?
We refer you to our responses under Q6 and Q28
 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.]
We refer you to our responses under Q6 and Q28

• Planning for Complete Communities

Rayleigh
 Q56d. Are there areas that require protecting from development?
CFS77, CFS087 and EXP12
Rochford and Ashingdon
 Q57d. Are there areas that require protecting from development?
CFS035, CFS084, CFS085 (see Q43 response above)
Hockley & Hawkwell
See representations at Q48
 Q58d. Are there areas that require protecting from development?
CFS041, CFS074, CFS150

I list the following objections;

To build more than 6000 houses mostly all of which will need access onto the B1013, seems to be severely overstretching matters. If you assume an average of 1.5 cars per property, you are left with almost 10000 cars using already overused roads. Also, where will they all be going, there are probably not enough job vacancies in this area, so the likelihood of greater unemployment should be realised.
This assumes most will be using cars but what if not, there is not really a bus service to cope with this much extra load and should some wish to commute to London for work, the train service is hardly adequate, or for that matter, reliable. The amount of road accidents will surely increase, stretching emergency service still more. If CFS261 goes ahead, more children will be involved in accidents as the proposed new road is to be accessed via a new roundabout right outside Holt Farm School.
Children in these developments will be struggling to find school spaces and we already have fully occupied schools, so what next. The subject of young children also brings up the questions of air pollution from a greater traffic flow, and the need for more Dentists and Doctors. It can already take hours to try for a G.P. appointment so this will soon become completely overwhelmed.

Thank you for the chance to provide comments and initial observations to this vast and extremely complex subject. Emotions will run high on this sensitive initiative which will cloud some of the critical issues that need to be resolved.

Whilst I feel the over consumption of our open spaces and converting these into housing and/or commercial buildings is not in the best interest of the community as a whole, the reality is we need to provide affordable and appropriate housing for our ever increasing population. As such I’m not necessarily contesting the sites themselves but rather, sounding concerns and the clear basic needs that this major scale of building demands. I believe the key points have been trapped/identified in your various documents but what's absolutely vital is that we simply do not flag these points simply as a tick box exercise but rather, effect real actions that will address the major impacts.

1. Infrastructure – this is pretty obvious and it not only centres around the supporting roads for the new sites but equally, wider consideration to the roads that feed Hockley, Hawkwell, etc. As numerous people have already pointed out, the traffic congestion into and out of these places is pretty dire and adding more homes, businesses will only exacerbate this situation further. Just acknowledging this and failing to take mitigating action is no longer acceptable. As our leaders and management of local the communities your roles are to ensure you take sound and well considered decisions that properly measure the whole picture. Implementing further building programmes (through more housing, etc) whilst at the same time, tinkering around the edges of the supporting infrastructure is no longer acceptable nor truly viable. Infrastructure also extends to the drains and the ability to soak away the rainfall and occasional flooding that we sometimes experience. Equaly, it extends to proper maintenance and investment of services to support these additional solutions so that they continue to be fit for purpose.
2. Services – the ever increasing of new residential homes brings an increase in demands on Doctors, Dentists, Schools, nursery’s , sewage, broadband, and so forth. Some of these services are failing to provide the appropriate level of support to the community today, adding more residents into the mix will drive the levels of frustration even further when people are unable to access these services in a reasonable timeframe. Yes funding cuts make this a challenging issue but increasing demand on these basic services at the same time obviously makes the situation worse.
3. Floodplains –We all recognise climate change and the worsening impacts we are witnessing in our day to day lives, is it really sensible that we path over further parts of our green and open spaces within the areas we live. We need flood management solutions that can combat this increasing risk to our environment.


I fully appreciate the above are major factors that are not quick fixes, require significant investment and asks for strong leadership form those empowered. But reality is, we have been expanding our community by large scale housing developments (house building) for many many years now but failed to properly develop fundamental infrastructure plans along the way. We need investment in these areas to cope with the growing residents numbers. At some point, the demands on the infrastructure become overwhelming and it can no longer properly function. In many cases, we are beyond that tipping point already.

1.0 Introduction

1.1 These representations are submitted to the Rochford Local Plan Spatial Options (RLPSO) on behalf of M Scott Properties Ltd (‘Scott Properties’) in relation to Land North of Doggetts Close, Rochford (‘the Site’).

1.2 The Site has previously been submitted into the Call for Sites, reference CFS217, with representations submitted to the Issues and Options consultation in 2017.

1.3 Scott Properties is promoting the Site for specialist accommodation for the elderly to meet an identified need. The benefits of such accommodation include the provision of the homes themselves, and that it enables people to ‘rightsize’, releasing typically larger family homes back into the general market.

1.4 The Site is currently located within the Green Belt, this being the only significant constraint in bringing forward this land for specialist accommodation. The Site is otherwise unconstrained and is in a sustainable location, particularly for the specialist homes proposed.

1.5 These representations are also accompanied by a Summary Vision Document (Appendix A) to provide further information on the Site and the proposals for specialist accommodation.

2.0 Response to Spatial Options Consultation Questions

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 Strategic Objective 2 refers to providing a mix of homes, including support for the ageing population. However, this is referred to as being through the provision of private and social care schemes.

2.2 Whilst some older people will need to utilise a care scheme, many do not and simply need access to more appropriate housing. This includes the provision of bungalows, which can provide an attractive option for people as they age and as mobility may become more challenging.

2.3 Age-restricted bungalows sold on the open market also provide residents with an opportunity to retain the freehold ownership of their home, something that Scott Properties has found is desired by many older people.

2.4 Providing such housing gives people an option to ‘rightsize’ into suitable accommodation at an earlier stage in their life and can help avoid unnecessary falls and mobility issues later in life, when moving home can also become more of a challenge.

2.5 Strategic Option 2 should recognise the importance of providing such homes alongside the provision of care schemes.

Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.6 Rochford is home to a wide range of services and facilities and we agree that it should be highly ranked within the settlement hierarchy. As one of the larger settlements in the District, it is important that this is recognised so that proportionate growth reflecting its characteristics can be directed to it.

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

2.7 Any option taken forward should also recognise the importance of providing suitable homes for older people. With the ageing population in the District and a 46% increase in over 70s by 2040 compared to current levels, it is particularly important that suitable housing is provided.

2.8 Specialist homes should be located in sustainable locations so that residents have easy access to services and facilities within close proximity. To reflect this, such sites should be within or at the edge of existing settlements, in locations that provide easy access to local amenities.

2.9 There are limited potential sites within existing settlements, and these are in any case often either too small to accommodate specialist housing as part of a mix of dwellings, unsuitable for such a use, or unviable. Edge of settlement sites are ideal for providing specialist housing schemes as they are well located in relation to services whilst being large enough to deliver a sufficient quantum of homes to create a local community, and more likely to be viable for such development.

2.10 As part of any strategy for growth, in order for the Local Plan to be sound, it will be necessary to direct a relatively large proportion of housing growth to Rochford. The Rochford and Ashingdon area is categorised as a top tier settlement within the current Development Plan, i.e. it has been confirmed as one of the most sustainable settlements to which to direct additional growth.

2.11 As the RLPSO recognises, Rochford and Ashingdon together form a functionally-connected 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 facilities.

2.12 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.

2.13 Development around Rochford and Ashingdon forms part of Strategy Options 2 and 3, with a potential urban extension under Option 2 and larger scale concentrated growth under Option 3. Under Option 4, it could also form part of the strategy, with this comprising a mix of previous options.

2.14 Given the existing size of Rochford and the services and facilities available, it will be important for any option taken forward to include growth directed to Rochford. This is of further importance given the need for housing in the short and medium term, with housing adjacent to the existing settlement of Rochford able to be delivered quickly given the infrastructure already available.

