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?

Thank you for consulting Castle Point and Rochford Clinical Commissioning Group (the CCG) on the Rochford New Local Plan: Spatial Options Consultation paper 2021. The CCG and the Mid and South Essex Health and Care Partnership (HCP) welcome the
opportunity to provide comments on the consultation document. The focus of the comments is on the document’s approach to health and wellbeing and, the provision for healthcare facilities.
Draft vision
It is noted that the draft vision for Rochford in 2050 makes references to achieving a network of infrastructure including health as well social and green infrastructure, enabling residents to work locally and have many accessible and high quality open spaces including coastline that residents can enjoy. These ambitions will promote the health and wellbeing of our population and are supported.
Draft Strategic Priorities and Objectives
The strategic priorities to meet the need for homes and jobs in the area; to provide for retail, leisure and other commercial development, infrastructure and climate change mitigation and adaptation are supported. Amendments are suggested to strengthen the strategic objectives that support these priorities.
Strategic objective 2: The stated objective is to plan for a mix of homes needed to support current and future residents, in particular viably addressing affordability issues and supporting our ageing population. The objective is supported; access to quality housing is one of the wider determinants of health.
Reference could be drawn from the Lifetime Homes standard to ensure that homes make life as easy as possible for as long as possible, providing accessible and
adaptable accommodation for everyone, from young families to older people and individuals with a temporary or permanent physical impairment. This approach should,
over time, allow older people to stay in their own homes for longer and reduce the need for home adaptations.
It is also important to recognise the housing needs of younger members of the population and to address the challenges of entering the housing market. In addition,
the ability of health and social care workers to access the housing market should be considered when addressing the affordability of housing. A local health and care
workforce, as well as built and digital infrastructure, is needed to successfully deliver services for the benefit of our population.
Strategic objective 3: Economic wellbeing is a wider determinant of health and so objectives to deliver more local jobs such as strategic objective 3 are supported.
Strategic objective 4: In addition to allocating land for employment development, provision should be made to enable working from home, which has the benefits of
reducing travel. Houses should be of sufficient size and flexible designs to accommodate this option.
Strategic objective 7: The scope of this objective could be extended from the town centres in Rayleigh, Hockley and Rochford meeting local niche shopping and leisure
needs to include a broader range of activities. These could include shared workspaces for local businesses, community cafes and drop-in facilities for early intervention health services, which would support health and wellbeing of the population.
Strategic objective 8: This objective could include improvement of village and neighbourhood centres to enable the delivery of some health services such as
vaccination centres and drop-in facilities. This would benefit the health and wellbeing of residents and reduce the need to travel.
Strategic Objective 11: Encouraging walking and cycling and so levels of physical activity is supported. Ensuring that our population is well served by public transport is
important to achieving equal access to healthcare services and is important both in new developments and to link established and new developments.
Strategic objective 14: The CCG and HCP welcome the inclusion of strategic objective 14 and look forward to working with the Council and other partners to ensure that our population has access to good quality social and health and wellbeing services.
Strategic objective 15: The inclusion of a reference to older people in this objective is positive. However, it should be made clear that promoting healthy and active lifestyles, and improving physical and mental health and wellbeing, is important for people of all ages, including young people.
Strategic objective 23: Mitigating and adapting to climate change is supported. This objective should be amended to make it clear that those changes are current as well as
forecast and so require immediate action.
Figure 16 – Typical Levels of Growth required to Deliver Infrastructure
It is important to note that the level of growth required to deliver a primary healthcare centre given is, as the title indicates, only typical. There are circumstances where a new facility would be triggered by a development of less than 3,500 additional dwellings and others where 3,500 new dwellings would not result in the provision of a new healthcare facility.
Spatial Strategy Options
Additional healthcare capacity will be needed to provide primary care services to meet the needs of new residents in each of the spatial strategy options. How this additional capacity is achieved will need to be the subject of discussion
informed by more detail about the scale and location of development. New facilities are one option but may not be the most appropriate solution in all cases. Increased capacity through reconfiguration and/or extension of existing premises will also be considered.
It is requested that the wording in the ‘This strategy could deliver…’ text boxes on pages 30, 31 and 32 be amended from ‘…new medical facilities…’ to ‘additional medical facility capacity’. This is to clarify that new facilities will not necessarily be delivered in relation
to all growth whether through urban extensions, concentrated growth or a balanced combination of the options presented.
Further information about the scale and location of developments in the options presented would be needed to form any preference for a particular spatial strategy. The Health and Care Partnership would welcome discussions with the Council and further involvement in development of the local plan strategy to ensure that healthcare needs are properly addressed.
Question 9 – It is agreed that a sequential approach should be taken, and development should be located away from areas at risk of flooding. The HCP would not support the provision of healthcare premises in areas of high flood risk.
Question 10 – The Coastal Protection Belt and Upper Roach Valley should be safeguarded from development as they are a valuable resource to help residents
maintain good physical and mental health.
Question 11 – The principle of requiring developments to source energy from low-carbon and renewable sources in supported. Care should be taken to ensure other important resources, such as landscape are not compromised as a consequence.
Question 12 – Yes, developments should be striving for the highest energy efficiency standards. New NHS buildings are being designed to standards higher than the building regulations in the drive to achieve net-zero carbon developments.
Place-making and design
The inclusion of a place-making charter for Rochford in the Local Plan is supported. It should secure high quality buildings and built environments as well as green and blue spaces; encourage active travel; make provision for local/community food production; and require accessible and adaptable homes. It is also important that existing
communities and new developments, including for our travelling communities, are successfully integrated with easy active travel options and public transport between
them. This approach will help to ensure that development has positive impacts on the health and wellbeing of all of our residents
Healthcare facilities
The structure of healthcare bodies in Mid and South Essex changing. Separate clinical commissioning groups are coming together in an integrated care body which will be part of an integrated care system with other health and social care partners. It is therefore requested that the reference to the Castle Point and Rochford Clinical Commissioning Group is removed.
It is suggested that the ‘Healthcare Facilities’ text on page 57 of the consultation document is replaced by:
With a growing and ageing population, provision of health and community facilities and services within the district is going to become even more important. There is a need to
provide health care facilities that meet existing and future needs, including those arising from the population growth across the plan period. There are currently 10 GP practices in Rochford and the average list size is around 9,500 patients.
The shape of healthcare delivery in Mid and South Essex is also changing. As well as increasing capacity in all three hospitals in Mid and South Essex, the health and care partnership is aiming to invest in and support GP practices to work together to provide
joined up care, building activities in prevention, helping people at an earlier stage and
avoiding serious illness. These priorities will require healthcare hubs that can host a wider
range of healthcare services including diagnostics and early intervention services; support
a move to improved digital services and provide capacity for drop-in and wellbeing services. These will be established through a combination of refurbishment and/or extension of existing facilities; sharing of facilities; and new build projects. The Health and Care partnership is pleased to have to opportunity to respond to the Rochford Local Plan consultation and requests ongoing engagement in development of the plan.

1. Introduction
These representations are submitted by Wood Group UK Ltd (Wood) on behalf of Bloor Homes Ltd.
⚫ Section 2 provides a summary response to the Spatial Options consultation,
specifically in support the ‘Potential Cross-Boundary Opportunity’ east of Wickford,
explaining why the site should be part of whichever Strategy Option is taken forward
as it performs so well.
⚫ Section 3 sets out further detailed justification for a strategic land allocation to the
east of Wickford - centred on the release of sites CFS222 and CFS239 from the Green
Belt and improvements to remaining Green Belt in this area1
- in the context of
national Green Belt policy, sustainability, limited harm and the Council’s evidence base.
⚫ Section 4 explains the specific opportunities and benefits associated with a strategic
land allocation east of Wickford, supported by a concept masterplan and proposed
revision to the Green Belt boundary. This is intended to aid understanding of the
significant potential of this location.
⚫ Section 5 provides answers to the specific questions identified in the consultation
document.

2. Summary
A strategic site allocation to the east of Wickford has such significant credentials in sustainability
and Green Belt terms that it should be allocated as a strategic site whichever Strategy Option is
taken forward - the allocation could be central to Strategy Options 2, 3 or 4. Option 1 (urban
intensification) is unsound given that it does not meet the district’s housing needs and would not
constitute a positively prepared plan.
The size and status of Wickford as essentially a Tier 1 settlement equivalent to Rayleigh at the top
of Rochford’s settlement hierarchy means that this is where development should be focussed.
Wickford is a highly sustainable location for growth and development. It has a range of services,
two secondary schools, strategic employment, retail and a recently upgraded railway station
providing trains to London Liverpool Street. This is all within close proximity to land east of Wickford, which adjoins Wickford Business Park, lies on the A129 high frequency public transport
corridor and is just a 15-minute bus/cycle journey to the railway station and town centre.
In Green Belt terms the ‘exceptional circumstances’ for reviewing boundaries required by NPPF140
are evidenced and justified by the lack of available land outside the Green Belt to meet the district’s
needs through to 2040. When reviewing Green Belt boundaries, the promotion of sustainable
patterns of development and use of previously developed land or sites well-served by public
transport are policy requirements (NPPF142) which the site supports given the sustainability
credentials outlined above. The extent of land controlled by Bloor in this location also provides
the opportunity for compensatory improvements to the remaining Green Belt, through the
provision of new/enhanced sports pitches, biodiversity net-gain and improvements to
walking/cycle links (also NPPF142).
Land east of Wickford is well-related to the urban edge, is visually well-contained, already contains
urbanising influences and has the long term robust boundary of the A130. The presence of the
A130 as such a strong recognisable physical barrier - central to defining Green Belt boundaries
through plan-making under NPPF143(f) - is a particular advantage that other strategic Green Belt
locations in Rochford district do not have (for example, in contrast, there is no such significant and
defensible barrier for development sites centred on Strategy Option 3b, north of Southend).
Release of land east of Wickford will therefore not result in urban sprawl, nor lead to neighbouring
towns merging or encroachment into the countryside. In Green Belt terms land east of Wickford is
a unique opportunity and the best performing strategic location for Green Belt land release,
resulting in the least harm.
From a landscape and heritage perspective it also one of the best performing strategic locations
assessed as part of the Spatial Options consultation (again, in contrast, Strategy Option 3b is in
proximity to designated heritage assets and in an area with low landscape capacity to
accommodate new development). It also an area of lower landscape sensitivity when compared
with other options.
As illustrated on the accompanying plans (Appendix A), a strategic site allocation east of Wickford
can deliver around 1,500 new homes and employment at a scale which supports the delivery of
new community infrastructure, including a primary school and new local centre (convenience retail
and other community facilities). An allocation here would reduce the pressure on other
communities in Rochford district.
In terms of delivery, the land is all under the single control of Bloor Homes, a 5* housebuilder
committed to working with Rochford District Council, the local community and key stakeholders to
realise the opportunities presented by this important opportunity.

3. Justification for a strategic land allocation /
cross boundary opportunity east of Wickford
3.1 Green Belt
NPPF Green Belt Policy
Exceptional circumstances (NPPF140)
The case for exceptional circumstances for Green Belt land release in Rochford – as required by
NPPF140 - is established under Strategy Options 2 and 3. As recognised on page 29 of the Spatial
Options, Strategy Option 1 (urban intensification), predicated on no Green Belt land release, will
not meet Rochford’s growth needs, and is therefore unlikely to be considered sound, being not
positively prepared. Green Belt land is needed. The question is where the best locations are to do
so whilst limiting the overall harm to the Green Belt and with respect to the requirements of
NPPF142 and NPPF143 in particular.
Promoting sustainable patterns of development and giving first consideration to land which has
been previously-developed ‘and/or’ is well-served by public transport (NPPF142)
Wickford is rightly recognised as equivalent to a Tier 1 settlement2
– i.e. the top of the settlement
hierarchy alongside Rayleigh. It has two secondary schools, strategic employment and retail, with
Wickford railway station - recently subject to a £4m package of improvements – providing trains
into London Liverpool Street.
Land east of Wickford is highly sustainable, as supported by the Council’s evidence base, including
the Complete Communities Topic Paper. As shown on Figure 4 of this topic paper the site adjoins
frequent public transport (more than 4 services per hour), with bus stops to the north west
(Southend Road roundabout3
), east (A129/Old London Road) and west (Hodgson Way). As part of
a strategic site allocation there is the potential to route a bus into the site and enhance
accessibility.
As supported by the Site Appraisal Paper all key facilities are nearby, including secondary school
(Beachamps High), local shops and Post Office (centred around the junction of Southend
Road/Fanton Walk/Bruce Grove), healthcare (Shotgate Surgery), jobs and employment (at
Dollymans Farm, Wickford Business Park & Fanton Hall Farm). Furthermore, the site is well-located
in proximity to extensive areas of open space, including sports pitches at The Warren, Rayleigh FC
Boys & Girls, Chichester Ground Football Pitches and Shotgate Park (with respect to the Site
Appraisal Paper, the site should at least score ‘4’ given proximity within 400-800 metres). Land
east of Wickford is just a 15-minute bus/cycle journey from the railway station and the town centre.

Promoting sustainable patterns of development in NPPF Green Belt terms therefore means
directing a significant share of new growth and development towards Wickford, whichever Strategy
Option of 2, 3 or 4 is pursued.
The site is already part brownfield and part developed with clear urbanising influences - as
acknowledged in the Site Appraisal Paper - encompassing one of the district’s twelve ‘informal
employment areas’ (Economy & Skills Topic Paper) as well as an existing dwelling and curtilage at
Dollymans Farm.
A particular benefit in terms of sustainable patterns of development is the ability to provide a scale
of development which supports additional infrastructure and investment, with the 1,500 homes at a
level which sustains provision of a new primary school, as well as supporting facilities including a
local centre, which alongside existing and enhanced public transport all helps to create a truly
‘walkable’ neighbourhood. The ability for strategic allocations to deliver infrastructure
improvements is identified in the Spatial Options Document, supporting Strategy Options Topic
Paper and the Interim Integrated Impact Assessment IIA4
. This will also be a sustainability benefit to
the existing area – including users of Wickford Business Park and neighbouring residential areas.
This would support the intentions of Strategy Options 2, 3 and 4 whereby the ability to fund and
deliver new infrastructure is identified as a clear opportunity.
Delivering compensatory improvements to the environmental quality and accessibility of the
remaining Green Belt land (NPPF142)
Compensatory improvements to the environmental quality and accessibility of the remaining Green
Belt - another key objective of NPPF142 - could also be secured given the extent of land within
Bloor Homes’ control (e.g. around CFS223, 226, 227, 230 & 238). Improvements could include a
combination of enhanced green infrastructure connectivity, new recreational routes for walking and
cycling and additional playing fields/sports provision. This would also align with NPPG002 (Green
Belt - Reference ID: 64-002-20190722) in terms of the range of compensatory improvements. By
tying such improvements in with the allocation and future planning permission, this would also be
deliverable in the context of NPPG003 (Reference ID: 64-003-20190722) and can be secured via the
S106 process.

Defining a clear Green Belt boundary (NPPF143(f))
The A130 is a significant clear physical feature and long term permanent boundary to the east of
Wickford which would form a logical defensible boundary which is capable of enduring beyond the
plan period. In this regard land east of Wickford is a unique opportunity – with no other strategic
locations having such a significant and robust Green Belt boundary, in combination with
accessibility, sustainability and suitability (being of lower environmental value).
The Council’s Green Belt Study (Assessment Area AA01 / Sites 222, 239, 238 & 223)
Against the fundamental purpose of the Green Belt – to prevent urban sprawl (NPPF137) – the
Green Belt Study rightly recognises that the area makes a weak contribution. Surprisingly it then
identifies a ‘High’ harm impact score which then follows through into the Site Appraisal Paper.

This appears predicated on the conclusion that the area makes a ‘strong contribution’ to
preventing encroachment on the countryside. However, the assessment is flawed because it fails to
reflect the existing urbanising influences in the area, incorrectly stating that the area is
undeveloped. The presence and extent of ‘urbanising land uses and features that could diminish
openness or compromise the rural character of the countryside’ are identified as key factors in the
Green Belt Study’s own methodology (2.46, 2.477, 2.50 and 2.53) but then disregarded in the
assessment of Parcel 1/AA01. Examples of the urbanising features on the site are illustrated on the
photographs presented at Figure 2. Urbanising influences include the employment areas at
Dollymans Farm (note: non-agricultural uses), and residential use at Dollymans Farm itself, as well
Fanton Hall employment area to the south east. The presence of the A129 and A130, pylons,
employment distribution infrastructure and railway line are also urbanising influences.
Furthermore, the assessment of encroachment and wider performance of the land in this area in
terms of Green Belt purposes then fails to reflect the role of strong physical boundaries, i.e. the
A130 in this case. The dictionary definition of encroachment concerns a gradual advance beyond
usual or ‘acceptable limits’ – the acceptable limit in this case being the A130. This should be a
fundamental consideration as part of the assessment and at present is a significant omission in the
study’s methodology and in the appraisal of Parcel 1/AA01. The assessment should be revised to
conclude a weak contribution to this Green Belt purpose.
In reality, and as explained earlier in this section this is a unique and strongly performing Green
Belt site because it is so well-related to the existing urban edge, already contains urbanising
influences, is visually well-contained and has such a strong boundary in the A130 that other
strategic development locations do not have. It is the best option with the least level of harm to
the Green Belt particularly with regard to the fundamental policy aim of the NPPF in preventing
urban sprawl.
Revised scoring for Parcel 01 (from the Stage 1 Assessment) and Parcel AA01 (from the Stage 2
Assessment) is therefore presented in Figure 3. It is concluded that the overall contribution to
Green Belt purposes is weak and the harm of release reduces to low-moderate. This should then
be coupled with the site’s sustainable development credentials.

