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?

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.

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

2.0 Response to Spatial Options Consultation Questions
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
2.1 In combination with an overall vision for the district, a vision for each settlement (or some of the settlement) may be helpful in articulating a specific, focused objectives for a settlement, distinguishing its development aims from another settlement. It is important that the visions do not prevent development from reacting to change, such as the demands and expectations from homes and businesses, technology, and construction
methods.
Q4. Do you agree with the strategic priorities and objectives we have identifies? Is there anything missing from the strategic priorities or objectives that you feel
needs to be included?
2.2 The Priorities and objectives identify a fairly broad approach to development demands, covering a lot of aspects of development under each priority. It is recommended that these could be more focused on the spatial challenges and opportunities to ensure they
add value to the plan making process.
2.3 While recognizing that the spatial Options are still open to be determined, one omission is that there is no clear indication of where the district may seek to direct development. There is reference to supporting rural areas but there should be a clear steer towards growth in the most sustainable locations. Regardless of the eventual decision on the spatial distribution, the Vision should identify that the majority of growth will be in the
most sustainable locations and close to existing larger settlements where services are most accessible and available. While we support some development in more rural areas, as currently drafted the Vision appears to articulate the approach to rural diversification, support for rural economic development and supporting rural communities, far more clearly than it does any urban developments or extensions to existing settlements.
Presumably urban extensions will provide the larger share of growth over the plan period and therefore the Vision should more clearly articulate the support for urban developments and extensions to existing settlement. In addition, there appears to be some potential strain between the support for rural development in the Strategic Priorities compared to the objectives in Priority 5 - Making provisions for climate change, conservation and enhancement.
2.4 For the above reasons, we recommend that references to delivering sufficient, sustainable housing is welcome but this should be emboldened by a clear indication of where the majority of growth may be directed and why. Following the adoption of a spatial
strategy it is recommended that the Vision is updated to include where the majority of development will be directed to, and that this should identify the larger settlements as providing the best opportunities for the majority of sustainable development.
2.5 We also consider that the objectives are too ambiguous in relation to affordability and recommend that there should be a distinct objective to improve the affordability of housing in Rochford District, as identified in the spatial challenges.
2.6 The RLPSO notes (page 12) that:
“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times to average
annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”.
(RLPSO, page 12).
2.7 The most recent data available1
reports that the median house price in the District is
11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’).
This is significantly greater than the national average, and indicates housing affordability has worsened considerably in recent years.
2.8 In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69
– significantly below the District’s 11.57.
2.9 In addition, the longer term impact on housing demand resulting from the Covid-19
pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Whilst empirical data is currently limited, there are early indications there has already been an increased desire to move from more to less urban areas, due to a greater desire for homes with larger gardens, space for home offices, better access to good quality open space, and situated within less densely populated areas.
2.10 At the same time, the pandemic has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely expected there will be a degree of return to office-working, it is anticipated that the need for employees to be physically present within a particular office will be substantially reduced.
2.11 As a consequence, it can be predicted that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via rail from parts of the District; and house prices are relatively affordable when compared to other areas in and around London. As a consequence, the area may well prove an increasingly popular destination for those migrating out of higher density areas in and around London. This in turn is likely to put considerable pressure on the housing market. If insufficient homes are provided, it is also likely to result in a significant worsening of affordability. Ensuring a sufficient supply of homes will be imperative if the Council is to tackle the issue of housing affordability in the District.
2.12 The RLPSO’s proposed Strategic Objective 3 is:
“To facilitate accelerated growth in our local economy through supporting the delivery of suitably located land which meets businesses needs at each stage of their lifecycle (including delivering grow-on space to enable local businesses to flourish), the continued functioning of London Southend Airport as a thriving regional airport,
serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park”
2.13 We support this and, in addition, suggest this objective should recognise that the critical role house-building plays in supporting the local economy, and the economic benefits house building would have for the District.
2.14 As the Local Plan Spatial Options recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.
2.15 Employment relating directly to the construction of the development will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
2.16 We agree that Rayleigh should be identified as the highest ranked settlement, reflecting the wide range of services and facilities available, alongside sustainable transport options and employment opportunities.
2.17 The RLPSO estimates (Figure 7) the 2018 population of the town to be 33,663, equating to 39% of the District’s total population.
2.18 In preparing the Core Strategy (2011), the Council identified that 44.4% of the demand for housing on the Council’s housing waiting list was focused on Rayleigh.
2.19 The adopted Core Strategy also noted, at paragraph 2.68, that Rayleigh has the best access to services within the District. As a retail centre, Rayleigh is by far the largest in the District. The RLPSO recognises this, identifying Rayleigh as the lone Tier 1 settlement in the District.
2.20 Rayleigh is one of only three settlements in the District served by a railway station, and is better served by bus services than the majority of the District. Combined with the range of facilities and services contained within the town itself, it perhaps has the best
potential of the District’s settlements to accommodate growth without reliance on use of the private car.
2.21 It is clear that a significant proportion of the District’s housing growth should be directed to Rayleigh as part of any spatial strategy, and that such development would be
sustainable.
2.22 Finally, it is not clear that Hockley and Rochford (including Ashingdon) provide only local services, as set out in the hierarchy and we recommend the assessment could benefit from not elevating Rayleigh too far above these other settlements, with the implications this may have on growth in these other sustainable locations, the scale of inward investment, and the benefits that come from development.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
2.23 Given the market and affordable housing needs, affordability issues and heritage and environmental constraints in the District, it is important that the overall strategy seeks to provide a wide range of housing options throughout the Plan period in suitable locations. As such, the strategy should utilise a range of different sites to maximise options to bring forward these new homes and associated infrastructure.
2.24 The temporal dimension of any strategy will also be an important consideration. The Local Plan should seek to ensure that homes can be provided across the plan period, including within the early years. Indeed, it is particularly important for the strategy to deliver homes in the early years of the plan period, given current housing needs against housing delivery.
2.25 For the Local Plan strategy to be sound, we consider that it will need to direct a significant proportion of housing growth to Rayleigh as the most sustainable settlement in the district.
2.26 We consider Option One to be far less likely to result in a sound Local Plan, or to deliver attractive sustainable development that would be welcome in the district, in comparison to the other Options. Option 1 (urban intensification) states this option entails making best possible use of [our] existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations). The RLPSO claims this approach could deliver 4,200 dwellings over the next 10 years.
2.27 It is important to recognise that in order to be consider sound, the Local Plan is required to meet objectively assessed housing needs. The RLPSO reports that the minimum housing requirement for the District over a 20-year period is 7,200 dwellings.
2.28 If Option 1 were to deliver 4,200 dwellings, this would result a significant housing shortage in the District. This would result in significant negative social and economic
impacts – it would not deliver sustainable development.
2.29 Furthermore, we question whether urban intensification would deliver as many as 4,200 new homes unless densities were increased in a greater number of locations that simply the town centres. To achieve this would require an average of 420 dwellings per annum (dpa) to be sustained over a 10-year period. The Council’s Annual Monitoring Report
2019/20 reports that over the10-year period between April 2010 and March 2020, the District averaged delivery of 176.8 dpa.
2.30 The 1,768 dwellings delivered over this period included a significant number from allocations made through the Rochford Allocations Plan (2014), and did not merely comprise dwellings provided through the redevelopment of previously developed land / urban intensification.
2.31 It is also relevant to note that over the last 10 years, local and national policy has supported the redevelopment of suitable previously developed land for residential use. It is likely that much previously developed land that is suitable and viable for residential
development has already been redeveloped for housing.
2.32 It is also unclear whether a strategy of intensification could meet the range of different housing needs. The RLPSO appears to suggest that it would deliver a low proportion of affordable housing (only 800 out of a total of 4,200).
2.33 A further concern is whether urban intensification would result in the same level of infrastructure improvements and other community benefits that larger allocations are capable of delivering.
2.34 Finally in relation to Option 1, it is unclear what the spatial distribution of housing would be through this approach, and whether it would result in a sustainable pattern of growth.
2.35 Rather than relying on urban intensification, it is clear that if the Local Plan strategy is to be sound and is to deliver sustainable development, it will be necessary to release some Green Belt and allocate land for residential development.
2.36 The NPPF confirms (paragraph 140) that it is appropriate for Local Plans to make alterations to the Green Belt boundary, provided there are exceptional circumstances for doing so, and that these are justified and evidenced. It is considered that within Rochford, a case can readily be made that exceptional circumstances exist to justify the release of land from the Green Belt given the scale of the District’s objectively assessed
need, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet those needs.
2.37 With Option 1 failing to deliver the growth required, we consider the other options to represent far more appropriate strategies for the Plan and provide a short commentary on these below.
2.38 Strategy Option 2 is to focus on urban extensions, Option 2a focuses such growth on the District’s main towns; and Option 2b dispersing to all settlements based on the settlement hierarchy.
2.39 Option 2a would identify sustainable sites at the edge of settlements, which would include Rayleigh, to deliver a range of housing developments. This provides flexibility to utilise smaller sites to deliver homes earlier, alongside larger sites to meet the overall housing need, as urban extensions. Option 2b disperses the growth in accordance with a settlement hierarchy. There is merit in both Options, but would advise that when factors such as accessibility, service availability and constraints are considered, the same sites may well be identified under either option. Further, a rigid application of a settlement
hierarchy can be problematic if suitable sites in more sustainable locations are omitted in favour of following the hierarchy. Finally, lower-tier settlements are often overlooked for any development opportunities through a hierarchy approach, again potentially omitting suitable sites.
2.40 Option 3 focuses growth on one of three locations (west of Rayleigh (3a); north of Southend (3b); and east of Rochford (3c)). We consider there is merit to strategic scale growth that can help deliver significant infrastructure improvements, however, this needs
to be complemented by the delivery of a range of different sites, including those that can deliver in the shorter term and do not require significant infrastructure improvements. It is also important to reflect that the District comprises a number of distinct settlements
with their own identities and communities, all of which the Local Plan should seek to support. We therefore caution against concentrating on a few strategic allocations to
meet housing need as this may not deliver consistently over the plan period and may result in an inflexible approach for the authority if any of those sites do not deliver as expected. We therefore recommend that growth in and around existing settlements should always form part of the Council’s strategy.
2.41 Strategy Option 4 entails a mix of the other options, and rightly recognises that the allocation of strategic growth sites and the allocation of urban extensions are not mutually exclusive. We consider this option to be the most appropriate for Rochfrod district and note that it scored positively in the Integrated Impact Assessment (IIA) in relation to its social, economic and environmental impacts. This option will allow current housing needs to be addressed in the short and medium term while enabling provision for strategic allocations. It will also allow for proportionate growth to be directed to the
District’s various communities through settlement extensions, including Rayleigh, whichwe consider should always form part of the distribution strategy to provide sustainable development.
2.42 A balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.
2.43 The Bellway Strategic Site at Hambro Hill can form an important part of such a strategy, delivering around 250 homes in a highly sustainable location. The Site is unconstrained, is partly developed already with good access, and can start delivering homes early in the
Plan period and through into the medium term at a character that respects Rayleigh while transitioning to open space beyond.
Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the
District, or should different principles apply to different areas?
2.44 We caution against applying the same approach everywhere in the District as different areas within Rochford are very different to one another.
2.45 With over 300 listed buildings and 10 conservation areas in the District, clearly some areas have a historic nature that needs to be considered, whereas others will not.
2.46 Should the Council seek a District wide place-making charter, this will need to be relatively high level to ensure that it does not unduly restrict development and prevent it from being appropriate to its context, as recognised in Section 12 of the NPPF 2.47 Any place-making charter should be formulated through consultation with stakeholders, including developers, to ensure that it is realistic, achievable and does not result in development becoming unviable. Such a charter should be published as part of the Local Plan to ensure that all parties have an opportunity to comment and input.
Q16a. Do you consider the new design guides, codes or masterplans should be created alongside the new Local Plan?
Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual
settlements or growth areas?
2.48 Given the pressing housing and affordability needs within the District, it is important that homes are delivered as soon as possible. This is particularly pertinent given that adoption of the Local Plan is not anticipated until late 2023 at the earliest. We primarily recommend that design guides, codes and Masterplans are not necessary in order to achieve good quality development, and the planning system is capable of ensuring good design is achieved without the need for additional layers of design work to be added to the process.
2.49 If the Council seek to deliver design guides or codes, these should be developed alongside the Local Plan with input from stakeholders to ensure that once the Plan is adopted development can commence without delay. There is otherwise the risk that the Council adopt a Plan but development is significantly delayed, to the detriment of residents in need of new homes.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of
housing?
2.50 With areas within the District having different characteristics and development over the Plan period likely to be of varying scales, it is important for developments to be able to provide homes suitable for the site and location. A fixed housing mix across the district will not work, as different locations are suitable for different lifestyles. Option 2 provides flexibility, which is welcomed and this is the option we believe the Council should proceed with. It also recognises that different scales of development can be better placed to
provide greater flexibility of types of housing, such as self-build Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred?
2.51 We consider the provision of additional parkland has the potential to have numerous ecological and social benefits. In particular, the Central Woodlands Arc Regional Parkland appears to have considerable potential to provide an alternative recreational
destination to internationally important habitats within the District, including Special Protection Areas.
2.52 From Figure 32 of the RLPSO, it appears that the proposed extent of the Central Woodlands Arc Regional Parkland, passes very close to – or even adjoins – the extent of existing settlements, including in Hullbridge. If such parkland is to be provided, it is considered that it should be located such that it can be sustainably accessed by existing and future residents. However, at the same time, it is important that the precise
boundaries of any such designation do not preclude highly sustainable sites for housing from consideration for residential allocation.
Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
2.53 We agree with the principles of the vision. We would caution against identifying a strict boundary for the settlement area, as the experience of the urban area does not have a clean cut off between (for example) Rayleigh and Hockley. Accordingly, we consider that Hambro Hill (105) is better aligned to Rayleigh than to Hockley and should be considered in that regard.
Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rayleigh?
2.54 Land at Hambro Hill, Site CFS105, is on the boundary of the area identified in figure 44.
The land should be included within the area of Rayleigh for the reasons above. That is, the site is most closely associated with Rayleigh and would be capable of providing a sustainable and attractive development on a despoiled site in the highest tier settlement
in the district. To associate the site with Hockley misses the spatial position of the site adjacent to the boundary with Rayleigh, with a considerable area of open space between the site and the urban edge of Hockley, extending to some 80ha. This appears to follow the political ward boundary but has little relationship to how the site is experienced and its relationship to Rayleigh. We strongly recommend that this is corrected.
2.55 The site should be used to provide housing alongside new public open space.
2.56 The site already benefits from access to existing infrastructure and would therefore
represent and effective and efficient use of land. The site is within walking distance of
all categories of school, GP surgery, open space, the Town Centre and the rail station, all of which are made even more accessible with the ready access to bus routes. 2.57 Accordingly, the site should be identified as part of Rayleigh and we consider it to be ideally located for residential development, as identified by the Council in the SHELAA. The only constraint on the site is its current Green Belt designation. The need to release
land in the Green Belt is covered elsewhere in these responses, alongside a comparative assessment of the harm of releasing this site from the Green Belt, which is considered to be superior to other more high performing green belt land, while on other criteria the site scores no worse that vast tracts of land in the district.
2.58 The Site represents a logical extension to Rayleigh that would provide a sustainable development of around 250 dwellings. The Site is well placed to deliver much needed homes for residents, whilst contributing towards local infrastructure, both directly from the development and in the long term from spending in the local economy by residents. With the exception of the Green Belt policy constraint, it is unconstrained and represents a logical ‘filling in’ of the existing development pattern.