2.15 In relation to Option 1 (urban intensification), we do not consider this to be a realistic option on which to base the Local Plan strategy.

2.16 The RLPSO describes this option as making best possible use of 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).

2.17 The RLPSO suggests that at least 4,200 homes will be built over the next 10 years under Option 1 and notes 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.

2.18 Clearly, it will be appropriate for the Local Plan to encourage an element of urban intensification and the efficient use of previously developed land to help meet housing needs. However, the approach cannot be relied upon to meet development needs in full.

2.19 The NPPF (paragraph 60) stresses that it is a Government objective to significantly boost the supply of housing and to meet local housing needs. Furthermore, as per paragraph 35 of the NPPF, it is a specific requirement of a sound Local Plan for it to seek to meet the area’s objectively assessed needs, as a minimum.

2.20 Option 1 alone cannot meet objectively assessed needs in full. The RLPSO suggests a need to plan for at least 7,200 additional homes, but that Option 1 would only deliver 4,200 homes over 10 years. This would leave the District significantly short on housing.

2.21 In any case, we question whether it is realistic to project delivery of 4,200 homes over 10 years through such an approach. To provide this number would require an average of 420 homes to be delivery per annum over a 10-year period. The Council reports that between 2010 and 2020 the District average was 176.8 dwelling completions per annum. It also reports that this number included contributions from strategic site allocations made by the Rochford Allocations Plan. It is totally unfeasible, therefore, to suggest that this rate can be more than doubled without any further allocations, particularly when one considers that there is only a finite supply of previously developed land suitable and viable for residential redevelopment, much of which is likely to have already been redeveloped.

2.22 One of the tests of soundness for a Local Plan is its effectiveness – whether it is deliverable. We do not consider that a strategy which relied on urban intensification to deliver 4,200 homes would be effective.

2.23 A further concern with a strategy that relies principally upon urban intensification is its ability to deliver the types and tenure of homes that are required. It is likely urban intensification would deliver primarily smaller dwellings and on individual sites each comprising a relatively small number of dwellings. As such, this approach is unlikely to provide a range of different accommodation types to meet the needs of all future residents. Furthermore, it is unlikely that this approach would deliver a range of different tenures of accommodation, including affordable housing, in a manner that may be expected from larger developments. Additionally, it is unlikely that such sites will be able to deliver other community benefits on top of housing, or significant infrastructure improvements.

2.24 We would also question whether a strategy that sought to significantly increase densities would be appropriate for the District. Such an approach is likely to be of detriment to the character of the District’s settlements, and potentially harmful to the amenity of existing and future residents.

2.25 We consider that in order to ensure a sound Local Plan, deliver sustainable development that meets the needs of all of the District’s residents, and to formulate a Local Plan that complies with national policy, it will be necessary to revise the existing Green Belt boundaries and allocate additional sites for development.

2.26 It is entirely appropriate for revisions to the Green Belt boundary to be made through the Local Plan, as the NPPF confirms at paragraph 140. The NPPF also states that alterations to the Green Belt 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.
2.27 Exceptional circumstances are not defined in national policy or guidance. However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:

• the scale of the objectively assessed need;
• constraints on supply/availability of land with the potential to accommodate sustainable development;
• difficulties in achieving sustainable development without impinging on the Green Belt;
• the nature and extent of the harm to the Green Belt; and
• the extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.

2.28 Given the scale of the District’s objectively assessed need, and the inability to sustainably meet the range of different needs without revising the Green Belt boundary, it is evident that there are exceptional circumstances that justify alterations to the Green Belt through the Rochford Local Plan. The Local Plan will need to make revisions to the Green Belt boundary in order to provide a sound, sustainable strategy for the District.

2.29 As such, this directs the Local Plan towards Options 2, 3 or 4.

2.30 Under Option 2, sites could be utilised at the edge of sustainable settlements, which should include Rochford, to deliver a range of housing growth. This option provides the flexibility to utilise smaller sites to deliver homes earlier alongside larger sites to meet the overall housing need.

2.31 Both Options 2a and 2b include development to the east of Rochford, which we consider is appropriate and necessary to assist in meeting the housing need, direct growth to sustainable locations and provide choice for residents.

2.32 Option 3 comprises concentrated growth of 1,500+ dwellings. A potential location is shown to the east of Rochford, Option 3c. Whilst this scores negatively in the Integrated Impact Assessment (IIA) in relation to landscape, environmental quality and natural resources, some of these impacts will depend upon the exact scale of development chosen and there are likely to be opportunities to utilise smaller sites which can come forward sooner and may have less of an impact.

2.33 In relation to environmental quality, this negative effect seems highly uncertain given that the impacts on air quality cannot be known at this time, especially considering that mitigation could be provided if needed.

2.34 Option 4 comprises a balanced combination of the previous options. This scored most highly within the IIA given the flexibility to provide a tailored approach.

2.35 We agree with this conclusion and consider that Option 4 will provide the best approach to meeting housing, and other needs, within the District. For specialist homes for older people in particular, it is important that specific sites are allocated in sustainable locations to meet this high need. A balanced approach under Option 4 gives the flexibility to be able to do this.

2.36 The Site promoted by Scott Properties is in a sustainable location and can deliver specialist housing for older people (in the form of bungalows) early in the Plan period. The location of the Site adjacent to the existing developed area of Rochford enables it to utilise existing infrastructure and it could form part of Options 2, 3 and 4.

2.37 Whichever option is taken forward, the allocation of the Site to provide housing for older people should form a key part of this to deliver much needed homes to meet the requirements of the ageing population of Rochford.

Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas?

2.38 Any place-making charter should reflect that areas of Rochford District are different to one another and that different forms of housing have their own characteristics and requirements.

2.39 Providing specialist housing for older people, for example, requires a different approach to traditional family homes, with different requirements and character of development. Bungalows require a greater land take than two-storey homes, with it important to consider and reflect this to ensure that design is not stifled and schemes can respond to their surroundings and individual requirements.
2.40 Should the Council wish to provide a place-making charter, it will be important that this is through engagement with stakeholders, including developers, especially in relation to specialist housing.

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?

2.41 To provide suitable specialist homes for older people, it is important that these are carefully considered and specifically allocated for.

2.42 Whilst requiring all new homes to be built to Part M4(2) and a proportion to Part M4(3) of the Building Regulations can help ensure homes are available for a wide range of people, it does not specifically ensure provision of homes to meet the needs of older people, as the NPPF instructs. At paragraph 61 of the NPPF, it emphasises the need to ensure the housing needs of different groups, including but not limited to older people and people with disabilities, are met.

2.43 It is necessary for the new Local Plan to specifically consider the housing requirements for older people, and make specific provision, rather than meeting this through a requirement for housing to be generally in compliance with Parts M4(2) or M4(3).

2.44 The best way to plan for housing for older people is to allocate specific sites to meet this need. This then allows such sites to come forward without needing to try and compete with developers seeking to build general open market housing, which specialist housing providers are often unable to do.

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?

2.45 The recognition of the need to plan for specialist housing is welcomed.

2.46 However, this should include housing for older people.

2.47 The housing needs of older people have often been overlooked, to the detriment of older people, as well as the housing market more generally. The housing needs of this ageing population are not being met at a national level. A 2020 study by the Centre for the Study of Financial Innovation found that since 2000, retirement housing has only accounted for 2% of all new homes built nationally – around 125,000 homes. However, each year approximately 700,000 people in the UK turn 65.

2.48 Separately, the increasing under-occupation of the national housing stock caused by a rapidly ageing population has been blamed for a dysfunctional housing market, in which first-time buyers find it difficult to get on the housing ladder and families find moving to larger homes prohibitively expensive.