Wider local plan evidence base: Site Appraisal Paper – Land East of Wickford
The Site Appraisal Paper identifies all land within Bloor Home’s control in this location as
deliverable within 5-years subject to policy, encompassing sites CFS222, CFS239, CFS238, CFS223
and CFS226. The Site Appraisal Paper shows how well-located the area is in landscape terms, lying
outside of the more sensitive landscapes in the district. Informed by the findings of the Landscape
Character, Sensitivity and Capacity Study identifies land east of Wickford as lying within a ‘LowMedium’ landscape sensitivity and ‘Medium-High’ landscape capacity to accommodate
development. The main development sites comprising CFS222 and CFS239 are also unaffected by
designated heritage assets, unlike other strategic development areas assessed in the District.
These sites all perform well in terms of accessibility given proximity to high frequency public transport on the A129 and access to facilities and services. However, there is an inaccuracy in the
scoring with respect to access to open spaces. This does not reflect the latest position on the ground, whereby the sites are very well-located in proximity to extensive areas of open space,
including sports pitches at The Warren, Rayleigh FC Boys & Girls, Chichester Ground Football
Pitches as well as Shotgate Park. The scoring for CFS222 and CFS239 should be increased from ‘1’
to ‘4’ given the extent of open space provision already within 400-800m.
In terms of access to public transport, whilst accessibility to high frequency bus routes is
recognised, the scoring for CFS222 does not yet reflect the ability to deliver
enhancements/improvements as a central part of any development scheme. In reality CFS239 –
which scores well with a ‘4’ given that it abuts the A129 and is within 400 metres of bus stops at
Southend Road roundabout – would form part of the single comprehensive allocation which aligns
with the masterplan enclosed at Appendix A. The masterplan reflects the ability for a bus to route
in and out of the scheme in order that new homes would be within 400m, so this could easily be dealt with as part of the allocation and consenting process, in which case CFS222 would also score
4.
Figure 4 presents the revised scoring for sites CFS222 and CFS239 under Bloor’s control on land east of Wickford which are to form the main area for Green Belt land release presented in section 4.
The land clearly outperforms other locations with respect to Green Belt, landscape, accessibility,
ecology and heritage.

4. Strategic land allocation - concept masterplan,
potential & opportunities
As summarised in section 2 and justified in section 3, land east of Wickford is the best location for a strategic land allocation, and should play an important role under Strategy Options 2, 3 and 4. In Green Belt terms, Wickford’s status akin to a Tier 1 settlement, accessibility to high frequency
public transport, services and facilities – and ability to deliver new community infrastructure – is
entirely consistent with promoting the sustainable patterns of development envisaged by NPPF142.
The A130 is a strong and longer term defensible Green Belt boundary unique to this location, helping limit sprawl and encroachment. Alongside the area’s relationship with the existing urban edge, visual containment and existing urbanising influences it is the best performing location for
Green Belt land release with the least harm to the overall role and function of the Green Belt in Rochford district.
In landscape and heritage terms this area would also result in the least harm when compared with other strategic options. It provides the opportunity for the Council to deliver growth in a location which minimises impacts on existing communities and environmental assets.
Appendix A provides a draft concept masterplan, with Appendix B providing a context plan and proposed revision to the Green Belt boundary in this location.
The draft concept masterplan is based on the following key features and benefits.
⚫ Around 1,500 homes, a mix of market and affordable in response to local needs, on a net residential area of around 40ha.
⚫ 2ha of land for a new 2FE primary school, supporting the Spatial Options opportunity to deliver growth at a scale which provides and sustains new infrastructure.
⚫ A new local centre, located next to the new school site, providing convenience retail
and other community uses.
⚫ A robust, long-term and defensible Green Belt boundary, capable of enduring beyond the plan period and supporting the sustainable patterns of development envisaged by NPPF142(f) Green Belt policy. The A130 and railway line provides a clear boundary using an existing physical feature that is readily recognisable and likely to be permanent, entirely consistent with NPPF132(f). Appendix B sets out the proposed Green Belt boundary revision.
⚫ New and enhanced playing pitches as a ‘hub’ for sports and recreation. The Council’s Playing Pitch Assessment and Action Plan identifies the opportunity to provide greater security of tenure for sports provision in this location – including at The Warren (CFS226) which is land under Bloor’s control. Further pitches could be provided west of the Warren/A130 or land to the east which is also within Bloor’s control. This would utilise existing bridleways all of which would link sports provision with the new homes, across the existing Pegasus crossing on the A129, with access off the A129.

Alongside the bridleways and existing crossing, the scheme would promote the use of public transport through the ability to route a bus into the site to secure a 400m walkable catchment and could provide ped/cycle links to the west through to Wickford.
⚫ Visual containment can be maximised by retaining key landscape features and enhancing structural planting alongside the site’s northern and eastern boundaries, complemented by the provision of sustainable drainage and wildlife habitats to deliver net biodiversity gain all on-site. 50% of the site would comprise green uses.
⚫ Access would be via a new roundabout on the A129, providing a tree-lined avenue
into the neighbourhood, with a potential secondary access located to the east (refer to
the masterplan in Appendix A for details).

5. Response to specific questions
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
For the reasons explained in section 2, the cross-boundary opportunity east of Wickford has such
significant and unique credentials in sustainability, Green Belt and deliverability terms that it has a
role to play in delivering all Strategy Options 2, 3 and 4.
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?
Standards for new developments relating to both energy supply and energy efficiency standards should be left to national building regulations (e.g. linked to the Future Homes Standard or similar
initiatives in the future).
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
Under Strategy Options 2, 3 or 4, a strategic land allocation east of Wickford could clearly support
the opportunity for new green infrastructure, including a new hub for sports provision in this
location (improving both the quality and quantity of sports pitches), improvements to GI
connectivity (e.g. upgrading existing bridleways), biodiversity net gains and further strategic
landscaping, particularly associated with the establishment of a robust and defensible Green Belt
boundary to the east of Wickford / west of the A130. This package of measures would also support
the environmental quality and accessibility of remaining Green Belt land, as set out in NPPF142.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to
deliver new or improved community infrastructure?
Under Strategy Options 2, 3 or 4, a strategic land allocation east of Wickford can deliver growth at
a scale – 1,500 homes plus employment - which provides and sustains new community facilities,
including land for a 2FE primary school, new local centre (which provides convenience retail and
other community provision), extensive green infrastructure as well as new and enhanced sports
provision. Further details are provided in sections 3 and 4 of these representations.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help
deliver improvements to open space or sport facility accessibility or provision?
Bringing forward a strategic land allocation east of Wickford – under Strategy Options 2, 3 or 4 –
would support improvements to open space and sports provision. There are opportunities to deliver additional pitches as well as greater security of tenure, for example, on retained Green Belt
land centred on sites CFS223 and CFS226, all on land which Bloor Homes controls and would tie in
with a new strategic land allocation. The opportunity to provide greater security of tenure at The
Warren in particular (CFS223) is identified in the Playing Pitch Assessment and Action Plan. Further
details are provided in sections 3 and 4 of these representations, with the opportunity to provided
new pitches identified on the concept masterplan presented in Appendix A (6-7ha of
new/enhanced pitch provision complemented by extensive green infrastructure and biodiversity
net gains).
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?
The potential for impacts on the significance of heritage assets and their setting is a key constraint
to consider through plan-making and subsequent decision-taking on planning applications. The
Council should look therefore towards options with no/limited heritage constraints, as is the case
for land east of Wickford, recognised in both the Site Appraisal Paper and IIA.
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?
Growth should be directed to the most sustainable locations already well-served by high frequency
public transport, services and facilities, and where there is the opportunity to deliver a scale of development to sustain new services and facilities to deliver truly walkable neighbourhoods.
Promoting sustainable patterns of development is central to the review and release of Green Belt land and where land east of Wickford performs particularly well. Wickford is equivalent to a Tier 1
settlement, has rail access into London Liverpool Street, with the opportunity that Bloor has identified just a 15-minute bus/cycle ride to the station and lying on a high frequency public transport corridor (recognised in the Connecting Communities Topic Paper). Land east of Wickford
is already identified as having a positive contribution to sustainable transport in the IIA. Further detail on transport and sustainability for the cross-boundary opportunity east of Wickford is provided in sections 2, 3 and 4 of these representations.

Having reviewed the Strategy Options presented, Option 3b appears less suitable in transport terms for the following reasons.
⚫ A review of the potential development sites outlined in Figure 17 associated with Option 3b of the Spatial Strategy Options shows there is a lack of suitable infrastructure to support a significant level of housing growth in this region when compared with other strategic options (e.g. land east of Wickford). Figure 2 of the Complete Communities Topic Paper shows that this area is also less well-served by public transport – highlighting non-frequent bus services and services less than 4 per hour when compared with the high frequency public transport provided on land east of Wickford (tested under Option 3a).
⚫ The land identified for Option 3b within the Spatial Strategy Options is sandwiched between the River Roach to the north, Potton and Foulness Islands to the east, the existing settlement of Southend-on-Sea, and the River Thames to the south and London Southend Airport to the west.
⚫ The only strategic route to and from this area is via the A127 which provides a route
west towards the A130 (north / south route) and the M25. All vehicle redistribution and growth associated with a new, large residential settlement in this area would therefore be required to utilise the A127 as the main route in and out of the area. This route also serves as the main route for London Southend Airport which is due to continue to expand.
The other option for movement into and out from the area is less strategic and comprises the A13 London Road though this would require traffic to travel through
the centre of Southend-on-Sea.
⚫ If a strategic scale of development is proposed then significant new transport
infrastructure may be required, whereby the location of Option 3b presents limitations. For example, the proximity of London Southend Airport to the A127 to the south, and River Roach to the north mean there is very little scope to enhance a connection east from lands north of the town centre.

Q63a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state
reasoning]
Land east of Wickford sits within Rawreth parish but is fundamentally related to and links to
Wickford/Shotgate, lying east of the A130. Engagement with the parish council will be central to
our approach, including how the wider transport, green infrastructure, sports pitches, school and
local centre to benefit existing residents in this area.
Q63b. With reference to Figure 51 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 Rawreth?
Linked with the response to Q63a, the cross-boundary opportunity east of Wickford should be
recognised and allocated as part of the new local plan under whichever strategy option is taken
forward. The opportunities associated with this land allocation are presented in sections 2, 3 and 4
of these representations, supported by the concept masterplan provided in Appendix A.
Essentially, it would comprise a new walkable neighbourhood of around 1,500 homes, employment
plus 2FE primary school and local centre, through removing sites CFS222 and CFS239 from the
Green Belt. A new defensible Green Belt boundary would be established to the west of the A130
and north of the railway line, as shown on the plan enclosed at Appendix B.
Retained Green Belt land under Bloor Homes control – comprising CFS238, CFS223, CFS226, CFS227 and CFS230 – could deliver compensatory improvements to the environmental quality and
accessibility of remaining Green Belt land, including new and improved sports pitches (e.g. CFS222 and CFS226/The Warren), biodiversity net gain, improved walking/cycle links and strategic landscaping.

Introduction

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

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

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


Comments on the Consultation itself

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

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

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

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


District Profile

Population Statistics = a strange change of approach.

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

Presenting a confusing and contradictory picture

I found your approach here very confusing.

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

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

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

Use proper hard credible metrics

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

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

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

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

A suggested alternative

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

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

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

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


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


Spatial Strategy Options

Option 3a = the best strategic solution

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

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

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

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

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

Option 2 is tactical not strategic

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


Spatial Themes - suggested additions

Waste and Recycling

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

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

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

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


Digital Infrastructure

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

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

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



Green Belt Policy

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

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

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


Bio-Diversity

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


Spatial Themes - Flood Risk

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

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

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


Transport and Connectivity

Public Transport

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

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

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

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

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

Walking

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

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

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


Conclusion

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

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

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


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

Electronic Car Charging

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

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

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

This will present the District with significant Planning challenges:

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

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

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

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

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

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

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

Firstly – the consultation document was inaccurate, misleading and used historical data – this makes the consultation invalid.
To evidence this I will give just one example of each of these;
Inaccuracy: map marked the Wakerings and Barling contained area CFs060 – which was then omitted on the map titled ‘stonebridge and Sutton’
Misleading: Even though it was clearly minited at a policy planning committee meeting (prior to the spatial options consultation being released) to use ‘ward names only’ (minuted as voted unanimously by the committee) it contained a map called ‘Stonebridge and Sutton’ this mislead residents.
Historical data: figures 9 and 10 (relating to Rochford residents work/destinations) this data is from 2011!
I will now comment on the areas to the east of the district; Named: ‘Wakerings and Barling’ and ‘Stonebridge & Sutton’ and list the reasons why the sites put forward are not suitable:
Road infrastructure:
Wakering/Barling is a peninsula with only 2 main roads into and out – if there is an emergency (as there has been historically) then these roads will barely cope. One road will NOT even be able to be widened as there are houses either side at key points. There are no viable options for a 3rd road.
Sites put forward for consideration provide no indication of where they would exit/entrance be – we have already seen the impact of a site in the current local plan where an inappropriate exit/entrance has been allowed – at the behest of Essex County Highways. The country lanes are not suitable for large developments – to reinforce this remember that the Majority of accidents (killed and seriously injured) happen on rural roads – more building will increase the use of the country lands and increase accidents.
Then think where the traffic would travel to and from: Only recently the leader of Rochford Council spoke against a development in the heart of the district clearly siting ‘severe’ impact on already struggling roads – this development was refused by the planning committee. This was a small development compared to some of the sites put forward for consideration - Access from the east of the district to and through the rest of the district is beyond capacity and cannot be expected to take any more traffic so if that one small site was deemed unsuitable because of its impact on the road – then building anywhere below this area in the district should be too.

Flooding:
Much of the east of the east of the district is in a high risk flood zone – this is expected to increase with the impact of global warming. Where it is not tidal flood risk there are areas of ‘high risk of surface flooding’ this will only increase with development.

Drainage and sewer systems are already at capacity with regular issues and reports to the flood forum – it is unable to take more homes. (fact: refer to reports to flood forum)

Impact on the environment
The sites put forward are currently farmland. This would result in a detrimental impact on: wildlife, bio-diversity, sites of archaeological interest. It will also increase the carbon footprint as removing land that currently acts to reduce carbon.
Increased traffic will increase the carbon output of this community. Pollutants and particles increase and reduce air quality.

You will be aware that the carbon footprint of a newbuild 2 bed house is 80 tonnes of C02e – of course the new local plan may include a pledge that all houses are carbon neutral (but how this be enforced?) But even if homes are carbon neutral there will ultimately be an increased carbon footprint from population increase – but leaving the agricultural land will at least allow for a ‘green lung’ in the east of the district.

This consultation does not explain how the new plan will meet the requirements of the government’s own Environment Bill and the government’s goal of carbon neutrality?

Health and well-being
People live in a village community because of the way of life. By building more houses the community element will be lost. Health and well-being of residents will be detrimentally affected. Crime will increase – and fear of crime. Poorer air quality – there is an abundance of reasons why health and well-being will be affected in Public Health England’s report on Health and wellbeing in rural areas.

My final comment is not to urbanise the east of the district. (forget the terminology of ‘garden village’ as it will be no such thing – it will be a bolt on to Southend) There may be a duty to cooperate with Southend Council – but there is a more pressing, more important duty to address carbon neutrality. By leaving our rural fields and providing a green lung this will at least go some way towards this.

Dear Sir / Madam,

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

Thank you in advance for your attention to this matter.

Kind Regards,
Jane

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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


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


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


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

Q5. Do you agree with the settlement hierarchy presented?


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


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

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

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

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

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

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


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

Spatial Themes

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


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


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


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


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


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


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


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


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

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


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

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

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


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

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

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


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

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

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

Housing for All

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


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

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

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

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


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

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


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

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


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

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

Employment and Jobs

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


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

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

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

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


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

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

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


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

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

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

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


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

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


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

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

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


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

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

Biodiversity

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


YES

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

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

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


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

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

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

Green and Blue Infrastructure

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


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

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


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


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

Community Infrastructure

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


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

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

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


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

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

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

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


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

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

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

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


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

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


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

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


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

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


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

Heritage

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


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

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


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


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

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


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

Town Centres and Retail

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


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

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

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


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

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

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

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


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

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


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

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

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


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

Transport and Connectivity

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


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

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


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

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

Green Belt and Rural Issues

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


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

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

Planning for Complete Communities

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


N/A


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


N/A


Q56d. Are there areas that require protecting from development?


N/A


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


N/A

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



N/A

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


N/A


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


N/A


Q57d. Are there areas that require protecting from development?


N/A



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

N/A

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

N/A

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

N/A

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


N/A

Q58d. Are there areas that require protecting from development?


N/A



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


N/A


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

N/A

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


N/A




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


N/A





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


N/A


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


N/A


Q60a. Do you agree with our vision for Hullbridge?


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

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

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


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

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


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

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


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

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


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

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


N/A


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


N/A


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


N/A


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

N/A

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

N/A



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


N/A


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


N/A


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

N/A



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

N/A



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


N/A





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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A

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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A






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


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

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


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

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


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

Create a Country Park to the west of Hullbridge.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

1. INTRODUCTION
1.1 These representations have been prepared by Pegasus Group on behalf of Penland Estates Limited in respect of their land interests in Rochford District Council (RDC).
1.2 These representations are submitted in response to the current Rochford Local Plan Regulation 18 ‘Spatial Options' consultation, which sets out the different growth
strategy options that could be pursued by the Council in the emerging Local Plan. The evidence base accompanying the Spatial Options document includes a Site Appraisal Paper which identifies the suitability of potential sites for allocation, including Penland Estate Limited's interests at:
• Site Reference CFS190: Land South of Pooles Lane, Hullbridge
1.3 The purpose of these representations is primarily to respond to the questions raised by the consultation to ensure there is a sound basis for emerging policies, as well as to support the most sustainable growth options of those set out in the consultation. These representations also confirm the deliverability of the above site and the exceptional circumstances in support of a minor revision to the Green Belt alongside the provision of a site-specific policy that allocates Land South of Pooles Lane, Hullbridge, for residential development in the emerging Local Plan. The representations are supported by high-level technical assessments and an indicative Framework Plan.
1.4 These representations should be read in conjunction with the enclosed high-level technical assessments and an Illustrative Framework Plan, which explain further
the opportunities available to create a high-quality and sustainable residential development with the ability to contribute positively towards the District’s significant housing needs.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

To whom it may concern,

Please find below my comments on the Spatial options document consultation.

Ref: COL07 and COL20

I strongly object to any development on the site C0L07 (Mill Hall, car park and green) and also site COL20 (Civic Suite and gardens) being included in the Local plan for future residential development.