3.0 Comments on Integrated Impact Assessment
Assessment Framework
3.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identify.
3.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?
3.3 We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.
3.4 The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In
2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 –
significantly below the District’s 11.57

1.0 Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options on behalf of Bellway Strategic Land in relation to Land North of Brays Lane, Ashingdon (‘the Site’).
1.2 The Site has previously been submitted into the Call for Sites, references CFS126 and CFS007, which Bellway Strategic Land are promoting together to ensure a
comprehensively planned extension to Ashingdon.
1.3 Representations were submitted to the New Local Plan Issues and Options consultation in 2018 to further promote the allocation of the Site to help meet market and affordable housing need in a logical way at the edge of an existing settlement.
1.4 The only current constraint to development is the location of the Site within the Green Belt, with it being unconstrained in other regards. The Site can be used much more effectively to deliver around 250 new market and affordable homes to meet the identified needs within the District and provide new public open space.
1.5 A Vision Document (Appendix A) is submitted as part of these representations to provide further detail about the Site and its proposed development.
2.0 Response to Spatial Options Consultation Questions
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
2.1 A vision for each settlement could be helpful, but we would highlight that these should not be too restrictive. Given the length of time the Local Plan will cover, there will be changes in the local areas, some of which could be significant. It is important that the visions do not stop development reacting to such changes or the potential responding to new technology, and does not stifle innovation.
Q4. Do you agree with the strategic priorities and objectives we have identifies? Is there anything missing from the strategic priorities or objectives that you feel
needs to be included?
2.2 We suggest that objectives of the Local Plan should include to improve the affordability of housing for people of Rochford District.
2.3 The RLPSO notes (page 12) that:
“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times to average annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”. (RLPSO,
page 12).
2.4 The most recent data available reports that the median house price in the District is 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). This is significantly greater than the national average, and indicates housing affordability
has worsened drastically in recent years.
2.5 In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69
– significantly below the District’s 11.57.
2.6 In addition, the longer term impact on housing demand resulting from the Covid-19 pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Whilst empirical data is currently limited, there are early indications there has already been an increased desire to move from more to less urban areas, due to a greater desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.
2.7 At the same time, the pandemic has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely expected there will be a degree of return to office-working, it is anticipated that the need for employees to be physically present within a particular office will be substantially reduced.
2.8 As a consequence, it can be readily predicated that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London. As a consequence, the area may well prove an increasingly popular destination for those migrating out of higher density areas in and around London. This in turn is likely to put considerable pressure on the housing market. If insufficient homes are provided, it is also likely to result in a significant worsening of affordability. Ensuring a sufficient supply of homes will be imperative if the Council is to tackle the issue of housing
affordability in the District.
2.9 The RLPSO’s proposed Strategic Objective 3 is:
“To facilitate accelerated growth in our local economy through supporting the delivery of suitably located land which meets businesses needs at each stage of their lifecycle (including delivering grow-on space to enable local businesses to flourish), the continued functioning of London Southend Airport as a thriving regional airport,
serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park”
2.10 We support this and, in addition, suggest this objective should recognise that the critical role house-building plays in supporting the local economy, and the economic benefits house builder would have for the District.
2.11 As the Local Plan Spatial Options recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.
2.12 Employment relating directly to the construction of the development will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.
2.13 Development of additional homes in the District will also engender sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of new homes on first occupation, on home set up cost, and on an ongoing basis in local shops and services in the area.
2.14 Furthermore, ensuring the provision of sufficient, suitable accommodation is important to securing investment and employers in the District.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
2.15 We agree that Rochford, including Ashingdon, should be highly ranked within the settlement hierarchy to reflect the wide range of services and facilities available,
alongside sustainable transport options and employment opportunities.
2.16 As the RLPSO recognises, Rochford and Ashingdon together form a functionallyconnected settlement.
2.17 Its ranking as Tier 2 is justified given the range of facilities available, but we would highlight that it would be beneficial for the settlement hierarchy itself to state ‘Hockley, Rochford and Ashingdon’, rather than referring to Ashingdon in the accompanying text only. This will be clearer and provide greater clarity to the decision maker.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
2.18 Given the market and affordable housing needs, affordability issues and heritage and environmental constraints in the District, it is important that the overall strategy seeks to provide a wide range of housing options throughout the Plan period in suitable locations. As such, the strategy should utilise a range of different sites to maximise options to bring forward these new homes and associated infrastructure.
2.19 The temporal dimension of any strategy will also be an important consideration. The Local Plan should seek to ensure that homes can be provided across the plan period, including within the early years. Indeed, it is particularly important for the strategy to deliver homes in the early years of the plan period, given current, acute housing needs.
2.20 For the Local Plan strategy to be sound, we consider that it will need to direct a significant proportion of housing growth to Rochford / Ashingdon.
2.21 As the RLPSO recognises, Rochford and Ashingdon together form a functionallyconnected settlement home to around 18,000 residents. Between Rochford town centre and a number of neighbourhood centres located throughout the wider settlement, the Rochford provides for a wide range of services and business spaces, including a number of specialist employment areas supporting nearby London Southend Airport. The
settlement also benefits from a railway station and has good public transport links, particularly when compared to much of the District.
2.22 Rochford / Ashingdon is characterised as a top tier settlement within the current Development Plan, i.e. one of the most sustainable settlements to which to direct
additional growth.
2.23 The Census 2011 suggested that Ashingdon Parish has an ageing population, with a
median age of 45, compared to the nation median of 39. Nevertheless, in 2011 over
20% of the population of Rochford and Ashingdon were aged 17 or under – children / young adults still make up a significant proportion of the local population, suggesting a
relatively large cohort of young people growing up in the area who may well wish to form their own households within the community in which they were raised. However, in the last 10 years, the average price paid for a homes in Ashingdon has increased 61% and the current average dwelling value is estimated to be £337,818. This suggests a lack of housing supply compared to need in the area.
2.24 Rochford and Ashingdon benefit from a range of facilities, services and employment opportunities, many of which are located in Ashingdon, as shown in Figure 2 and discussed in the previous section of this document. This resulted it being categorised (along with Rochford) as a top tier settlement in the District’s hierarchy within the current Development Plan
2.25 Ashingdon was identified as a suitable location to accommodate a proportion of the District’s housing needs through the Rochford Core Strategy (2011) – an approach that was confirmed as sound through a robust examination of proposals. The characteristics of Ashingdon remain broadly the same as they were 10 years ago, and it is evidently still a sustainable location to accommodate some growth.
2.26 One of the options presented by the RLPSO is considered far less likely to result in a sound Local Plan or to deliver sustainable development: Option 1 (urban intensification).
The RLPSP states this option entails making best possible use of our existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification
could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations). The RLPSO claims this approach could deliver 4,200 dwellings over the next 10 years.
2.27 It is important to recognise that in order to be consider sound, the Local Plan is required to meet objectively assessed housing needs. The RLPSO reports that the minimum housing requirement for the District over a 20-year period is 7,200 dwellings.
2.28 If Option 1 were to deliver 4,200 dwellings, this would result a significant housing shortage in the District. This would result in significant negative social and economic impacts – it would not deliver sustainable development.
2.29 Furthermore, we question whether urban intensification would deliver as many as 4,200
new homes.
2.30 To achieve this would require an average of 420 dwellings per annum (dpa) to be sustained over a 10-year period.
2.31 The Council’s Annual Monitoring Report 2019/20 reports that over the10-year period between April 2010 and March 2020, the District averaged delivery of 176.8 dpa
2.32 The 1,768 dwellings delivered over this period included a significant number from allocations made through the Rochford Allocations Plan (2014), and did not merely comprise dwellings provided through redeveloped of previously developed land / urban intensification.
2.33 It is also relevant to note that over the last 10 years, local and national policy has supported the redevelopment of suitable previously developed land for residential use. It is likely that much previously developed land that is suitable and viable for residential development has already been redeveloped for housing.
2.34 Even if urban intensification could meet housing needs in full, it would be highly questionable as to whether such development would be suitable. To deliver such a quantum of development within existing settlement boundaries would clearly necessitate
significantly greater densities of development than existing. This in turn would likely result in harm to the existing character of the District’s settlement, and risk harm to amenity of existing residents.
2.35 In addition, it is unlikely that such urban intensification could meet the range of different
housing needs. The RLPSO appears to suggest that it would deliver a low proportion of affordable housing (only 800 out of a total of 4,200).
2.36 A further concern is whether urban intensification would result in the same level of infrastructure improvements and other community benefits that larger allocations are capable of delivering.
2.37 Finally in relation to Option 1, it is unclear what the spatial distribution of housing would be through this approach, and whether it would result in a sustainable pattern of growth.
2.38 Rather than relying on urban intensification, it is clear that if the Local Plan strategy is to be sound and is to deliver sustainable development, it will be necessary to release some Green Belt and allocate land for residential development.
2.39 The NPPF confirms (paragraph 140) that it is appropriate for Local Plans to make alterations to the Green Belt boundary, provided there are exceptional circumstances for doing so, and that these are justified and evidenced.
2.40 Exceptional circumstances are not defined in national policy or guidance. However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:
 The scale of the objectively assessed need;
 Constraints on supply/availability of land with the potential to accommodate
sustainable development;
 Difficulties in achieving sustainable development without impinging on the Green
Belt;
 The nature and extent of the harm to the Green Belt; and
 The extent to which impacts on the purposes of the Green Belt may be mitigated as
far as practicable.
2.41 Given the scale of the District’s objectively assessed need faced, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green Belt through the preparation of this Local Plan.
2.42 Overall, we consider that a balanced combination of utilising appropriate small scale and larger sites, on both brownfield and greenfield sites is the best approach to seek to meet identified housing needs within the District.
2.43 A balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.
2.44 Bellway Strategic Land’s Site north of Brays Lane can form part of this approach, delivering around 250 homes in a sustainable location. The Site is relatively
unconstrained and can start delivering homes early in the Plan period, continuing to deliver in the medium term. It has the potential to deliver much needed new market and
affordable homes to the area at a density and layout that reflects the existing pattern and character of development in the locality.
Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the
District, or should different principles apply to different areas?
2.45 We caution against applying the same approach everywhere in the District as different areas within Rochford are very different to one another.
2.46 With over 300 listed buildings and 10 conservation areas in the District, clearly some areas have a historic nature that needs to be considered, whereas others, such as east of Ashingdon, do not have such heritage considerations.
2.47 Should the Council seek a District wide place-making charter, this will need to be relatively high level to ensure that it does not unduly restrict development and prevent it from being appropriate to its context, as recognised in Section 12 of the NPPF. A small scale proposal on brownfield land in the middle of a town, for example, will have very different design requirements to a larger scheme of homes on the edge of a settlement.
2.48 Any place-making charter should be formulated through consultation with stakeholders, including developers, to ensure that it is realistic, achievable and does not result in development becoming unviable. Such a charter should be published as part of the Local
Plan to ensure that all parties have an opportunity to comment and input.
Q16a. Do you consider the new design guides, codes or masterplans should be created alongside the new Local Plan?
Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
2.49 Given the pressing housing and affordability needs within the District, it is important that homes are delivered as soon as possible. This is particularly pertinent given that adoption of the Local Plan is not anticipated until late 2023 at the earliest. If the Council seek to deliver design guides or codes, these should be developed alongside the Local Plan with input from stakeholders to ensure that once the Plan is adopted development can commence without delay.
2.50 There is otherwise the risk that the Council adopt a Plan but development is significantly delayed, to the detriment of residents in need of new homes.
2.51 An alternative could be to allow developers to produce design guidance for allocated sites with input from the Council, local community, etc. As set out in the submitted Vision Document, Bellway Strategic Land has begun to consider the design of the land north of
Brays Lane and how development could appear.
2.52 This has been based on technical work and an assessment of the nearby area, building on the successful scheme opposite. Whilst we are keen to engage with the Council, stakeholders and local community in relation to the layout to progress this further, it is not considered that detailed design guidance is required to deliver a successful scheme on this site given the work already undertaken and success of the scheme opposite.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of
housing?
2.53 With areas within the District having different characteristics and development over the Plan period likely to be of varying scales, it is important for developments to be able to provide homes suitable for the site and location.
2.54 Option 1 appears too inflexible in this regard and does not recognise that individual areas have different needs in terms of housing requirements. Such an approach risks being overly restrictive and not allowing development to be appropriate to its context.
2.55 Option 2 does provide such flexibility, which is welcomed and the option we believe the Council should proceed with. It also recognises that different scales of development can be better placed to provide greater flexibility of types of housing, such as self-build.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
2.56 Utilising a range of sites across the District, especially edge of settlement extensions,
can provide significant opportunities for new green and blue infrastructure.
2.57 As set out in the Vision Document, land north of Brays Lane can provide significant new public open space, connecting to footpaths in the wider area. This will assist in delivering new green infrastructure for both existing and future residents.
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing?
2.58 Whilst we agree with the principles of the vision, it should also include reference to the provision of new homes to meet local needs and help sustain the existing services and facilities.
2.59 Not providing any new homes in the area risks affordability issues worsening and negative social and economic impacts.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?
How could that improve the completeness of Rochford and Ashingdon?
2.60 Land north of Brays Lane should be utilised to provide new market and affordable homes, alongside new public open space, site references CFS007 and CFS126.
2.61 Utilising such locations already benefitting from infrastructure allows development to commence early in the Plan period to start delivering homes.
2.62 As set out in the Vision Document, the Site is within a sustainable location in close proximity to a wide range of services and facilities within easy reach by sustainable
transport methods.
2.63 The Site represents a logical infill adjacent to the existing settlement, extending no further east than existing development to the south.
2.64 The Site is currently defined as being within the Green Belt, being the only constraint to its development.
2.65 Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’) considered the Site as part of Parcel 61 in the Stage 1 Assessment. Parcel 61 is a large area of land covering the entire eastern side of Rochford and Ashingdon. Clearly an assessment of this size parcel of land has limited use when assessing specific sites given that the characteristics are very different. We would caution the Council against giving this weight in the assessment process. Instead, as identified through the Welwyn Hatfield Local Plan Examination, it is important that Green Belt is considered at a sufficient fine grain. In the Examination of this Local Plan, the Inspector advised as follows: “The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied
to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might reasonably be considered further”. (EX39 of the Welwyn Hatfield Local Plan Examination, December 2017).
2.66 The Green Belt Study (2020) Stage 2 assessment did not consider the Site specifically in detail. The Site was considered as assessment area AA112. However, only a brief assessment is provided with an overall conclusion on the level of harm rather than a detailed assessment against each purpose of the Green Belt.
2.67 The Green Belt Study (2020) found that the Site makes a moderate contribution to preventing sprawl of the built-up area and a strong contribution to preventing
encroachment on the countryside. For any site not already within a built up area, these conclusions are highly likely to be similar, which must be recognised. Furthermore, as the Site is bounded by existing residential development on three sides, it is important to
consider how its development would be perceived, which is as an extension to the built up area rather than a site within the countryside.
2.68 The Site would ‘round off’ the existing settlement pattern and is already well connected to existing development. As such, it is considered to have low potential to lead to unrestricted urban sprawl when considered against purpose 1 of the Green Belt.
2.69 In relation to purpose 2, the Site is some distance from the nearest other settlement, being approximately 2 miles from Canewdon to the east. Its development would not have any risk of either actual or perceived coalescence of Ashingdon with any other
settlement.
2.70 In respect of purpose 3, there is no existing, strong defensible boundary between the urban area and adjoining countryside. There are hedgerows associated with existing garden boundaries, but no dominant landscape feature. Existing development is present
and visible within the landscape, with the site providing an opportunity to reframe this edge. The Site is not currently considered to strongly assist in safeguarding the
countryside from encroachment.
2.71 The Site is not adjacent to a conservation area or any listed buildings. Ashingdon itself has a limited number of listed buildings, with two to the very north and to the south a considerable number within Rochford. This is pertinent given that there are over 300 listed buildings within the District. The Site makes no contribution towards preserving the setting and special character of historic towns in respect of purpose 4.
2.72 In respect of purpose 5, this is only applicable where development needs can be met in full on previously developed land. For Rochford District, this is not an option as the amount of market and affordable homes that could be delivered is significantly below the
identified need.
2.73 The above assessments have been informed by the site-specific Landscape / Visual
Appraisal prepared for the Site and previously submitted to the Council. Overall it is
considered that the Site makes limited contribution towards the purposes of the Green Belt, and its residential development would not undermine the strategic purposes of the Green Belt.
2.74 The Council’s SHELAA 2017 considered that the Site is available and achievable, with the suitability dependent on an assessment of the Green Belt purposes. It was considered suitable in other regards. As set out above, the Site is considered to make limited contribution towards the Green Belt purposes and should be considered suitable, available and achievable.
2.75 As set out in greater detail in the submitted Vision Document, the Site is unconstrained and located in an already sustainable location. It can provide around 250 new homes, including a mix of sizes, market and affordable.
2.76 With infrastructure already in place, homes can start to be delivered early in the Plan period to meet identified needs.
2.77 The proposal on the Site is of a scale suitable for its surroundings, reflecting its location
adjoining the built up area of Ashingdon. It can reflect the popular and well received
Bellway development opposite on the south of Brays Lane, continuing this high quality design to provide new homes and public open spaces.
2.78 Overall, the Site is well placed to deliver much needed homes for residents, whilst contributing towards local infrastructure, both directly from the development and in the long term from spending in the local economy by residents. With the exception of the Green Belt policy constraint, it is unconstrained and represents a logical ‘filling in’ of the existing development pattern.

3.0 Comments on Integrated Impact Assessment
Assessment Framework
3.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups
in the community; and 2) maintain and enhance community and settlement identify.
3.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs
of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities,
including specialist services for disabled and older people?
3.3 We support the above decision-aiding question, but suggest that, in addition to meeting
the District’s housing needs (including affordable housing), the Local Plan should seek
to improve the affordability of housing for local residents.
3.4 The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened
significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national
average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.

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]

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.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

02. NATIONAL PLANNING POLICY FRAMEWORK
2.1. The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to Option 3b.
PLAN LED APPROACH
2.2. The National Planning Policy Framework states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
ƒ meet the development needs of their area;
ƒ align growth and infrastructure;
ƒ improve the environment;
ƒ mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
2.3. This element of the Framework and specifically how the proposal at South East of Rochford and North of Southend will assist the Council in delivering a sustainable pattern of development is considered in detail at Section 5 of these representations.
2.4. Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and enhancement of the natural, built and historic environment. These policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to
address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
LARGE SCALE GROWTH
2.5. The most recent revisions to the Framework include the requirement:
‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’.
2.6. This is applicable in respect of the current proposal at Option 3b and is detailed in full at Section 7 of these representations.
2.7. The Framework at para 73 considers that

“The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes). Working with the
support of their communities, and with other authorities if appropriate, strategic policy-making authorities should identify suitable locations for such development where this can help to meet identified needs in a sustainable way”. (Our emphasis)

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

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

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

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

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

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

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

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

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

VITALITY OF RURAL COMMUNITIES
2.10. The updated Framework at Para 79 states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities.
Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.
2.11. There are a range of existing rural communities in the vicinity of the proposed growth option. The emerging Masterplan and all future proposals will ensure that the character and identity of these existing settlements is retained, while also delivering new infrastructure and services which will be of benefit to the established rural communities. These existing communities do not currently have a genuine choice in terms of travel option, with the private car for many people the only form of transport available. The Local Plan, and the proposals for large scale growth, have the potential to address this through substantial investment in public transport in the district.
2.12. Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could
accommodate some of the identified need for development, as demonstrated through the statement of common ground.
2.13. Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where
exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation recognises that RDC are unlikely to have
sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.

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

03. REGIONAL POLICY MATTERS – CONTEXT FOR GROWTH.

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

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

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

04. REGIONAL POLICY MATTERS – CONTEXT FOR GROWTH.
Current Situation
4.1. In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2. The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
Future Housing Needs & Supply
4.3. Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040 in RDC. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in
10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4. The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. The emerging evidence provides a strong indication that SSBC will not be able to meet its development needs for housing and employment in full within its borough boundaries.
Southend has a constrained supply of land which also limits its ability to deliver family housing.
Given the close-relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services between the two authorities, the Council needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5. Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.