2.49 The NPPF requires (paragraph 61) planning to meet the housing needs of different groups, including but not limited to older people and people with disabilities, are met.

2.50 Planning Practice Guidance (PPG) is clear on the importance of planning for housing to meet the needs of older people. The PPG expressly states:

“The need to provide housing for older people is critical” (Paragraph: 001 Reference ID: 63-001-20190626, emphasis added).

And;

“The provision of appropriate housing for people with disabilities, including specialist and supported housing, is crucial in helping them to live safe and independent lives.” (Paragraph: 002 Reference ID: 63-002-20190626).

2.51 The NPPF recognises that ‘older people’ are not a homogeneous group, but that older persons have a variety of differing accommodation needs. It defines older people for the purposes of planning as:

“People over or approaching retirement age, including the active, newly retired through to the very frail elderly; and whose housing needs can encompass accessible, adaptable general needs housing through to the full range of retirement and specialised housing for those with support or care needs”. (NPPF Annex 2)

2.52 The PPG confirms the need to recognise that there are multitude of different types of specialist housing designed to meet the diverse needs of older people, and that needs cannot be met simply through extra-care or sheltered housing. It notes that specialist housing for older people includes age-restricted general market housing. It states that this type of housing is generally for people aged 55 and over and the active elderly, and that it may include some shared amenities such as communal gardens, but does not include support or care services.

2.53 The PPG also states that specialist housing for older people can include retirement living, with limited communal facilities and generally without care services, but with some support to enable independent living (for example, the potential for 24 hour on-site assistance through an alarm system).

2.54 Many people do not require care but wish to ‘rightsize’ into a more suitable homes, often releasing equity in the process. With the ageing population expected to significantly increase in the District, as the RLPSO acknowledges, it is important that suitable homes are provided accordingly.

2.55 Currently residents are often left with no choice but to remain in larger family homes, sometimes as a single person household. Scott Properties’ proposal seeks to provide older people with an option at a point in their life before they require care.

2.56 Providing suitable homes in, and close to, existing settlements allows people to remain within their local community in more suitable housing. Providing a cluster of specialist homes together can create a community within the scheme itself, a further benefit of allocating specific sites.

2.57 In addition to the obvious benefit to older people who would directly benefit from the provision of such accommodation, an attractive rightsizing option for older people which still allows them to live independently and own their own home can help reduce the under-occupancy rate of the existing housing stock, and free-up larger dwellings for families currently in housing need.

Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing?

2.58 Whilst we agree with the principles of the vision, it should also include the provision of suitable homes for older people to enable them to live in appropriate housing in their local community, reflecting that this is evidently an important issue for the District and one the NPPF instructs Local Plans to address.

Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?

2.59 The Site promoted by Scott Properties (CFS217), should be made available for specialist homes for older people.

2.60 As set out above and reflected in the Spatial Options document, the District has an ageing population and it is important to deliver new homes to meet this need, as required by the NPPF.

2.61 The provision of specialist homes also has a further benefit that it releases larger family homes back into the general market as residents move out of those homes and into more suitable homes.

2.62 To reflect the differing needs of older people in respect of housing, the Site should be allocated to provide specialist housing in the form of bungalows.

2.63 The Site is located in a sustainable location close to existing services and facilities, with many within walking distance. As a triangular and relatively small arable field it is currently underused and could be utilised much more efficiently to provide homes suitable for older people.

2.64 New residents on the Site would bring an additional benefit in terms of increased spend in the local area, helping to maintain the vitality and viability of Rochford town centre and support the proposed Vision Statement for the town centre as set out in the RLPSO.

2.65 It should be recognised that the development of the Site for specialist housing for older people would have a very different impact on local infrastructure than a general residential allocation. For example, it does not have any impact on early years, primary or secondary school infrastructure. In addition, it has a very different impact on the highway network, generating very little additional traffic at peak times compared with a general residential development. Not only are there likely to be significantly fewer vehicular movements associated with commuters generated by this development, but there will also be a lack of traffic generated associated with the school run. This is of particular relevance given the significant impact vehicular movements associated with transport to and from schools has – the sustainable transport charity Sustrans estimated in 2014 that school traffic contributed, nationally, to 24% of all traffic at peak times.
2.66 The Site itself is currently constrained by being designated as Green Belt, but has no other constraints as recognised in the SHELAA 2020. This recognised that the Site is deliverable, achievable and potentially suitable (subject to Green Belt review).

2.67 The Stage 2 assessment within the Council’s Green Belt Study 2020 states that the Site’s designation within the Green Belt limits harm to the Green Belt beyond. However, this is not a reason for keeping the land within the Green Belt. If the Council considers the wider land necessary to remain within the Green Belt that is a different consideration to whether the Site itself should be released from the Green Belt, and this should not be a reason for keeping the land as Green Belt.

2.68 In respect of the purposes of the Green Belt, the Site is contained by a Local Wildlife Site to the west and north, Doggetts Chase to the east and Rochford itself to the south. The Site is not located in close proximity to another settlement and its development would not result in actual or perceived coalescence.

2.69 Whilst Rochford does have numerous listed buildings, development of the Site will not adversely impact these and is such would not harm the historic setting of the town.

2.70 Whilst the current boundary to Doggetts Chase itself is relatively open, the hedgerow to the east of the track does provide a defensible boundary and there is an opportunity to provide significant new landscaping and a new boundary to the open countryside beyond.

2.71 A Green Belt Report in respect of the Site has previously been prepared and submitted to the Council, and is re-provided again here for completeness as Appendix B.

2.72 Overall the Site is in a sustainable location and well-placed to provide much-needed specialist homes for older people. Its removal from the Green Belt will enable this unconstrained Site to start delivering homes in the early part of the Plan period to meet the needs of the ageing population, with other resultant benefits for the District.

2.73 As set out above, the allocation of the Site can form part of strategy Options 2, 3 or 4. It could be an urban extension under Option 2, form part of larger scale development under Option 3, or either Option under 4. Whilst we consider that Option 4 is the most appropriate, the allocation of the Site to meet a specific need should be part of any option taken forward, as any sound strategy will need to include sites that can sustainably deliver in the short-term, and sites that can meet the needs of older people – allocation of CFS217 does both. 

3.0 Response to Integrated Impact Assessment

Assessment Framework

3.1 We welcome the recognition within the Integrated Impact Assessment (IIA) (at A.3) that “delivery of suitable homes for an ageing population…is a particular issue for the district”.

3.2 Furthermore, we agree with the findings of the IIA at A3 that medium and higher growth options provide greater opportunity for a wide range of different types of homes to be delivered, including specialist housing for older people.

3.3 However, we are concerned that, despite the recognition of this as being a particular issue for Rochford District, there is otherwise very little within the IIA regarding the need to ensure appropriate accommodation for older people is delivered.

3.4 Table 1.1 of the Integrated Impact Assessment (IIA) sets out the assessment framework for the IIA. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identify. We support these objectives.

3.5 The IIA then sets out assessment questions intended to be used to assess whether options will meet these objectives. This includes:

Will the option / proposal promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?

And

Will the option / proposal meet the identified objectively assessed housing needs, including affordable, for the plan area?

3.6 We suggest that, given the requirements of the NPPF and PPG to address the diverse range of accommodation needs for older person, together with the acknowledgement that delivery of suitable homes for ageing population is a particular issue for the District, the IIA should include an assessment question which specifically asks whether options / proposals would help meet the accommodation needs of older people.
 
4.0 Conclusion

4.1 These representations have been submitted in relation to Land North of Doggetts Close, Rochford, to promote the allocation of the Site to provide much needed specialist accommodation.