The sites are in the existing RDC designated Conservation Area and should not be used for new housing or commercial / council developments or redevelopments. Rayleigh Town Council agrees with this statement in their official response to the Spatial Options consultation - I quote:

———

"Q44. Are there areas of the District we should be considering for conservation area status beyond those listed in this section? You should not take areas of precious woodland to make way for housing. Sites within the existing Rayleigh Conversation Area should not be considered"
All green spaces, no matter how small, hold some significance, especially to those who use them for recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on.

Rayleigh like other towns that have suffered from overdevelopment in recent decades and should be protect from large scale private development during the forthcoming Plan Period. Only development or local needs should be permitted. Local facilities like Mill Hall would be saved and car parking retained and made cheaper to assist local town centre business to survive what will be a challenging period. Secondary shopping facilities in Rayleigh would be supported and encouraged with public finance where required.
Public transport would be supported and encouragement, especially when given for children to reach school without parents’ vehicles. Renovation and refurbishment of historic buildings with modern green energy would be promoted over demolition and intensification. Public services would be encouraged to return/expand to Rayleigh, in existing buildings like Council Offices, Police Station and Library etc. The town centre should be the heart of our community not just something you drive through to reach somewhere else. This could be our vision and our aim for the future.

——— ends

The loss of car parking will have a devastating effect on an already under strain Rayleigh town centre. Demolition of existing buildings and rebuilding is bad for the environment. The Royal Institute of Chartered Surveyors (RICS) estimates that 35% of the lifecycle carbon from a typical office development is emitted before the building is even opened. It says the figure for residential premises is 51%. This all happens during demolition and new building. Upgrading of under efficient council properties should be the way forward, not demolition.


Many trees and green areas will be lost in our conservation area if the above sites are developed which is unacceptable. This will harm wildlife.

Development of the Mill Site will seriously harm the Scheduled ancient monument Mount area and Listed Windmill as will development of the Civic Suite site with its Grade 2 listed Barrington’s building. This is underlined by the Spatial Options evidence base in the ECC Place Services Heritage assessment:

Rayleigh Civic Suite - Assessment: Major Adverse
The development of this site will cause substantial harm to a heritage asset. There are likely no options for mitigation. Proposals causing this level of harm to the significance of a heritage asset should be avoided.
Built heritage - Lies within the Rayleigh Conservation Area and & medieval town extent. Contains GII Listed Barringtons [1168536]

Archaeological impact - Will need archaeological investigation.

Mill Events Centre - Assessment: Moderate Adverse
The development of this site will cause (less than) substantial harm to heritage assets and this harm is considerable. There are likely no options for mitigation. Proposals causing this level of harm to the significance of heritage assets should be avoided.

Built heritage - Lies within the Rayleigh Conservation Area & medieval town extent. Careful master planning will be required with early involvement of the Conservation Officer.

Archaeological impact - Impacts the scheduled Monument of Motte and Bailey

Options 2a and 2b ‘Urban Extension’ must not be allowed to happen, especially in the area of Rayleigh which is already overdeveloped and has no additional infrastructure to cope with any more.

My preference for any future development of the district is for a satellite new garden village in the East of the District to be built under Options 3a and 3b with the site close to Fossetts Way on the Southend Border. Co-operation with Southend on these options is good for all of Rochford District.

Thank you for your time.

Dear Sir/Madam,
I refer to the Rochford District Council Spatial Options Consultation. As part of the Ministry of Defence (MOD), the Defence Infrastructure Organisation (DIO) is the
estate expert for defence, supporting the armed forces to enable military capability by planning, building, maintaining, and servicing infrastructure.

Background
The MOD has significant land interests within the district of Rochford, known as MOD Shoeburyness. MOD Shoeburyness is owned by the MOD and operated by
QinetiQ Ltd under a Long-Term Partnering Agreement (LTPA). MOD Shoeburyness offers a broad array of weapon and military equipment test, evaluation and training over land and firm tidal areas.
The Range covers a land area of 7,500 acres with 35,000 acres of tidal sands. MOD Shoeburyness consists of 21 operational firing areas and unique capabilities for Demilitarisation and Environmental Testing of Live and Inert stores. This unique terrain enables the over-water recovery of munitions up to a range of 22km, groundto-ground firings of up to 27km, long-range direct fire up to 3.5km, sea danger areas
up to 35km, and large radial safety areas for explosives trials.
MOD Shoeburyness is a centre of excellence for environmental testing of Ordnance, Munitions and Explosives (OME) and houses the largest Environmental Test Centre in the UK for the testing of Live stores as well as some unique demilitarisation facilities.
60% of MOD Shoeburyness’s 7,500 acres is made up of eight farms and 74 residential properties (let to civilians) in two hamlets and is required to support the operational areas and outputs through the provision of a safe area in which Test & Evaluation activities can be conducted. The site is only accessible through Landwick Gate which is a secured access point.
All access to MOD Shoeburyness is on a formally permitted basis (other than to the public highways and byways) through the Landwick Gate security gate.

National Planning Policy Framework
The Council will be aware of the requirements of paragraph 97 of the National Planning Policy (NPPF) as quoted below:
“97. Planning policies and decisions should promote public safety and take into account wider security and defence requirements by:
b) recognising and supporting development required for operational defence and security purposes, and ensuring that operational sites are not affected adversely by the impact of other development proposed in the area.”

Spatial Options: Existing Open Space
It is acknowledged that there is an area of existing open space within MOD Shoeburyness defined within the current adopted plan and this area of land is proposed to continue to be defined as open space within the Spatial Options Report.
In studying this piece of land (to the west of Bridge Road), we wonder whether there has been a drafting error as this appears to be an isolated area of land unconnected to any existing community. Instead we question whether the intention was to define the fenced play area between no.s 4a and 19 Churchend?
It is important to note that due to access to the site being on a permitted basis only, it should be acknowledged that this fence play area would not be available for use by
the wider population.

Spatial Options: Other Open Space
It is noted on the interactive map that an area of land to the west of 2 Churchfields is proposed to defined as other open space within the new local plan and has been
informed by the Council’s emerging work on open spaces. The MOD does not consider this area of land meets the criteria to be considered as open space as
defined within the NPPF and National Planning Practice Guidance. This land is a grass field that is not subject to any regular mowing schedule by the landowner, there are no formal pathways or paraphernalia. Residents under their tenancy agreements are not permitted to access this area. It is noted that the existing fenced play area between no. 4a and 19 Churchend is within easy walking distance from the existing community.
Therefore, it does not appear to us that the land is demonstrably special to the local community, provides particular beauty or holds a particular local significance, has recreational value, tranquillity or a richness of wildlife to be defined as open space.

Spatial Options: Promoted sites
There are a number or parcels of land immediately abutting and in close proximity to the MOD boundary that are being promoted for development. The Council will be
aware of the provisions of The Town and Country Planning (safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002
(Circular 01/2003). Safeguarding zones have been designated at MOD Shoeburyness to safeguard its capacity as a military technical site/explosive storage
area and maps have previously been issued by Ministry of Housing Communities and Local Government to the Council. Within these designated areas the MOD is a
statutory consultee and would expect to be consulted on planning applications. For the avoidance of doubt please find attached the latest safeguarded areas (a copy of
the GIS data can be provided upon request). In accordance with Circular 01/2003 the outer boundary of safeguarded areas should be indicated on proposals maps accompanying local plans and the plan should state why the area has been safeguarded.
It is noted that a number of the promoted sites fall within the safeguarding zones and therefore development within this area could be at risk of harm from MOD activities.
In addition, potential development of these sites could require a change to MOD activities so that MOD can continue to be a good neighbour. This could include, as a
result of a third party development, restricting operations in certain facilities, requiring the implementation of additional engineered safeguards, constraining the ability to manage any future change and restricting the potential of future development requirements – all to the cost of the public purse. In such circumstances this operational defence site could be affected adversely by the impact of development proposed in the area, contrary to paragraphs 97 and 187 of the NPPF.
The Council may consider it prudent (considering paragraph 97 of the NPPF) to include a further Strategic Objective within Strategic Priority 4 to specifically
recognise and support development required for operational defence and security purposes, and ensuring that operational sites are not affected adversely by the
impact of other development proposed in the area.
The Council may also wish to propose a specific planning policy for MOD Shoeburyness that provides and protects both on-going and future operational defence needs for the site and serves to ensure that any neighbouring development does not adversely impact upon these operations or, in turn, would be affected by
the established use. For example, any policy could include that proposals associated with defence and military operations at this existing site will be supported where they would enhance or sustain operational capabilities. The MOD will be seeking to modernise buildings and facilities across the site to improve their energy efficiencies, ensure they are resilient to climate change, contribute to climate change objectives and for residential buildings make sure they are fit for modern living. It would be beneficial for any policy to support these environmental improvements. Any policy should also ensure that for any non-military or non-defence related development within or in the areas of a defence or military site will not be supported where it would
adversely affect military operations or capability.

Spatial Options: Regional Parkland
Large parts of the proposed Regional Park includes land within MOD ownership. The South Essex Green and Blue Infrastructure Strategy (SEGBIS) says that Regional
Parks are lands reserved to protect and conserve areas in natural or modified landscapes but are also suitable for sustainable public recreation and enjoyment.
Due to the ongoing operational need of the estate and the associated activities the landholding would not be suitable for any public access over and above that
currently permitted by the existing public rights of way. The MOD is aware that part of the estate is either directly within or adjacent to Foulness SSSI, Foulness Ramsar
and Foulness SPA designated sites and recognise that restricted public access assists with conservation of these areas. The MOD is cognisant of its stewardship
obligations in regard to the management of these designated sites and it works closely with Natural England, the Environment Agency, tenant farmers, the RSPB, Foulness Area Bird Survey, and other members of the MOD Shoeburyness Conservation Group to ensure that key habitats and species on the site are monitored, maintained, and where appropriate, enhanced.
It is important to recognise that the landholding is required for the purpose of national defence and the planning process serves to protect such national infrastructure. The MOD’s land holding would not provide public recreation or enjoyment to meet the criteria of a Regional Park. In addition, the proposed boundary to this designation does not follow easily identifiable and physical features on the ground for the boundaries of the Regional Park to be permanent and to endure throughout and beyond the plan period. For assistance a copy of the MOD ownership boundary has been included. We would strongly recommend that the proposed boundary is
amended to avoid any of the MOD ownership.

Flood Zone
Whilst the site is within Flood Zone 3 it does have the benefit of a flood defence which would need to be considered within any planning applications within the area as mitigation.

I hope the above is of assistance and reflects the MODs position at the time of this letter. Should you need any further clarification please do not hesitate to contact me.
We would be pleased to be included within any further consultation events as the plan progresses

We are instructed on behalf of Mr. Francesco Vasile (our client) to submit representations to the Spatial Options Document which is currently the subject of consultation to inform the preparation of the New Rochford Local Plan.

Our client owns the freehold ownership interest in land situated to the east of Shoebury Road and south of New Road, Great Wakering (extending to approximately 14.96 hectares), which is referenced on the Interactive Spatial Options Map as Site CFS065 and identified in the accompanying Site Assessment Proforma as being both ‘available’ and ‘deliverable’ for housing development (with a potential housing capacity of 335 dwellings). The full extent of this land is outlined in red on the attached site location plan.

The proforma assessment categorises the site as a ‘Potential Plan Strategy Option 2’, which is predicated on meeting the growth strategy requirements of the New Local Plan through a combination of urban extensions focused in the main towns (Option 2a) and urban extensions dispersed to settlements based on hierarchy (Option 2b). The other growth options being contemplated are ‘urban intensification’ (Strategy Option 1), ‘concentrated growth’ (Strategy Option 3) and ‘balanced combination’ (Strategy Option 4). The Spatial Options Document acknowledges that the Strategy Options 2, 3 & 4 would all be dependent on releasing Green Belt land across a number of locations and/or a significant redrawing of the Green Belt boundary. In this respect, it is instructive that approximately 70% of the land in the district is currently protected by Green Belt designation.

Site CFS065 is situated within the Green Belt and therefore referenced on the Site Assessment Proforma as being ‘deliverable – subject to policy’. The current evidence base for the emerging New Local Plan includes a Green Belt Study (specifically the ‘Rochford District and Southend-on-Sea Borough Joint Green Belt Study) that was undertaken by LUC and published (as a final report) in February 2020. The Study takes the form of a Stage 1 assessment (assessing how strongly the different areas of the Rochford District contribute to the five stated purposes of Green Belts set out in national planning policy) and a Stage 2 assessment (examining the relative merits of land for development that have previously been promoted to the Council).

Site CFS065 is situated within the Stage 2 Assessment Area AA145 and is referenced as Site 65. The assessment concludes that the loss of this site to development could potentially result in significant harm to the remaining Green Belt land to the east, which would be contained on three sides by inset development. The assessment further concludes that releasing an area of land to the south of Great Wakering (and west of Shoebury Road), identified as Site 57 would potentially result in the creation of a more regular Green Belt boundary. Notwithstanding this, it is acknowledged that there are no ‘readily recognisable boundaries to mark this area’ and hence an arbitrary line has been drawn to define the area that could be released from the Green Belt. In our view, this is surprising as Site CFS065 has clearly defined boundaries to the north (New Road), west (Shoebury Road), south (housing area and which also extends partly to the east of the site), while to the east (and beyond the part housing areas) the existing Green Belt openness would continue to be maintained. Furthermore, the site could potentially deliver a significant amount of housing (in both numerical and percentage terms) relative to the objectively assessed need and so we would contend that there are strong and convincing reasons to justify releasing this land from the Green Belt to help the Council deliver its future growth strategy. Additionally, on the Council’s own assessment criteria, the site is sustainable and there are no known constraints to development in terms of topography and the related issues of tree, ecology and flood risk impact. The site is available and deliverable and would contribute positively towards short-term housing need.

Significantly, our client would also be keen to promote a housing development predicated on modern methods of construction (MMC) in the form of a modular build which would be highly sustainable and carbon efficient. This would result in significantly reduced delivery and construction times relative to a traditional build and the format is also being championed by Homes England as a solution that would speed up the delivery of affordable housing around the country. Our client has an established business relationship with one of the leading modular housing firms in the country, which has expressed a strong interest in the site.

Hence, our client would strongly support a housing land-use allocation on this site and to that end we would welcome the opportunity of engaging the Council further on the merits of this proposition in due course.

In the meantime, we trust these representations are helpful and if we can be of any further assistance in this respect, please do not hesitate to contact the undersigned.

Persimmon Homes is a FTSE 100 housebuilder with a national presence. In 2020 the Group delivered 13,575 new homes, down from 15,855 in 2019 (largely in part due to the impact from Covid-19 on operations), although the selling price increased by about seven per cent.
Persimmon Homes has a strong presence in Rochford, having an option to deliver site CFS087: Land between Western Road and Weir Farm Road Rayleigh, and are actively seeking additional sites in Rochford to deliver much needed housing and regeneration in the Borough. Persimmon Homes welcomes the opportunity to comment on the New Local Plan Spatial Options Consultation Paper 2021.

In the short term, Persimmon Homes is aware that Rochford’s existing Local Plan is now out of date, as per the tests of the NPPF. Ensuring that an adequate supply of housing is provided is a key policy requirement of the NPPF. The Rochford District Core Strategy, which was adopted in December 2011, fails to meet the requirements of the NPPF. Therefore, it is imperative that the draft Local Plan continue to be progressed to allow it to be adopted as soon as possible so that the District can continue to plan effectively to meet the District’s ongoing needs.

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

The technical evidence that Rochford is preparing is comprehensive, though we would suggest the following additional evidence (which may be included within the evidence base documents listed) will also be required to inform the new Local Plan:

Heritage

An ‘initial Heritage Assessment’ is listed, which is vague, which is not sufficiently detailed or robust to properly consider the relationship of heritage assets and emerging site allocations. Persimmon Homes is, in particular, concerned that it identifies site CFS087 as having a ‘moderate-adverse’ impact on the Grade II listed Weir Farmhouse, despite this asset being located some distance from site CFS087 and screened from view (as would have been evidence if Place Services had undertaken site visits) by existing mature vegetation and twentieth century housing developments. The heritage asset listed within Place Services report therefore has no relationship with our allocated site, and cannot be seen from the site.

It is recommended therefore that the Council’s Heritage Evidence Base will need to be properly updated to include, at a minimum, some or all of the following:

• A Heritage Asset Review, to assess the significance of heritage assets and the contribution they make to their environment;
• Lists of Buildings of Local Architectural or Historic Interest;
• Conservation Area Character Appraisals Programme – noting that these were last reviewed in 2008 and therefore these need updating so that the Council have up to date evidence and therefore able to properly consider applications affecting these assets;
• Historic Environment Characterisation Studies; and
• Heritage Impact Assessments, and Archaeological Evaluation Reports, where relevant, on each allocated site. We would strongly recommend that these are prepared in accordance with each site developer and will need to involve site visits, rather than relying on a simple mapping exercise.

Highways

An ‘initial Transport Assessment’ is listed as being provided, which is a vague description and does not specify the required level of detail to support the Plan. It is recommended that this will need to include, at a minimum, some or all of the following:

• Transport evidence for the new Local Plan;
• Transport evidence mitigation;
• Sustainable Modes of Travel Strategy;
• Cycling Action Plan/Local Walking and Cycling Infrastructure Plan/Cycling Delivery Plan;
• Transport modelling of key strategic routes/junctions – the Spatial Options Document goes on to highlight the congestion affecting the road network, and identifies the improvements already planned for the A127 and Fairglen Interchange; and
• Infrastructure Delivery Plan.

Housing

Alongside the HELAA and SHMA, we would recommend the following:

• Self-Build Custom Build Housebuilding Register;
• Housing Implementation Strategy;
• Settlement Capacity Studies;
• Brownfield Land Registers;
• Schedule of Brownfield Sites and Extant Permissions; and
• Housing Trajectories.

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?