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

4.6. In this respect, the Planning Practice Guidance provides clarification on the standard method
reiterating that it provides the minimum starting point and details the circumstances actual housing need is higher than the standard method indicates, stating:
Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in
place to promote and facilitate additional growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground.
3.7. Set against this, the Council’s Housing and Employment Land Availability Assessment considers
the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,500 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short
of the District’s housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
[SEE ATTACHED DOCUMENT FOR TABLE COMPARING LAND SUPPLY TO HOUSING NEED]

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

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

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

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

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

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

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

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

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

[SEE ATTACHED DOCUMENT FOR TABLES DETAILING LANDSCAPE CHARACTER ATTRIBUTES]

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

CONTEXT
7.1. The RDC Spatial Option Consultation identifies a number of strategy options that could form the basis of the plan’s approach to growth over the next 20 years and beyond. These representations endorse Strategy Option 3: Concentrated growth » Option 3b: Focused north of Southend.
7.2. As detailed in these representations, Option 3b is required in order to deliver the ambitions of the Local Plan with large scale growth focused in one location which will provide a sufficient critical mass in order to deliver the required infrastructure for the District. Strategic growth at this location is embedded within the evidence base which supports this Local Plan including the South East Essex Strategic Growth Locations Assessment (2019) and the South Essex Strategic
Growth Locations Study (2020).
7.3. This location provides the opportunity to deliver strategic development at scale which includes new homes and employment land, new strategic transport infrastructure, local services and associated community facilities and additional open space and recreational facilities. The strategic rationale for growth is to:
ƒ Contribute to meeting the strategic housing need for market and affordable housing in Rochford and also potentially unmet needs from Southend in a location close to where the need arises;
ƒ Locate growth at a sustainable location close to the concentration of existing employment opportunities at and around London Southend Airport, Temple Farm and Purdeys Industrial Estates, Fossets Way and Gardon Park, to reduce the need to travel and achieve a high
proportion of travel by sustainable modes;
ƒ Provide strategic scale development where housing can be brought forward alongside local employment opportunities, schools, healthcare facilities, local shops and services in line with the principles of 15 minute neighbourhoods in order to reduce the need to travel;
ƒ Deliver concentrated strategic growth which reduces the scale of incremental growth of the District’s existing towns and villages which can place pressure on their local infrastructure and adversely affect their character;
ƒ Enable strategic infrastructure improvements alongside growth including improved eastern access to London Southend Airport Rail Station, Temple Farm and Purdeys Industrial Estates, and address congestion pinch points including Bell House Junction, Priory Crescent and
Warners Bridge.
Figure 7.1: Land South East of Rochford & North of Southend Broad Location for Growth
[SEE ATTACHED DOCUMENT]
THE VISION
7.4. There are a number of themes which have informed the vision for the subject site -
ƒ A sequence of new neighbourhoods – the proposals include four individual, future facing neighbourhoods in Rochford, which contain mixed-use neighbourhood centres and the key community infrastructure and services required to support residents needs and reduce the need to travel, that can be brought forward alongside one another with a distinct identity and character. The character of these neighbourhoods can vary and respond to their location – with new hamlets and villages within Rochford which respond to the morphology of settlements in the area.
ƒ A Connected Place – the neighbourhoods will be physically connected by new green, sustainable transport corridors which also provides a link between the two train lines (Southend Airport and Thorpe Bay) and encourage sustainable transport choices. Proposed infrastructure will also help redress existing capacity constraints on the highways network.
Digital infrastructure is also at the forefront of the strategy to deliver connectivity. The proposals will help to deliver new strategic infrastructure which addresses existing congestion issues along the A127 and A1159 Eastern Avenue;
ƒ A Place with Identity – the proposals seek to identify and establish a character that draws from that of the surrounding context and is informed the existing site features. This involves drawing out local character and distinctive features associated with the area. .
ƒ A Working Place – the proposals are underpinned by an economic strategy to help transform the profile of the local economies, by attracting a more highly skilled demographic looking to locate here as a lifestyle choice, supported by employment floorspace provision.
7.5. This vision reflects the new requirement introduced through the Framework for larger scale developments ‘policies should be set within a vision that looks further ahead (at least 30 years),
to take into account the likely timescale for delivery’. The draft policy demonstrates the level of growth that is anticipated during this Local Plan (up to 2040) and also considers the longterm potential of this growth option up to 2050 and beyond. The emerging Masterplan has been
designed as such to allow for the delivery of individual villages which can all be connected in time but equally allowing for the villages to be independent in their own right with sufficient services and infrastructure to meet their needs without reliance on future growth to deliver infrastructure.
DRAFT POLICY: LAND SOUTH EAST OF ROCHFORD & NORTH OF SOUTHEND STRATEGIC
ALLOCATION
Land south east of Rochford, east of London Southend Airport and north of Eastern Avenue is allocated as a cross-boundary strategic growth location with potential to deliver around 10,000 homes on land in both Rochford District and Southend-on-Sea. Mixed-use development is
envisaged to deliver a minimum of 4,600 homes in Rochford District together with necessary community, employment, transport, green and blue infrastructure; of which approximately 1,850 dwellings are expected to be delivered in the plan period to 2040.
Development should include:
ƒ Housing - a minimum of 4,600 homes in Rochford District to including market and affordable housing, specialist housing for older persons, and self- and custom-build homes;
ƒ Employment – around 11 ha of employment land to include provision for flexible commercial floorspace or workspace hubs (Class E) within neighbourhood centres and industrial land located east of London Southend Airport; together with infrastructure to support home working;
ƒ Social and community infrastructure – including provision for local shops and services, multi-use community space, health and education infrastructure to be structured around 15 minute neighbourhood principles;
ƒ Enhanced transport infrastructure – including high quality bus services to key employment locations, town centres and rail stations, high quality infrastructure for walking and cycling and strategic highways infrastructure to enhance east-west connectivity and mitigate impacts.
Development should include a buffer to prevent coalescence with and maintain the separate identities of the settlements of Great Wakering, Little Wakering and Barling.
To guide development a Framework Masterplan SPD should be developed jointly with the Councils, local community, site promoters and infrastructure providers to ensure the comprehensive integrated development of land in both Rochford and Southend and to coordinate the delivery of infrastructure. This Masterplan should include:
ƒ A Green and Blue Infrastructure Strategy providing a coordinated framework for provision of publicly-accessible formal and informal open space, play space and other sport and recreational facilities and provide new green corridors linking the Southend Urban Area to
the River Roach.
ƒ A Transport and Movement Strategy which should prioritise cycle and pedestrian movements and public transport through development of a comprehensive pedestrian and cycle network including green sustainable transport corridors providing links to major trip generators and London Southend Airport Rail Station and linking the two rail lines; and wider measures to promote sustainable travel. The Strategy should address the
phasing of development with highways improvements necessary to mitigate the impacts of development.
ƒ A site-wide Energy Strategy detailing how the range of land uses and associated infrastructure across the masterplan will combine to achieve a site-wide net-zero carbon target. The scale of development and variety of uses presents opportunities to coordinate energy generation, transference and consumption, together with carbon sequestration to achieve net-zero carbon.
ƒ Infrastructure Delivery Plan - to coordinate the funding and delivery of development and on- and off-site infrastructure and addressing long-term stewardship of community infrastructure
Planning applications for development should be accompanied by a Phasing Strategy addressing the phasing of development and infrastructure; and a Sustainability Strategy outlining measured to be taken to achieve a net zero carbon development, high quality
digital connectivity, biodiversity net gain and to future proof development to achieve long-term sustainability.
Figure 7.2: Concept Masterplan for Land South East of Rochford & North of Southend
[SEE ATTACHED DOCUMENT]

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

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

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

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

08. RESPONSE TO QUESTIONS RAISED IN THE CONSULTATION.

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

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

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

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

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

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new
Local Plan? Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas? Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting? [Please state reasoning]
8.14. We support the preparation of design codes. Design codes provide briefing for consistency, from
site wide to detailed design. As such, each phase will require its own design code and each time a phase is complete, a review of the completed phase will inform the production of the design code for the following phase.
8.15. Typical content of a design code shall include -
ƒ Movement strategy where appropriate
ƒ Access and street hierarchy where appropriate
ƒ Landscape and open space strategy
ƒ Land use and mix
ƒ Density
ƒ Heights
ƒ Number of homes
ƒ Identity and character of buildings and public spaces
ƒ Employment

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

GREEN AND BLUE INFRASTRUCTURE
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure? [Please state reasoning]
8.26. As detailed in these representations, the ambition is to deliver a sequence of new ’15 minute walkable neighbourhoods’ with local services and a strong character and identity set within a high quality green network which connects Southend’s existing urban area and the new areas of growth through to the River Roach, whilst protecting important Estuary and wetland
environments, historic environments and biodiversity. We want to deliver a vibrant place to live, work and visit which successfully integrates and improves coastal, rural and urban environments, delivers family housing in strong local communities and helps to deliver transformational change and growth in the local economy and new strategic infrastructure.
8.27. It is considered that that new strategic green and blue infrastructure is essential in order to create the community envisaged in this location. We support the delivery of the South Essex Estuary Park and The Island Wetlands. In order to ensure these landmark green and blue infrastructure projects can be delivered this will need to be balanced with the Council meeting their strategic needs. The provision of growth in southeast of Rochford and north of Southend will enable investment into strategic green and blue infrastructure projects in the location. We welcome the opportunity to work with the Council in terms of the extent and location of the green
and blue infrastructure.
OPEN SPACES AND RECREATION
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver
improvements to open space or sport facility accessibility or provision?
8.28. A critical aspect in delivering a new community such as that proposed at Option 3b will be the
delivery of high quality public open space. The initial design work has considered green fingers separating the series of neighbourhoods as illustrated at Figure 5.2. Our client is keen to work with the Council to explore how the proposed scheme can contribute towards and assist in the delivery of the South Essex Estuary Park. Moreover, the proposed is of such a scale and critical mass that
will ensure each neighbourhood provides generous public open space and sports facilities.

HERITAGE
Q43. With reference to the options listed in this section, or your own options, how do you feel we can best
address heritage issues through the plan? [Please state reasoning]
8.29. Rochford is identified as one of the top five local authorities in England as having heritage potential as defined by the Heritage Index 2020. This means that the District has untapped heritage potential and suggests that local heritage is a further asset for consideration to achieve the goal to grow the tourism economy. There is an opportunity through delivering growth in the district to celebrate the heritage assets of Rochford.
8.30. The Thames Estuary 2050 Growth Commission aims to utilise opportunities in existing sectors,
environmental assets and planned development to create a ‘tapestry of productive places’ along a global river. These assets present an opportunity to support the attractiveness of Rochford as a place to live, work and visit, and contribute to the potential for growth of the tourism economy in the District.
TRANSPORT AND CONNECTIVITY
Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take?
[walking, cycling, rail, bus, road etc.]

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

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

09. ECONOMIC BENEFITS TO ROCHFORD
OF OPTION 3B

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

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

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

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.

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

Spatial Options Consultation

Q2. Do you agree with our draft vision for Rochford District? Is there anything missing from the vision that you feel needs to be included? [Please state reasoning]
We agree with the draft vision for Rochford District, especially in relation to the delivery of high quality homes supported by accessible and responsive services and facilities, creating healthy and sustainable communities.
Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included? [Please state reasoning]
We agree with Strategic Priority 1, Objective 1, facilitating the delivery of high quality and sustainable homes that meet your local community needs. Whilst we agree that previously developed land should be an important part of meeting needs for development, the council needs to be realistic about how much of the district’s need for development can be accommodated on previously developed land.
We agree with Strategic Objective 2 of Priority 1 which states that Rochford need to plan for a mix of homes to support current and future residents. It is important that the council take into account the types of dwellings required when allocating sites, considering the likely sizes and types of dwellings likely to be accommodated on any given site. Sites such as that at Hall Road, Rochford, being promoted by Croudace, offers an important opportunity to provide a diverse portfolio of housing, addressing the affordability issue that Rochford currently struggles with. From 2016-2019 Rochford only delivered 677 of the 876 new dwellings set out in the housing delivery test (2020). This rate of delivery also falls short of the South Essex Strategic Housing Market Assessment of May 2016 and June 2017 which stated that between 331 and 361 new dwellings should be delivered per annum up to 2037.
We agree with Strategic Objective 6 of Priority 1 which states that the council want to ensure that all new homes “are built to the highest attainable quality, design and sustainability standards”. Croudace prides themselves on the quality and design of the housing they build and we are certain we will meet the council’s standards for development.
We agree with Strategic Objective 11 of Priority 3 which wants to encourage sustainable travel within the district such as walking and cycling. Croudace’s two sites, CFS081 and CFS082 at Hall Road in Rochford, are within walking distance of Rochford town centre, encouraging residents to walk or cycle to the town centre. This factor should be given significant weight when appraising possible Greenfield and green belt releases.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required? [Please state reasoning]
We agree with the settlement hierarchy presented as we think it is reasonable to have Rayleigh, the largest town should be at the top of the hierarchy with Hockley and Rochford in tier 2 and the smaller settlements in the tiers below.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan? [Please state reasoning]
Of the identified strategy options we believe Option 2b should be taken forward by the Plan. Option 2b would see urban extensions dispersed to settlements based on hierarchy. We agree that spreading the housing supply across a number of builders is the correct and less risky strategy and means that more housing can be delivered sooner, relieving Rochford of its affordable housing supply shortage. We believe that some of the better sites for sustainable development are within the greenbelt so as Option 2b states, some Green Belt land will need to be released. Option 2 would deliver 3,000 – 5,000 more dwellings than Option 1, which already delivers 3,000 – 5,000 homes, with 1,000 – 2,000 of these new houses being affordable, giving a potential total of 10,000 new houses of which 4,000 are affordable houses. We believe this is the correct solution to solving the affordable housing issue in Rochford. As stated in the 2021 draft Local Plan for Rochford, for every 10 additional homes the local community sees the benefit of creating or sustaining 9 local jobs and bringing in £250,000 in additional local spend from new residents.
Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at? [Please state reasoning]
For residential development, the Planning Practice Guidance (paragraph 012) is clear that any energy performance standard required by a local policy should not exceed the equivalent of Level 4 of the Code for Sustainable Homes. The building regulations remain the most straightforward way of the country as a whole meeting the challenge of climate change. The Government is working on its Future Home Standard for significantly reducing the carbon emissions of homes, with a challenging but achievable timetable for introduction over the period to 2025. Local policies on the subject can add value where there is a locally-specific justification or opportunity, but the council needs to be clear that the policies it proposes on this front are justified, will add value, and will be capable of implementation without creating substantial duplication of work for both council and applicant that is more simply administered through the building regulations system.
Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas? [Please state reasoning]
The plan should include a place-making charter that informs relevant policies. However, the same principles should not apply everywhere in the district because some policies would not be relevant in a residential development for example.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included? [Please state reasoning]
The principles set out in the draft place-making charter are commendable but it is important that the Council set out in policy what they require regarding place-making in the district. These policies will have to be financially budgeted for and may slow down development.
Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
It would not be necessary to create new design guides, codes or masterplans alongside the new Local Plan as this would create an additional burden on the council and potentially delay the release of the new Local Plan. Any design guides, codes or masterplans could be created once the new Local Plan was published.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing? [Please state reasoning]
The best method to ensure Rochford Council can deliver different types, sizes and tenures of housing is to allocate different types of sites to be available for builders to buy. Ranging from brownfield sites in urban areas to Green Belt land being released for new housing developments, making available different types of sites will ensure a mix of housing types, size and tenure are built. It is also important to take into account when creating policy regarding the development of housing that the demand for different type, size and tenure will fluctuate as the demographic and requirements in relation to services of the district change. For this reason, it is important that some flexibility be designed into the policy when determining what size, type and tenure of housing is to be built on a site and that this be determined when the application is received taking into account the current local housing context. With regard to affordable housing, we expect the council to calculate how many affordable houses they need for a given period so as to not slow down the application process with lengthy negotiations. We also want to raise the issue of all the other policy measures and building regulations that builders have to comply with when assessing the number of affordable houses that need to be built, and taking into account the financial feasibility of these requirements.
Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas? [Please state reasoning]
For Sites CFS081 and CFS082 at Hall Road, Rochford, Strategy Option 2b would be suitable for the specific housing approach which would see a mix of 1 to 4 bedroom houses built on these parcels of land. The suitable housing tenure for these sites would be a mixture of owner occupation and affordable houses falling under affordable rented tenure and intermediate (shared ownership) homes. What is required to meet the housing needs in these areas are an increased land supply to provide more housing for Rochford. Rochford has become one of the most unaffordable district counties in the country, with house prices increasing by 70% in the past 15 years. The 2016 and 2017 South Essex SHMA calculated that Rochford district council needed to build at least 360 houses for the next 20 years, however, Rochford currently build on average 166 new houses per year, which falls below the government requirement set out in the SHMA. If Rochford continue to undersupply new dwellings, housing-related issues such homelessness and concealed homes, where young people are forced to stay or move back in with their parents longer than they would want to, will become an increasing issue within the district.
Q23. With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan? [Please state reasoning]
By providing well designed, high quality and affordable housing Rochford will be able to attract more potential workers and businesses to the district and prevent young people moving away from the area in search of affordable housing. This will ensure a stable and able work force whilst also providing jobs to the local population during the construction period of the new dwellings.
Q27. Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g. skills or connectivity?
The foundations of long-term economic growth is through having affordable housing young people can afford. This will decrease the likelihood that they will move away, taking their skills with them, whilst also attracting potential businesses to the area to provide services. Providing this housing will also create new jobs during the construction phase which can up-skill workers over a prolonged period of time.
Q31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?
We believe net gains for biodiversity are best delivered off-site. This ensures there are no unforeseen costs during a development and we believe it is more beneficial to the environment to have biodiversity in specific areas than have it spread through developments.
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state reasoning]
We think the best plan to ensure Rochford’s town centre remains vibrant is through option 6, specifically providing sustainable connections from any large-scale new housing development to Rochford town centre. Building new housing developments within a 20 minute walk of the town centre is a method of providing sustainable connections to existing town centres, and sites CFS081 and CFS082 fall within these parameters. Additionally, providing accommodation for more residents will provide greater footfall to the businesses within the town centre, further sustaining the services and employment opportunities for Rochford district.
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]
We agree with your vision for Rochford and Ashingdon, however, the allocation for housing has not been covered. Providing new housing will support Rochford and Ashingdon’s town centre business and provide more sustainability to services.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other
We believe that site CFS081 and the eastern part of CFS082 (as shown on the attached plan) should be made available for housing market falling under Strategy Option 2b. This could improve the completeness of Rochford and Ashingdon by providing the required ‘critical mass’ in terms of housing density for additional services such as a more frequent bus services or an additional bus stop on the proposed site. This will improve the site assessments access to a bus service from a 1 to a 5 and improve the access to bus services assessment. Site CFS082 is missing from Figure 45 when it is included on the Interactive Consultation Map. We propose to build on half of the total site, preventing Rochford and Hawkwell coalescing and retaining and protecting part of the metropolitan green belt. With these two sites combined, over 600 houses could be delivered for Rochford, which would provide three main benefits. The first benefit would be to local businesses, as an increasing population would bring additional income to the business, which would allow local businesses to grow. The second benefit is that with an increasing population, other firms would view the district as a viable location to establish themselves in, further increasing employment opportunities in the district and providing more services to the area. The third benefit would be Rochford and Southend Borough District would avoid housing-related shortage issues such as homelessness and concealed households. Building more housing would also prevent young people moving away in search of housing they can afford, preventing an ageing demographic which would present its own challenges to the district.
Q57c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
Sites CFS081 and the Eastern half of site CFS082 should be presumed appropriate for development as they are within sustainable walking distance to Rochford town centre, and therefore offer a highly sustainable way of accommodating the housing needs of the town, a factor which we believe has been given inadequate weight in the council’s published site assessments. As well as meeting housing needs, building these developments would provide jobs over the construction period and prevent homelessness and concealed households becoming an issue within the district. These developments would also increase footfall for local businesses, making local businesses more sustainable, and potential businesses seeing Rochford as a viable area to locate their business. These factors bring the added benefit of greater sustainability to the local businesses and employment opportunities to the wider community.
We acknowledge that sites CFS081 and the eastern half of CFS082 are currently in the green belt. As we are only proposing building on the eastern part of site CFS082, the green belt harm assessment should be re-examined for this site to ensure that it has been fairly appraised relative to all other sites being considered. Limiting development to the eastern part of CFS082 reduces the potential harm caused to green belt purposes, preventing Rochford and Hawkley merging into one another in line with paragraph 138 subsection b of the 2019 NPPF.
The recent development of 620 homes to the east of sites CFS081 and CFS082 has demonstrated that growth of Rochford town in this direction can be successfully accommodated. There is a strip of land along the western edge of that development which remains designated as green belt, providing public open space. We believe the council needs to assess sites CFS081 and CFS082 (east) in light of the fact that the open space there is now not countryside, but is meeting the open space needs of the urban area. If sites CFS081 and the eastern part of CFS082 were to be released from the green belt they would effectively continue the urban area around this open space.
We also question the impact on Built Heritage assessments for sites CFS081 and CFS082 labelled at 1 and 2 respectively. We can only conclude that this low score is due to the nearby Pelham’s Farmhouse, which is a grade II listed building. However, on a site the size of CFS081 there is scope to plan the open space on site so as to minimise direct impacts which may arise to that heritage asset.
We question the assessment for site CFS081 in regards to the access to bus stop being scored at 2. CFS082 assessment scored a 4 and we propose linking the two sites allowing site CFS081 better access to bus stop services, and the area is closer on foot to the town centre. CFS081 and the eastern part of CFS082 are also large enough that they would reasonably be expected to make contributions toward new bus stops and improving bus services. We would also like the access to bus services re-appraised if were given permission to develop on the two sites as the increase in population density may provide the ‘critical mass’ to make the sites viable for the Rochford SS4 1NL bus service to come more frequently then it currently does. This would improve the appraisal score and make the development more sustainable.
The access to secondary schools for site CFS081 is appraised at a level 4 whereas site CFS082 is appraised at the lowest level of 1. With these two sites side by side, with access to the same road network as each other, we question why site CFS082’s access to secondary schools was appraised so low. If needs be, we can provide a financial contribution to a local secondary school to improve the facilities and size of the local secondary school.
We would like the access to town centre for site CFS082 to be reappraised as it is only a level 1 whereas site CFS081 is appraised at a level 4. With the two sites being developed on, a pathway through site CFS081 could be created for site CFS082 allowing it better access to Rochford town centre. The two sites fall within a 20 minute walk of Rochford town centre which should mean the appraisal for site CFS082 is higher.
We also question the appraisal for the access to employment site for site CFS082 at level 2 when CFS081 is appraised at level 4. With both sites having access to the same road network, these appraisals should be the same. We also question if the town centre has been considered as an employment site as it often is a major source of employment within a town. The town centre is only a 15 minute, 1 mile walk away or a 3 minute drive so the access to employment site for site CFS082 should be appraised higher.
We question why both sites CFS081 and CFS082 are appraised at levels 3 and 2 respectively for distance to strategic road network when both have access to the A127 being only 6 minutes away and 2 miles in distance via Cherry Orchard Way.
We would also like the appraisal for access to train services for site CFS082 to be reappraised as site CFS081 is appraised at level 3 whereas the former is at level 2. Through the development, site CFS082 will have access to Rochford train station like site CFS081. Rochford station is only a 15 minute walk or 3 minute drive away from the sites, at a distance of 1 mile from both sites. We therefore argue that the appraisal for access to train services for both sites should be higher.
We would also like the appraisal for site CFS082 proximity to water apparatus to be reassessed as it is a level 1 whereas neighbouring site CFS081 is appraised at a level 5. The River Roach does flow south of both sites and there is Rochford Reservoir only 1 mile away.
The assessment for Critical Drainage Risk for site CFS082 can be improved from a level 2 with implemented drainage systems for the proposed development.
We also question the level two assessment of impact on Ancient Woodland for site CFS082 being at a level 2 when the site is currently used as an agricultural field with no Ancient Woodland currently existing on the site. Site CFS081 with no ancient woodland on it as well was assessed at level 5 for impact on Ancient Woodland.