4.2 The Site has previously been submitted into the Call for Sites, reference CFS217, with representations submitted to the Issues and Options consultation in 2017.

4.3 As set out, we consider that Strategy Option 4 will be the most appropriate to utilise a range of different options across the District and seek to provide housing across the Plan period. Option 4 should include some smaller sites in already sustainable locations which can start delivering earlier in the Plan period, being highly important given the high housing needs.

4.4 Being located adjacent to the existing developed area of Rochford, Scott Properties’ Site at Land North of Doggetts Close is one such site that is in a sustainable location and capable of delivering homes quickly.

4.5 The only significant constraint to the Site is the current Green Belt designation. As detailed above, the Site does not make any meaningful contribution towards the five purposes of including land within the Green Belt, with this designation preventing a sustainable site from delivering much needed homes for older people. The Local Plan provides an opportunity to rectify this and remove the Site from the Green Belt.

4.6 As recognised within the RLPSO, the District has an ageing population and, as set out in national policy and guidance, it is important for the Local Plan to seek to meet the needs of this age group. Whilst some older people will unfortunately require a care home or sheltered housing, many people simply wish to ‘rightsize’ whilst maintaining their independence. The Local Plan must reflect this and allocate specific sites to meet this need, as otherwise it risks failing to meet an identified need contrary to national policy.

4.7 Scott Properties’ Site at Land North of Doggetts Close is well located to provide bungalows for older people to help meet this need, providing residents with a choice of housing whilst enabling them to live independently in their local community. The accompanying Summary Vision Document provides further information about the Site and the proposals but we are also keen to discuss further with the Council to support its allocation.

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

2. Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

3. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

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

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley?
How can we also ensure our village and neighbourhood centres remain vibrant?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

Rochford District Council – Land to the north of Sutton Road, Rochford
Representations to the Spatial Options Consultation
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local Plan.

Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
1.2. Claremont Planning on behalf of Southern and Regional Development’s Ltd are generally supportive of the settlement hierarchy proposed. Rochford is identified as a ‘Tier 2’ settlement within the hierarchy recognising the settlement’s sizeable population and comprehensive local service base. Whilst it is acknowledged that Rochford has a considerably smaller population than
that of Rayleigh, meriting its location below Rayleigh within the settlement hierarchy; the placement of Hockley and Rochford within the same ‘Tier’ in the hierarchy is disputed. Although the populations are of a similar size, the proposed settlement hierarchy fails to account for the
strategic location of Rochford adjacent to London Southend Airport. The close proximity of Rochford to the airport provides the settlement with key transport infrastructure which connects Rochford to the wider South Essex region and rest of the country. As such, it is considered that Rochford should be distinguished from Hockley within the proposed settlement hierarchy by
virtue of its local and nationally strategic location.
1.3. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy In accordance with the provisions of Paragraph 16 of the National Planning Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is
advisable that the overall distribution of growth is informed by this imperative and larger quantum of growth apportioned to those settlements which are identified by the hierarchy as being most sustainable. The proposed settlement hierarchy acknowledges the sustainability of Rochford for development, whilst these representations have also sought to illustrate the strategic location of
the settlement due to the presence of the London Southend Airport and its planned continued expansion to provide additional employment floorspace and associated employment opportunities.

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

Strategy Option 1: Urban Intensification
1.4. It is advised that Strategy Option 1: Urban Intensification is not advanced. The current standard
method identifies a housing requirement of 7,200 dwellings in the district across the next 20 years however the consultation document establishes that approximately only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
1.5. It is recognised that Strategy Option 2, which seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would therefore see the largest quantum of growth apportioned to the most sustainable settlement settlements within the District as established by the proposed settlement hierarchy and it is therefore recommended that growth at sustainable settlements such as Rayleigh and Rochford should be prioritised if this option is taken forward.
1.6. Moreover, the land north of Sutton Road at Rochford as promoted by Southern and Regional Developments, has been identified within the initial appraisal undertaken by the Council as making a potential contribution to Strategy Option 2. It is agreed that the promoted land off Sutton Road could make an effective contribution to the delivery of this Strategy Option where the land abuts established areas of residential development at the settlement and is located in close proximity to employment opportunities at the Purdeys Industrial Estate. As such, the land at Sutton Road is considered to represent a logical location for the further expansion of Rochford should Option 2 be advanced by the Authority.
Strategy Option 3: Concentrated Growth
1.7. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead-in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond. As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of these allocations arise. Topic Paper 9: Housing prepared in support of the
Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing completions to meet the local housing need identified for the new Local Plan. The
Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider allocating sites of a variety of sizes which can be builtout relatively quickly and make a more immediate contribution to housing supply.
Strategy Option 4: Balanced Combination
1.8. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2). Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s
housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not adversely affect housing delivery in the District.
1.9. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing
that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. As established, the land at Sutton Road as promoted by Southern and Regional Developments has been assessed by the Council under reference CFS067 within their 2021 Site Appraisal Paper prepared in support the Spatial Options consultation. Within this assessment, the land at Sutton Road is positively considered by the Authority and its availability and deliverability for residential development recognised.
Moreover, Claremont Planning assert that the Council should recognise that the land at Sutton Road performed strongly through this assessment in relation a wide variety of criteria including but not limited to flood risk; landscape harm; site hazards and conditions; and access to facilities and services. As such, the land at Sutton Road should be strongly considered for allocation
through the emerging Local Plan, given both its environmental, and social sustainability.

2. Spatial Themes
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood
risk and coastal change?

2.1. National policy, chiefly paragraph 161 of the NPPF is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the District is influenced by high flood risk that is likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rochford and Rayleigh which are the areas within the District
at lower risk of flooding.
2.2. The land at Sutton Road promoted by Southern and Regional Developments represents a suitable location for development if the sequential approach to flood risk is adopted. Although an inappreciable area to the extreme south east of the land is located within Flood Zone 3, the
Environment Agency’s flood map for planning identifies that this area of the site also benefits from flood defences; whilst the rest of the land promotion is located within Flood Zone 1, being at low probability of flooding. 2.3. Within the 2021 Site Appraisal Paper, the Council identified that the promoted land at Sutton Road performs very strongly in relation to flood risk, recognising that this small area of flood risk on site is not detrimental to the land’s deliverability. The pragmatic approach advanced by the Council in relation to flood risk on site is therefore supported. Moreover, any development scheme proposed on the site would be designed such to sensitively respond to the risk of flooding on site, through the promotion of this area as public open space. This would ensure that flood
risk on site can be suitably accommodated whilst also enhancing the quality of any development scheme pursued through the provision of high quality public open space. Given that the vast majority of the promoted land at Sutton Road is sited within Flood Zone 1, alongside the Council’s recognition that the site performs strongly in respect of flood risk, Claremont Planning consider that the development of this land would be in accordance with the recommend sequential approach to flood risk in the Plan.

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

3.1. Meeting the need for different types, sizes, tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2 is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and mid-sized semi-detached and detached dwellings.
Claremont Planning consider that the release of Green Belt land, including the promoted land off Sutton Road should be strongly considered by the Council whereby the release of this land will both assist the Council in meeting their overall housing need, and facilitate the delivery of an appropriate mix of housing. In particular this will assist the delivery of family sized housing which
is better suited to delivery on greenfield land than constrained urban sites.

4. Future of London Southend Airport
Q28. With reference to the options listed above, or your own opinions, how do you feel we can best manage the Aiport’s adaptations and growth through the planning system?
[please state reasoning].