The draft vision at present appears to be too vague and lacks a real vision. It is clear that the two big challenges facing the country in the next 20-30 years are a lack of homes, particularly for both young and elderly, along with the impending threat of climate change and its attendant impacts. Therefore, both of these need to be reflected in the vision. Rochford should strive, in its local plan, to not only meet its housing supply but to plan beyond, as well as to meet the threat of climate change by encouraging
all developments to be ‘green’, to exceed climate change targets and to seek alternatives to the private car to transform how Rochford residents travel.
For example, the ‘Our Society’ vision needs to have a greater vision for the delivery of new housing and
supporting infrastructure. Rochford should welcome the challenge of building at least 360 homes per year, by choosing to focus on high quality developments and the attendant benefits of planning for the delivery of these homes.
Similarly, the ‘Our Environment’ vision does not refer to climate change, which is a missed opportunity, given the pressing need facing the Country in addressing Climate Change impacts and its repeated messages within the NPPF, particularly as detailed within Chapter 14, and at paragraph 153 which states that, “Plans should take a proactive approach to mitigating and adapting to climate change…”.
Alongside this, the Covid-19 pandemic has transformed how people work, with more people now choosing to work from home, more often. This needs to be reflected in the ‘Our Economy’ vision – can Rochford provide the employment hubs and flexible working conditions to meet the new ‘normal’ for example.

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

Persimmon Homes would agree that separate visions for each settlement would help guide decision making and notes, for example, the wide character as detailed within the settlement profiles from page 71 onwards of the Spatial Options paper. This confirms that Rochford ranges from Tier 1 Settlements such as Rayleigh with 34,000 residents, to isolated hamlets such as Paglesham and Stonebridge of only 250 residents. Clearly, the type and level of development is going to differ and a set of visions for each settlement would provide clarity to developers on the type, and level, of development that would be appropriate. Such vision statements could usefully be informed by the following:
 Historic Environment Characterisation Studies;
 Heritage Impact Assessments;
 Settlement Capacity Studies;
 Transport Studies and Strategies;
 Green Belt Studies;
 Strategic Land Availability Assessment;
 Flood Risk Assessments;
 Design and Development Briefs; and
 Masterplanning Studies

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?

The Spatial Options Paper lists 23 Strategic Options and Persimmon Homes broadly agrees with these, though we would have the following observations to make:
 Strategic Objective 1 – Persimmon Homes understands the Council’s reasons for looking to prioritise previously developed land first. However, the Paper goes onto confirm at page 29 that previously developed land will not be able to meet the Council’s housing targets in full; therefore there is no justification in prioritising previously developed land first. In many cases, greenfield sites are able to be brought forward quicker than previously developed land, particularly in the case of previously developed land having existing uses that need to be relocated first, or contaminated land that requires remediation. Accordingly, this objective could be reworded as follows:
“To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs, through working with our neighbours in South Essex and encouraging the redevelopment of previously developed land alongside suitably located greenfield sites to ensure the plan requirements are met in full.”
 Strategic Objectives 4 and 5 – these objectives could usefully reference the change in remote working patterns and confirm that Rochford will promote the use of flexible working practices to meet the needs of the ‘new normal’ arising from Covid-19, as well as offering flexible work
spaces to meet the needs of the 21st Century Office;
 Strategic Objective 6 – we would disagree with the phrasing ‘highest attainable quality’ as this is vague and imprecise; design is, to a large degree, subjective (particularly moreso where Local Authorities lack design codes and guides to guide the design of built form). We would therefore recommend the following revised wording:
“To ensure that all new homes and commercial premises are built to a high quality design and sustainability standard with a good level of access to green space and the countryside.”
 Strategic Objective 13 – this objective could usefully highlight Governments’ requirement to direct development to Flood Zone 1 (i.e. areas at the lowest risk of flooding);
 Strategic Objective 23 – the sole objective relating to climate change could usefully reflect Governments’ Future Homes’ requirement (being introduced in 2025).

Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
Persimmon Homes would agree with the settlement hierarchy presented, which demonstrates that growth should be predominantly located at Rayleigh, Hockley and Rochford. As Rayleigh is the sole ‘Tier 1’ settlement, it is logical that as the Plan progresses, that Rayleigh takes a larger proportion of development than other settlements.

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

The NPPF makes it clear at para 61 that Local Planning Authorities should be looking to use the Standard Method to determine how many homes are required, stating, “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance…”.
Accordingly, it is confusing at Figure 15 that it includes a ‘current trajectory’ scenario of only 4,500 homes when this scenario will not deliver the Standard Method requirement of a minimum of 7,200 homes. The Council could, therefore, be clearer in this regard and confirm that this Scenario cannot be taken forward in isolation.
The Plan presents four options; Persimmon Homes would support a combination of Options 1 and 2.
Our comments of which are as follows:
 Strategic Option 1 – The Paper itself acknowledges that this Option will not be able to fully meet the Standard Method requirement, as well as acknowledging that it will not be able to deliver the brand new infrastructure that is required alongside new homes.
It is also identified within the Integrated Impact Assessment that the lower growth options will not deliver the required levels of growth, stating on page 25 that:
“The lower growth option will not meet the needs of all people in the district during the plan period. The medium and higher growth options will meet the needs of all people in the district and improve accessibility to housing, employment, training, health, and leisure opportunities.
The higher growth option is more likely to meet the needs of not only people in the district but beyond, as well and encourage the integration and interaction of cross-boundary communities through the delivery of large-scale developments. The medium and higher growth options are also considered for their overall potential to deliver a wider range of housing types, tenures and
sizes, particularly catering for the needs of groups with protected characteristics, such as specialist housing for the elderly and disabled.”
Furthermore, the Integrated Impact Assessment states that: “…smaller scale development proposals bring less opportunity for strategic infrastructure improvements, and may place increased pressure on local road networks.”
The Paper also identifies that said option to increase densities in urban areas are unlikely to be compatible with historic centres and local character, as confirmed within the Integrated Impact Assessment, which states:
“…it is recognised that the lower growth option will focus development in existing urban areas, with a higher potential in this respect to impact on historic centres.”
It also goes on to confirm
"Option 1 would not deliver sufficient housing to meet local needs over the Plan period, in this respect it is also likely to deliver less affordable housing and long-term negative effects can be anticipated.”
Again, we would request that the Council undertake updated Conservation Area Appraisals and Settlement Surveys so that the Council has the required evidence base to consider if increased densities, taller buildings etc. would be appropriate in the historic centres and urban areas, as this would help inform the actual number of dwellings available under this option.
We would also question that this Option uses sites that have retained site allocations from the 2011 Core Strategy, and would question why these sites have not been developed by now – are these sites developable and deliverable as per the tests of the NPPF. This is something that the District Council should review.
Accordingly, this option cannot be taken forward within the next stage of the Local Plan on its own, though it is acknowledged that some level of urban intensification on appropriate sites may be suitable to help meet the Standard Method.
 Strategic Option 2 – Option 2a proposes Urban Extensions focused in the main towns; as Rayleigh is the Districts sole Tier 1 settlement, it is logical and sensible that urban extensions should be focused in Rayleigh. Furthermore, it benefits from not being restricted by any flood zones, being sequentially preferable to many other settlements in the District.
The Spatial Options document identifies that this option would be able to deliver new infrastructure; meet local housing needs; and deliver quickly; all of which Persimmon Homes endorses.
This Option would also deliver the required level of growth required for employment needs, as confirmed within the Integrated Impact Assessment:
“The medium and higher growth options are more likely to have a significant positive effect on this IIA theme through the delivery of new employment land and retail floorspace. These options are also likely to deliver more new infrastructure upgrades and sustainable transport routes to attract further inward investment. Further to this, the higher growth options could contribute to the delivery of sub-regional improvements to green and blue infrastructure, which could have a positive effect on the tourism economy. Whilst positive effects are considered likely under all options, the lower growth option is considered less likely to lead to positive effects of
significance.”
It goes on to state:
“Urban extensions under Options 2a and 2b provide large scale development opportunities that can deliver new infrastructure provisions to support both existing (particularly those in edge of settlement locations) and future residents.”

It concludes:
“Significant positive effects are considered likely under Options 2a, 2b and 4.”
The delivery of sites under the medium and higher levels of growth would also allow for the delivery of climate change measures that are required and discussed later in the Spatial Options Document. The delivery of these measures may not be possible through reusing
existing buildings (Strategic Option 1) as confirmed within the Integrated Impact Assessment:
“…the delivery of large-scale growth that is more likely to come forward under the medium and high growth options present more opportunities for the delivery of low carbon infrastructure through economies of scale compared to the lower growth option.”
On the same theme, the medium and higher levels of growth options are much more likely to be able to deliver the biodiversity and green infrastructure improvements and contributions required, than on existing brownfield sites, as also confirmed within the Integrated Impact
Assessment:
“The medium and higher growth options are also noted for their potential to support the delivery of strategic green infrastructure provisions and associated biodiversity net gain. This includes improvements being explored in the green infrastructure network across the sub-region through the South Essex Green and Blue Infrastructure Study (2020), such as the Regional Parkland.
The Regional Parkland has the potential to act as alternative greenspace targeted at reducing recreational pressures at designated biodiversity sites. These options thus provide a greater contribution to the principles of the Essex Coast Recreational disturbance Avoidance &
Mitigation Strategy (RAMS).
The lower level of growth will mainly result in the delivery of new homes on urban and brownfield sites so has greater potential to avoid designated sites and support urban greening to some extent. The urban focus however is less likely to bring forward strategic mitigation, such as the Regional Parkland to mitigate the recreational pressures on designated biodiversity resulting from a growing population. As a result, the medium and higher growth options are considered more likely to perform better overall in relation to this IIA theme; however, the potential for a significant effect is uncertain as will be dependent on the location of growth.”
It continues:
“…the potential for larger-scale development under Options 2a and 2b is recognised for the potential for greater net gains in biodiversity.”
The site that Persimmon Homes is promoting – site CFS087 – would be capable of being delivered under this Option.
 Strategic Option 3 – The Spatial Options document identifies a number of significant ‘Cons’ which would impact upon the delivery of this option (and thus threaten the delivery of the plan as a whole), all of which we would agree with and would therefore recommend that this option is not progresses as:
o The plan identifies that this option involves complex land ownership issues which is likely to be difficult to resolve and address;
o Significant redrawing of the Green Belt boundaries, including proposing development in more sensitive Green Belt locations than other strategic options;
o Focussing development in a single location/settlement would deprive other settlements of being able to accommodate development, and thus potential infrastructure improvements.
On Environmental impacts, the Integrated Impact Assessment identifies that harm that this option would have on Environmental Quality, stating that:
“…extensive countryside development proposed through the concentrated growth options (Options 3a, 3b and 3c); which is considered highly likely to lead to negative effects of significance in this respect. Options 3a and 3b are also likely to intersect the flood plains of the Crouch and Roach tributaries, and development will need to ensure appropriate mitigation to avoid impacts on water quality…Negative effects of significance are considered more likely under Options 3a, 3b, 3c and 4 given the extent of concentrated growth development locations
in the countryside.”
 Strategic Option 4 – This option proposes a ‘balanced combination’ of all three; we would recommend a balanced combination of Options 1 and 2 represents the most suitable Spatial Strategy going forwards for the reasons given above and indeed as detailed within the Spatial Options document, and the Integrated Impact Assessment, which concludes:
“Option 4 is noted for its potential to perform better against a wider range of the IIA themes than the remaining options. This predominantly relates to the flexibility provided in a tailored approach, essentially combining the best performing aspects of each individual approach (urban intensification, urban extensions and concentrated growth).”

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

Southend are currently consulting on its ‘Local Plan - Refining the Plan Options’, with the Consultation running through until 26 October 2021. The NPPF is clear that Local Authorities should also plan to meet housing needs that cannot be met within neighbouring authority areas (para.61), stating that, “In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for”.
In this regard, it is noted that within their Plan proposes a ‘Development Opportunity D’ of c.10,000 homes, of which 4,900 homes lies within Rochford.
It is imperative, therefore, that Rochford works alongside Southend to understand if it needs to plan for these 4,900 new homes alongside its own minimum of 7,200 homes, which would need to be reflected within the next stage of the Rochford District Local Plan.

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

Persimmon Homes would request that further spatial themes topic papers are required, or updated, for:
 Place Making and Urban Design – further questions within the Spatial Options paper deal with design (Q14 – Q16), but as yet a corresponding topic paper has not been published to consider this issue. The NPPF places an increasingly strong emphasis on design, with the recent 2021 revision further emphasising the Governments’ commitment to building ‘beautiful’ homes and places, to be underpinned by Design Codes and guidance. Understanding how Rochford District Council intends to interpret this requirement will be key for Developers as the plan progresses and beyond.
 Flood Risk and Drainage – Briefly discussed within the Climate Change topic paper, but this issue needs to be sufficiently evidenced as the plan progresses.
 Landscape and Visual Impacts – As above.
 Heritage – The Heritage Topic Paper confirms that existing Conservation Area Appraisals date back to 2007 (if they exist at all) and that these, along with the ‘Local List’ may be updated as the Local Plan progresses. Persimmon Homes would strongly support this evidence being undertaken as understanding heritage impacts is often key, which cannot be understood without up to date evidence.
 Duty to Co-Operate and Strategy Options – As identified at Q7, these topic papers do not address the potential for Rochford needing to meet Southend’s housing needs, as is currently presented as a potential option within their new Local Plan ‘Refining the Plan Options’ consultation.

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?

Persimmon Homes strongly recommends that Rochford take the sequential approach to Flood Risk as required by paragraphs 161-162, confirming that new development should be directed to areas with the
lowest risk of flooding from any source.
The flood map at Climate Change and Resilient Environments Topic Paper identifies that the four
settlements least impacted by Flood Zones are Rayleigh, Hullbridge, Hockley and Ashingdon, and therefore these settlements are sequentially preferable for residential development to meet the Local Plan needs than those settlements that lie within Flood Zones 2 or 3 (such as Great Wakering).
We would also take this opportunity to identify to the Council that the site that Persimmon Homes is
promoting (Site CFS087: Land between Western Road and Weir Farm Road, Rayleigh) lies within Flood Zone 1 and is therefore sequentially more preferable than those sites being promoted that lie within Flood Zones 2 and 3.

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

Climate change is a principal risk for Persimmon Homes and a significant issue, with more extreme weather events such as heatwaves, rising sea levels and flooding being experienced and resulting in impacts of both global and local significance. Society is more environmentally conscious with the international community and Government taking a leading role to reduce greenhouse gas emissions by setting and legislating ambitious targets for all to achieve.
As one of the UK’s leading house builders we acknowledge our role in supporting these common aims.
We understand the risks and challenges that climate change presents to our business and the wider industry. We are proactively working with all stakeholders to more effectively integrate climate change issues within our operations and ensure that sustainable improvements are managed in a pragmatic and robust manner.
We recognise that we have a key role to play in minimising our contribution to climate change, through
our own operations, our supply chain and by striving to ensure that the homes and communities we build are sustainable, inherently energy efficient and encourage our customers to live in a way that minimises any impact to climate change. We are committed to working alongside all stakeholders to achieve this.
Working with the Carbon Trust, a global climate change and sustainability consultancy providing specialist support to assist businesses to reduce their greenhouse gas emissions, Persimmon has set ambitious targets to be net zero carbon in our homes in use by 2030 and in our operations by 2040.These targets are supported by interim science based carbon reduction targets to reduce greenhouse gas emissions from our own operations by 46.2% (2019 baseline) and our indirect operations (i.e. those from our homes in use and our supply chain) by at least 22% per m2 completed floor area by 2030 (2019 baseline).
Referring back to the Spatial Strategy Options, the delivery of sites under the medium and higher levels
(Strategy Options 2 & 3) of growth would allow for the delivery of climate change measures that are required. The delivery of these measures may not be possible through reusing existing buildings (Strategic Option 1) as confirmed within the Integrated Impact Assessment:
“…the delivery of large-scale growth that is more likely to come forward under the medium and high growth options present more opportunities for the delivery of low carbon infrastructure through economies of scale compared to the lower growth option.”

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?

Persimmon Homes would support new homes being built to meet the new Future Homes Standard (being introduced from 2025), which proposes an ambitious uplift in the energy efficiency of new homes through changes to Part L (Conservation of fuel and power) of the Building Regulations. This will ensure that new homes produce 75-80% less carbon emissions than homes delivered under current regulations.

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?

As the Spatial Options document identifies, Rayleigh is diverse area with a mix of character and vernacular. Accordingly, a ‘Place-Making Charter’ would be welcomed as an overarching theme to guide all new development in the area during the plan period. Persimmon Homes welcomes the Government’s increasingly strong emphasis on design and place making, noting and agreeing with the Government’s statement at paragraph 126 of the NPPF that, “high quality, beautiful and sustainable buildings and places is fundamental to what the planning and development process should achieve.”
Accordingly, the more guidance on this that Rochford can produce (noting that design is often, subjective and without suitable guidance, decisions can be delayed), would only assist developers in understanding the Council’s aspirations in this regard. This would be supported by paragraph 126 of the NPPF, which states that, “being clear about design expectations, and how these will be tested, is essential for achieving this.”
It would also assist decision making in local residents and members are involving in the creation of
place-making charters and other design guidance; to ensure that design is properly considered by members and local residents at an early stage in the process and to ensure their views on design and place making are heard early; rather than such views being made during the application process (such as at Committee) which will delay decision making.
This would also identify if the same principles should apply throughout the District, or if certain settlements have specific principles and design, requirements that only apply to their settlement for example. Such an approach would be supported by paragraph 127 of the NPPF (“Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics.”)
As above, the more guidance that can be produced, and the more involvement and agreement with local residents/members, can only guide and aid the decision making process.
Of the principles identified within Spatial Options paper, the majority of these would apply everywhere in the District, albeit on some sites certain principles may not apply (impacts on the historic environment for example).
On Design Codes, the NPPF confirms at paragraph 128 that, “all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences. Design guides and codes provide a local framework for creating beautiful and distinctive places with a consistent and high quality standard of design. Their geographic coverage, level of detail and degree of prescription should be tailored to the circumstances and scale of change in each place, and should allow a suitable degree of variety.” Persimmon Homes would support Rochford District Council in the preparation of
Design Codes in the District.

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

Persimmon Homes would broadly support the draft Place-Making Principles, as they would provide a
broad framework for future Design guidance and policy produced by the Local Authority. We note however that there is not a principle relating to Biodiversity; given the Government’s commitment to ensure that development pursue opportunity for net gains to Biodiversity, it may be appropriate to reflect this within the place-making charter.