I wish to submit comments with regard to the Spatial Options Consultation, specifically around the 20 sites resulting in a potential 3.5K houses across the villages of Barling, Little Wakering & Great Wakering.

I will endeavour to complete the online feedback for each site but to ensure clarity of my concerns I have also addressed them within this email for your reference. Whilst I understand numbers need to be met, and the person receiving correspondence associated with this project is not responsible, I have great concern for our future and that of younger generations.

Schools and education
• Limited nurseries in the village with many already unable to accept children without the added pressure of further housing and families.
• Primary education - Great Wakering is already at capacity, Barling Magna is close and currently has a class without a dedicated classroom – this is against the Department for Educations guidelines, we are already failing current pupils without increased pressure.
• Some secondary schools offer dedicated buses, however general connections and access is limited.
Connectivity i.e. public transport
Current public transport options are limited, schedules and availability worse. Consideration must be made into safe access for all residents across the village, road infrastructure and the impact that increased vehicles will have. Rail access is currently not viable on foot or cycling.

Traffic and pinch points/congestion
Already exist areas of concern due to traffic and congestion as well as safety due to blind bends, existing parking, pedestrians, horses, speed etc. There are limited roads in and out of the village, as many of us have experienced when road works are in place, problems very quickly arise. A great example was recent roadworks resulting in gridlock along Little Wakering Road at school pick up time when Barling Road was closed.

Parking
Roadside parking often leaves limited space i.e. single track traffic, often there are reports of access concerns for emergency services and safety risks as a result of limited spaces and increased vehicles within the village. The impact around schools result in tension and concerns for children’s safety. Consideration must also be taken for those with disabilities or wheelchair users who often find footpaths blocked by poor parking and few suitable access points/pathways.

Doctors and medical
The Doctors surgery is often a topic of discussion due to difficulties getting appointments, increased residents will simply impact this further. To my knowledge there is one medical centre for both villages and I would be interested to understand recommended capacity for care under the Department for health.
With regard to other medical services, I believe these are also limited, for example I don’t believe there is a dentist locally.

Wildlife and nature
There is great beauty in the local area, wildlife thrives, and some rare species have been observed. It is vital to protect green areas, to protect wildlife and insects as these all support human existence.

A127/A13 access
Access to the South East is widely limited to the A127 and A13, these roads are already congested and result in delays and pollution levels locally.

Parks and open spaces
Parks and public areas are also limited, living in Barling there isn’t a park in the village for local children. In fact the village only offers a church and a school, there are no shops, few pavements and a limited offering for new developments.

Drainage
Problems are already widely reported to exist in Little Wakering Road and Kimberly Road where recently human waste was washed into residents gardens due to increased rainwater and unsuitable drainage.

Flood risk
I believe the creek originally travelled to Barling pond, should water levels continue to rise as expected, considerations must be taken into future viability.

Complimentary Designs
It is vital that any developments are complimentary in their designs to any existing properties and the village feel. Sadly developments already completed are not in keeping with historic buildings.
The tip road which was argued against and supposedly temporary, remains in place. The mounds as a result are now visible from several areas across the village and pollution caused by large vehicles still travelling back and forth extremely unfortunate.

Fair local knowledge and consideration
I understand that of the group leading the consultation – none live within the villages potentially affected. It is therefore vital to share local views and impact that developments may cause. It is also key to understand if the owners of the identified land are in agreement.

Should further detail/research/evidence be required for any of the above claims or concerns please let me know, whilst this isn’t an immediate problem, it would be remiss to not consider long term impacts. Now is time to act responsibly, both for the environment and future generations.

1.0 Introduction

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

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

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

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

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

2.0 Response to Spatial Options Consultation Questions

Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?

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

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

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

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

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

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

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

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

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

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

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

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

2.11 As the RLPSO recognises, Rochford and Ashingdon together form a functionally-connected settlement home to around 18,000 residents. Between Rochford town centre and a number of neighbourhood centres located throughout the wider settlement, Rochford provides for a wide range of services and facilities.

2.12 The RLPSO also recognises that Rochford benefits from good walking access to most services, and that the only parts of Rochford with particularly poor access to services are around Purdeys Industrial Estate and the residential neighbourhoods of Ashingdon village.

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

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

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

2.16 The RLPSO describes this option as making best possible use of existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations).

2.17 The RLPSO suggests that at least 4,200 homes will be built over the next 10 years under Option 1 and notes the Urban Capacity Study suggests up to a further 1,500 homes could be built through a mixture of maximising the capacity of planned housing developments and taking a more permissive approach to higher densities in urban areas.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2.46 However, this should include housing for older people.

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

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

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

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

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

And;

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.0 Response to Integrated Impact Assessment

Assessment Framework

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

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

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

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

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

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

And

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

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

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

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

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

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

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

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

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

Please see below our response to the above consultation; an acknowledgement of safe receipt would be appreciated, thank you.

Page 22 Strategic Priority 4 Objective 15: we note the objective and broadly agree with its content; however, we would prefer to see ‘access for all’ embedded into the strategic objectives of the new Plan and this followed throughout the lower levels. We suggest that it is amended to read: 'To protect and enhance leisure, sport, recreation and community facilities and to support the delivery of a fully accessible multi-functional green infrastructure network’.
Page 38 Place-Making Charter for Rochford: whilst we broadly agree with this Charter, we ask that again access for all is embedded within it. We suggest that the fourth bullet point is amended to read: ‘Improve health and wellbeing by encouraging active travel and securing access to multi-functional, connected green and blue spaces, including parks and coastal areas, which is accessible to ALL user groups – walkers, cyclists, equestrians and the less mobile’.
Page 54 Green and Blue Infrastructure: the main issue which appears not to be included is accessibility for all users. We broadly agree with the options, but it is vitally important that ALL user groups are catered for within the green infrastructure particularly, as the usual default option is to cater for walkers and cyclists only. We would ask that equestrians are also included within this default when green infrastructure is considered.
Public rights of way networks and other accessible green infrastructure is frequently fragmented and this Plan needs to be bold and aspirational to enhance the connectivity of existing and new open spaces so that the network becomes a useable active travel option for all users, both for utility and leisure.
Page 58 Open Spaces and Recreation: Similarly, the need for open spaces to include full accessibility is also very important – and where new open spaces are proposed that access for ALL user groups is the default so that equestrians are not omitted.
Page 67 Transport and Connectivity: we are very pleased to see equestrians being included in the transport hierarchy diagram but we are disappointed that further on reference is made to preparing a Local Walking and Cycling Infrastructure Plan to identify further need for improvement. We ask that this is a ‘Sustainable Travel’ Plan which includes all modes of transport – walking, cycling and horse riding (bearing in mind that the Government has confirmed that horse riding is absolutely a form of active travel) otherwise equestrians could lose out on any potential access opportunities on an enhanced network. We suggest that this aspiration is amended to include equestrians.
Potential Site Allocations: we note the various sites that have come forward under the Call for Sites in preparation for this Plan and we are not intending to comment on the suitability or otherwise of specific sites at this stage. We ask though that when a site is considered, any existing public rights of way network is both protected and enhanced, and the opportunity is taken to upgrade footpaths to bridleway status where possible within new developments, thereby ensuring access by walkers, cyclists and equestrians.

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.

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.

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

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

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.)

RDC/Spatial Consultation 2021 Questions. Hullbridge Parish Council official response/answers. 14th September 2021.

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?

Hullbridge Parish Council feels 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 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. Rochford District Council 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?

Hullbridge Parish Council believes 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?

Hullbridge Parish Council agrees that there should be separate visions for each settlement, however, these should be determined by each Parish Council working with 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 council’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.

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 Hullbridge Parish Council 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, and would 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.

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. Suggestions from councillors regarding other opportunities to supply renewable energy ranged from a solar farm in a place that will not impact its surroundings to solar panels 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?

Again, this is something that is a fantastic plan providing 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.

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.

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.

New homes should meet the standards set out in Parts M4(2) or M4(3) of Building Regulations.

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 selfemployed 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. 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.

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; additionally, Parish Councils could maintain coastal paths with funds from Section 106 agreements.

Q34. With reference 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. This section 106 money was instead given to RDC in respect of the existing Malyons Farm development. 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.

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.

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 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 reestablish 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.

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.

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.

Hawkwell Parish Council - Official Response to RDC's Local Plan Spatial Options Consultation

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 full infrastructure assessment should be conducted,
to include a local highway study/up to date traffic
assessment. This study needs to be undertaken prior
to deciding the best option to deliver the new Local
Plan. The cumulative effect of the development of the
present District Plan on Hawkwell’s road system; the
Christmas Tree farm, Rectory Road, Hall Road and Brays
Lane sites, without the impact of Sapwoods site yet to
be developed.
It would also be important to obtain some
statistics/reports from schools & doctor surgery and
drainage capacity. All these areas appear to be at or
near capacity already.
Comprehensive air quality testing is a necessity, with
the increase in traffic volumes (34.5%) there must have
also been increased air pollution, which is dangerous to
the health of residents and must not be overlooked.
With reports of government already struggling to meet
their climate change targets and the extremely
worrying IPCC report it is essential that we start to
consider the consequences of the rising temperatures,
therefore a Flood Risk assessment should be provided.
There are many areas in our District that are predicted
to be under flood level by 2050 and the areas that
aren’t in the flood risk zone are already suffering from
surface flooding problems when we have torrential
downpours. (A very high proportion of
Hawkwell/Hockley sites are rated 2 for flood risk)
Perhaps a windfall report? It would be good to know
how many houses have already been built over the
course of the last Local Plan that couldn’t be included.
This could potentially be used for challenging
government for a reduction in the housing target,
which is something we would like to see.
We find it very difficult to respond to this consultation
without having the above technical evidence.

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]

No. The Council believes that Hawkwell Parish should
not be split with West Hawkwell joined with Hockley
and East Hawkwell joined with Rochford in this study.

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 explained above each settlement has its own
unique needs and characteristics and it is only by
working with Parish Councils and residents that their views can be reflected in the Plan to ensure the unique
character of each settlement is protected.

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]

Strategic Option 2 fails to address the problems of the
aging population within the District, partly due to the
failure to provide low rent social housing. The strategy
should provide council housing stock in small local
exception sites.

STRATEGY OPTIONS

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

No. Council does not agree in splitting Hawkwell Parish
into West and East and joining these areas with Hockley
and Rochford/Ashingdon respectively. Hawkwell is the
largest Parish in the Rochford District, except for
Rayleigh Town Council, yet doesn’t feature as a
complete settlement in the hierarchy.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan? [Please state reasoning]

Option 3a is Council’s preferred option. This seems the
least disruptive option and a new village to the west of
Rayleigh has the advantage of being close to exiting
road hubs (A127 and A130) which would enable good
transport links to Wickford, Basildon, Chelmsford,
Thurrock and Southend (the main employment routes).
Option 3a would attract Section 106 funding for
infrastructure, rather than adding to existing villages
and hoping for S106 funding afterwards towards
schools, community centres, medical centres and
shopping parades.
The Council promoted this option in the last Local Plan.
Option 3b would put even more pressure on existing
roads and erode the green belt and current separation
between Rochford District and Southend.
Option 3c would only lead to demands for a Southend
Bypass, promoted by developers which would lead to
further developments alongside the bypass.

Q7. Are there any reasonable alternatives to
these options that should be considered
instead? [Please state reasoning]

Yes. A combination of Option 1 and Option 3a after
utilising all available brownfield sites and infrastructure
improvements have been planned and/or completed.