4.1. Following the adoption of the current Joint Area Action Plan for the London Southend Airport in 2014, the context for the Airport’s future growth has altered substantially. The consultation document establishes that the Airport’s development will need to respond to the emerging Government Aviation Strategy. Moreover, the COVID-19 pandemic has substantially impacted the Airport, with planned growth now envisaged to take place over a much longer time period than initially anticipated. Claremont Planning therefore agree that it is prudent to prepare an updated Joint Area Action Plan which accounts for both the changed policy, and economic
context of the Airport’s growth.
4.2. The regional importance of the airport, alongside its strategic cross-boundary location within Southend but adjacent to Rochford necessitates that a joint approach for the Airport’s growth is advanced in accordance with a coherent vision. Although Option 2 would satisfy the need for a joint, cross boundary approach to the Airport’s growth, national policy is clear that strategic policies should be focussed on setting overall strategies for the pattern scale and design. As such, development at London Southend Airport would more appropriately be considered within a detailed Area Action Plan rather than through Local Planning Policy. As such, Claremont
Planning would support the pursuit of Option 4, where this Option will ensure that any resultant Area Action Plan can be prepared in accordance with policies contained within the new Local Plan.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality green and blue infrastructure is valuable to the wellbeing of Rochford residents, this must be balanced against
the region’s need for growth. It is therefore recommended that identifying general objectives for
strategic green and blue infrastructure (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements.
5.2. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on site improvements to be delivered. Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy established in Chapter 3 of the Framework the role those strategic
policies should play, which is to set out the overall strategies for the pattern, scale and design quality of such places. As such, policies relating to the site specific provision of green and blue infrastructure would be more appropriately dealt with through the preparation of non-strategic level Plans and Policies, such as those in Neighbourhood Plans.
5.3. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas, and waterfronts. Whilst Option 3, requiring certain new developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development. Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy in meeting that criteria for soundness as identified in the NPPF.

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

6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in continuing to support the viability and vitality of town centres. It is considered important however, that the Council recognise the important of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can
increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need, and confirms that early discussions with adjacent authorities have not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed that the
emerging Local Plan will be able to demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) supporting this consultation contains detailed site assessments of the contribution made by promoted sites to the purposes of the Green Belt, including an assessment of the promoted land north of Sutton Road at Rochford that is within a wider Parcel 63. The assessment of the land presented within the Green Belt study is supported, where the assessment recognises the diminished contribution
made by the site to the purposes of the Green Belt, particularly safeguarding the countryside from encroachment and preventing coalescence, by virtue of the site’s relative enclosure by the established Rochford settlement. When the harm of the Parcel’s release was assessed at Stage 2 of the Study, it was concluded that moderate harm to the Green Belt would result. Claremont
Planning contest this conclusion, and assert that instead the harm resulting from the Parcel’s release is instead low, or low-moderate. The Stage 2 assessment undertaken recognises that this parcel of land is weaker performing Green Belt due to its high level of containment, going on to establish that by virtue of this containment the release of land in this area would be of no harm to adjacent Green Belt parcels. Due to the recognition within this assessment that the release of
this land from the Green Belt would not be detrimental to the wider Green Belt, the subsequent conclusion that moderate harm to the Green Belt would result, is not considered to be robustly justified.
7.3. National planning policy, chiefly paragraph 142 of the NPPF, sets out that where exceptional circumstances are demonstrated, a pragmatic approach to Green Belt release, giving first consideration to land which is previously developed and/or well-served by public transport, should be advanced. Claremont Planning support the assertion made within the Joint Green Belt
Study paper that the environmental and sustainability effects of Green Belt release need to be considered alongside the harm to the Green Belt of release, where the most sustainable locations for development may not be the areas which would result in the least harm to the Green Belt. Where this nuanced approach to Green Belt release is considered, Claremont Planning contend
that the merits of releasing the promoted land off Sutton Road are especially evident where it has been established that the site represents a both a highly sustainable location for development at one of the District’s main settlements, and a location at which harm to the Green Belt arising from the land’s release is limited. In light of both the limited contribution made to the Green Belt by this parcel, alongside the negligible harm arising from the land’s release and highly sustainable location, it is strongly recommended that the Council consider the promoted land at Sutton Road
for Green Belt release.

8. Planning for Complete Communities
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you
feel is missing?
8.1. The proposed vision statement for Rochford and Ashingdon is generally supported by Claremont
Planning, where it proposes the further growth and development of the settlement. In particular, the vision statement’s recognition of the settlement’s strategic location close to key employment sites and London Southend Airport, and intention to bolster its regionally significant role is strongly supported. However, it is considered that the proposed vision statement places too great an emphasis on economic growth at the settlement. Instead, Claremont Planning recommend
that the proposed vision statement be amended to include a more balanced and holistic approach
to growth, where it is considered that the Council should recognise the role that residential development has in supporting both the vitality and viability of town centres, alongside a recognition that economic and jobs growth must be supported by sufficient housing provision to
support the local workforce. Moreover, as a ‘Tier 2’ settlement in the District, Rochford represents a highly sustainable location for residential development and should therefore represent a location for significant growth through the emerging Local Plan to assist in meeting the District’s housing needs. As such, it is advised that the vision statement be revised to recognise the role of residential, alongside economic development in realising the growth ambitions of the district.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other
8.2. Promoted site CFS067 as identified on Figure 45: Map of Rochford and Ashingdon, should be made available for residential development. Through these representations to the Spatial Options consultation, Claremont Planning have sought to identify that the central location of the promoted land at Sutton Road within the Rochford settlement establishes the land as both a highly sustainable, and logical location for further residential development. This assertion is complemented by the 2021 Complete Communities Topic Paper prepared by the Authority within with the promoted land is located within an area identified as having a high walking completeness score of 11-13, meaning that there are a large number of services and facilities located within walking distance of the site. However, the Complete Communities Topic Paper also identifies that whilst the most complete areas in the settlement are located near the town centre, there are areas of low population density in and around the centre where future growth might optimise proximity to services. As established, the land off Sutton Road is entirely enclosed by the established Rochford settlement, and abuts existing residential development and employment
land at all elevations. Given the high walking completeness score of the land, the development
of the site represents an opportunity to both locate development at the most sustainable locations
within the settlement, whilst increasing the number of residents living in ‘complete’ areas.
8.3. The Complete Communities Topic Paper demonstrates that Rochford has good levels of
completeness in respect of access to education, health, civic, and sport and leisure facilities whilst only 8% of the settlement is located within the walking catchment of green infrastructure. It is considered that the release of the promoted land off Sutton Road for residential development represents an opportunity to address this shortfall. Within the south of the site at Sutton Road is
a small area of Flood Zone 3 which is promoted for use as public open space / access arrangements through any development proposal advanced. Moreover, the north-easternmost corner of the land is located within the Southend Airport Public Safety Zone within which
development potential is restricted. As such, this area is also promoted for and provides an opportunity to deliver public open space and ecological enhancement. Through careful scheme design it is therefore considered that any proposed development on site will deliver a connected series of public open spaces and green infrastructure, supporting both recreational activities and
delivering biodiversity gains. Given the relative enclosure of the site by established development, it is considered that both future occupants and residents of the wider site area will benefit from this enhanced green infrastructure provision.
Enclosed : Site Location Plan

I have seen the options put forward by the council about potential sites for placing houses in our district in response to the most recent Govt requirement to build up to 12k houses across the region

I have lived in Rayleigh since 1996 and like many was attracted to the semi-rural nature of the town. This is something that has been increasingly encroached upon over this time and we have seen significant building in the town, particularly in the Rawreth Lane area. This has created increasing traffic around the town which brings almost total congestion at rush hours and weekends. I don’t see any additional roads or road widening that will accommodate 20-30k more people and cars that would be using the towns existing infrastructure within the plans provided. I also don’t see additional schools or doctors surgeries – again both of these are under increasing pressure.