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

Persimmon would welcome the use of design guides, codes or masterplans, which would be supported by the NPPF:
“Being clear about design expectations, and how these will be tested, is essential…” (para. 126)
“Plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable.” (para. 127)
“To provide maximum clarity about design expectations at an early stage, all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences.” (para.128)

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

Persimmon Homes would refer to paragraph 129 of the NPPF:
“Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale, and to carry weight in decision-making should be produced either as part of a plan or as supplementary planning documents. Landowners and developers may contribute to these exercises, but may also choose to prepare design codes in support of a planning application for sites they wish to develop.
Whoever prepares them, all guides and codes should be based on effective community engagement and reflect local aspirations for the development of their area, taking into account the guidance contained in the National Design Guide and the National Model Design Code. These national documents should be used to guide decisions on applications in the absence of locally produced design guides or design codes.”
However, given the variety of settlements and styles within Rochford, we would suggest that separate
Design Codes be created for each settlement.

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

The National Model Design Code, published July 2021, confirms that the preparation of a Local Design Code should follow seven steps:
1. Analysis.
1A - Scoping: Agreeing on the geographical area to be covered by the code and the policy areas that it will address.
1B – Baseline: Bringing together the analysis that will underpin the code and inform its contents.
2. Vision.
2A – Design Vision: Dividing the area covered by the code into a set of typical ‘area types’ and deciding on a vision for each of these area types.
2B – Coding Plan: Preparing a plan that maps out each of the area types and also identifies large development sites from allocations in the local plan.
2C – Masterplanning: On larger sites working with land owners and developers to agree a masterplan for each of the development sites establishing the key parameters and area types.
3. Code.
3A – Guidance for Area Types: Developing guidance for each area type by adjusting a set of design parameters.
3B – Code Wide Guidance: Agree on a set of policies that will apply equally across all area types.
We would advise the District Council to use the Model Design Guide as the basis for the production of
all Design Codes in the District.

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?

Of the options listed, Persimmon Homes would support:
 Option 2 – requiring a suitable or negotiable mix of housing that is response to the type or location of development;
 Option 5 – all homes to meet NDSS;
 Option 6 – all homes to meet M4(2); and
 Option 7 – a proportion of homes to meet M4 (3).
Option 1 listed proposes a non-negotiable mix to be provided on all housing developments. Clearly, this
option is unworkable in practice as certain sites are unable to deliver certain types of housing. For example, Brownfield sites in the urban areas are unlikely to be able to deliver suitable proportions of larger dwellings; likewise, heritage constraints in certain areas may influence the size of dwellings that a site could deliver to satisfy historic environment consultees. It is therefore more appropriate to require housing mix to be agreed during pre-application discussions, having regard to site and location characteristics, with the latest SHMA evidence used as a broad guide to inform those pre-application discussions.

Similarly, option 3, which proposes to allocation specific sites for certain types of housing, such as affordable homes, would have the potential to result in ‘ghettos’ and not created mixed inclusive communities (as required by paragraph 92 and 130 of the NPPF; good place-making would be achieved by requiring all developments to deliver policy compliant levels of affordable or specialist housing (subject to viability etc.) and to ensure that housing is of the same build quality/appearance as the
market housing.

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?

Guidance confirms that net gains should normally be delivered on site. However, where achieving biodiversity net gain is not possible on site whilst still delivering a viable project; developers have the option to contribute at a local or regional scale to off-site Offsetting or Compensation. This approach can often successfully result in greater gains for biodiversity than could be provided within a constrained development site. It supports delivery of Local Nature Recovery Strategies and is consistent with the central conclusion of the 2010 report ‘Making space for nature’, that we need more, bigger, better and joined up habitats.
Referring back to the Spatial Strategy Options, the medium and higher levels of growth options are much more likely to be able to deliver the biodiversity and green infrastructure improvements and contributions required, than on existing brownfield sites, as confirmed within the Integrated Impact Assessment:
“The medium and higher growth options are also noted for their potential to support the delivery of strategic green infrastructure provisions and associated biodiversity net gain. This includes improvements being explored in the green infrastructure network across the sub-region through the South Essex Green and Blue Infrastructure Study (2020), such as the Regional Parkland. The Regional Parkland has the potential to act as alternative greenspace targeted at reducing recreational pressures at designated biodiversity sites. These options thus provide a greater contribution to the principles of the Essex Coast Recreational disturbance Avoidance & Mitigation Strategy (RAMS).
The lower level of growth will mainly result in the delivery of new homes on urban and brownfield sites so has greater potential to avoid designated sites and support urban greening to some extent. The urban focus however is less likely to bring forward strategic mitigation, such as the Regional Parkland to mitigate the recreational pressures on designated biodiversity resulting from a growing population.
As a result, the medium and higher growth options are considered more likely to perform better overall in relation to this IIA theme; however, the potential for a significant effect is uncertain as will be dependent on the location of growth.”
It continues:
“…the potential for larger-scale development under Options 2a and 2b is recognised for the potential
for greater net gains in biodiversity.”

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?

Persimmon Homes would support a combination of option 1 and 3 listed on page 55 of the Spatial Options document to address green and blue infrastructure through the Local Plan:
 Option 1 – Allocating specific areas of land for strategic infrastructure appears a sensible and logical strategic objective to deliver tangible green and blue infrastructure through the course of the Local Plan. Strategic policies to the enhancement and protection of these areas would
be required to provide a policy framework for these specific areas (the coastal path project and South Essex Estuary Park for example), and contributions towards funding these projects could be secured, where required/relevant etc., through S106 contributions or CIL;
 Option 3 – Development sites of a certain scale (particularly edge of settlement, greenfield sites) are typically capable of being able to deliver on-site green and blue infrastructure; of providing connections to green and blue infrastructure through their site; or of securing financial contributions to improving green and blue infrastructure in the local area. With reference to our
site at Western Road, Rayleigh, the site benefits from an existing public right of way running through the centre of the site, and informal footpaths running along the southern boundary along the woodland edge. These informal paths have to be managed yearly in order to maintain these paths for the use of existing residents; without this regular maintenance these footpaths
would not be usable. The development of the site therefore look to retain these links and provide permanent, sustainable connections and to enhance these where possible, providing improved footpaths and links to the surrounding area, including to Kingley Woods to the west of the site. Access to the wider countryside can also be promoted through the development as
existing footpaths can be improved and maintained. There is scope to enhance the Green Infrastructure Network in the locality by providing more formalised and accessible links through the green spaces.

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

With reference to the four options, we would comment as follows:
 Option 1 – support the protection of existing school and healthcare facilities through specific allocations.
 Option two – support the allocation of specific sites for the creation of new community infrastructure (providing that site is being allocated for that use or would not conflict with other site promotions).
 Option 3 – Broadly support requiring new developments to deliver new community infrastructure on site, though would caution that this would only apply to sites of a certain scale.
For example, the Essex County Council Developers’ Guide to Infrastructure Contributions highlights that developments with an individual or cumulative size of 1,400 homes are likely to be required to deliver a new two-form entry primary school, whilst developments with an individual or cumulative size of 4,500 homes or more will need to provide a new two-form entry secondary school. It would be simpler for the LPA to identify new sites for community infrastructure (new schools/extensions to existing schools, new surgeries/extension to existing surgeries etc.), and require developments to contribute towards those new facilities (with reference to para.34 of the NPPF requiring that Local Plans should clarify the level of contributions expected from new developments).
With reference to the Spatial Strategy Options, the Integrated Impact Assessment states:
“The medium and higher growth options are more likely to have a significant positive effect on this IIA theme through the delivery of new employment land and retail floorspace. These options are also likely to deliver more new infrastructure upgrades and sustainable transport routes to attract further inward investment. Further to this, the higher growth options could contribute to the delivery of sub-regional improvements to green and blue infrastructure, which could have a positive effect on the tourism economy. Whilst positive effects are considered likely under all options, the lower growth option is
considered less likely to lead to positive effects of significance.
We would also question whether the Council intends to progress with a Community Infrastructure Levy, to fund the development of new infrastructure in Rochford, as no reference is currently found on the Council’s website (and no reference is made to CiL within the Spatial Options Document). CIL is seen by many as creating a more transparent contributions system, whereby developer contributions can be calculated upfront (which assists developers with viability calculations, as well providing clarity to local residents/interests groups on the level of funding provided by new development and where that funding is directed towards).
Persimmon Homes would support Rochford District Council in the development of a Community Infrastructure Levy.

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?

Persimmon Homes would request that the Conservation Area Appraisals be updated as part of the emerging Local Plan process; these were last produced in 2007 so by the time the plan is adopted, these will be over 15 years old. The Local Authority are aware that settlements and areas change over time, and as such, it would assist greatly for these documents to be regularly reviewed.
Persimmon Homes are also concerned that our site at Western Road, Rayleigh (ref. CFS087) is marked poorly in the accompanying Site Appraisal Paper due to impacts on Built Heritage. This appears to have been assessed purely on the basis that there is a listed building – the Grade II listed Weir Farmhouse (List UID: 1322351) – but that this assessment has seemed to be have been undertaken purely as a mapping exercise and without any consideration to the sites relationship to this asset on the ground. The listed building is located a considerable distance from our site, and is screened from view not only by existing twentieth century development but also by considerable mature trees (which would be retained as part of any development proposals); therefore development of our site (ref. CFS087) would have no impacts on the setting of this listed building, as is fully confirmed within the Heritage Statement that accompanies these representations.
With reference to the Spatial Strategy Options, the Spatial Options Paper identifies that said option to
increase densities in urban areas are unlikely to be compatible with historic centres and local character,
as confirmed within the Integrated Impact Assessment, which states:
“…it is recognised that the lower growth option will focus development in existing urban areas, with a higher potential in this respect to impact on historic centres.”
We would therefore recommend that all assessments of built heritage impacts be fully assessed by up to date evidence, noting that the Council’s Conservation Area Appraisals haven’t been updated since 2007 and therefore may not accurately reflect existing site conditions.

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?
Persimmon Homes would support the four options listed to address transport and connectivity through the plan.

Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [walking, cycling, rail, bus, road etc.]

With reference to, our site at Western Road, Rayleigh (ref. CFS087), and the site is within a very sustainable location being walking distance to local amenities including schools (0.6 miles) and a train station (1.1 miles). A main bus route also runs in very close proximity to the site. The wider main road network is also easily accessible.
The development will provide betterment to existing footpaths, creating enhanced foot and cycle links to services and employment areas for new and existing residents. The existing PROW could be upgraded into a cycle link and a formal path that can connect to an east/west foot/cycle link that runs from Western Road to Weir Farm Road. This will allow a good connection to High Road and therefore services/employment/further transport networks. As previously stated, existing footpaths running through the site are informal and could be upgraded as part of the redevelopment proposals for the site to provide permanent, sustainable connections for existing and new residents.
Access to the wider countryside can also be promoted through the development as existing footpaths can be improved and maintained.

Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
Persimmon Homes agrees with the vision for Rayleigh. As the District’s only Tier 1 settlement, it is correct that it should take large proportion of the District’s Plan Requirements during the Plan Period.

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

Persimmon Homes is promoting site CFS087 for residential development. This 10-acre site is located
north of the A127 by Rayleigh Weir. The site is contained between the current residential area defined by the southernmost extent of Western Road and Eastern Road with the A127.
The majority of the site comprises rough grassland, which has no beneficial use. There is a Public Right
of Way (No25) running south from Eastern Road. The development offers the opportunity to formalise footpath links from Western Road. It would also offer the opportunity to create recreational routes through to Weir Farm Road. The allocation has the potential to enhance the Green Infrastructure Network in the local area.
The site benefits from being closely related to the existing built up area of Rayleigh, its town centre, train station, bus routes and key services. The Vision is that the site will add to the growth of Rayleigh, providing homes in a sustainable location close to existing services, transport links and accessible green space.
The site is located immediately south of the Main Settlement of Rayleigh and north of the A127.
Rayleigh Town Centre is within a 10-minute walking distance and the Train Station, with a direct link into London, is only 1.1 miles walking distance. A main bus route linking the town centre/train station, Southend, Basildon and Canvey Island runs through High Road. This is in close proximity of the site. The site has good access to the wider main road network.
The site is within walking distance to the nearest Primary and Secondary School (0.6 miles and 1.1 miles respectively).
The development of the site would provide beneficial enhancements to the public open space provisions
and improved walking/cycling links across the site to encourage new and existing residents to use
sustainable modes of transport.
The site does not serve the five purposes of Green Belt (as confirmed within the Council’s evidence base) and would benefit from housing development to allow for improved biodiversity creation and management. Development of the site would also provide an enhanced settlement boundary to the A127 and provide an improved setting for Ancient Woodland and Local Wildlife Site.
Development of the site will allow for delivery of required housing in a sustainable location.
Persimmon Homes are currently preparing an updated Promotional Document to support the allocation of the site for residential development, which will be submitted shortly.

Conclusion
The adoption of the new Local Plan (2023) remains, optimistically, 2 years away. The Council does not
have a published strategy for bolstering housing land supply in the period up to the adoption of the new Local Plan. The Council need to identify a strategy to boost significantly the supply of housing in the period up to the adoption of the development plan, such measures should include the early identification of suitable new sites and seeking to pro-actively work with landowners and developers to bring such sites forward.
The Council must ensure that a new development plan is taken forward without further delay. The continued lack of an up to date development plan is significantly hampering delivery and the regeneration imperative.
Persimmon Homes have an interest in site CFS087: Land between Western Road and Weir Farm Road
Rayleigh, which the Site Appraisal Paper confirms suitable, deliverable and available for residential
development, and are actively seeking additional sites in Rochford to deliver much needed housing and
regeneration in the Borough. Further details of this site, along with plans, are submitted as part of this submission to support its allocation within the Local Plan for development.

Dear RDC,

Re CFS043 land at Bolt Hall Farm which we will refer to as Lark Hill from now on.

We wish to persuade you to give this a higher site assessment score rather than proposing it for ‘exclusion as too remote’.
Canewdon is seen by many as only ‘the village’ but Canewdon is a big parish with a large percentage of parishioners living outside of ‘the village’, they are forgotten when it comes to amenities as only ‘the village’ is the focus of attention. A development at Lark Hill will help many of these forgotten parishioners.

Lark Hill is an ideal position, it does not as others do, fall in the Coastal Protection Belt which RDC designated as having the most stringent restrictions on development. The existing high hedge along Lark Hill Road which will be kept, screens the site from being seen from Lark Hill Road. All development proposals in Canewdon will by default bring extra traffic, but Lark Hill will not bring extra traffic through Canewdon Village, past Canewdon School and the pinch point in the high street opposite one of the school entrances and Rose Cottage which is really only wide enough for one car at a time, as is much of Anchor Lane especially during school time. There is not a even a complete pedestrian pavement through Canewdon high street leading to the park and village hall, residents of Canewdon Village do not want a development that brings extra traffic through their village making it more unsafe for pedestrians.

The 80 or so houses adjacent to the proposal at Lark Hill do not have access to mains sewage, a public bus stop, public bus service, walking infrastructure, green space/playing field. They have lost the bus route along Lark Hill/Canewdon Road where there used to be at least 4 bus stops including one on the proposed Lark Hill stretch of road; as youngsters this was our route to Rochford, Rayleigh and Southend. This bus route has been lost for the moment but a development at Lark Hill would stimulate demand for this route to be reinstated, this would be a benefit to so many especially as public transport is going to be so important in a future low carbon economy.
Canewdon Parish has lost so many facilities to development which have been turned into housing; Younnes Village shop, the Chequers Pub and Creaksea Ferry Inn; hairdresser, bakers, hardware shop and village garage; the village café along Lambourne Hall Road and of course the riding stables which was enjoyed by people far and wide and is now a housing development.

We would like to persuade RDC that Lark Hill is not remote, a recent case Braintree Council v Secretary of State for Communities and Local Government found that a site for residential development in a rural area should not be considered to be isolated, ‘if there are other houses close by’, there are circa 80 dwellings close by along Lark Hill Road and Pudsey Hall Lane. All of these adjacent dwellings will benefit from a development at Lark Hill.
If developed, Lark Hill will aid/provide the following:
1: Sewage will need to be laid on for Lark Hill allowing a connection to mains sewage for nearby houses.
2: Public transport will once again become viable along Lark Hill/ Canewdon Road.
3: A green space/park will be built at Lark Hill.
4: Walking infrastructure will be improved alongside Lark Hill Rd.
5. The creation of up to 8km of bridleways.

We have picked some scores for Lark Hill that we would like to discuss from your site assessment proforma for CFS043..
Critical Drainage only 2: It is envisaged all surface water will be recycled on Lark Hill in 2 large ponds and a wildlife reed bed will be created.
Impact on Built Heritage and Archaeology only 2s: Is this because of the Pill Box? This will be protected and will not be demolished as so many have been, as a family we are proud to be caretakers of a piece of history.
Access to bus services is only 1: We agree with this and it highlights the need for the bus route to be reinstated for the existing residents along Lark Hill/Canewdon Road/Hyde Wood Lane and Pudsey Hall Lane.
Public rights of way only a 3: There is a public foot path through the site which links to a network of footpaths so why such a low score? There will be a public footpath created to the North of the site which will join with other parts of the local footpath network leading to the River Crouch.
Secondary Schools only a 1: Considering the catchment area for King Edmunds encompasses Wakering and Foulness we believe Lark Hill should be higher as Greensward is only 2.9 miles away and closer still King Edmunds 2.3 miles.
Impact on jobs only a 3: The land at Lark Hill only provides enough work for about 1/10th of a man year, developing Lark Hill will create many local jobs.
Access to train services only a 1: Train stations at Rochford and Hockley are nearby being only 3.6m and 3.2m away. When reading estate agents selling points for properties along Lark Hill Road, they extol the fact Greensward and King Edmunds schools and the train stations at Hockley and Rochford are so close.

Self Builds: Government encourages self- build housing and councils to make sites available, there is already a demand with over 80 people on the RDC self-build register. Self-builders would be actively encouraged at Lark Hill so fulfilling the duty RDC has to provide self-build plots.
The community benefits of a development at Lark Hill.
1: No extra traffic through Canewdon Village.
2: Access to mains sewage for existing adjacent residents.
3: Improved public footpath network.
4: Reinstated bus route.
5. Creation of bridleways.
Environmental benefits of a development at Lark Hill.
1: 2 wildlife ponds will be created on site.
2: A 22 acre reed bed will be created for wildlife.
3: During the building phase spoil will be used to help create the reed bed and for maintenance of the Upper Raypits seawall, so no muck away lorries will need to use the local road network.
4: With the transition away from gas and also hydrocarbons Lark Hill will be heated by a community heat network using the latest green renewable energy technology available.
5: Green renewable energy will be generated to produce as close to 100% availability as possible.
6: Houses to be built to Passive Haus standards.
Points 4, 5 and 6 will be a showcase for existing communities such as Canewdon village showing how to lower their carbon emissions. Government is banning the use of gas and oil in new build houses by 2025 which as we write this letter is only just over 3 years away. It`s unbelievable that new developments are still being built using gas and oil for heating and without electric car charging points infrastructure at the 11th hour!