SPATIAL THEMES

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

Council is concerned that the whole character of the
District will change with the urbanisation of the District.
Accessibility to some of the consultation documents
has been very problematic and Council has concerns
that residents, particularly those without access to a
computer, are not realistically able to view or respond
to the 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? [Please state
reasoning]

We agree that it is essential that both flood risk and
coastal change be considered when developing a suitable plan and development sites. A plan needs to
focus on limiting flooding, protecting people, wildlife
and properties.
According to the climate central coastal risk screening
tool, the land projected to be below annual flood level
in 2050 includes a large part of the district (areas
affected include Foulness, Wakering, Barling,
Paglesham, Stambridge, South Fambridge, Hullbridge,
Canewdon and Rochford).
The main route out of Rochford between the train
station and the airport is also affected, roads leading to
for example, Watery Lane, Lower Road etc and
including the A130 & A1245.
Large retail areas such as Purdeys Industrial Estate may
also be affected which would affect employment. As
would employment areas such Battlesbridge, Rawreth
& Shotgate.
As the sea levels rise further other complications may
include:
• People unable to get mortgages and insurance,
therefore they may not be able to live in those
areas.
• People wanting to migrate to areas of lower
flood risk.

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]

The Coastal Protection Belt only lasts to 2025 and
needs to be extended for many years. All development
in flood plains must be resisted as the danger of
flooding will increase. Hockley Woods and Cherry
Orchard Country Park must be protected from
development. The fields around St. Mary’s church in
Hawkwell and the network of footpaths around
Clements Hall and Glencroft Open Space need to be
protected for its contribution to wildlife habitat.

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?

The way forward is renewable energy, wind farms and
solar panel farms, provided they are not in places with
impact on sensitive areas.
The area does not have enough free land to support
wind or Solar P.V farms to create enough energy. These
farms have a massive impact on the community as
large trenches have to be dug over great distances to
lay the cables to Sub Stations, that have to be built.
Other sources of producing Zero Carbon energy should
be selected, before covering every piece of land with
P.V panels or Wind turbines.

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, providing the cost is not passed to the house buyer
making the cost prohibitive. Local building control
inspections should only be carried out by the Council’s
Inspectors.

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]

Foulness Island could be a good location for a Solar
Farm and wind turbines off the shore.
The plan cannot support local low carbon generation
and renewable energy. The only way this can be
achieved by all the Districts or Counties is if the grid is
de-centralised and smaller power stations are sited in
places like Foulness, where impact to the Community
would be kept to a minimum.

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]

Yes. They should be settlement specific to allow for
individual characteristic of each area, sufficiently
detailed to avoid confusion.

Q15. Are the principles set out in the draft placemaking charter the right ones? Are there other principles that should be included? [Please state reasoning]

Yes, provided that individual settlements are consulted,
and 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. Each individual settlement should be at the centre
of it and considered as their own entities, with their own individual characteristics identified.

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]

Design guides should be area specific under one single
guide covering the whole district.

c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting? [Please state reasoning].

The Design Guides must reflect the character of the
settlements while allowing for some growth.

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? [Please state reasoning]

Meet the needs for different types of tenures of
affordable, social, council and specialist housing by
requiring all types are provided on all new
developments.

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]

There is a need for more flats, bungalows, 2 bed
houses. These can be accommodated in Option 3a. In
addition, the Council has a long-held view that
bungalows should not be converted into houses as this
depletes the bungalow stock which are required for an
ageing population.

According to the strategy options/growth scenarios, the house price to local earning ratios, suggest our area is the least affordable in the country. It also states that our housing registers has grown by 20% in the last year.
With house prices going up it would mean that younger
generations are priced out of the area. If they leave the
area it would create more of a retirement settlement
than before, therefore requiring less employment & retail space etc.
Focus on building smaller properties (e.g. 1-3 bedrooms) and tailored towards singles/couples/first time buyers/young adults who are still living at home with parents.
Other priorities should be for ground level properties,
suitable for the aging and disabled residents, we should
be safeguarding existing bungalows which are rapidly
disappearing. Providing these options would ‘free up’
the larger properties within the district, meaning we
shouldn’t require so many larger (4/5 bedroom) homes.
It is important to note that first time buyers, buying a
property in the area will more than likely already live in
the district and own a vehicle. This means that no new
traffic is created, however for larger, more expensive
properties that attract buyers from outside the area
will also bring additional vehicles onto the already
congested roads.
Social housing and homes for homeless and vulnerable
residents also needs better consideration.

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]

Affordable housing for the disabled and starter homes
should be planned for.

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]

Possible need a permanent traveller site which could be
controlled in terms of site population exceeding 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]

Sites need to be away from residents but also close
enough to schools. Also needs to be near main roads to accommodate large vehicles and caravans.

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 Q21. In addition, sensitive green belt
areas should not be considered as potential locations.

EMPLOYMENT & 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? [Please state reasoning]

Ensure that Essex Education Authority provides evening
and afternoon classes to offer affordable, local adult
education to address skill shortages and allow
opportunities to support residents to get back into
work or upskill/retrain. Work with local colleges, as
well as businesses, job centres and Essex County
Council to assess what sustainable employment is
needed in the District.
Large retail areas such as Purdey’s Industrial Estate may
be affected by flooding in the future, which would
affect employment. Current businesses within the flood
risk area may possibly need to be relocated or they
could lose employment opportunities.

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]

Greenbelt sites must be controlled by regularisation of
informal sites. Brownfield sites should be used first and
protected from housing development if they have a
current or future potential to provide employment
opportunities. There is a need for employment in local
communities as this is a greener option as it reduces
transport use.

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

Council’s preferred option 3a provides many
employment opportunities to establish the new
infrastructure over many years. Various types of
employment facilities, i.e. industrial units, hospitality,
retail and other employment could be included in
option 3a. This option satisfies the ‘Employment
Option 4’ which states “meeting future needs by
prioritising employment space alongside any new
strategic housing developments.”

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

Yes, lacking in ‘green’ industries. Sites for ‘sustainable
living’ businesses e.g. refill stores, market type sites for
locally grown or manufactured foods or crafted items,
small holdings, upcycling or repair & restore facilities.

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 and public transport links to serve
new schools and colleges required as result of the
increase in population linked to development. Also
improve footpaths and cycle path access. Consider
higher or further education facilities and availability of
apprenticeships and training for all ages, to address the
current and future skills shortages.

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]

Careful consideration should be given to the growth of
the airport; it would bring additional jobs and business
opportunities, but it would also put more strain on the
existing transport network and would bring additional noise and air pollution. It would also require more land.
Improvements to the public transport system and road
network would be required to enable growth and jobs
linked to the airport industry. Airport linked transport
adjacent to both the existing airport industrial park and
Saxon Business Park should be included in the strategy.
Given the ongoing uncertainty surrounding the impact
of Climate Change on the aviation industry (e.g., urgent
carbon reduction), we should 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.

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? [Please state reasoning]

Yes. Gusted Hall Wood, Hockley Woods (ancient
woodland). The upper Roach Valley, the lower Crouch
Valley. The rivers Roach and Crouch.
All local Nature Reserves and ancient woodland sites
must be protected at all costs. Magnolia Nature reserve
is home to protected Great Crested Newts.
We should avoid building on green belt, park land and
coastal locations, to protect wildlife and habitats.
Evidence suggests that society is losing its connection
to nature, we must not allow this to continue and must
ensure that future generations have a legacy. New
wildflower meadow creation would also be very
valuable as our insects and pollinators are in decline.

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. Many areas provide important wildlife habitats for
protected, endangered or rare wildlife and fauna. It is
important that these areas are protected for future
generations.

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.

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?
[Please state reasoning]

By retaining what is already in existence by ensuring
the links are in place to join as many locations as
possible. Additionally, ensuring that Public Rights of
Way (ProW) are free from land-owner obstructions and
that they are kept free from any debris. Also, paths
need to be made accessible to the disabled to ensure
all- inclusive facilities.

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]

By lobbying central government to allow revision of
RDC plans to support a quality green and blue
infrastructure; additionally, Parish Councils could
maintain paths such as costal paths with funds from
Section 106 agreements.

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]

Our choice of Option 3a, Council believes there should
be concentration on brownfield and town sites to
protect rural communities and the Green Belt.
Alternative options 3 or 4 mean less development in
rural areas and are therefore more accommodating to
the needs of smaller rural areas.

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? [Please state reasoning]

It is important to assess the shortfall of facilities and
networks before plans are approved to ensure
adequate planning and funding can be secured before
any building takes place.
Options could be considered to get people across the
road without the need to stop the traffic, such as a
walking bridge/flyover on Ashingdon Road where there
are 3 crossings within close proximity to each to other,
which is a significant cause of traffic and congestion.

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

Any section 106 monies should be legally
specified/described in the plans to state that it must be
allocated to the development area stated within the
plans and not used for other sites elsewhere.

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]

Ashingdon Road is gridlocked most days and has a
severe congestion problem. There should be public
transport links that allow residents to easily travel
between parishes within the district (for example:
Ashingdon to Hullbridge, or even travelling from East to
West Hawkwell would currently require 2 buses). Even
if Section 106 grants were made available, healthcare
facilities in Hawkwell are currently severely restricted,
especially since the pandemic due to doctor shortage;
those grants are unlikely to improve the situation.
Further development in Hawkwell would put further
burden on the healthcare provision.
A new site for the waste recycling site should be
located; the tip in Rayleigh seems to be insufficient
now.

OPEN SPACES & 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? [Please state reasoning]

Permanent all year-round bus services to our main
leisure sites.
Section 106 monies, if available, should help fund the
improvement of the football pitches at Clements Hall. It
is important to safeguard, improve and maintain
existing open spaces and recreational sites.

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 where
appropriate.

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]

The potential sites seem acceptable.

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?

There could be improvements made to Clements Hall,
including public transport links to and from the leisure
centre. Council’s preferred option 3a. would enable
delivery of new open space and sports facility provision
and S106 monies from larger developments could help
fund appropriate new 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]

Magnolia Nature Reserve and all other Reserves, green
spaces, parks, woodlands and the reservoir must be
protected.

HERITAGE

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

Villages and rural areas need to be protected from over
and/or inappropriate development through careful
planning considerations. A list of sites should be
composed with local consultation and those sites
maintained 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? [Please state reasoning]

Areas of precious woodland should not be taken 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]

The updated Local List needs to be made available for
an answer on this section.

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 reasoning]

People need to ‘want’ to visit towns. People’s habits
have changed and therefore entertainment and shop
offerings need to reflect this. If nightlife is going to be
improved then consideration needs to be given to
security; people need to feel safe, especially in areas
that are prone to Anti-Social Behaviour (ASB) already.
Transport links to town shopping and amenities need to
be improved. For example, there are no easy transport
links from Hullbridge to Hockley, Hawkwell 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]

Rochford District Council (RDC) needs to encourage
business with free parking and reduced business rates.
Businesses should be encouraged to work together, or
a number of shops have extended opening hours to
encourage shoppers coming out in the early evening.

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]

N/A

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 selection of retailers is essential. There needs to
be a balance of outlets that keeps the area viable.
Consideration should also be given to the restriction of
chain stores as these tend to be the first to go in a
crisis.

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 option 3a will allow the most
opportunity to expand retail both in terms of including
retail space and bringing customers into the town
centres, nearest to new developments. Depending on
the development size, in a new development there
would be scope to add a small, medium, or large retail
precinct.

TRANSPORT & 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? [Please state reasoning]

Development should not be seen without seeing
infrastructure first. Prepare an Infrastructure Delivery
Plan to deliver meaningful improvement to transport
networks, including cycle routes, walking pathways,
public transport and roads. It is worth noting these
modes are currently completely stretched and
therefore modernisation and improvements
need to occur before future housing developments are
built. (An electric scooter scheme could also be
introduced.) RDC need to work with Government,
Highways England, Essex County Council etc to deliver
meaningful road improvements to both the main and
local road network. However, the Southend Bypass
scheme which will destroy a large green belt area
should be opposed.

Q52. Are there areas where improvements to transport connections are needed? What could be done to help improve connectivity in these areas?

There needs to be an extensive review of the area with
highways and transport revisions.

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 bypass scheme that would only incorporate cycling,
walking and scooters etc around the outskirts would
help with congestion issues on the overcrowded roads.

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? [Please note you may wish to comment on the use of specific areas of land in the next section]

Green belt and farmland / agricultural sites must be
protected. Rural and village life must also be
safeguarded.

Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities? [Please stare reasoning]

There should be support for the requirement of
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

Q56.
a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing? [Please state reasoning]

N/A

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?

N/A

How could that improve the completeness of Rayleigh?

N/A

i. Housing [market, affordable, specialist, traveller, other]

N/A

ii. Commercial [offices, industrial, retail, other]

N/A

iii. Community infrastructure [open space, education, healthcare, allotments, other]

N/A

iv. Other

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

N/A

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

N/A

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?

N/A

Q57.
a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]

Hawkwell Parish shares the Ashingdon Road with both
Ashingdon and Rochford Parish so any development
has an impact on East Hawkwell, which is not
mentioned in the consultation. Development not only
affects our Primary Schools and Doctors Surgeries but
also the road network. The proposed sites (some 5,000
properties) accessing onto Brays Lane leading onto the
Ashingdon Road and Rectory Road, onwards to Cherry
Orchard Way plus developments proposed in West
Hawkwell (some 1,280 properties) would lead to the
majority of the total development being concentrated
in this part of the District and would result in complete
urbanisation.

b. 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?

Council’s preferred Option 3a would alleviate the
pressure on the villages of Hockley, Hawkwell,
Ashingdon and Rochford.

i. Housing [market, affordable, specialist, traveller, other]

N/A

ii. Commercial [offices, industrial, retail, other]

N/A

iii. Community infrastructure [open space, education, healthcare, allotments, other]

N/A

iv. Other

N/A

c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]

N/A

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

N/A

e. 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]

N/A

Q58.
a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing? [Please state reasoning]

The vision “In 2050, Hockley and Hawkwell should be
the District's gateway to the green lung of the Upper
Roach Valley, making the most of its access to ancient
woodland and a network of nature reserves. Its town
and neighbourhood centres should be vibrant places
with an emphasis on independent businesses and
providing for a diverse range of jobs. Deprivation should
continue to be largely absent from Hockley and
Hawkwell however housing affordability should have
been addressed to ensure that local first-time buyers
can greater afford to live locally.”
Firstly, it will not be a green lung if houses are built
within it. To be the ‘gateway to the green lung’, it
needs to be protected. Some of the proposed areas for
Hockley & Hawkwell contain ancient woodland. A
gateway also presumes by its nature that throughfare
of traffic is required, which could be interpreted as
traffic problems.
Also, Hockley has a village centre whereas Hawkwell is
mainly residential and comprised of green spaces
rather than leisure/social facilities, except for Clements
Hall, so the term vibrant would only be appropriate for
Hockley. As answered in Questions 2 and 5, Council
believe that there should be separate visions for
Hockley and Hawkwell as they are very different.
We agree that: “deprivation should continue to be
largely absent from Hockley and Hawkwell however
housing affordability should have been addressed to
ensure that local first-time buyers can greater afford to
live locally.”

b. 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

Most of the sites listed for Hockley & Hawkwell are
marked as severe/mildly severe harm when it comes to
the green belt. There are also a number of sites that
contain ancient woodland.
Hawkwell & Hockley are already at capacity and
therefore would require infrastructure improvements
before even considering any further development. Any
sites that create traffic through Rochford, Hockley or
Hullbridge would be opposed, in particular those that
need to utilise Ashingdon Road, Spa Road & Lower
Road, and those that empty traffic onto the B1013, due
to already being over capacity.

c. Are there areas in Hockley and Hawkwell that
development should generally be presumed appropriate? Why these areas? [Please state reasoning]

No, we feel it is not possible to comment on any sites
regarding their suitability without the full infrastructure
delivery plan being provided beforehand.
No green belt sites would be appropriate.
Development should be on brownfield sites only.
If the land would be of no use to agriculture and that
infrastructure had current capacity to absorb the extra
homes/residents. This would need to be evidenced.

c. Are there areas in Hockley and Hawkwell that
development should generally be presumed appropriate? Why these areas? [Please state reasoning]

No, we feel it is not possible to comment on any sites
regarding their suitability without the full infrastructure
delivery plan being provided beforehand.
No green belt sites would be appropriate.
Development should be on brownfield sites only.
If the land would be of no use to agriculture and that
infrastructure had current capacity to absorb the extra
homes/residents. This would need to be evidenced.

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

Yes, green belt needs to be protected for biodiversity
reasons and agriculture sites must be protected, as one
of the consequences of climate change could mean we
would have to look at growing produce locally. Ancient
woodlands must not be touched as they are
irreplaceable. Any sites containing wildlife must also be
protected, even those that serve as a barrier from
human life to wildlife as this creates a safe zone and
habitat.

e. 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]

They would hold local and national significance, as they
are green spaces and therefore hold significance,
especially in mitigating the effects of climate change.

Q59.
a. Do you agree with our vision for the Wakerings and Barling? Is there anything QUESTIONS you feel is missing? [Please state reasoning]

N/A

b. 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

N/A

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

N/A

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

Q60.
a. Do you agree with our vision for Hullbridge? Is there anything you feel is missing? [Please state reasoning]

N/A

b. 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

N/A

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

N/A

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

N/A

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]

N/A

Q61.
a. Do you agree with our vision for Canewdon? Is there anything you feel is QUESTIONS missing? [Please state reasoning]

N/A

b. 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

N/A

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

N/A

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

N/A

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]

N/A

Q62.
a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing? [Please state reasoning]

N/A

b. 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?
N/A

i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other

N/A

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

N/A

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

N/A

e. 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

Q63.
a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state reasoning]

N/A

b. 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

N/A

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]

N/A

e. 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

Q64.
a. Do you agree with our vision for Paglesham? Is there anything you feel is missing? [Please state reasoning]

N/A

b. 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

N/A

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

N/A

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

N/A

e. 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]

N/A

Q65.
a. Do you agree with our vision for Sutton and
Stonebridge? Is there anything you feel is missing? [Please state reasoning]

N/A

b. 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

N/A

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

N/A

e. 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]

N/A

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

N/A

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

N/A

INTRODUCTION
1.1 These representations have been prepared by Pegasus Group on behalf of Taylor Wimpey Strategic Land 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 Taylor Wimpey’s interests at:
• Site Reference CFS074: Land South of Mount Bovers Lane, Hawkwell

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 and reaffirm the deliverability (suitability, availability and viability) 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 Mount Bovers Lane, Hawkwell, for residential development in the emerging Local Plan.