The proposed sites effectively removes almost all the green sites along Rawreth Lane – removing the cricket ground which many people enjoy in the summer months and the Lubbards Farm area which is used by runners and dog walkers alike.

My concerns are that if the plans go ahead the essential nature of the town will be lost for good and we will become just another suburban East London sprawl, like Southend, Basildon and Thurrock. And the congestion and infrastructure issues will become even worse.

I accept some building will be required but would suggest that we look at the currently undeveloped areas to the East first, before developing what is left in Rayleigh.

1.0 Introduction

1.1 These representations are submitted to the Rochford Local Plan Spatial Options (RLPSO) on behalf of Generator Group and in respect of Stewards Elm Farm, Great Stambridge (‘the Site’).

1.2 The Site has previously been submitted in response to the Council’s Call for Sites, and is reference CFS141 in the Council’s plan-making process.

1.3 The Site is being promoted for residential development to form a sustainable and proportionate extension to the village of Great Stambridge.

1.4 Detailed proposals have yet to be prepared for the Site, instead, we would welcome further discussions with the Council regarding what scale of development is considered appropriate to help sustain the vitality of the village, and what other benefits to the community are sought which development of the Site could assist in delivering.



 
2.0 Response to Local Plan Spatial Options Consultation Questions

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 The RLPSO recognises that affordability of housing is an issue in the District, stating on page 12:

“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 the 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”.

2.2 The ONS reports that the median house price in the District in 2020 was 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). This suggests affordability of housing in the District is significantly worse than the national average.

2.3 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.

2.4 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 urban to less urban areas; and for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.

2.5 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.

2.6 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.
2.7 As a consequence, the area could 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, particularly for the District’s more rural communities.

2.8 We support Strategic Objective 4:

“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”

2.9 We suggest that, in addition, this objective should recognise the critical role house-building plays in supporting the local economy, and the economic benefits house building would have for the District.

2.10 As the RLPSO recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.

2.11 Employment relating directly to the construction of the development will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.

2.12 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.

2.13 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 outlined above, it would also likely significantly deter inward investment by potential employers, if insufficient, affordable accommodation was not available locally to provide a local workforce.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?

2.14 Given the market and affordable housing needs, affordability issues and heritage and environmental constraints in the District, it is important that the overall strategy seeks to provide a wide range of housing options throughout the Plan period in suitable locations. As such, the strategy should utilise a range of different sites to maximise options to bring forward these new homes and associated infrastructure. It will be important that, for whichever spatial strategy is ultimately chosen, the Local Plan directs a proportion of growth to the District’s smaller settlements.

2.15 The National Planning Policy Framework (NPPF) calls on policies to enable smaller settlements to grow and thrive, and for growth to be located in rural areas where it will enhance or maintain the vitality of rural communities.

2.16 In order for the Local Plan to promote sustainable development, it is necessary for it to direct a proportion of the District’s housing growth to its smaller settlements – the NPPF is clear that planning should support smaller rural communities, and allow them to thrive.

2.17 Great Stambridge is an established rural community with a population of 700 (as per Census 2011). As such, it is important that the Local Plan allows it to grow and thrive, including by directing some growth to the village.

2.18 The RLPSO recognises Great Stambridge as an important settlement for its key centre of population. It benefits from a good level of services / provision facilities / service provision for a settlement of its size, noting that it has a primary school, church and village hall. In addition, it also benefits from a public houses and bus services to larger nearby centres, including Rochford and Southend. It is important for the village and its existing community that such facilities are sustained, and the provision of some growth to the village will greatly assist in this regard. The danger is that, if the Local Plan fails to direct any growth towards such smaller settlements, then like many villages in recent years, it will struggle to retain the services it does have. The loss of such facilities / services would of course be of significant detriment to existing residents, as well as the vitality and sustainability of the remaining community.

2.19 The RLPSO suggests that the vision for Great Stambridge includes that it should remain an independent village with its own sense of community. To achieve this, we suggest it will be important to direct some housing growth to the village over the plan period.
2.20 Any strategy which seeks to ensure any additional housing is directed to Great Stambridge would require alterations to the Green Belt boundary, which is currently drawn tightly around the existing residential envelope in the current Development Plan.

2.21 The NPPF confirms (paragraph 140) that Local Plans are the appropriate vehicle through which the make alterations to the Green Belt boundary, provided there are exceptional circumstances which are fully evidenced and justified.

2.22 Exceptional circumstances are not defined in national policy or guidance.

2.23 However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:

• The scale of the objectively assessed need;
• Constraints on supply/availability of land with the potential to accommodate sustainable development;
• Difficulties in achieving sustainable development without impinging on the Green Belt;
• The nature and extent of the harm to the Green Belt; and
• The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.

2.24 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. This is clearly demonstrated through Spatial Option 1, which sets out that around 4,300 homes could be provided without releasing land from the Green Belt, being a shortfall of around 3,000 homes compared to the identified need. Furthermore, only 800 of these are expected to be affordable homes. With an affordable need of up to 296 homes per year, this would only meet 2.7 years of the need.

2.25 To meet both market and affordable housing needs, it is clear that the District can only feasibly achieve this through the release of Green Belt land.

2.26 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.

Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing?

2.27 We support the broad thrust of the propose vision for Great Stambridge, but suggest it would benefit from making specific reference to seeking to ensure the existing facilities and services in the village are sustained and, where possible, enhanced; and that the vitality of the community is also supported.

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

2.28 National policy is clear on the importance of promoting thriving rural communities. The NPPF states at paragraph 79 that:

“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services”.

2.29 In addition, the Planning Practice Guidance (PPG) notes that housing in rural settlements can be important in ensuring their sustainability, and that villages in rural areas often face issues relating to housing supply and affordability. It states:

“People living in rural areas can face particular challenges in terms of housing supply and affordability, while the location of new housing can also be important for the broader sustainability of rural communities”.

2.30 Great Stambridge is considered an established rural community. Within the Settlement Role and Hierarchy Study (2021) Great Stambridge is categorised as ‘Tier 4: Other Villages’. However, as stated within the RLPSO, the ‘Tier 2’ Rochford and Ashingdon Town is less than a mile from the western edge of the village and provides an important service base for the population of Great Stambridge.

2.31 Such locations that already benefit from infrastructure and services with easy connectivity to higher scoring settlements are the type of rural settlement the NPPF encourages new housing to, to support the vitality of the area. As such, we consider it important that the Local Plan ensures the sustainable, proportionate growth of Great Stambridge as part of any option taken forwards.

2.32 To take advantage of the existing services and facilities, it will be important for any development to be well located in relation to the existing developed area of Great Stambridge. Such an approach also allows development to commence quickly given that significant infrastructure is not required to be delivered, which will be important to help meet housing need in the short and medium term.

2.33 In relation to Great Stambridge, Land at Stewards Elm Farm (reference CFS141) is located immediately adjacent to the existing developed area and is a logical extension to the settlement. It should, therefore, be utilised to provide new market and affordable homes to help meet identified needs and maintain the vitality of the rural area.

2.34 The Site comprises Stewards Elm Farm and surrounding grassland located to the west of Great Stambridge. It measures approximately 11.2 hectares in total and is relatively flat and featureless, with the exception of ponds and trees in the north-west; and trees / hedgerows around the site boundary.

2.35 The Site is not subject to any additional landscape-related policies that seek to restrict development other than the Green Belt, which is pertinent given the Coastal Protection Belt to the east.

2.36 Together with the Green Belt designation, parts of the Site are identified as being within Flood Zones 2 and 3. As stated above, detailed proposals are yet to be prepared for the Site but we are confident that development can be accommodated with suitable mitigation where necessary.