In the 60`s Canewdon was at the forefront of housing development when the ` new model village` was created and could be at the forefront again. Lark Hill is ready to step up if given the go-ahead to showcase a new affordable low carbon emission community that we all need to adopt for the future.

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.

Re: Rochford District Council, New Local Plan: Spatial Options Consultation Paper 2021
Consultation regarding the proposed Spatial Options identified by Rochford District Council identifying the
range of challenges and opportunities relating the proposed growth within the Rochford District over the
next 20 years.
Essex Police welcome the opportunity from a designing out crime and crime suppression perspective to comment on the Rochford District Councils – New Local Plan: Spatial Options Consultation Paper 2021.
After review of the documentation, the ‘Essex Police – Designing out Crime Office’ (DOCO) would wish to raise the below for further consideration and would welcome further consultation regarding the below observations.
Please note that it wouldn’t be appropriate for Essex Police to make comment on questions that are commercially sensitive or where the question relates to a specialism outside of the Designing out Crime remit.

Q2. Do you agree with our draft vision for Rochford District?
Essex Police value the importance of addressing the natural environment and health and wellbeing within communities and would request embedding within the vision statement, a focus on promoting and designing a safer community. Implementing designing out crime measures will ensure a sustainable community, where crime is designed out, promoting a feeling of safety.
Appreciative of the holistic vision, Essex Police would welcome the embodiment of ‘safe and secure’ concepts within the vision for Rochford and embedded within such Strategic Documentation. Such an inclusion will ensure that safety has been considered within new proposed allocations.

Q4. Do you agree with the strategic priorities and objectives we have identified?
With regard to the specific strategic priorities and objectives, Essex Police have the following comments and observations:
Strategic Objection No. 5:
Consideration of adopting the principles and accreditation to SBD Schools.
Strategic Objection No. 6:
We would recommend seeking accreditation to SBD Homes and application of CPTED principles throughout the design lifecycle.
Strategic Objection No. 9: Please see the response to Question 51 regarding embedding sustainable transport links
Strategic Objection No. 10:
Essex Police would advocate adopting the ‘Safe Roads Approach’ when designing road infrastructure to ensure the safety of all road users.
Strategic Objection No. 11
Consideration is required to ensure the design embeds the appropriate level of permeability with connectivity
Strategic Objection No. 14
We would recommend the completion of a Health Impact
Assessment, (further information can be found within Q8)
Strategic Objection No. 17
The Essex Police DOCOwelcome the inclusion within this Strategic Objection of engaging with the ‘designing out crime’ team to ensure that all ‘new developments and the public realm are well designing and safe environments’.
Strategic Objection No. 18
Consideration of adopting the principles and accreditation to SBD Schools.
Strategic Objection No. 22 Please see the response to Question 43 regarding heritage and the built environment.
The Essex Police DOCO would welcome when designing safe and secure environments adopting Secured by Design (SBD)principles. As the preferred enabler to mitigate crime, Essex Police advocate both applying ‘Crime Prevention through Environmental Design’ (CPTED) principles and seeking the various accreditations incorporated within the applicable SBD schemes.

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

Constructing well designed places, buildings and communities that promote both sustainable
communities and health and wellbeing is an objective that the Essex Police DOCO widely supports; however, it is imperative that they must also be safe, secure, and accessible. This can similarly be evidenced within the Health Impact Assessment, as mitigating the opportunities for crime is not only about reducing and preventing injury and crime, but it is also about building strong, cohesive, vibrant, and participatory communities.

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?

Secured by Design (SBD) seeks to achieve sustainable reductions in crime through design and other approaches to help communities live in a safer society. Achieving SBD Homes Gold Accreditation will satisfy the security needs assessment requirements within BREEAM, but also address many of the associated security risks.
Academic research has proven that the application of crime prevention and SBD can see up to 75%
reductions in burglary and 25% for Vehicle crime and ASB. There are substantial Carbon cost savings
associated with building new communities to SBD standards, i.e. replacing not only poor-quality doors and windows, but also the stolen property as a result of criminal acts. This will ensure that designing out crime and crime reduction is considered throughout, be that residential, businesses and commercial space.
When considering the lifecycle and increasing the lifespan of building materials and security hardware, (such as doors and windows), Essex Police would recommend utilising companies that have achieved Secured by Design (SBD)Police Preferred Specification.
There are substantial Carbon cost savings associated with building new communities to SBD and SBD
Preferred product standards, i.e. replacing not only poor-quality doors and windows, but also the stolen property as a result of future criminal acts.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
Essex Police DOCO would welcome the potential inclusion for consultation on all proposed Design
Guides / Codes and or Masterplans to embed designing out crime concepts from the initial stages. To supplement this consultation, Essex Police DOCO would strongly recommend local authorities engage with the DOCO to embed designing out crime and CPTED principles throughout.

Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
Essex Police DOCO would advocate that across the various Design Guides / Codes and Masterplan’s a
consistent approached is garnered when approaching designing out crime and mitigating any potential security risk. The perception of crime and the fear of crime can be an influential factor in determining the synergy and ongoing sustainability of the wider community. Essex Police would recommend the developer considers the foreseeability of crime and maximise on the opportunity to embed CPTED principles, as these crime types can potentially be ‘designed out’ and minimised with due consideration. This will in turn prevent the need for bespoke situational crime prevention measures in the future and promote a sustainable community.

Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?
When designing new homes and community amenities, it is imperative to consider crime as a material consideration. The perception of crime and the fear of crime can be an influential factor in determining the synergy and ongoing sustainability of the wider community. Essex Police would recommend developers consider the foreseeability of crime and maximise on the opportunity to design such issues out, as to prevent the need for bespoke situational crime prevention measures in the future.
It is imperative that design specifications of buildings and the surrounding community are risk commensurate (i.e. correlate to the Security Needs Assessment) and it is important that an effective and realistic level of physical security is commensurate with the risk.
Encouraging residents and users of places to feel a sense of ownership and responsibility for their
surroundings can make an important contribution to the safety of a community. This can be facilitated by clarity in where public space ends and where communal, semi-private or private space begins (intermediate space). Uncertainty of ownership can increase the likelihood of crime and ASB going unchallenged. Inclusive of the above, Essex Police actively encourage the following generalised considerations:
• Access and movement – places with well-defined routes, spaces and entrances that provide for convenient movement without compromising security.
• Structure – places that are structured so that different uses do not cause conflict.
• Surveillance – places where all publicly accessible spaces are overlooked.
• Ownership – places that promote a sense of ownership, respect, territorial responsibility, and community.
• Physical Protection – places that include necessary, well-designed security features.
• Management and maintenance – places that are designed with management and maintenance in mind, to discourage crime in the present and future.
Essex Police would recommend all developments seek accreditation to the various Secured by Design (SBD) Guide or at a minimum the SBD principles.

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites?
With regard to future proposals for the design of Gypsy and Traveller Sites, we would recommend
consideration of the following:
• Careful consideration appertaining to the road infrastructure into the proposed sites, as this will not only promote a safe haven for occupants but may also discourage criminal activity.
Appropriate Emergency Service Access (including necessary turning circles) is required to ensure appropriate access onto the sites.
• Road access to the site and the ongoing farm raises concerns over access and egress onto the site for emergency services and safety of the staff. Along that stretch of road what traffic calming measures will be in place, will this be replicated across the development?
• Necessity for detailed border treatments for the site as judicious planting may not be of a robust nature.
• Boundaries delineation between the public and public realm space needs to be clearly defined, with any open spaces displaying features which mitigate any potential unauthorised access.
• Consideration of the ‘Communities and Local Government, Designing Gypsy and Traveller Sites, Good Practice Guide’ when fine tuning the detail across the site.
• Early liaison with the Designing out Crime Team at the appropriate state of the design to ensure ‘CPTED principles’ are embedded within the design.

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?
Heritage indirectly features within designing out crime in many respects to ensure that any developments within the conservation areas, (containing listed buildings or other features of value), are protected from crime and ASB within those early planning considerations.
Sometimes heritage becomes an afterthought and measures put into place within a building development that may be to the detriment of a heritage asset, for instance an asset that once had good natural surveillance and passage of the public, becomes within an isolated location with little natural surveillance.

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?

To create environments that are healthy, accessible, and well-designed, there will be a need to reimagine the way that developers and landscapers deliver key service functions that are effective, and positively influence the design of public realm space. It is important to ensure that the design is such, that any community spaces and broader public realm, do not become a central point for ASB, thus having an adverse effect on those communities. Careful consideration is required around
desired levels of permeability and access and egress (i.e. wayfinding) to ensure that crime is not generated as a result.
Consideration is requested by developers and designers to adopt the “Safe system approach” when designing local roads, access road and transport links across proposed development. This will take into consideration the various road user groups who wish to access these roads.
We appreciate that it is important to create a sense of place and build communities with the provision of accessible services and facilities that encourage walking and cycling etc. It is also important to ensure that the design is such, that any community spaces and broader public realm, do not become a central point for ASB or generate a fear of crime when using that space, thus having an adverse effect on those communities.
With a focus on sustainable travel across the site, consideration needs to be given to the secure external storage facilities and bicycle security, be this within the home environment or within communal bicycle stores.

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

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

Climate Change and Resilient Environments
Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the
district to supply low carbon or renewable energy?
13. Whilst the Council can set targets as to the percentage of a home’s energy use that should be obtained from decentralised energy sources it is important that the Council recognises that this will place an additional financial burden on development and will therefore need to be considered in the viability study.

Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?
14. No. The housebuilding industry, through the HBF, recognises that there is a need to improve the environmental performance of new residential development. In order to achieve this, we established with a wide range of partners the Future Homes Task Force. This task force examined how the house building industry can work toward delivering net zero carbon homes in order to support the Government’s target of the country delivering net zero carbon emissions by 2050.
The initial outcomes of this work can be found at https://www.futurehomes.org.uk/ with a summary of the Delivery Plan resulting from this work attached to this
response.
15. The delivery plan published by the task force in July outlines the need to operate on a collective basis recognising the need for housebuilders, their supply network and the trades people building homes to successfully transition to the delivery of low carbon homes. In addition, it recognises the need for both national and local government alongside housebuilders to ensure those people buying new homes are confident in the technologies and systems being used.
16. As the Council are aware the proposed amendments to the building regulations will see development up to 2025 deliver a 31% improvement on C02 emissions
compared to current standards. The Future Homes Standard that will be introduced from 2025 will see new homes emit 75% fewer emissions than current standards. However, to deliver further reductions and achieve the national commitment of net zero emissions by 2050 will require the decarbonisation of energy supply at a national level rather than from the Council setting additional requirements for new homes above those set by Government.
17. Given the improvements that will be made through the amendments to building regulation the HBF do not consider it necessary for additional local standards to
be set with regard to energy efficiency and CO2 emissions. Only through a nationally consistent and phased approach to the introduction of the new
standards and technologies will the house building industry be able to maintain housing supply, ensure consumer confidence and deliver the required
improvements in emissions.
18. A national and standardised approach to improving the energy efficiency of buildings is the most effective approach to ensuring improvements in energy
efficiency whilst also ensuring the continued delivery of housing and infrastructure. The HBF considers a universal standard is necessary to allow the development of supply chains that focus upon responding to agreed national targets, and for training providers to plan their programmes to equip the labour force to meet these
new requirements. Importantly, a phased approach to delivering these improvements ensures those people buying new homes are fully aware of the new
technologies being used in their homes. It is vital that consumers are confident with the technology being used in their new homes and increase the wider appetite for similar standards to be adopted in the existing stock.
19. The HBF considers it important that Councils recognise that it will take time to ensure that the technology and supply chains required to achieve the significant reductions in emission from new homes required by the Future Homes Standard. There is still considerable work to do to ensure that supply chains are in place to meet demand from the housebuilding industry as well as having a workforce with the technical skills in place to deliver and maintain systems such as ground and air source heat pumps on a much larger scale. It is important that these systems when they are used work to ensure that the public are satisfied with the product and can rely on it to meet their needs.
20. Should the Council seek to go beyond what is required by building regulations then they will need to clearly set out in their viability study the additional costs this will place on development in the Borough. These costs can be significant and in combination with the other costs that are placed on development through the local
plan can lead to development becoming unviable.

Place-making and Design
Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the district, or should different principles apply to different areas?
21. It is not clear what the charter is supposed to offer with regard to decision making process and whether these will be reflected in the policies set out in the Local
Plan. In order to provide an effective steer to applicants and decision makers the Council must set out its expectations in policy and ensure that these are consistent with the approach set out in nationally in the NPPF and its supporting guidance.

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

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

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

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

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

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

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

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

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

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

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

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

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

To whom it may concern
I object to site COL07 (Mill Hall, car park and green) and also site COL20 Civic Suite with landscaped gardens to the rear being included in the Local Plan as a future residential development site.
Under Section 71 of the Planning (listed Buildings & Conservation Areas) Act 1990 and other legislation Rochford District Council has a duty to preserve and enhance the Rayleigh Conservation Area. Both sites are surrounded by listed buildings and a Scheduled Ancient Monument in the case of Mill Hall, neither should not be developed for housing. The setting of the listed buildings are also greatly enhanced by the gardens and the landscaped car parks which make a significant contribution to the conservation area, these would be lost if developed for residential use.
Under S.39 Planning & Compulsory Purchase Act 2004, the Planning & Compulsory Purchase Act 2004 and other legislation and guidance, Rochford has a duty to contribute towards achieving sustainable development.
It is widely acknowledged that the greenest building is the one already there. The carbon footprint of demolishing existing buildings on these sites will significantly increase the carbon footprint of the whole district. In is important therefore to invest in the present buildings and make them more sustainable (Mill Hall would appear to offer significant opportunities.).
Under S.40 of the Natural Environment & Rural Communities Act 2006, the local planning authority has a duty, when exercising its functions, to conserve biodiversity. The green areas and trees on both sites greatly contribute to the biodiversity of the area. In particular in this conservation area, which is not only valued for its buildings but for the mature trees and open space owned by the public. The loss of this biodiversity would be unacceptable if these sites were changed to residential use in the next local plan.
The contribution of car parking to the vitality of the town centre is significant and loss of public car parking within COL07 an COL20 would be detrimental to the Rayleigh Town Centre.
The above are borne out by Rochford Council's own plans and policy documents.

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

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

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

Rochford Local Plan Regulation 18 Spatial Options Consultation
Representations on behalf of Rydon Homes
Responses to Questions
Q2. Do you agree with our draft vision for Rochford District? Is there anything missing from the vision that you feel needs to be included?
A : The draft ‘Vision’ for Rochford contains many appropriate and supportable elements, but it should contain a commitment to delivering sufficient high quality homes to meet need.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
A : Yes, there should be separate ‘Visions’ for each of the main settlements. This will help capture their diversity and distinctiveness. It may be necessary to have a a generic ‘villages / hamlets’ Vision for the smallest communities.
Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?
A : The strategic objectives are generally supported. However, the number should be expanded to cover cross-cutting themes. An example would be to make the link between the objective for zero carbon and the concentration of new development in sustainable locations (ie. the larger towns) explicit.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
A : Yes, the settlement hierarchy is sound. It correctly identifies Rayleigh as the Tier 1 primary settlement in the District.

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

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

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

Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood
risk and coastal change?
A : A sequential approach to flood risk is both logical and in accordance with the guidance in the NPPF.

Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character?
A : The Coastal Protection Belt and Upper Roach Valley should have continued protection.

Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
A : Agree in principle, the difficult question is what is the appropriate percentage which is both viable and deliverable.

Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?
A : This may not be necessary since the Government is already proposing to strengthen Building Regulations to deliver high energy efficient standards. If the Local Plan was to propose even higher standards, this would need to be rigorously tested in terms of the impacts on both viability and delivery.

Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas?
A : Yes, a high level ‘place making charter’ would be useful, in principle to provide guidance whilst not being inflexible.

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

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

Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
A : A single Design Guide for the whole District would become too generic and fail to identify what makes each settlement unique. Settlement specific design guides would be most effective, as long as they do not stifle innovation and can allow alternatives approaches,
where fully justified.

Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?
A : It is important that any documents are not too prescriptive and allow a degree of flexibility. All documents should include a date by which they will be reviewed.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing?
A : The appropriate response is to negotiate a site specific mix which is appropriate to the settlement and the characteristics of the site itself (Option 2). National Space Standards are appropriate. The approach to Part M4 of the Building Regulations could reflect that adopted in the London Plan.

Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
A : Option 4A is the most appropriate solution to meeting open space needs if they can all be met on site. Any needs which cannot be met on site should be met by off site contributions.

Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant?
A : Option 2 (incorporating Town Centre policies in the Local Plan) is the most appropriate approach.

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

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

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

Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate? Why these areas?
A : Yes, sites CFS053 and 086 south of Wellington Road.
Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
A : The green spaces shown are of local significance and should be identified as such. No additional green spaces should be identified as having local significance.

*I object to site COL07 (Mill Hall, car park and green) and also site COL20 Civic Suite with landscaped gardens to the rear being included in the Local Plan as a future residential development site.*

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

*Under S.39 Planning & Compulsory Purchase Act 2004, the Planning & Compulsory Purchase Act 2004 and other legislation and guidance, Rochford has a duty to contribute towards achieving sustainable development.*

*It is widely acknowledged that the greenest building is the one already there. The carbon footprint of demolishing existing buildings on these sites will significantly increase the carbon footprint of the whole district. In is important therefore to invest in the present buildings and make them more sustainable (Mill Hall would appear to offer significant opportunities.).*

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

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

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

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

Background

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Strategy Options

Q5: Do you agree with the settlement hierarchy presented?

No.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Spatial Themes

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

No.

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

Yes.