1.4 These representations build upon and should be read in conjunction with Taylor Wimpey’s previous representations to the Rochford Local Plan-making process, which included high-level technical assessments and an Illustrative Framework Plan. These early representations explained the opportunities available at the above site to deliver 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 in respect of Taylor Wimpey's interests in Rochford.

Question 1: 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 agreed as being required to inform the preparation of a sound Local Plan
capable of effectively addressing local housing need. It is important to ensure the evidence is prepared under a robust and appropriate methodology and is subject
to scrutiny.

2.3 It is noted that the list of evidence includes a Settlement Role and Hierarchy Study (2021); this document is also referenced elsewhere within the Spatial Options document. However, this document is not available on either the consultation webpage or on the full evidence base webpage. This document should be made available for public review and Taylor Wimpey reserves the right to comment further once this document has been made available.

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?

2.4 The strategic objectives identified by the Council are agreed as being broadly logical and suitable for guiding the formulation of strategic policies within the emerging
Local Plan. As will be explored later in these representations, Taylor Wimpey will be able to contribute towards achieving the objectives relevant to residential
development. In particular, Strategic Objective 1 (to deliver sufficient, high quality and sustainable homes to meet local community needs) and Strategic Objective 2
(to plan for the mix of homes needed to support RDC’s current and future residents) will be met through the delivery of a wide range of new open market and affordable homes. It is agreed that the delivery of new homes should be assigned great importance, as the new housing will help to meet existing housing need, improve
housing affordability for all and aid in meeting the economic objectives of achieving new business growth.

2.5 Taylor Wimpey support the reference in Strategic Objective 1 to the need to prioritise the development of previously developed land. However, it should also be
acknowledged that sufficient brownfield sites are not available to meet the District's minimum housing needs in full, as stated in the Spatial Options document and
supported by the RDC Urban Capacity Study (2020). It should be referenced that the National Planning Policy Framework (NPPF, 2021) allows for changes to Green
Belt boundaries through the Local Plan-making process where exceptional circumstances exist (paragraph 140) and where this promotes sustainable patterns of development (paragraph 142). In a district where approximately 70% of the land is Green Belt, some release of Green Belt land may be necessary in appropriate locations to achieve sustainable patterns of development in line with the NPPF.

Question 5: Do you agree with the settlement hierarchy
presented? If not, what changes do you think are required?

2.6 As mentioned in answer to Question 1, the Settlement Role and Hierarchy Study (2021) does not appear to have been made available on the Council's website at the time of writing. Our answer to Question 5 is therefore given without a review of this document, which forms an important part of the evidence base in relation to the specific matter of the settlement hierarchy. The adopted Core Strategy categorises Hockley (including Hawkwell) as a Tier 1 settlement, alongside
Rochford and Rayleigh. The proposed separation of Rayleigh into Tier 1 by itself does not necessarily mean Hockley (including Hawkwell) is not as sustainable. It
cannot be stated at this time whether the settlement hierarchy has been derived using a robust and objective process until the Settlement Role and Hierarchy Study
has been reviewed.

2.7 Notwithstanding the above, Taylor Wimpey considers the settlement hierarchy presented within the consultation document should identify the settlement of
Hockley (including Hawkwell) at or near the top of the settlement hierarchy (i.e. Tier 1 or 2) as per the adopted Core Strategy (2011). This would be commensurate
with the sustainability of this settlement in terms of the important services and facilities required to meet day-to-day needs that are available within accessible
distance for residents of this settlement. Hockley (including Hawkwell) is able to sustainably support additional growth, and its position within the settlement
hierarchy is agreed in that sense. However, the Local Plan process going forward should take care to appreciate that the sustainability of a settlement is not fixed; it can be bolstered as a result of new and additional development, which can help to support the provision of new services or support the vitality of existing services through an increase in use and custom.

Question 6: Which of the identified strategy options do you consider should be taken forward in the Plan?

2.8 Taylor Wimpey supports the aim of the Council to ensure sufficient growth takes place over the local plan period to meet local housing need requirements as based on the use of the standard method to calculate the minimum housing needs for the District in line with paragraph 61 of the NPPF (2021). The Spatial Options document identifies a housing requirement of 7,200 homes (between 2020 – 2040) based on the standard method (i.e. 360 dwellings per annum).

2.9 Moreover, the consultation identifies a potential growth option of up to 10,800 new homes (2020 – 2040), representing the Standard Methodology + 50% which could help drive local economic growth or address unmet needs from elsewhere.

2.10 Taylor Wimpey strongly supports the Council's ambition to explore the opportunity to accommodate additional growth above that required by the standard method, to take on unmet need from neighbouring authorities in accordance with the NPPF requirement for Local Plans to be positively prepared. The neighbouring authorities are highly constrained both geographically and spatially, such as through large areas of Green Belt and areas of high flood risk. In general, the neighbouring
authorities have faced significant challenges in delivering sufficient levels of housing to meet identified housing needs. Southend-on-Sea to the south of Rochford District is particularly constrained with tight boundaries leaving limited available space for new development. Southend has a minimum housing requirement using the Standard Methodology of 1,180 new homes per annum and highlighted within their recent Local Plan Reg 18 consultation (2019) that even with Green Belt release, Southend will only be able to deliver around 20,000 new homes and that to meet their full requirements, neighbouring authorities such as Rochford will need to assist in the delivery of the additional 3,620 dwellings in the period 2020-2040. Rochford District will therefore need to make all possible efforts to accommodate housing above the levels required by the standard method to encourage economic growth and/or meet unmet needs arising from neighbouring authorities, acknowledging that this is a minimum requirement in light of the national priority to significantly boost the supply of housing in line with paragraph 60 of the NPPF. This will ensure the Local Plan is capable of meeting both Rochford District's needs as well as unmet need arising from Southend-on-Sea.

2.11 Taking the identified strategy options in turn. Option 1 (Urban Intensification) would not deliver a sufficient level of housing to meet identified needs, and it is
agreed that following this strategy would not result in a Local Plan being put forward that is sound in accordance with national policy. The strategy also relies too heavily
on committed developments and there is a risk that these developments will not deliver the expected levels of housing during the Plan period, with significant adverse social and economic impacts on the District as a result.

2.12 Option 3 (Concentrated Growth) is also not supported. It is considered that pursuing a growth option that focuses solely on the three towns Rayleigh, Southend and Rochford, would not lead to a sustainable level of growth. The Plan should seek to meet the needs of residents across the entire District; existing residents are likely to want to buy a home close to their existing ties to the local community and family. New growth should therefore be sensibly dispersed across the District to all settlements. Furthermore, Option 3 would lead to a high reliance on a few key strategic sites. Such large scale sites are likely to have slow rates of delivery; this
would make it difficult to meet the local housing requirement and maintain the rolling 5-year supply of housing required by paragraph 68 of the NPPF. Strategic
sites may also be subject to other risks to delivery, such as viability if the sites are also required to fund pieces of strategic infrastructure. In addition to delivery, this may also affect the level of affordable housing such strategic sites are able to deliver.

2.13 Option 2 (Urban Extensions) is strongly supported as it presents a strategy that would allow for sustainable growth to take place across the District, including the
organic growth of smaller settlements. This would allow the delivery of the Districts local housing needs as required by national policy for a sound Local Plan to be
adopted. The delivery of housing to meet local need would ensure the exceptional circumstances required for the release of land from the Green Belt could be met. It
is considered reasonable to disperse growth to all settlements as guided by the settlement hierarchy. This would ensure growth takes place in the towns and large
settlements that have the services and facilities needed to sustainably support a higher level of growth, while also ensuring smaller rural settlements can organically
grow in the manner required to sustain the vitality of the villages and meet the housing needs of local residents.

2.14 Taylor Wimpey is also in broad support of Option 4 (Balanced Combination) which combines elements of the above three options. A balanced combination of all
options would negate the negative outcomes of Option 1 not delivering sufficient levels of housing growth, as well as the risks associated with Option 3's reliance on a few key strategic sites. It would still allow for sustainable growth to take place in a dispersed manner across the District. It would however be key to get the balance
between the different options correct. It may be that under option 4, there is a need to ensure sufficient smaller urban extensions are allocated so they can be
brought forward early in the plan period to ensure there is no heavy reliance on the delivery of large strategic sites – as there are still risks associated with under-
delivery on large sites. A balanced approach to allocating a variety of sites both in terms of size and location will also have far greater potential to deliver a wide mix
of housing types and styles.

Question 9: Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

2.15 In answer to the first part of question 9, Taylor Wimpey agrees that a sequential approach needs to be applied in allocating sites, as required paragraph 161 of the NPPF. This should be recognised as placing a further constraint on potential suitable land available for development and further necessitating the release of suitable Green Belt to ensure sustainable development can take place.

Question 11: 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?

2.16 Taylor Wimpey fully supports the transition towards a zero carbon economy and for new development to be as sustainable as possible, which includes new homes
that are energy efficient and minimise carbon emissions. Taylor Wimpey is committed to being a sustainable housebuilder and continues to incorporate sustainability into their business practices, helping to create better homes and communities and a stronger business for the longer term.

2.17 It should be recognised in the emerging Local Plan that before thinking about how 'green' the energy used is, it should first be considered how energy use itself can
be minimised. This includes ensuring the construction of homes is undertaken in a manner that allows the effective retention/insultation of heat in the winter and
natural cooling in the summer, ensuring less energy is required to heat the home and take a fabric first approach in the design of houses to further improve energy efficiency. All of these measures are secured under the relevant Building Regulations, an uplift to which will be secured through the implementation of the
forthcoming Future Buildings Standards.

2.18 The need to require development to source a percentage of their energy requirement from low-carbon and renewable sources should be assessed against
the above energy efficiency requirements. The actual percentage should also be calculated with regard to potential impacts on the viability of future developments,
and the financial costs for implementation will need to be considered in the Local Plan Viability studies.

Question 12: Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?

2.19 As explained above, the forthcoming new Building Regulations, which all development will be required to comply with, will ensure that all new homes that are built in the future will be built to a high energy efficiency standard. There is considered to be no beneficial need to require energy efficiency standards above those required by the new Building Regulations which will be in place upon adoption of the Local Plan. If the Council is to consider applying higher energy efficiency standards, robust evidence will be required supporting such a requirement. The evidence should include an assessment demonstrating no adverse impact on the
viability of future proposed developments.

Question 14. 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?

Question 15: Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?

2.20 In answer to question 14, Taylor Wimpey has no objections with a District-wide place-making charter that can form the basis for site-specific decision making. The
importance of good design in creating attractive and liveable places is wellunderstood. The place-making charter should clearly appreciate that each site is
unique, with different contexts, constraints and opportunities that will need to be taken into account.

2.21 However, it is not entirely clear what policy position such a charter would hold in the Local Plan and the level of consideration the decision maker will need to give
to the character. Thus, in answer to Question 15, it should be made clear how the charter should be read in relation to specific policies. Then it would be relevant to
consider what principles are appropriate to contain in a charter. At this stage, it is considered that any charter included as guidance should be high-level and
overarching, with specific detail to be provided in the accompanying development management policies. This will avoid the duplication of local planning policies, as
encouraged by paragraph 15 of the NPPF. The local plan policies themselves will need to consistent with the relevant provisions of the NPPF and national guidance.

Question 16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
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?
Question 16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?

2.22 The need to produce design guides, codes or masterplans alongside the new Local Plan is questioned. The production of such documents is likely to take considerable time, particularly if the Council intends to seek to adopt or endorse a design document for each proposed allocation. This would inevitably delay the Local Plan process and delivery of new homes as the Council's resources are drawn away.

2.23 Instead, Taylor Wimpey suggests that design codes or masterplans should only be encouraged at such an early stage for large strategic urban extensions that are of a scale and mix of land uses where a design code document would be helpful in regularising design principles across the entire site and/or ensuring a coordinated approach to the delivery of strategic allocations where multiple landownerships/interests are present.

2.24 For smaller scale extensions and developments (i.e. single ownership developments of <500 dwellings), it is considered that the masterplans and other design material that is submitted at the planning application stage, which may include Design Codes prepared by the Applicant in consultation with RDC and the local community at the Planning Application stage, would be sufficient for allowing the Council to provide input and ensure the correct design principles are being delivered.

Question 17. 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?

2.25 Taylor Wimpey considers that proposed Option 2 would provide a suitable approach to address the District’s housing need. This option would allow an element of certainty that overall housing needs will be met, while also allowing flexibility for local site-specific factors to influence the housing mix a development provides at the application stage. These factors could range from site-specific environmental or technical constraints and opportunities to local market intelligence and demographics indicating a need for certain types and tenures of housing. Option 2 would align with the NPPFs objective of creating strong, vibrant and healthy
communities (paragraph 8) that are mixed and well-balanced (paragraph 63).

2.26 However, it is considered that Option 3 would also operate well in conjunction with Option 2. Allocating specific sites for specialist housing for older people and selfbuild and custom-build housing in particular would allow the housing need to be addressed where it is most needed, which is in line with the recommendations of
the Planning Practice Guidance.

2.27 Taylor Wimpey further support Option 5 which requires all homes to be built to Nationally Described Space Standards, Option 6 requiring all homes to meet Part M4(2) (accessible and adaptable homes), and Option 7 requiring a suitable proportion of new homes to meet Part M4(3) (wheelchair user dwellings). However,
as is required by the NPPF (footnote 49) and supporting national guidance, these options will require sufficient evidence to be gathered and provided by the Council
to support the need for these requirements, and whether it is appropriate for all homes to meet these requirements rather than a proportion of new homes. As footnote 49 states, the Council will need to demonstrate through robust evidence that there is an identified need that would be met through the application of the Part M4(2) and Part M4(3) optional standards. The need to apply the internal space standards must also be justified. The Planning Practice Guidance expands on this to explain that the evidence produced must also take into consideration viability and site-specific factors in addition to need, ensuring that the application of these additional standards does not risk the delivery of new homes.

Question 31. 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?

2.28 Taylor Wimpey considers it is for the Council to undertake research and identify a suitable pipeline of sites towards which off-site biodiversity net gain contributions could be made. Biodiversity net gain should be delivered on-site wherever possible; however the possibility of off-site net gains should not be discounted for developments that are constrained geographically or by viability or other factors. Taylor Wimpey is committed to protecting and enhancing the biodiversity of its sites wherever possible.

2.29 Taylor Wimpey recognises that climate change, declining nature and other environmental problems are increasingly becoming a threat to the wellbeing of
people today and future generations. In respect of Land south of Mount Bovers Lane, Hawkwell (CFS074), Taylor Wimpey has commissioned an initial Phase 1 ecology survey and assessment (Appendix A) which demonstrates the potential for a measurable biodiversity net-gain to be delivered on the site through habitat
creation and restoration. Developments which can demonstrate Biodiversity Net Gain should be looked upon favourably by RDC both when allocating sites within
the emerging Local Plan and when determining schemes at Planning Application stage.

Question 34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?

2.30 In respect of Option 3 which requires new developments to provide on-site green and blue infrastructure, and/or contribute towards off-site green and blue infrastructure. Taylor Wimpey supports the provision of such local infrastructure, which can help to mitigate the impacts of flooding and contribute towards creating and improving wildlife habitats and enhancing the character and appearance of newdevelopment.

2.31 Land south of Mount Bovers Lane, Hawkwell (CFS074), is capable of contributingtowards the objective of creating enhanced local green infrastructure. As indicated on the Illustrative Landscape and Ecological Masterplan (Figure 9, Appendix B) the site has the potential to enhance the existing vegetation on the site through new planting such as shrubs, wildflower grassland and hedgerow. The landscape proposals also provide a new community orchard, new woodland planting and tree lined streets. These improvements to green infrastructure would help deliver the objectives of the South Essex Green and Blue Infrastructure Strategy, in particular the creation of the Central Woodlands Arc Regional Parkland and enhancements to the Upper Roach Valley to create a successful ‘green lung’ through the District.

Figure 1: Illustrative Landscape and Ecological Masterplan
[see document for image]

2.32 This local green infrastructure would enhance existing biodiversity, create an attractive landscaped setting for the new homes and enhance the leisure
opportunities available for both new and existing residents in Hawkwell, thereby delivering wider health and well-being benefits also. The site provides opportunities for links to be provided to the existing Public Rights of Way network located on the site boundaries, which will improve permeability and ease with which access can be gained to the wider countryside.

2.33 In terms of blue infrastructure, the submitted information further indicatively shows that the scheme has the potential to provide a network of ponds or swales that could create a new 'blue' corridor within the open space to the west. These ponds would complement the SuDS basins that will be provided within the developable,
eastern part of the site to deliver additional benefits. The blue infrastructure would help to mitigate the risk of flooding by assisting with the flow of water away from
homes, as well as provide ecological enhancements and assist in creating a naturalistic open space area to be enjoyed by residents.

2.34 It is noted that Option 3 states 'certain new developments' will be required to provide or contribute towards local green and blue infrastructure projects. As this objective is developed into a policy, it will be important to ensure that the threshold where Option 3 will apply to developments is made clear.

Question 35. 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?
Question 36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?

2.35 Taylor Wimpey supports in principle the options that are suggested for meeting community infrastructure needs through the Local Plan. The options should be
maintained as being non-exclusive, so flexibility can be maintained to allow infrastructure needs to be met in the most appropriate manner for each settlement and site location.