2.37 In terms of the designation of the Site within the Green Belt, it is important to consider the contribution it makes towards the Green Belt purposes. Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’) considered the Site as part of Parcel 79 in the Stage 1 Assessment. Parcel 79 is a large area of land covering the entire eastern side of Rochford and Ashingdon. Clearly an assessment of this size parcel of land has limited use when assessing specific sites given that the characteristics are very different. We would caution the Council against giving this weight in the assessment process. Instead, as identified through the Welwyn Hatfield Local Plan Examination, it is important that Green Belt is considered at a sufficient fine grain. In the Examination of the Welwyn Hatfield Local Plan, the Inspector advised as follows:

“The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might reasonably be considered further”.

2.38 The Green Belt Study (2020) Stage 2 assessment did not consider the Site specifically in detail, with it considered as part of assessment area AA126. However, only a brief assessment was provided with an overall conclusion on the level of harm rather than a detailed assessment against each purpose of the Green Belt.

2.39 The Green Belt Study (2020) found that the Site makes a strong contribution to preventing encroachment on the countryside as it was considered predominantly uncontained, open and undeveloped and to have a strong relationship with the wider countryside due to a lack of significant boundary features. However, it should be noted that the Site does contain an existing dwelling and numerous large agricultural buildings. Further, it must be recognised that for any site not already within a built up area, these conclusions are highly likely to be similar.

2.40 The Site is bounded by existing residential development to the east, with formal tree lined and fenced boundaries to the south and west. As such, the boundaries of the Site are currently defined and through the development of the Site, these could be enhanced through new planting. As such, it is considered to have low potential to lead to unrestricted urban sprawl when considered against purpose 1 of the Green Belt.

2.41 In relation to purpose 2, the Site is some distance from the nearest other settlement, being approximately 1 mile from the edge of Rochford to the south west. Its development would not have any risk of either actual or perceived coalescence of Great Stambridge with any other settlement.

2.42 In respect of purpose 3, there is no existing, strong defensible boundary between the urban area and adjoining countryside. There are tree lined and fenced boundaries to the south and west but no dominant landscape features. Existing development is present and visible within the landscape, with the Site providing an opportunity to reframe this edge. The Site is not currently considered to strongly assist in safeguarding the countryside from encroachment.

2.43 The Site is not subject to any heritage or ecological designations, but is in proximity to a Grade II listed building to the south east. This listed building is nestled amongst the existing built up residential area and separated from the Site by numerous existing buildings. Therefore, redevelopment of the Site would not be harmful to its immediate or wider setting. The Site makes no contribution towards preserving the setting and special character of historic towns in respect of purpose 4.

2.44 In respect of purpose 5, this is only applicable where development needs can be met in full on previously developed land. For Rochford District, this is not an option as the amount of market and affordable homes that could be delivered is significantly below the identified need.

2.45 Overall it is considered that the Site makes limited contribution towards the purposes of the Green Belt, and its residential development would not undermine the strategic purposes of the Green Belt.

2.46 The Council’s SHELAA 2017 considered that the Site is available and achievable, with the suitability dependent on an assessment of the Green Belt purposes. It was considered suitable in other regards subject to flood risk mitigation. As set out above, the Site is considered to make limited contribution towards the Green Belt purposes and detailed proposals for the Site would identify suitable flood risk mitigation where necessary. It should, therefore, be considered suitable, available and achievable.

2.47 The Site can deliver homes early in the Plan period to meet local and wider needs, whilst providing an important role in helping to maintain the vitality of the rural area and provide choice and new homes for local residents.

2.48 Overall, we consider that a balanced combination of utilising appropriate small scale and larger sites, on both brownfield and greenfield sites is the best approach to seek to meet identified housing needs within the District. This balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.
 
3.0 Comments on Integrated Impact Assessment

Assessment Framework

3.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identify.

3.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:

• Meet the identified objectively assessed housing needs, including affordable, for the plan area?
• Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
• Improve cross-boundary links between communities?
• Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
• Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?

3.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.

3.4 The median house price in the District is 11.57 times the median gross annual workplace-based 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.

3.5 In addition, affordability is a concern in more rural areas of the District where limited housing growth and often ageing populations further exacerbate affordability issues.

3.6 The NPPF recognises the important of providing housing in rural areas, being clear that housing should be located where it will enhance or maintain the vitality of rural communities and that policies should identify opportunities for villages to grow and thrive (paragraph 79).

3.7 The NPPF further recognises that housing growth in rural areas can support services, both in the local area and in nearby villages. The RLPSO recognises Great Stambridge as an important settlement for its key centre of population, benefiting from a good levels of services for its size. As recognised by the NPPF, it is important for the Local Plan to reflect the importance of these services and assist in maintaining their viability in the longer term. Providing additional housing to Great Stambridge provides an opportunity to do this, encouraging existing residents needing new housing and/or new residents to live in the area and spend money in the local economy.

3.8 The assessment questions in respect of objective 1 should therefore include recognition of the importance of providing housing in rural areas, to provide choice for residents, improve affordability and to support the vitality of services.

3.9 In respect of the assessment of the spatial strategy options within the IIA, under the population and communities theme it does not mention supporting rural communities. It refers to using brownfield land under option 1 and ‘transformative’ opportunities under options 2 and 3, referring to larger scale development. It does not consider or reflect that small scale development could be undertaken in rural areas and the importance of this for areas such as Great Stambridge.

3.10 The importance of providing housing in existing settlements and not relying on large allocations was highlighted in the recent examination of the Uttlesford Local Plan. The letter from the Inspectors highlighted that the proposed strategy of relying upon large Garden Communities could restrict housing delivery in the short to medium term and ‘would be likely to adversely affect the vitality and viability of services in existing towns and villages and result in a lack of housing choice in the market’ . This highlights the need to plan for housing in existing settlements, including smaller areas like Great Stambridge. Such considerations should be included in the assessment of spatial strategy options to be able to understand their impact across the District as a whole.

Objection to Spatial Option on Greenbelt Land - Wellington/Napier/Bull Lane
Reference Numbers:

CFS027
CFS098
CFS086
CFS029
CFS053

We'd like to register our extremely strong objection to the spatial option plan to build on the protected greenbelt land and countryside around Wellington, Napier and Bull Lane Farm Road.

I'd like to think that you and any council would totally agree that Greenbelt land should be protected at all costs for the good of our community, our planet, our future and our children's futures.

As I'm sure you are aware, Greenbelt land should never be built on and can only be considered for development for the below exceptions:
• Buildings for agriculture or forestry
• Provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it
• The extension or alteration of an existing building provided that it does not result in disproportionate additions over and above the original building
• The replacement of an existing building provided the new building is in the same use and not materially larger than the one it replaces
• Limited infilling in villages, and limited affordable housing needs
I'm sure you will agree that the spatial plans to build 329 new homes do not meet any of the above exceptions - meaning that this should be a total non-starter.

Just the fact that it is greenbelt land should be enough to stop any building plans but we'd also like to raise the below very strong objections:

Pollution: We've just moved our young family to Albert Road from Greenwich in London. The main reason for this move was we have a 2 year old little girl and a 6 month old baby boy. Little girl has developed asthma due to the pollution in London so we moved to Rayleigh to escape this and found a beautiful countryside spot in Albert Road, Rayleigh. By destroying this countryside and building 329 new homes, it would significantly decrease air quality generated by the countryside and increase pollution.

Before buying this house for £550,000 we paid £150 to our solicitor for a local planning report to be carried out to ensure that there were no plans to build on this land and the report came back saying there were not any plans. In fact, the report came back highlighting that it was protected greenbelt land and therefore there was no chance the land would be built on, except in exceptional circumstances to fulfil one of the aforementioned criteria. This was the basis for our decision to go ahead and buy in Rayleigh.