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

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

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

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


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

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

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

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

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

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

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

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

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

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

Please see our response to Q16 and Q59.

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

Please see our response to Q14.

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

Yes.

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

Please see our detailed response to Q16b. and Q16c.

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

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

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

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

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

Please see also our response to Q16b.

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

Housing For All

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

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

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

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

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

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

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

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

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

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

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

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

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

Q19. Are there any other forms of housing that you feel we should be planning for? How can we best
plan to meet the need for that form of housing?
No.

Biodiversity

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

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

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

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

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

Community Infrastructure

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

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

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

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

Yes.

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

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

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

Yes – see our response to Q.36.

Open Spaces and Recreation

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

BDW support Option 4.

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

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

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

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

Yes.

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

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

No.

Transport and Connectivity

Q51: With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
BDW support a combination of all Options identified by the Council in addressing the need for sufficient and
accessible community infrastructure through the plan.

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

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

Please also see our response to Q51.

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

Q53: With reference to your preferred Strategy Option, are there opportunities for growth to deliver
new transport connections, such as link roads or rapid transit? What routes and modes should these
take? [walking, cycling, rail, bus, road etc.]

Please see our response to Q52 / Q53.

Planning for Complete Communities

Wakerings and Barling

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

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

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

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

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

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

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

Next Steps

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

Yours faithfully
David Churchill
Partner

Dear Sir,
I write to submit feedback on the proposed new housing development sites in our area.

(New Local Plan: Spatial Options Document 2021) https://rochford.oc2.uk/document/207/28308#d28422

In common with the majority of residents I believe Rayleigh and surrounding areas already have enormous new build projects underway. We should stop further housing sprawl especially on the outskirts of towns such as Rayleigh where upgrading the road system is impractical. The uncertainty of the situation is causing anxiety amongst my friends and neighbours who maybe directly impacted.

My concerns are the usual ones:
• Loss of greenbelt and wildlife habitat
• Traffic congestion and associated air pollution
(Inability to widen the narrow residential roads in Rayleigh)
• Surface water drainage
• School and GP services

Fundamentally I fear we are on a path of infinite housing growth that surely cannot be sustained without deterioration to our quality of life. I feel we should halt all new housing developments on town borders (greenbelt land) and create new towns with the required infrastructure instead.

Thank you for the opportunity to provide my feedback, please find my responses to the questions enclosed.

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

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

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

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

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

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

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

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

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

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

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

Strategy Options

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Spatial Themes
Q8: Are there any key spatial themes that you feel we have missed or that require greater emphasis?
No.
Q9: Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?
Yes.

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

Q10: Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from
development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character?
BDW would expect these designations to be afforded the necessary weight in the emerging Local Plan and/or
at the planning application stage. Subject to the Council selecting either Option 2b or 4 as set out in the
response to Q.6 above, BDW also suggests that sites which are unconstrained from such designations should
be the focus of allocations in the emerging Local Plan.
Q11: Do you agree we should require development to source a percentage of their energy from low carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
Whilst BDW support the principle of requiring a percentage of energy in developments to be from low-carbon and renewable sources, this should be subject to consideration of viability.

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

Q12: Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?
Whilst BDW support the principle of requiring energy efficiency standards of developments to be higher than
the building regulations, this should not be a requirement for all developments. The ability to achieve this will be subject to the viability of a scheme.
Therefore, to be acceptable in planning terms, developments should meet the energy efficiency standard set out in the building regulations. If a scheme were to exceed building regulations, this should be recognised as a bespoke merit / positive of the scheme, that should weigh favourably in the planning balance.
Q14: Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas?
BDW support the inclusion of a place-making charter and the listed standards, in principle.
Whilst broad objectives (e.g. aiming for carbon-neutrality; tackling air quality; promoting active travel) may help
achieve a collective Vision for the area, sufficient account and flexibility must be given for settlement / site-specific circumstances.
Please see our response to Q16 and Q57.

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

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

Q16b: If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
BDW oppose the imposition of a single, broad design guide/code for the District. As the Council recognise,
this would fail to account for and preserve the mix of historic, natural, and urban environments that help to
create distinctive local vernacular and character. Conversely, BDW would also oppose the production of
specific, prescriptive design codes on a site-by-site basis which would not provide sufficient flexibility, restrict the use of innovative methods and technologies, and frustrate artistic interpretation – all of which may impact
a development’s viability and contribution to “beauty”.
BDW support the imposition of broad strategic objectives (as set out in the place-making charter, as well as
the National Design Guide and National Model Design Code) with sufficient flexibility for design to be responsive to circumstances of a site as they evolve. This might include more specific, but still broad objectives are settlement/area level.
Indeed, Paragraph 129 of the NPPF advises that developers may also choose to prepare design codes in
support of planning application for sites they wish to develop. This option would give the freedom to provide
interpretation and sufficient resourcing from the private sector to develop appropriate design codes, in
accordance with the National Design Guide and National Model Design Code.

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

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

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

Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas?
As set out in Figure 28 of the consultation document (taken from the South Essex SHMA) the overwhelming
need for dwellings in Rochford District are houses (85%), rather than flatted development (15%). BDW observe
the allocation of smaller, urban/previously developed sites will not satisfy the prevailing demand for
dwellinghouses, which typically require a greater extent of land.

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

A more dispersed growth strategy also provides opportunities to balance housing trajectory across the District and the wider South Essex HMA – as greenfield sites typically have quicker lead-in times / build out rates
compared to those often associated with complex brownfield sites.
Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing?
No

Biodiversity
Q31: Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?
Whilst the Environmental Bill is still to receive Royal Assent, the intention of the policy to achieve biodiversity
net gains is clear and supported in principle by BDW.
This does not mean the Council should not seek to encourage developments to secure biodiversity net gain in excess of the 10% set in the draft Environmental Bill – which of course is a legal minimum. However, any
requirement to demonstrate a net gain in excess of 10% should be subject to a viability assessment and should
not be considered a requirement to make the development acceptable in planning terms (i.e. any provision in excess of the 10% figure should be considered an additional benefit of a proposed scheme).
PPG Paragraph 022 (Reference ID: 8-022-20190721) advises that biodiversity net gain can be achieved on-site, off-site or through a combination of both on-site and off-site measures. National guidance does not explicitly state the percentage split between such provision, but Paragraph 023 (Reference ID: 8-023-20190721) confirms such gain can be delivered entirely on-site or by using off-site gains where necessary.
Therefore, BDW would expect the Council to reflect the ambitions of the Environmental Bill and incorporate
the necessary level of flexibility in any allocation requirement and/or policy, providing opportunities to create networks to not just support biodiversity enhancement on-site, but also to encourage residents to have access to the natural environment on other sites (off-site) across the District. This would ensure improvements are both beneficial and viable.
BDWs site at Hall Road, Rochford is located on the River Roach and therefore offer substantial opportunities to improve the biodiversity of the site and deliver BNG.

Community Infrastructure
Q35: With reference to the options above, or your own options, how can we address the need for
sufficient and accessible community infrastructure through the plan?
BDW support a combination of all listed Options identified by the Council in addressing the need for sufficient
and accessible community infrastructure through the plan.
Whilst the Council should seek to invest and protect existing community infrastructure, it should seek to first
locate development in areas with adequate proximity to existing infrastructure (such as Land South of Hall
Road, Rochford) before seeking to promote sites that are capable of facilitating the delivery of much needed
community infrastructure in other areas.

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

Q37: Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities?
How can we best address these?
Yes – see our response to Q.36

Open Spaces and Recreation
Q38: With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
BDW support Option 4.
Larger and strategic developments are capable of delivering areas for open space and recreation as part of a holistic redevelopment of a site. As set out in our Vision Document, Land South of Hall Road has incorporated
approximately 4.18 ha of public open space, including a local equipped area of play (LEAP) within the current
design.
Q40: Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering?
Yes.
However, the Council should consider that larger and strategic development sites are capable of delivering
areas for open space and recreation as part of a holistic redevelopment of a site.

Q41: With reference to your preferred Strategy Option, are there opportunities for growth to help
deliver improvements to open space or sport facility accessibility or provision?
Yes.
Larger and strategic development sites are capable of delivering areas for open space and recreation as part
of a holistic redevelopment of a site.
Q42: Are there particular open spaces that we should be protecting or improving?
No.

Transport and Connectivity
Q51: With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
BDW support a combination of all Options identified by the Council in addressing the need for sufficient and
accessible community infrastructure through the plan.
As set out in our response to Q5 and Q6, the Council should seek to incorporate a dispersed growth strategy.
A more dispersed growth strategy will provide a balance between utilising and optimising existing connections in the more sustainable settlements, whilst providing improvements to less sustainable locations. A more
dispersed growth strategy will also work to avoid overuse and unnecessary congestion on more densely
populated areas, which bring with them problems of air quality and noise pollution.

Q52: Are there areas where improvements to transport connections are needed?
Please see also our response to Q51.
As part of a more dispersed Growth Strategy, the Council should seek to ease congestion by locating
development in locations which can benefit from wider improvements. This should be combined and recognised with the delivery of such infrastructure through contribution and/or bespoke delivery in larger allocations.
Q53: With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [walking, cycling, rail, bus, road etc.]
Please see also our response to Q52 / Q53.

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

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

Yours faithfully

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

• Dear Sir/Madam, On your Rochford district web page it states that I could give my comments to this e-mail address. I object to site COL07 (Mill Hall, car park and green) and also site COL20 Civic Suite with landscaped gardens to the rear being included in the Local Plan as a future residential development site.
Under Section 71 of the Planning (listed Buildings & Conservation Areas) Act 1990 and other legislation Rochford District Council has a duty to preserve and enhance the Rayleigh Conservation Area. Both sites are surrounded by listed buildings and a Scheduled Ancient Monument in the case of Mill Hall, neither should not be developed for housing. The setting of the listed buildings are also greatly enhanced by the gardens and the landscaped car parks which make a significant contribution to the conservation area, these would be lost if developed for residential use.
Under S.39 Planning & Compulsory Purchase Act 2004, the Planning & Compulsory Purchase Act 2004 and other legislation and guidance, Rochford has a duty to contribute towards achieving sustainable development.
It is widely acknowledged that the greenest building is the one already there. The carbon footprint of demolishing existing buildings on these sites will significantly increase the carbon footprint of the whole district. In is important therefore to invest in the present buildings and make them more sustainable (Mill Hall would appear to offer significant opportunities.).
Under S.40 of the Natural Environment & Rural Communities Act 2006, the local planning authority has a duty, when exercising its functions, to conserve biodiversity. The green areas and trees on both sites greatly contribute to the biodiversity of the area. In particular in this conservation area, which is not only valued for its buildings but for the mature trees and open space owned by the public. The loss of this biodiversity would be unacceptable if these sites were changed to residential use in the next local plan.
The contribution of car parking to the vitality of the town centre is significant and loss of public car parking within COL07 an COL20 would be detrimental to the Rayleigh Town Centre.

RDC/Spatial Consultation 2021 Questions

Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
A: Evaluate the impact of the current developments, especially in Rayleigh and Hullbridge.
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]
A: Mostly, although I do not feel you have included enough information on how you might achieve housing for the hidden homeless or those on low incomes, emergency housing provision, schemes to allow the elderly in large houses to be able to downsize or how you plan to provide suitable commercial units of varying sizes, to allow businesses to up or downsize into a suitably sized premises without them needing to relocate into another area.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making? [Please state reasoning]
A: Yes, as each settlement has its own characteristics and needs.
Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included? [Please state reasoning]
A: Don’t know.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required? [Please state reasoning]
A: Yes. Rayleigh is the largest town in the district but you need to maintain the green boundaries between the surrounding areas.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan? [Please state reasoning]
A: A combination of 3 and 4.
Creating a new town would enable all the infrastructure to be put in place, allowing more scope for cycling routes and pedestrianised areas. This will stop the urban sprawl which is currently happening in the larger town (and proposed in option 1), creating traffic havoc and pollution. Combining this with option 4 could help with spreading the balance of housing needs, traffic, etc. across the whole of the district and not just in one place.
Q7. Are there any reasonable alternatives to these options that should be considered instead? [Please state reasoning]
A: Windfalls should be included in the housing quota.
Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis? [Please state reasoning]
A: Yes: Cultural and Accessibility.
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change? [Please state reasoning]
A: Yes. We need to ensure we have a suitable plan to protect not only our towns and village communities (houses/businesses) but also the natural areas as well. We need adequate defences to limit flooding in all areas, protecting people and wildlife. Maybe these could be incorporated in the “natural” landscape theming so as to deflect any water away from these areas. New developments not only need to address their carbon footprint but also the design of the housing they build so that they limit flood damage.
Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character? [Please state reasoning]
A: Yes. I feel all of our coastal areas and areas of special interest, where there is a significant risk of flooding and harm to the environment needs careful consideration. Our ancient woodlands also need to be protected and well managed.
Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
A: Vast swathes of land being used for solar panels or unsightly wind farms should not be allowed. I do not feel we have used the potential of tidal renewable energy themes. We have potential in some areas to explore this without defacing our district. All new homes should be fitted with solar, either on their roof or windows and commercial properties could be encouraged to fit solar panels to their roof.
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].
A: I believe that we should aim to achieve a higher standard if possible and encourage developers to put forward new ways of achieving this. We are planning for future generations and should not be stuck in the past. Why go for minimum standards? Always aim higher!
Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported? [Please state reasoning]
A: Solar in all new development as standard. Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs (there are many flat roofed buildings all over the district that could accommodate solar panels without damaging the landscape). Explore tidal energy and seek out suitable locations in order to ascertain whether it is viable. No wind turbines! They would ruin the landscape.
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]
A: The district has some very distinct areas and a “one shoe fits all” would be detrimental to some smaller communities. The place-making charter should be bespoke, with each area being considered in its own right. The rules on building should be strict so as to enhance the areas of development and needs to consider the wider picture in respect of amenities, open spaces, retail, schools, services, pollution, character and accessibility (to name but a few). There should not be deviation of plans unless there are exceptional circumstances. Time and time again out SPD2 documents are ignored and ugly extensions and dormers are built to the detriment of the area.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included? [Please state reasoning]
A: They are, as long as they are adhered to.
Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
A: Yes.
➔ Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas? [Please state reasoning]
A: You need different design guides/etc as our district is unique and diverse and the “one shoe fits all" would be detrimental to its character and charm.
➔ Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting? [Please state reasoning].
A: You need to ensure that the character and heritage of our settlements are adhered to whilst allowing for some growth, in order to rejuvenate the smaller settlements if needed.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing? [Please state reasoning]
A: By working closely with planners and developers, as well as different charities and communities, residents and businesses. You will then get a better understanding as to what you need and what will be achievable.
Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas? [Please state reasoning]
A: The district has a large number of houses, existing and approved that have 4 or 5 bedrooms. The number of homes available with 2 or 3 bedrooms is minimal, which increases their price and availability. The smaller properties are the ones that need to be affordable for families. We should ensure that our “affordable“ properties are not all flats and that the minimum (or higher) standards are met for gardens/recreational space. There are sure to be single, elderly residents that would like to downsize from their large family homes, into a smaller, more manageable one but do not wish to go into an assisted living/residential /retirement home. They may want a 1 or 2 bedroomed property, maybe one storey, or low rise apartment that they own freehold. We also need to consider that some of our residents may need residential care and we should be looking at ways to cope with the rising number of elderly and provide accommodation for them also. We desperately need to meet the needs of the hidden homeless. The adult children on low wages that have no hope of starting a life of their own away from their parents. By living in these conditions, even if the family unit is tight and loving, it will cause mental health issues, stress and anxiety. We also need accessible properties for our disabled members of our community, where they are assisted in order to fulfil a normal as possible life. Emergency and social housing also need to be addressed.

Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing? [Please state reasoning]
A: Housing for the hidden homeless – those “sofa surfing”, or adult children living at home with parents as they are on low wages or wages that would not allow them to move out to rent or buy somewhere on their own. Adapted homes for the disabled (physical, blind, etc.). Smaller, free hold properties for the older generation to enable them to downsize from large family homes. Social housing. Emergency housing.
Q20. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller accommodation needs? [Please state reasoning]
A: You need to find a permanent site that has a little room to expand but not exponentially. The “Traveller” life has changed over the years and many will not fit into this category. We need to be integrating those not deemed into the classification into everyday life and housing. We also need it to be managed so that illegal building work and population do not exceed its capacity. This site will need good access and be somewhere where it does not impose or affect other residents.
Q21. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs? [Please state reasoning]
A: You need to find a permanent site that has a little room to expand but not exponentially. The “Traveller” life has changed over the years and many will not fit into this category. We need to be integrating those not deemed into the classification into everyday life and housing. We also need it to be managed so that illegal building work and population do not exceed its capacity. This site will need good access and be somewhere where it does not impose or affect other residents.

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites? [Please state reasoning]
A: Easy access re large vehicles to the site and main roads to ensure the residential roads are not blocked by the larger vehicles. Room for some expansion that would not encroach on the surrounding area. Away from residents to reduce disturbance of vehicle movements. Not in an area of interest or recreation where the landscape would be blighted by the appearance of many vehicles. Not all in one area – spread out our quota across the district in order to avoid another Crays Farm scenario.