2.36 The infrastructure that will be required to support the delivery of Taylor Wimpey's interests in Hawkwell will be set out in further detail in the Infrastructure Delivery
and Funding Plan that is to be prepared by the Council. However, Taylor Wimpey is committed to investing in complementary infrastructure that is evidentially
required to support the delivery of new homes at this location. It is noted that
Hockley (including Hawkwell) is a sustainable settlement containing many of the services and facilities required to support the day-to-day needs of residents.
Contributions could be made towards this existing infrastructure as required to ensure sufficient capacity exists for the services to continue supporting existing and
new residents. The site also has the potential to provide new community infrastructure, such as land for education and/or healthcare which will complement existing facilities, subject to viability and clear evidence that additional infrastructure is required.

Question 38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
Question 41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?

2.37 The proposed Option 4 is of direct relevance to Taylor Wimpey in this instance, as it suggests requiring new developments to provide new open space or contribute towards enhancing existing infrastructure. Taylor Wimpey fully supports the objective of ensuring the open space and recreation needs of residents are met.

2.38 As illustrated on the submitted Development Framework Plan (Appendix C), the masterplanning for the site has been heavily influenced by the landscape strategy. This strategy seeks to maintain and enhance existing green infrastructure as explained in our response to Question 34 above. Nearly 50% of the site area is to
be maintained as green infrastructure and public open space, significantly above planning policy requirements. This will have the dual benefit of creating a defensible
boundary with the Green Belt, and creating new public open space to be enjoyed by all members of the local community, delivering enhanced opportunities for
recreation and social interaction, alongside the health and well-being benefits this brings.

2.39 In addition to the amenity green space that can be enjoyed for both leisure and activity, circular footpaths will be provided around the open space to encourage
walking within and through the open space. New woodland and orchard planting will provide visual amenity within the open space, as will the 'blue corridor' of ponds or swales. Formal play areas will be provided in accessible locations within the scheme, that will be open for use by all residents both new and existing. This will
therefore help to increase access to play space for residents of Hockley (including Hawkwell) in the vicinity of site CFS074. The objectives put forward by the Council are supported by Taylor Wimpey as contributing towards meeting the requirement in the NPPF (paragraph 92) for healthy places with accessible green infrastructure.

Question 46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant?

2.40 Taylor Wimpey supports the objective of ensuring the continued vibrancy of the District's town and neighbourhood centres, including those at Hockley and
Hawkwell. We do not seek to provide an opinion on how the Council can best plan to achieve this objective, however it is considered important to understand that
new growth is required if vibrancy and vitality is to be maintained. This will bring new custom for existing businesses in centres, and provide opportunities for new
business to come forward.

Question 51. 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?

2.41 Taylor Wimpey considers the options presented are logical approaches to explore further towards the goal of improving connectivity within the District. Option 2 is
relevant to Land South of Mount Bovers Lane, Hawkwell, and Taylor Wimpey would support appropriate contributions that are evidenced by a robust Infrastructure Delivery Plan as being required to support the development.

2.42 It is to be noted however that Land south of Mount Bovers Lane (CFS074) is located in a sustainable location that benefits from convenient access to local services and facilities via various modes of sustainable travel. This is demonstrated in the Sustainability Appraisal which accompanies these representations (Appendix D).

2.43 There are pedestrian and cycling routes leading towards the centre of Hawkwell where several services are located within comfortable walking or cycling distance of the site. This would reduce the reliance on day-to-day travel by private car. For locations further afield, travel by bus and train is available from bus stops adjacent to the site and Hockley train station located around 20 minutes' walk from the site. Both modes of public transport receive frequent services.

Question 58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing?

2.44 The vision statement presented is broadly supported and as highlighted above site CFS074 provides clear opportunities to contribute positively towards the green lung of the Upper Roach Valley through the provision of new woodland landscaping and
biodiversity net gain. Moreover, the aim to address housing affordability is fully supported, but will only be addressed through the provision of viable market
housing developments capable of delivering Affordable Housing.

Question 58b. 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

2.45 As mentioned in answer to Question 6, Taylor Wimpey supports following a strategy that allows growth in all settlements across the District, including Hockley and Hawkwell, at a level that is appropriate to the sustainability of each settlement. Hockley and Hawkwell is identified within the adopted Core Strategy (2011) as a
Tier 1 settlement, and the current Spatial Options Document proposes Hockley (including Hawkwell) as a Tier 2 settlement below only Rayleigh. This is
commensurate with the settlement being one of the most sustainable in the District, and its ability to support additional housing. It is clear that Hockley and
Hawkwell are eminently sustainable, as illustrated on Figure 43 which shows that residents are within walking distances of the range of services and facilities that
are available.
[see attached document for image]

2.46 For this site in particular, the following range of services and facilities are located close to the site, as further expanded within the accompanying Sustainability
Appraisal (Appendix D):
[see attached document for table showing accessibility from site to key destinations and facilities]

2.47 Hockley Train Station is also located just 1.5km / 20-minutes walking distance to the north.

2.48 Hockley, which is in close proximity to the site, supports a further range of local retail and employment opportunities.

2.49 On this basis, Taylor Wimpey strongly supports the 'allocation' of site reference CFS074 for up to 400 new homes and significant green infrastructure as illustrated
below. The site is also capable of contributing towards appropriate on-site or offsite social / physical infrastructure if further evidence demonstrates a need for such infrastructure.
[see attached document for masterplan of site]

Site Deliverability
2.50 The suitability and benefits of this site have been comprehensively presented in previous submissions to the Local Plan-making process, including in
representations to the Regulation 18 Issues and Options Consultation in 2018. This submission was accompanied by technical input and Taylor Wimpey are committed
to working collaboratively with the Council to ensure the timely delivery of the proposed allocation. The following seeks to further reiterate the deliverability and
suitability of the site for residential development in response to the 'scoring' of the site in the RDC Site Appraisal Paper (2021) as presented below. The scores given follow a scale as replicated in the figure below
[see attached document for screenshot of site appraisal criteria]

Drainage
[see attached document for screenshot of site appraisal scores]
2.51 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, and the score of 5 (best performing) is agreed with.

2.52 The score of 2 for 'critical drainage risk' appears to have been informed by a highlevel view of the surface water flood risk for the site. Mapping on the Environment
Agency long term flood risk website illustrates that the central valley of the site is associated with low to medium risk of flooding from surface water, with some areas
on the eastern boundary and areas within the western half of the site being associated with low to high risk of flooding from surface water.
[see attached document for screenshot on EA surface flood risk map]

2.53 However, 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 Illustrative Landscape and Ecological Masterplan (Appendix B) illustrates how the
matter of surface water flood risk can be mitigated, through the inclusion of SuDS basins and swales through the centre of the site where the valley is located. The
location and design of the basins and swales 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.

Green Belt and Landscape Impact
[see attached document for screenshot of site appraisal criteria]

2.54 The site is located within the Green Belt, albeit being directly adjacent to the existing settlement edge of Hawkwell. It is acknowledged that the Green Belt
designation carries significant weight as a material consideration, with the NPPF being clear that Green Belt boundaries should only be altered in exceptional
circumstances (paragraph 140). The site is also located within the Upper Roach Valley Landscape character area which seeks to protect a ‘green lung’ and landscapes of value (noting it also aims to promote recreation).

2.55 As explored earlier, Rochford District is highly constrained with limited opportunities to accommodate sufficient levels of growth outside the Green Belt.
The evidence base produced by the Council indicates there are not sufficient nonGreen Belt sites available to meet local housing needs. The Urban Capacity Study
(2020) found that urban sites may deliver between 3,300 and 5,000 sites over 10-
15 years. The Council has identified the need for a minimum of 7,200 new homes to be delivered over the Local Plan period, and at least 10,800 homes when a buffer is applied and the potential to accommodate unmet need from neighbouring authorities is taken into account, as Taylor Wimpey considers is required.
Furthermore, the most sustainable sites that are going to be available for potential allocation and development will be within the Green Belt, as the settlements identified in the settlement hierarchy as being the most sustainable and capable of accommodating new growth lie within the Metropolitan Green Belt.

2.56 There will be harm associated with the release of Green Belt land. However, the inherent shortfall in brownfield land available for development and the ability of Green Belt land to delivery sustainable patterns of development provides, in our view, the exceptional circumstances required to amend the Green Belt boundary.
The Green Belt Study (2020) prepared by the Council concludes (the Stage 1 Assessment) by stating at paragraph 3.39 that other than a few pockets of Green
Belt, the majority of the assessed land continues to serve the Green Belt purposes well.

2.57 It is noted here that our 2018 submissions included an independent Green Belt Assessment of the site which concluded that the site makes limited or no contribution to four of the Green Belt purposes, except for purpose 3 'safeguarding the countryside from encroachment' to which it was considered a partial contribution is made. Taylor Wimpey considers this appraisal remains valid and the value of this site to the Green Belt is limited and that any harm arising from its removal from the Green Belt would also be limited.

2.58 Notwithstanding this, paragraph 3.39 of the Green Belt Study (2020) does go on to state that the most sustainable sites for potential allocation may be located in areas that make a strong contribution to the Green Belt purposes. The contribution that a site makes must therefore be weighed against other relevant factors that
determine the suitability of a site for development, such as the existence (or lack thereof) of site-specific constraints, proximity to sustainable settlements and
transport connectivity.

2.59 A Landscape and Visual Appraisal, including Green Belt Appraisal (Appendix B), has been prepared to accompany these representations. The report considers the landscape and visual constraints the site is subject to, based on the potential impacts arising from the proposed development. This appraisal has in turn informed the creation of an Illustrative Landscape Masterplan, which demonstrates that a residential scheme that is led by robust landscape principles can be created that will be 'physically contained and have clear defensible boundaries', as well as make 'a positive contribution to the recreational aspects of the landscape in respect of the Upper Roach Valley.' A significant area of open space is proposed on the western half of the site (far in excess of policy requirements) which will further
contain the built form to remain in line with the existing extension of the settlement edge into the landscape.

2.60 With the implementation of the proposed landscape strategy, which will be formulated further as detailed design takes place, to create an appropriately designed residential scheme, the Appraisal demonstrates that the site would have only limited landscape and visual effects at a localised level and that such impacts can successfully be avoided or reduced through appropriate mitigation. The proposed inclusion of substantially improved areas of local green and blue infrastructure in addition to open greenspace will also allow the creation of a defensible Green Belt boundary, limiting the risk of additional 'sprawl' as well as creating an appropriate interface between the settlement edge and the wider
countryside.

2.61 Consequently, development of site CFS074 would complement the character of the wider landscape context and enhance the function of the Upper Roach Valley's as
a 'green lung' through the District. Any limited impacts can be mitigated and enhanced through the proposed landscaping strategy, with recreational benefits
arising from the proposed green infrastructure which will provide new health and wellbeing outcomes for existing and future residents of Hawkwell. An appropriate,
robust and enduring boundary to the Green Belt can therefore be created.

2.62 As such, the low scores given on Green Belt and Landscape Impact by the RDC Site Appraisal are challenged for the reasons set out above and should not preclude consideration of the site for allocation. Notwithstanding this, the discussion on other factors in answer to question 58b clearly demonstrates the suitability and sustainability of the site; this must be weighed against the potential harm caused to the Green Belt and in our opinion provides sufficient reason for further consideration of this site in later Local Plan stages.

Biodiversity
[see attached document for screenshot of site appraisal criteria]
2.63 Taylor Wimpey supports the scores given to the site relating to biodiversity. A Preliminary Ecological Appraisal has been undertaken which confirms that that the site is of limited ecological interest.

2.64 The proposed strategy set out in the Illustrative Landscape and Ecology Masterplan would therefore have the benefit of providing a measurable improvement of habitat and biodiversity net gain on the site.

2.65 The site itself is not covered by any statutory habitat designations. However, the site is located close to the Hockley Woods SSSI which is a nationally designated
ancient woodland. While development of the site would not result in any direct impacts on the SSSI, there is the potential for indirect impacts through additional
recreational pressure resulting from new residents. The site proposes to provide a significant amount of greenspace on the site, which will effectively mitigate the
recreational pressure that might otherwise be generated on surrounding environmental designations.

Heritage
[see attached document for screenshot of site appraisal criteria]
2.66 The scores relating to heritage are not considered to be accurate. A Heritage Statement has been prepared (Appendix E) which contains an assessment of potential impacts arising from the proposed development on the historic environment. In terms of archaeology, a review of the available recorded data indicates that there are unlikely to be any below ground remains which are of
historical interest. The potential for significant archaeological remains from any historical period is considered to be low. The score relating to impact on
archaeology should therefore be a 5 (i.e. best performing), as any potential impacts can be comfortably mitigated by way of a planning condition at the planning
application stage, which would control development of the site until the desktop findings have been confirmed through further investigation.

2.67 In terms of built heritage, there are a few Grade II listed buildings in the vicinity of the site but only two that may be impacted by the proposed development. The
Grade II listed Sweynes Farmhouse is located north-east of the site, however it is considered the site does not contribute to the significance of this asset and is not
a constraint to development of the site. The Grade II listed Mount Bovers is located to the west and a small part of the site was historically associated with the function of the heritage asset. To preserve the significance of the listed building, it is therefore proposed that a setback is maintained in the western part of the site, with an associated enhancement of vegetation on the north-western boundaries. As the emerging masterplan for this site proposes the retention of the entirety of the western half of the site as open greenspace with significant new planting, this setback will be comfortably provided for and maintained and it is considered that there will be no impact on this designated heritage asset. The score relating to built
heritage should therefore be at least a 4 (better performing).

Sustainability
[see attached document for screenshot of site appraisal criteria]
2.68 The scores relating to the sustainability of the site are broadly agreed with, although a Sustainability Appraisal (Appendix D) has been prepared which refutes
the scores given on some elements, as will be explored below.

2.69 The existing bus stops are located close to the site boundary on Main Road and Hall Road, at most around 10 minutes' walk for homes located furthest from the Hall
Road bus stop – with most homes being located at a much closer distance. Given the close proximity and convenient access to bus stops the score should be a 5
(best performing).

2.70 Similarly, the score for access to bus services is currently too low and should be at least a 4 (moderate positive). The no.8 bus service provides a regular and frequent service (every 30 minutes) on a weekday, allowing convenient access towards Hockley Town Centre, Rayleigh, Southend-on-Sea and Great Wakering. This bus service provision also means the score for access to town centre should be at least a 4 (moderate positive) rather than 1 (negative), as Hockley town centre is very accessible from the site, if not by bus then also by walking and/or cycling.

2.71 Other bus services are also available, and whilst less frequent they provide travel options to other settlements. There are bus shelters available for 3 of the 4 closest bus stops to the site, with the potential for improvements to be made to encourage use of the bus services.

2.72 The bus services available include providing travel to Hockley train station, which is otherwise around 20 minutes' walk from the site. This is considered to offer good access, making travel by train to settlements further afield or for commuting a feasible option. Indeed, the station provides frequent and regular trains towards
Southend Victoria and London Liverpool Street. The score for access to train services should be at least a 5 (positive).

2.73 The score of a 5 for access to walking infrastructure is strongly supported; the site is extremely well-connected and as the evidence within the Spatial Options Document illustrates there are plenty of opportunities to walk to everyday services and facilities within Hawkwell or even to Hockley centre. The footways are of a good quality and attractive, being safe and traversable. The score of 3 (moderately performing) for cycling is accepted, as while the roads in the vicinity of the site are suitable for cycling to local facilities, there is no formal infrastructure that can be utilised to encourage cyclists with less confidence.

2.74 The relevance of the scoring for access to the strategic road network is not clear. The A127 and A130 are accessible from the site, and are of a similar distance from the current site as they are from elsewhere in the district. The sustainability of the site lessens the reliance on the strategic road network. Furthermore, this is a
residential scheme where trips for day-to-day needs will be made locally – the SRN is not as significant as it would be for an employment scheme.

2.75 Turning to the scores given for access to facilities such as primary school, healthcare and any other centre (in this instance Hockley centre). The scores given are broadly agreed with as they acknowledge the sustainability of the site given the close proximity of these services. It should be acknowledged however that
certain services within Hockley centre such as the Co-Op (Supermarket), Pharmacy and Post Office are very close to the site (around 10 minutes' walk) and could
therefore be given a score of 5 (best performing). Similarly, the Practice Hawkwell (health centre) is also around a 10-15 minutes' walk from the site and could also be given a score of 5 (best performing) rather than a 4 (moderate positive).

2.76 With respect to the secondary school, the closest is Greensward Academy which is up to 30 minutes' walk or 10 minutes' cycle from the site. However, the journey
can also be made by bus in around 11 minutes (not accounting for waiting time). This is considered to be relatively normal travel times for a secondary school, where journeys are made independently by older children by bike, bus or walking. The score of 1 should therefore be at least a 4 (moderate positive) to reflect this.

2.77 Turning finally to employment, the score of 2 (moderate negative) is contested. Firstly, there has been a noticeable shift to homeworking which means there is less need for reliance to be placed on workers needing to be close to their place of employment. Nevertheless, there are employment sites located in the north of
Hockley within an accessible distance from the site and regular train services into London from Hockley Station as highlighted above, and this score should therefore
be upgraded to 4 (moderate positive).

2.78 In summary, these representations expand upon previously made submissions to demonstrate that Land south of Mount Bovers Lane, Hawkwell, is capable of
delivering a residential development in a sustainable and accessible location. Exceptional circumstances exist for the Local Plan to release land from the Green Belt, and the evidence submitted demonstrates development of this site will not adversely harm the Green Belt and a sensitively designed landscape-led scheme will help to mitigate and enhance the local landscape and deliver biodiversity net gain, alongside recreational improvements and the associated health and wellbeing outcomes this brings for existing and future residents. The District, and Hockley (including Hawkwell) in particular, has a pressing housing need and
affordability issue, which the delivery of this site can contribute significantly towards addressing. The site is capable of being delivered in the early stages of the
new Local Plan period, and Taylor Wimpey is willing to collaborate closely with the Council to ensure this can be achieved.

Site Availability
2.79 The site remains under single ownership and comprises managed agricultural land on the southern edge of Hawkwell. There are no legal constraints to the availability of the land for development.