Wildlife: In the 2 months since we have moved here, we have been for runs and walks in this beautiful countryside and seen horses, rabbits, hedgehogs, foxes, squirrels, a badger, many mole holes showing the presence of moles, a stunning array of birds, butterflies, dragon flies and insects and even a lizard! As well as amazing and diverse wildlife there is a beautiful array of plants, trees and flowers. It is also home to many crops which are vital. This area is absolutely vital for our eco-system and it would be incredibly callous and dangerous to destroy all of that. Rochford council must protect this land.

Horse Rescue: There is a horse's field which usually houses around 10 rescued horses. This is an incredible place that attracts many fantastic young adults (mucking out the stables, grooming them etc) and many families bringing their little children to see the horses - what a wonderful resource for the community! Where would these horses go? What about the fantastic young adults? Do we want to force them to hang around on the streets instead? What about the little children and families who love coming here?

Area of Outstanding Natural Beauty: As well as being home to a spectacular array of wildlife and flora, this is also an area of outstanding natural beauty that Rochford council and our community should be very proud of and protect at all costs. We simply cannot destroy this. We should treasure this.

Physical & Mental Health: This area is used by a huge amount of dog walkers, walkers and runners and is vitally important for all of those people. As you know this country is in the midst of a mental health crisis that is costing many lives every year and has a devastating impact, we should be promoting what a huge part walking and running in these surroundings can play in this crisis - not destroying this land, worsening the crisis further.


Bridelpaths & Public Walkways: There are many of these across the area you have mapped for development. These are protected and cannot be destroyed.

Stretched Facilities: Since moving into the area we have been informed we would have to get a private dentist as there is no availability remaining for an NHS dentist and the earliest appointment would be around December - a 5 month wait!


The majority of nursery's were full, after trying about 7 nursery's we finally got the last remaining place at one.


We are informed by the neighbours that wait times for doctor's appointments are weeks and it's very hard to get an appointment.


Flood Risk: This area has experienced flooding before and hence doesn't feel like a wise area to build 329 new homes.



We would like to reiterate the strength of our objection and would urge you to consider the many other sites before completely destroying Rochford's beautiful and extremely precious greenbelt land.

You as the council are the guardians of this and have the power to ensure it stays protected. Once it's gone, it's gone and it can never be replaced.

I am writing to lodge my objections to the proposed New Local Plan. Until there is a guarantee of a much improved infrastructure I feel it is ridiculous to even consider more than using infill sites for further housing. Already our roads are overcrowded and in poor condition, both reasons causing more accidents which in turn causes more congestion.

Our schools and doctors are overfull and with empty promises to address the problems it just isnt viable to keep constructing more homes. It is offers a poor standard of care by the council to consider these options,

What about the quality of life for both residents and wildlife alike, with possible building on green spaces. The increased risk of flooding - with climate change this is a major concern.

There are just so many reasons all these options are a terrible idea until a vastly improved infrastructure is in place.

In the brief time allotted to review the attempt to over-build the Rochford area I can only make
general comments on planned development proposed.

It seems that previous comments to Rochford council have gone unheeded as the infrastructure
and environmental changes to the area seem to have been overlooked or ignored
The dumping of large amounts of traffic onto narrow row roads, that are already overloaded and
easily blocked just by a delivery or collection vehicle stopping, seems to have been ignored in favour
of creating an urban sprawl. Previous developments around the area have seen the token construction
of a ‘roundabout’ or ‘junction improvement’ without considering where the traffic created goes to
on the narrow roads and pedestrian ways surrounding the developments.
Water supply and drainage again seems to deal only with getting it away from the sites rather than
all round increase in service enhancement. Likewise, power and other services only seem to be improved
local to the new-build sites.

I cannot see anything other than a commercial interest in the volume and sting of the majority of
these developments and nothing to improve or maintain the environment of the borough.

I would like to provide my feedback in relation to the New Local Plan: Spatial Options Consultation Paper 2021.

Having read the proposals, and seeing some thoughts from a recent local party leaflet I am in favour of creating a new garden village in the east of the district, away from existing towns and villages. This could be achieved using sites suggested in options 3a and 3b in the areas closer to Southend.

The reasons I am suggesting this approach is mainly due to my concerns about traffic congestion through Rayleigh. Building on more sites close to Rayleigh centre will only increase the traffic problem, which for me is the one factor that makes me think of moving out of this area. On a Saturday around midday, it can often take me around 30 minutes to just drive out of Rayleigh. My spare time at weekends is precious and spending it sitting in traffic reduces my quality of life. I would like to leave my car at home but the public transportation is simply not effective enough across Essex.

New garden villages attract young families which can help keep this area prosperous and continue our excellent sense of community. This type of development should also be accompanied with new road links and infrastructure to support more people moving to the area. That would not be possible building on already over-crowded area's close to Rayleigh.

I hope my feedback is taken into consideration when decided on the approach.

RESIDENTIAL DEVELOPEMENTS ROCHFORD DISTRICT COUNCIL

We have read with great interest further residential developments within the Rochford borough, with extreme disbelief and a total disgrace for a once wonderful area.

Even though we all appreciate that the volume of people within the UK is growing year on year and of course require housing, surely this must be in areas where space and infacturue is available and not in areas such as Rochford with limited resources which are now exhausted.

• WHERE ARE THE ADDITIONAL ROAD
• SCHOOLS
• GP SURGERYS
• EDUCATION FACILITIES
• TRAFFIC ISSUE – WHICH ARE AT THE LIMIT NOW
• ACCESSIBILITY OF EMERGERNCY SERVICES.

If you can confirm all the above, I rest my case , BUT YOU CANNOT !!!

We are all aware of the governments instructions to provide homes and we are also aware of the government’s green policy, do you honesty consider all the above to be green policy – if you consider over populating Rochford in every way, sorry to say the current officers at RDC should be receiving there P45 because they are not working for the good of residents.

I think you will find a very large number of Rochford residents, like myself, moved for East London many years ago to escape the over population and the deprivation which started to exist and exists today at an even great rate, and now appears to be moving to Rochford borough.

Obviously, if you have been a land owner or farmer in this area and sold your land for the purpose of building, good luck to them but why is the council allowing more and more of these projects and to ruin our local areas within the borough.

We as council tax paying’s have every right to be considered seriously when infringing on our daily life, so perhaps let’s have officers within the council with “balls” to stand up and protect this area and the residents who reside, instead of bowing down to developers who really couldn’t care less in building cardboard boxes and to make a quick buck.

Take proposed site CFS261 land to the back of King Edmund school, why 4447 homes ? consider – how many families – cars – school places – medical facilities. Why not consider, approximately 1500 and have a section 106 to provide services to the community or is the developers with the tail wagging the dog.

PLEASE WAKE UP ROCHFORD AND HAVE THE BALLS TO STAND UP IN PARLIMENT TO SAVE ROCHFORD AS I AM SURE WE ALL WHO RESIDE HERE WANT YOU TO DO.

It is a great pity today that in every walk of life, it’s money, and wherever it comes from we want it regardless.

No doubt you are not that interested in the Rochford residents, but remember we pay your salaries, so make us consider you are worth it.

For a very disgruntled Hockley resident.

No more houses
You simply cannot keep building more houses with no new road, new hospital, new doctors, new schools, etc.

We all know the Hall Road estate was built by two contractors to get round the planning having to include a school, and doctors surgery,

I live on the Main Road in Hockley and any one vehicle parked on the road causes immense tailbacks.

It is very easy to just keep building houses but where is the infrastructure?