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]
A: The council needs to stop developing existing commercial land into housing. Too many sites have already been lost and many more are planned to go. They can then concentrate on helping those businesses wanting to expand to be able to do so. They should look to working with local schools and colleges, as well as businesses and the job centre, to see what sustainable employment is needed in the district. They then need to assist in schemes to train all ages get back into work or upskill.
Q24. With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the Green Belt? [Please state reasoning]
A: No. The current employment site allocations on Figure 30 do not provide enough space to meet the District’s employment needs through to 2040. We have around 87,000 people in the district. There is no data on the form to suggest how many of these are in employment and how many are looking for work but the council need to reassess its future needs in order to future-proof our residents’ opportunities. We only need to formally protect sites that have a future and a potential to expand or continue effectively. Green belt sites should be assessed separately and decisions made on merit.
Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?
A: Option 3 could deliver new opportunities for employment as it would be a new site completely. Industrial units of various sizes, with room for expansion plus retail, hospitality and other employment could be included in the criteria for the development. Option 4 could assess existing sites across the district and the options to be able to expand, as well as areas for new sites.
Q26. Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?
A: Environmental services - woodland conservation/management. (We need to find funding for this as it is important!) HGV training school.
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?
A: Better road networks and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training.
Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system? [Please state reasoning]
A: Unsure, but I feel there is not enough room for too much expansion ie. add another run way. The council could consider a park and ride park, to divert some traffic away from the residential area, which could create jobs for security services, bus drivers, attendants, cleaners, etc. Expansion of the airport may affect the Grade 1 listed St Laurence and All Saints Church and this needs careful consideration.
Q29. Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
A: We all should be doing everything in our power to protect wildlife sites. All wildlife is important and we have been neglecting them, and slowly chipping away at them for years. Wildlife now enter suburban areas as their own habitats have diminished and they can no longer fend for themselves adequately from nature. We have a decline in Badgers and hedgehogs as well as rabbits, frogs, newts, voles and shrews. Ask yourselves: when did you last see a live hedgehog or badger? Most (especially badgers) are usually dead (along with foxes and deer) by the side of our roads. We have removed places that have housed bats and now we do not see them flying around the district in the numbers they did. Designating initial sites is a step in the right direction but we have to do more. It is proven that our mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was. Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. You mention that Doggett Pond no longer meets the standard but are there no steps to improve its status instead of dismissing it? It is obviously an important site for the wildlife in that area. To lose it would be to our detriment. We should be looking at creating new sites with every large housing development, and adding them to our protected list in order to improve our district and our own wellbeing. We should no allow private households to take over grass areas and verges (or concreting the verges over for parking and cost savings). These areas, although small are still areas for wildlife (bees and butterflies - also in decline, as well as bugs which feed our birds). We should create new wildlife meadows to encourage the pollinators in order to future proof our own existence. We should be exploring smaller sites that we could enhance, manage and protect in order to give future generations something to look back on and feel proud that we have given them a legacy. Something that we can be proud of.
Q30. Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
A: Yes. We need to protect them for future generations and teach our children their history and importance so that they can continue to keep them safe.
Q31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?
A: On site. You can then assess in real time and sort out any issues you would not have known about off site.
Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan? [Please state reasoning]
A: You need to enhance and maintain what we already have by ensuring the necessary links are in place to link as many as possible, and ensuring that public rights of way are not blocked by land owners and are kept free from debris. You also need to assess some paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look into offering this in the larger spaces (ie in the car park – a small toilet block and hand washing facilities). Obtaining funding from large (and medium) developments for enhancement of existing areas as well as providing new spaces and facilities is a step in the right direction.
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
A: They are a step in the right direction but you need to assess periodically in order to be able to add further links to any new parkland that may be created in the future. The map is unclear as it does not show exact routes. There is a large open space to the South West of Rayleigh (on the border), South of Bardfield Way and The Grange/Wheatley Wood, which could be enhanced.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure? [Please state reasoning]
A: Enhancing the areas we have and ensuring developers include green space/recreational facility areas within their developments. A new, separate development would be able to deliver this within their plan layout. Ensuring there are suitable links, access and footpaths. Making sure some of these footpaths are accessible for the disabled.

Q35. With reference to the options above, or your own options, how can we address the need for sufficient and accessible community infrastructure through the plan? [Please state reasoning]
A: Ensuring that funding for existing facilities comes from new developments and making sure that these facilities are built during the time of the development (not like the London Road/Rawreth Lane development where a site was “provided” for healthcare but has not been built). Assess the shortfall of facilities and networks before plans are approved so that adequate planning and funding can be secured before any building takes place.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure? [Please state reasoning]
A: A new town would have this infrastructure built into its plans. Funding for improvements must otherwise come from developers if an area is already overpopulated.
Q37. Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these? [Please state reasoning]
A: Rayleigh is overcrowded. It has a road network no longer fit for purpose. The schools are almost full. It is difficult to obtain a GP or dental appointment. There is little to no disabled play areas/equipment. There is always issues with waste collections, drain & road cleaning and verge trimming. The council does not have the staff to deal with all these issues. The council needs to either build another waste recycling site (as the one in Castle road is no longer capable of expanding and meeting the needs of its ever growing population) or develop a better waste collection program which allows extra waste to be collected next to bins. It also needs to find a site to address/install commercial waste facilities to stop fly tipping.
Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan? [Please state reasoning]
A: Improve what we already have. The tennis courts on Fairview Park need improvement. Safeguard our open spaces to ensure we have wildlife and recreation. Develop different types of sporting facilities – not just football pitches. There is a need for a larger skateboard park and BMX track. We need to offer free recreation for our teenagers.
Q39. Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering? [Please state reasoning]
A: The development of 3G pitches seems to be the trendy thing to do but they are plastic grass at the end of the day and we should be looking at ways to reduce our plastic use. If there is an area that already exists that is in a poor start of repair then it may be an option – especially if the “grass” is made from recyclables, but we should be thinking outside the box and not covering our parks with it.
Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering? [Please state reasoning]
A: They look suitable. They will probably need funding.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
A: A new development would be able to deliver this in their plans or fund improvements for existing facilities.
Q42. Are there particular open spaces that we should be protecting or improving? [Please note, you will have an opportunity to make specific comments on open spaces and local green spaces in the settlement profiles set out later in this report]
A: The sites will be specific in each parish. You need to protect all of these recreational spaces and improve if necessary as once lost to development, they can ever come back.
Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan? [Please state reasoning]
A: You need to reassess your policies on planning regarding alterations made to the buildings on your list, especially in our conservation areas. There have been a few occasions where buildings of “interest” (or other) have been altered, and that places in conservation areas have been allowed canopies, shutters and internal illumination of signage without challenge. Any building work (if any) needs to be sympathetic to the area and you should be able to request amendments to frontage, even if they have had it up for some time. Shop fronts are huge areas of uninteresting glass with garish colours. Signage and advertising (‘A’ board’s litter our pavements without challenge and large barriers are erected onto the pavements – totally out of character with a conservation area in a heritage town. Stick to your policies.
Q44. Are there areas of the District we should be considering for conservation area status beyond those listed in this section? [Please state reasoning]
A: Unsure although we need to stop taking areas of our precious woodland to make way for housing.
Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets? [Please state reasoning]
A: Don’t know. Mill Hall? Over 50 years old. Cultural centre in a conservation area. Needs massive investment and management. A new survey needs to be taken to ascertain whether there are any other areas that should be considered. There are many buildings along the High Road into Rayleigh (but not in the conservation area) which should be considered.
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]
A: You can only have a vibrant town centre if there are shops to go to. If these units are subsequently changed to residential then our town centres will be fractured and uninviting. The new Use Class E will mean it will be even more important for the council to protect our retail outlets. You need to work actively with premises owners in order to assist in the re-letting of any empty shops. Maybe offer a reduced rent to new businesses as a start-up scheme (you could contain this as a “local” business only – allowing the entrepreneurs in the Rochford District a chance to showcase their business). You also need to be able to negotiate with the owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows (ie. photos of the old towns or useful information) to make them more attractive.
You will need good access links with an excellent road and cycle network and reliable public transport that links effectively from all the villages to all the towns.
Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]
A: Yes.
Q48. With reference to Figures 38-40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
A: Yes
Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]
A: Yes. We do not want rows of hairdresser or rows of takeaways etc. as this would eventually kill off our high streets. We need to have a balance of outlets. You would lose the vibrancy you are hoping to achieve if you allowed this. You should also consider restricting use to giant chains as these tend to be the first to go in a crisis and make high streets lose their individuality by them all looking the same.
Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]
A: Unfortunately, some of our smaller retail areas have been sold off and housing development has been allowed (eg. Rayleigh - rear of Marks & Spencer and Dairy Crest plus Lancaster Road [builders’ yard]). In a new development there would be scope to add a small/medium/large precinct of retail etc. depending on the development size.
Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan? [Please state reasoning]
A: The council needs to address the “No development before infrastructure” mantra! Too many houses are being built without adequate road networks in place (including walking and cycling routes). A new road could be built from the A1245 to Hullbridge, limiting the traffic on Rawreth Lane. More work need to be done (and quickly) on the A127 and The Carpenters Arms roundabout. The feeder lanes proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions need to be done ASAP as this is a bottleneck. Hockley needs another access although I am unsure how that can be achieved. New developments should put in cycle paths and walkways and they could be made to link up with existing paths (which need updating and attention).
Q52. Are there areas where improvements to transport connections are needed? What could be done to help improve connectivity in these areas?
A: More work need to be done (and quickly) on the A127 and The Carpenters Arms roundabout. The feeder lanes proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions need to be done ASAP as this is a bottleneck. Hockley needs another access.

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.]
A: A new road from A1245 to Hullbridge is needed as Watery Lane is too narrow and winding, and is closed on a regular basis due to flooding. More (smaller) buses to link our towns and villages. Trams, although they seem a good idea, would cause congestion on our narrow roads and be unsustainable. Designated cycling paths (not on the roads or pavements) adjacent to our road networks would help improve traffic flow and these would need to be linked to be efficient.
Q54. Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided? [Please note you may wish to comment on the use of specific areas of land in the next section]
A: Yes, but if they are to be affordable only, then they should be offered to local residents first and not anyone from afar who wants a cheap house or for those with a buy to let mortgage.
Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities? [Please stare reasoning]
A: Improve public transport.
Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing? [Please state reasoning]
A: Yes but you also need to include a reduced volume of traffic and air pollution. The High Street is usually grid locked and this causes dangerous pollution for our pedestrians/shoppers/residents. An active Police presence.
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?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Access and increased congestion is going to be an issue with a lot of the sites in Rayleigh. If you keep adding small developments to the boundaries of the town we will create an overcrowded impacting on the developments already there and an urban sprawl effect. CFS 121 has potential for a new woodland area which could soak up some of the carbon emissions from the A127 traffic.
Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: We should be restricting any further large developments in Rayleigh and need to assess the impact of the current developments first.
Q56d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: CSF027 – The access road (Bull Lane) is a known rat run and is extremely busy. Any further traffic, which will also compete with large agricultural vehicles, could be a danger to the residents already there. Bull Lane near this point has also been flooded several times recently. CFS023 – Access to this road is via Wellington Road. It can be extremely difficult, especially at peak times (non-pandemic) to access to and from Hockley Road. Adding a large development here will have an adverse impact on existing residents and car users alike. Also, if these 2 developments are linked to Albert Road, the installation of a through road to Bull Lane will cause issues in parking, access and wellbeing as the road would become another rat run!
Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
The green space north of CFS121 could be linked by a new bridge over the railway and create a new habitat for wildlife, with meadows and woodlands, walks and a lake/pond. A car park with facilities could be created and a small retail space could be offered for snacks etc.
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]
A: I feel CFS261 would cause great harm to the area, with a potential of over 4,000 houses on the site. The road network is not sufficient to cope with half that amount of dwellings and new schools would need to be built.
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?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q57c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q57d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q57e. Do you agree that the local green spaces shown on Figure 45 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold some significance, especially to those who use them for recreation, and have community value. These should be protected.

Q58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing? [Please state reasoning]
A: Don’t know.
Q58b. With reference to Figure 46 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Hockley and Hawkwell?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q58c. Are there areas in Hockley and Hawkwell that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know
Q58d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: As Hockley Woods is the largest remaining wild woodland in the country you should be doing EVERYTHING you can to save it from development, either adjacent to or close by. You should also actively be adding to it by planting more trees to future proof its existence and status.
Q58e. Do you agree that the local green spaces shown on Figure 46 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q59a. Do you agree with our vision for the Wakerings and Barling? Is there anything you feel is missing? [Please state reasoning]
A: Don’t know.
Q59b. With reference to Figure 47 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of the Wakerings and Barling?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q59c. Are there areas in the Wakerings and Barling that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Any development needs to be sympathetic of the area.
Q59d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Don’t know.
Q59e. Do you agree that the local green spaces shown on Figure 47 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: Don’t know.
Q60a. Do you agree with our vision for Hullbridge? Is there anything you feel is missing? [Please state reasoning]
A: Yes, although you need to address the road networks as well as those you have suggested. A new link road from A1245 to Hullbridge, adjacent to Watery Lane would serve the increased population with an improved access route and divert traffic away from other areas.
Q60b. With reference to Figure 48 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Hullbridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Some of the sites have potential to include a mix of shops, leisure, recreation, offices and housing but a study needs to be made to assess the impact of the current development
Q60c. Are there areas in Hullbridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q60d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Anything too close to the river due to flood risk.
Q60e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q61a. Do you agree with our vision for Canewdon? Is there anything you feel is missing? [Please state reasoning]
A: Yes. A small amount of housing can be sustainable there as long as the community feel it is needed.
Q61b. With reference to Figure 49 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Canewdon?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Opportunities for mixed retail, commercial and housing could be achieved with some sympathetic development in this area.

Q61c. Are there areas in Canewdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q61d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Don’t know.
Q61e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing? [Please state reasoning]
A: Yes.
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 [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Any development needs to be sensitive and sympathetic to this small village.
Q62c. Are there areas in Great Stambridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q62d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Don’t know.
Q62e. Do you agree that the local green spaces shown on Figure 50 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q63a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state reasoning]
A: Don’t know.
Q63b. With reference to Figure 51 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 Rawreth?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q63c. Are there areas in Rawreth that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Yes. Those that border the main roads as this makes easy access.
Q63d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Those that change the dynamics of the village and those areas that border Wickford. There needs to be a significate amount of green belt land left to separate the 2 areas to prevent urban sprawl.
Q63e. Do you agree that the local green spaces shown on Figure 51 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q64a. Do you agree with our vision for Paglesham? Is there anything you feel is missing? [Please state reasoning]
A: I think the 30 houses is the maximum you should build to keep this hamlet special. Maybe less. The community should be consulted for their requirements.
Q64b. With reference to Figure 52 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 Paglesham?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: The 30 proposed houses should reflect the history of the area and should be modest in size and scale. These does not seem to be scope for any other building project with exception to open space. Any development should be sympathetic to the design and scale of the areas history.
Q64c. Are there areas in Paglesham that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Those proposed seem appropriate subject to local knowledge and support.
Q64d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: No building anywhere where it is liable to flood. No building near the waterfront in order to protect its charm and history.
Q64e. Do you agree that the local green spaces shown on Figure 52 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q65a. Do you agree with our vision for Sutton and Stonebridge? Is there anything you feel is missing? [Please state reasoning]
A: Yes. These areas should remain low key but have better access to services.
Q65b. With reference to Figure 53 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Sutton and Stonebridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know, but mass development should not go ahead. The potential of building thousands of houses, retail etc would be devastating. If any form of development was to go ahead then this should be in the way of a nature reserve/woodland etc.
Q65c. Are there areas in Sutton and Stonebridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q65d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Most of the area unless it is the creation of new woodland, ponds, meadows, etc.
Q65e. Do you agree that the local green spaces shown on Figure 53 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q66. Do you agree that our rural communities do not require individual vision statements? Are there communities that you feel should have their own vision? [Please state reasoning]
A: At this time – yes, but I feel they should have some consideration in the future in order to protect them.
Q67. Do you agree with our vision for our rural communities? Is there anything you feel is missing? [Please state reasoning]
A: Yes. Nothing missing I can think of.
Q68. Are there other courses of action the Council could take to improve the completeness of our rural communities?
A: Survey and listen to the residents to see where they would like to go next. See if they require anything specific (travel links, facilities, affordable housing, etc.)

I object to site COL07 (Mill Hall, car park and green) and also site COL20 Civic Suite with landscaped gardens to the rear being included in the Local Plan as a future residential development site.
Under Section 71 of the Planning (listed Buildings & Conservation Areas) Act 1990 and other legislation Rochford District Council has a duty to preserve and enhance the Rayleigh Conservation Area. Both sites are surrounded by listed buildings and a Scheduled Ancient Monument in the case of Mill Hall, neither should not be developed for housing. The setting of the listed buildings are also greatly enhanced by the gardens and the landscaped car parks which make a significant contribution to the conservation area, these would be lost if developed for residential use.
Under S.39 Planning & Compulsory Purchase Act 2004, the Planning & Compulsory Purchase Act 2004 and other legislation and guidance, Rochford has a duty to contribute towards achieving sustainable development.
It is widely acknowledged that the greenest building is the one already there. The carbon footprint of demolishing existing buildings on these sites will significantly increase the carbon footprint of the whole district. In is important therefore to invest in the present buildings and make them more sustainable (Mill Hall would appear to offer significant opportunities.).
Under S.40 of the Natural Environment & Rural Communities Act 2006, the local planning authority has a duty, when exercising its functions, to conserve biodiversity. The green areas and trees on both sites greatly contribute to the biodiversity of the area. In particular in this conservation area, which is not only valued for its buildings but for the mature trees and open space owned by the public. The loss of this biodiversity would be unacceptable if these sites were changed to residential use in the next local plan.
The contribution of car parking to the vitality of the town centre is significant and loss of public car parking within COL07 an COL20 would be detrimental to the Rayleigh Town Centre

I wish to object to site COL07 (Mill Hall, car park and green) and also site COL20 Civic Suite with landscaped gardens to the rear being included in the local plan as a future residential development site.

Both sites are surrounded by listed buildings and Mill Hall by a Scheduled Ancient Monument. The setting of the listed buildings is enhanced by the gardens and landscaped car parks, making significant contribution to the conservation area and would be lost if developed for residential use.
Rochford District Council has a duty to preserve and enhance the Rayleigh Conservation area, under section 71 of the Planning (listed Buildings and Conservation Areas) Act 1990 and other legislation.

The contribution of public car parking within COL07 and COL20 is significant to the town centre’s vitality and it would be detrimental to the town centre if it was lost due to development.

The local planning authority has a duty to conserve biodiversity when exercising its functions under S.40 of the Natural Environment and Rural Communities Act 2006.
It would be unacceptable if the mature trees and open space owned by the public in sites COL07 and Col20 were lost to residential use in the next local plan. The green areas and trees are greatly valued and contribute to the biodiversity of the area.

As Rochford Council has a duty to contribute towards achieving sustainable development under S.39 Planning and Compulsory Purchase Act 2004, the Planning and Compulsory Purchase Act 2004 and other legislation and guidance it is important to invest into present buildings to make them more sustainable.
The carbon footprint of demolishing existing buildings on these sites will significantly increase the carbon footprint of the whole district. Investment should be made into the current buildings to make them more sustainable.