2.80 The landowner is willing to make the site available for development and the site is under option and being promoted by Taylor Wimpey, one of the UK’s largest housebuilders, through the emerging Local Plan in addition to engaging with local stakeholders as part of this process.

2.81 The expertise offered by Taylor Wimpey ensures that subject to the removal of the current Green Belt designation through the Local Plan-making process, that the site will be available for development immediately and capable of delivering new homes in the early part of the New Local Plan.

Site Viability
2.82 The site will be expected to contribute to the provision of infrastructure, through a variety of mechanisms, including Section 106 and Section 278 Agreements, Community Infrastructure Levy (CIL) and appropriate Planning Conditions, provided such conditions are necessary and relevant to the proposed development and also where Planning Obligations are:
i) Necessary to make the development acceptable in planning terms;
ii) Directly related to the development; and
iii) Fairly and reasonably related in scale and kind to the development.

2.83 The full Infrastructure requirements in relation to this site are as yet unknown but will be set out within RDC’s forthcoming ‘Infrastructure Delivery Plan’.

2.84 The site comprises managed agricultural land (i.e. Greenfield land) and accordingly, it is not anticipated that there will be any abnormal costs associated with the
development of this site as may be expected on previously developed (brownfield) land.

2.85 As such, and subject to further ongoing site investigations and review of RDC’s Infrastructure Delivery Plan, CIL, Local Plan Viability Assessments and emerging Planning Policy wording once finalised, which will provide further details with regards to likely infrastructure requirements arising from the development of the site, it is to be anticipated that the site will be capable of delivering the Council’s emerging policies, including with regards to Affordable Housing provision.

3. SUMMARY AND CONCLUSIONS
3.1 This representation has been submitted on behalf of Taylor Wimpey Strategic Land in support of their land interests at:
• Site Reference CFS074: Land south of Mount Bovers Lane, Hawkwell

3.2 The representations respond to the questions raised by the consultation to reaffirm the deliverability (suitability, availability and viability) of the above sites and set out the exceptional circumstances in support of a minor revision to the Green Belt. The representations support the taking forward of this site to create a site-specific policy that allocates the site for residential development in the emerging Local Plan to deliver a high-quality and sustainable residential development to contribute positively towards meeting the District’s significant housing needs.

3.3 Site CFS074 represents a deliverable site and Taylor Wimpey is keen to work collaboratively with RDC and local stakeholders in the preparation of the new Local
Plan to ensure a positive policy position for the site is taken forward to deliver real benefits for the local community and the District as a whole.

NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION PAPER: 2021

Rochford in 2021- District Profile p.12
Our Social Characteristics

Rochford expected to shift to higher age groups. Housing affordability is an important issue. "..economically active individuals likely to decrease..fewer residents between ages 18-70..".

This is due to :-

Sale of Council houses, by Government dictat in 1980s. Said homes were for 2 classes: 1. Families who could never afford own homes; 2. Families unable to afford initially, but with cheap rent, could ultimately save deposit to buy own home.

Developers don't want to build "affordable", but have built eg luxury flats and "executive" mansions bought by "nouveau riches", usually middle aged, whose children long grown up and moved on. Thus unwealthy economic age groups with their children had to move to more affordable districts, hence current and possibly future age imbalance.

Many homes have been demolished to accommodate above expensive dwelling dwellings. Wealthy Londoners have sold up and moved to eg Rochford District to buy similar for less.

Cultural Characteristics

Most of them noted in Rayleigh and Rochford. But there are listed and heritage building in Hockley and Hawkwell and Ashingdon. There are the 3 mediaeval churches also. Many heritage items in said area have been demolished to accommodate flats and expensive homes. an example was at 1 Southens Road, formerly Blacks Farm, earliest from 17th century, on Local List. Developer planned replacement with flats: a former official at Planning Policy said Government now "frowned on" Local List. (Other councils claimed no knowledge of said Government dictat and didn't plan to abolish their Local List.) Plan for 13 flats was refused but no mention made of the house, demolition of which was included in application. Once house was demolished, said officer said Government now approved of Local Lists. New List omits several Hockley items on the earlier one. Many Hockley area heritage items have gone same way.

Environmental Characteristics

As you say 40% of Rochford area is at flood threat and the coastline also. This would preclude the area so designated as unsuitable for further development. It is known that insurance companies refuse to include cover against flood risk for homes in flood risk areas.

Economic Characteristics

The 2 main rail lines from Southend to London, one passing through Rochford District, are helpful for commuter traffic to London and for cargo purposes. It is risky that some airlines have withdrawn from Southend Airport. The nuclear station at Bradwell could be more of a risk than asset. Present road connections have served well in the past, but are getting inadequate now and won't support extensive future development.

Draft Strategic Priorities/Objectives for 2050 p.21

Strategic Priority 1: Meeting need for homes/jobs in the area

This states need to meet community need, working with South Essex neighbours, using already developed land first.

But increasingly, Londoners eg are selling for high prices and getting similar or bigger, for less, down here - eg new development in Hall Road (former agricultural land).

South Essex neighbours - be careful how much of their housing number needs aren't pushed into Rochford District.

Prioritising use of previously developed land first. Example - so-called "garden grab" - homes not in Green Belt have been called "land". Where two or three are adjacent - they are grabbed for "executive" houses (mansions), or luxury flats, others finally forced to move for price needing mortgage to move, when they don't want anyway. Others not moving are punished with 'executive' (big) development may be south of them - impacting them, so they become unviable.

Strategic Objective 2

"affordability" - as elsewhere, council houses were sold off in 1980s under "Right to Buy". Developers don't want to do affordable - one told me that at a meeting. Those builders with large estates to develop (requiring a percentage 'affordable') try to evade the rules, perhaps saying more than one firm involved.

"ageing population" - care homes are costly, the old don't want them. If pressured, their homes are sold off to pay for them.

Strategic objective 4

"accelerated growth" - avoid over-substantial Area Action Plans threatening retail centres - with jobs and businesses then lost. Southend Airport may struggle to survive from impact of Covid.

Strategy Options

Hierarchy of Settlements

Re Fig.14, Hockley is equivalent to Hawkwell and Ashingdon - village. Rochford is a market town.

Growth scenarios

Before any substantial growth can occur, a new motorway would be needed for Rochford District to overcome inevitable inadequacies of eg. Southend, Main, Greennward, Ashingdon and other B and C roads, which is doubtful unless a new large settlement occurs in Green Belt for most new housing-? behind Rpchford, to cross River Crouch somewhere near Hullbridge - unlikely and probably not tolerated by staff or residents.

Masterplan for towns etc centres - eg Hockley Area Action Plan more than a decade ago, involving replacement of some existing and erecting large supermarket and may be major store (? Unneeded with on-line shopping). Plan would have involved loss of businesses, jobs. It was unacceptable to traders and residents - a more limited HAAP was agreed.

Significant new community facilities - schools, primary care. These have been promised by developers of large estates, who then found excuses for not doing.

Re 'Important Note' - I'm relieved proposals aren't decided. Much gone already.

Planning for housing growth

HELLA 2020 identifies supply of 4,300 homes planned for, including sites with planning permission. Unfortunately some such have been overcome by huge mansion developments adjacently.

Planning for economic and retail growth

Completed Area Action Plans have provided enough retail space.

Levels of growth needed to deliver infrastructure

Section 106 doesn't always work. As earlier, huge new estate in hall Road (for which farming land sacrificed) developer promised new primary school, GP surgery, then found reasons not to do, causing pressure on existing.

Spatial Strategy Options

1. Urban intensification

There is no available space in any centres near stations. First issue of HAAP proposed building on parking area near Hockley Station, which would have been a mistake and didn't happen. Any intensification done already has often sacrificed existing dwellings, sometimes of heritage character. Others would be threatened. Blocks of flats have done likewise. Another proposal for latter is underway in Southend Road, Hockley, with potential disastrous results for many adjacent homes and would exacerbate a serious traffic problem.

2. Urban extension Would sacrifice Green Belt

Option 4

Your comments at CONS say it all.

Owners of house/garden, to protect themselves from building predators, obtained consent for 2 small homes additionally to their own - just resulted in massive adjacent demolition, replaced by huge dwellings, removing daylight and making light pollution.

Q6 and 7 I cannot agree to any of the 4. Only solution is small dwellings added to properties with large curtilages. This could still give problems re traffic access, neighbour resistance. problem is developers don't want "affordable", only mass demolition replaced by huge "executive" houses, block of luxury flats, making neighbours unviable. Mass sale of council houses -Right to Buy- 1980s was unfortunate.

Climate change and resilient environments

Development agreed in our district must be very limited due to flood risk and existing, expected coastal change.

Green Belt and heritage sites and homes/gardens need largely to be protected from Development. In fact, seeing your Diagram page 36, Rochford District can't accommodate substantial development/redevelopment even with need to provide co-operation needs of nearby districts. (one does realise big new buildings bring more council rates).

As earlier, companies won't five flood insurance in flood risk areas.

One agrees new development should provide energy from carbon neutral/renewable sources, but it's costly and in early stages. Those with gas heating feel threatened. Car reliance is unlikely to be reduced, but also electric cars instead of petrol driven will need plenty of energy-providing points in centres and elsewhere.

Place-making and design Q14-16

It would be very difficult, knowing developer wishes (and need for council rates to come from somewhere), but a design guide if possible, should now exclude further development of executive mansions, luxury flats, especially as Government now requires more affordable homes.

We need to exclude development involving further demolition of existing dwellings, replace by mansions, multi-storeyed units out of height/area with locale, causing daylight loss and night-time light pollution and outside incomes of most locale.

Housing for all

Lack of homes for locals. As before, developers erect executive houses, sometimes in big estates. Local families can't afford, but they are bought by eg Londoners who sell theirs for high prices and buy big ones here for less.

It could be said, in the past young adults lived with their parents, paying their "keep" towards household costs, because they couldn't afford to buy. They only left home on:- marriage, or getting a better paid job elsewhere.

Surely these problems need sorting as housing still "locally driven". Locals cannot afford and there is limited council housing, why they leave the district to find homes they can afford.

It's stated SHMA paper outline need for smaller dwellings, but recognises size is market driven. Developers build mansions for nouveau riches - normally middle-aged, their children grown up and have left. Difficult to change that.

Rented housing - "families with children who cannot afford to buy..ineligible for social housing" (?why). Reverts to social housing lost to Right to Buy of 1980s.

Need for affordable housing

Council housing (largely sold off as above). There are also homes acquired by housing associations charging social rent. it isn't true gardens are sold for inflated sums. Persons with home and garden are often pressured by developers to eave and get demolished for sums that they'd need mortgage in order to move. Developers charge inflated sums to erect outsized houses.

Employment and Jobs

Doubtful. Southend Council demolished much of Victoria avenue, replaced with office buildings c.1970s, may be in expectation of business chances arising from Britain joining European Union. Some firms, such as C E Heath, Norwich Union, opened up there. But it didn't last - both moved away, others likewise. Avenue is now largely re-residential.

Southend Airport was expected to thrive. But recent pandemic caused several airlines to move away.

Traditionally, office staff in S E Essex have commuted to the City and elsewhere in London to work. Arrival of new technology was expected to do away with most office and factory workers. Executive staff would work from home on computer, occasionally attending head office. But commuter trains to London continued to be packed since. Briefly pandemic led people to work from home, but this isn't lasting. Some are again commuting.

Employment land, Eldon way, Hockley was allocated by HAAP but results are limited apparently.

Future of Southend Airport

Probably restricted by loss of airlines, due to effects of pandemic. Further expansion in activity difficult to foresee, due to effect on local community of noise, night flights etc - the photo on p.50 in Spatial Options Local Plan issue shows how vast an area of housing is already affected, without further extension.

Biodiversity As side comment, Hockley isn't an "urban area" - on Wikkipedia it's a large village.

Qu.29-30 I agree in Local Plan wildlife Review. There are some protected species residing in some private gardens. These should be protected under the system. If some neighbours find them a nuisance, it could be explained to them how their boundaries can be safeguarded. However, while some resent eg their lawns dug into by creatures, some so-described objections arise from developer designs on other's properties, as transfer of protected species involves getting licence from DEFRA - complicated and expensive. They are determined to get the ground, regardless of owners' wishes, but don't want complications - they've been known to attack setts.

Green/Blue Infrastructure

Proposals are acceptable, but shouldn't be used as excuse for developers to grab existing/homes/gardens.

Q.35-37

Education As earlier, proof exists where developers of gigantic expensive estates have promised new school, surgery. When estate practically built, they said eg 2 builders involved, so failed to meet promises. result - school c.3 miles away has to take pupils from new estate. Developers of big 'executive' estates must be made in advance to provide, or be denied plan consent.

Healthcare Side comment - I'm concerned by your view of future GP clinics - no appointments, just on-line digital consultations. GP appointments are curtailed to eg phone ones during pandemic, just to avoid infection. This is ok sometimes, but other times impractical. Not all have computers by the way.

Early years/childcare There are plenty of nurseries, but private. I don't know how sate funding can be provided.

Secondary education Where shown this is already full locally, builders for big estates could combine to contribute additionally, if space can be found, or else contribute to extend existing, if area available.

Further education Locally provided by Southend branch of Essex University and other universities over UK. But may be builders of large estates could contribute to a national fund for this use.

Community, Open Spaces One can only suggest big developers contribute likewise and/or designate some of their land, if available.

Heritage

Q43-45 I fear heritage in Rochford has been somewhat selective. Several items in Hockley have been demolished, some in fact of widespread opposition. Your article in Spatial Options sets out straightaway with items presumably to be kept in Rayleigh/Rochford. Recent uproar over plan to remove Mill House has led to the matter going under review.

As earlier, plan to demolish 1 Southend Road for flats caused widespread rage (details earlier). Hockley councillor had flats refused, but nil said re the house, down for demolition on proposal.

It was on the Local List, so Plan Policy official said Government didn't approve that, so Rochford's was abolished. Once house demolished, officer said Government changed its mind. New Local List omitted some Hockley items on it earlier. spa pump house now on national list. May be St Peter & Paul church and Bull pub are listed. Others could be added to Local one, eg Hockley Cottage Southend Road, China Cottage Spa Road. Other items are demolished: Kent View Cottage, 2 Victorian Houses Southend Road, Manor at Plumberow, 17C house and forge opposite entry to Hockley woods.

Town centres and retail

Plan Objectives

"..retail - dominant town centre..struggling in light of on-going structural changes..in high streets/centres". On-line shopping has caused closure of eg clothing stores in towns, accelerated by pandemic. But, eg Hockley centre continues to provide basis needs successfully. Attempt to change it by original HAAP was unsuccessful.

If developers want to introduce residential in addition, it must not be at expense of businesses and be preferably 2 storey, not to threaten nearby low level dwellings.

[Figures 8, 25 and others eg 31-5 make clear Rochford District not suitable for drastic residential increase on grounds of flood risk particularly.]

Using Class E, allowing transfer from retail to residential without planning permission must not be allowed to threaten retail and not everyone has a car to do retail shopping elsewhere.

Q.46-50 Hockley Centre and its environs does not have space to provide additional facilities, residential (except as above) etc. You couldn't put a new supermarket in Eldon way, off the main road, and we have enough provision now. There are 1 or 2 stores in Southend Road, but remainder is residential, mostly 1 or 2 storey and basic needs shopping is adequate in the centre, food, hairdressing, ETC. Larger items, such as clothes, shoes, apart from on-line, people just bus to Southend. Hockley isn't big enough for more.

Transport and connectivity

"National Planning Policy states transport issues should be considered from the earliest stages of plan-making, so the impacts of development on transport networks can be addressed".

That is exactly the local problem. over-enthusiastic profiteering developers have been allowed forward, with often huge estates, without a major district motorway having been formulated and inserted first. Local main roads, particularly in Rochford District - an agricultural area - are former narrow, winding country lanes, later tarmacked over for motor traffic. I think Southend Council planned at one time for access from rear of Shoebury to reach the Crouch, traversing green belt area behind Rochford. Understandably I believe Rochford didn't agree.

Suggestion has been made for one huge development centre, served by one new motorway through green belt, but probably impractical in this rural, flood risk area and rising sea levels

Walking and cycling in preference to private car are excellent for leisure and short distance basic needs, but not eg commuting to work nor eg weekly shopping for families.

Bus services have suffered from increased private car use by middle classes, especially Nos. 7 and 8. Arrival of costly new estates are unlikely to change that.

Maps with your plan show how much of the district is flood threatened, including rising sea level. So I can't see answer to travel needs and extensive new development foreseen in plan.

Green Belt - Rural Issues

Q.54 Rural exception sites. Developers have said they don't want to do affordable. (One told me that at a meeting).

Planning for Complete Communities

Description of centres is accurate. But one must accept that provision for new motorways is largely out of the question. The main roads that have been suitable in the past cannot cope with endless new development and its attendant motor traffic - as earlier, main B C roads in district are former narrow winding country lanes, later tarmacked for motors. But motorway to any large new centre would contend with c.50% flood risk, rising sea levels and the district still has land in agricultural use.

Stonebridge and Sutton might possibly provide a substantial amount of new housing, judging only from the map, but provision of a new motorway (through where) seems doubtful.

Hockley and Hawkwell - housing availability and affordability "a key issue" - due to several problems.

Its services were adequate for its needs. But, as elsewhere in Rochford and UK, and as I wrote earlier, council houses designed for those of limited means were sold under Right to Buy (I believe this arrangement is now abolished). Also, as earlier, a new motorway would be needed, not possible.

Also, possibly attracted by convenience of rail line to London, this area has recently attracted wealthy residents from London and elsewhere. Modest homes/gardens have been demolished, replaces by mansions and blocks of flats. So, middle and low income families have been driven out to wherever they can afford, to be replaced by rich middle-aged. Elsewhere in the district large estates of expensive homes have been erected, presumably with the same results. Some driven out have been paid sums needing a mortgage in order to move. Developers don't expect to pay notable sums for "land" (including others' homes).

Mainly, only available land for building is Green Belt or "flood risk", not suitable.