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

Yes, new design guides are needed

Surely, the Local Plan will be influenced by the design guides, codes and masterplans so they must go hand-in-hand.

Yes this should be incorporated in the plan.

Given the local plan will have a lot of development; ensuring that design guides are in place prior to this would be helpful.

no comment

Yes, underpinned by the district level principles set out in any charter the plan produces.

I do not agree nor disagree

No

When considering whether to prepare new design guides, consideration should be given to how and whether they provide additionality to existing design guidance that would be applicable. In particular, the Essex Design Guide has been prepared by the EPOA and has the support of the Essex districts and covers many of the themes that would be expected in a district design guide. For instance, Sport England’s Active Design principles have been embedded into the Essex Design Guide and if applied in Rochford district it would not be considered necessary to prepare a separate local design guidance which repeated the approach.

providing it includes infrastructure and if we are truly trying to address housing need looks at affordability with a very high priority

Yes

Current guides seem suitable

Please consider local facilities like schools, doctors, tip (Wakering using Rayleigh), leisure like swimming pools, park, local shops and childcare and children’s centres.

I agree

Yes although a I would suggest this is at County level

If you don't have them then each developer will interpret the principles differently and you won't get what you want. I'd imagine they will be hard to enforce anyway as developers will probably say its all to onerous and not fair as it costs them more money so probably will all get chucked out anyway.

Persimmon would welcome the use of these, which would be supported by the NPPF:

“Being clear about design expectations, and how these will be tested, is essential…”
“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.”
“To provide maximum clarity about design expectations... 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.”

Yes – but design guides/ codes should only relevant be to allocated sites and strategic sized sites.

Yes, such information could then be specific to the settlement & require development to be appropriate to its location

Yes – but design guides/ codes should only relevant be to allocated sites and strategic sized sites.

The design guides should present realistic criteria, not bare minimum so that quality of life and wellbeing are maximised rather than sweating the assets and squeezing too many people/dwellings/cars into a small area. Get away from maximum profit from meeting minimum requirements

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 would expect to see reference to:
• The Infrastructure Delivery and Funding Plan
• Level 2 Strategic Flood Risk Assessment
• Local Cycling and Walking Infrastructure Plan
These plans are needed to assess the long-term sustainability of any proposed sites. Without these I find it difficult to make any comments.
Evaluation of the impact of current development on Hullbridge
I cannot comment on the suitability of the sites in the plan without the Infrastructure Delivery and Funding Plan which I have been told is being undertaken at present. In my opinion it is premature to consult without these.
I would expect it to see reference to
i) the main Roads and the principal junctions and exit points to Hullbridge on Lower Road, Watery Lane and Hullbridge Road as well as the junction with Rawreth Lane.
ii) Consultation with the schools in Hullbridge, Hockley and Rayleigh to accurately asses capacity, too often there are no places in specific school.
iii) Consultation with Doctors and Pharmacies as well the local Healthcare Trust, currently the Riverside Medical Centre are not moving forward with expansion proposals due to high costs.
iv) Air Quality Management - too many parts of the District 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 (sofa surfers) 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]
Broadly yes. But it is important that the hierarchy is not changed through developments and cross boundary development must be carefully planned.
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 urban development, possibly shared with Wickford 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, houses, and businesses but also natural areas as well. The district needs good defences to limit flooding in all areas, protecting people and wildlife. Maybe these could be incorporated in the “natural” landscape theming. 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. All building should be carbon neutral.
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]
Yes. All coastal areas and areas of special interest, especially where there is a 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 and the proposed Regional Park to the West of Hullbridge.
Q11.
Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the district to supply low-carbon or renewable energy?
Yes.
New developments should be able to produce all energy requirements from zero carbon 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 World is suffering a climate crisis, without higher standards we will not be able to reduce carbon sufficiently to avoid the crisis.
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 and heat pumps 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 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 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]
Yes, but they must be kept 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 small, 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.
We should 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. Improve manufacturing base and revisit the JAAP to make the airport Business Park a technological park.
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?
Other forms of sustainable transport (Tram), gigabit broadband and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training. No new roads.
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]
The airport brings little to the economy, It could be better used as an expanded technological park or for housing.
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 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.
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]
Most of the District feels overcrowded; the road network is 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 often 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. There are too few areas of accessible open space.
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.
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 4 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. 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. I feel that some of the sites out forward in Rayleigh, 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 proper cycle network as part of the plan. A tram system. No new roads should be built.
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.]
Better links to the Chelmsford perhaps through a tram system, new roads must not be built. 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]
No Comment
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?
No Comment
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.
a.
Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]
No Comment
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?
c.
Are there areas in Rochford and Ashingdon 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]
Hockley Woods
Rayleigh Town Council. Spatial Plan Response 17 V 2.0 Published 13th September 2021
Q60.
a.
Do you agree with our vision for Hullbridge? Is there anything you feel is missing? [Please state reasoning]
No. This has been written by someone with no awareness of Hullbridge. I support the Parish Council Vision.
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?
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 2040 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.
Housing [market, affordable, specialist, traveller, other]
c.
Are there areas in Hullbridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
All of the areas lie within the green belt, and many will be within the projected 2040 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.
d.
Are there areas that require protecting from development? Why these areas? [Please state reasoning]
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.
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.

On behalf of Thorpe Estate Limited (my client), please find our comments on the Rochford Local Plan Spatial
Options Consultation (SOC). My client is the owner of some 90 hectares of land to the north of Bournes
Green Chase and to the east of Wakering Road. It lies to the south west of Great Wakering. It is identified
on the plan attached.
The majority of the site falls within the administrative boundary of Southend on Sea Council (SoS) apart from
a small part of the site in the north east corner which falls within the administrative boundary of Rochford
District Council.
My client is in the process of producing an illustrative masterplan for their site, which will be supported
technical analysis on key topic areas, including transport, flood risk and ecology. This will be provided to the
Council in due course.
This masterplan for the site will be produced in conjunction with a wider masterplan and promotion of
neighbouring parcels of land by Cogent Land LLP. A collaborative approach is being taken with Cogent, which
includes co-ordination in respect of transport and other critical infrastructure.
These representations are made in the context of not having had the opportunity to engage with officers at
the Council and we would welcome a meeting at the earliest opportunity.
My client is the owner of the land, which should assure the Council that it is a site which is deliverable and
that there are no legal or ownership hurdles to overcome.
The legislative requirements for the production of Local Plans are set out in Part 2, Local Development, of
the Planning and Compulsory Purchase Act 2004 and in national guidance within the National Planning Policy
Framework 2021 (NPPF).
Paragraph 11 of the NPPF requires that ‘plans should promote a sustainable pattern of development that
seeks to meet the development needs of their area; align growth and infrastructure…..’.
It also requires that ‘strategic policies should, as a minimum, provide for objectively assessed needs for
housing and other uses, as well as any needs that cannot be met within neighbouring areas’.
Chapter 3 of the NPPF then goes onto set out the detailed requirements for plan making, including the
requirement set out in paragraph 24, that each authority is under a ‘duty to cooperate’ with each other on
strategic matters that cross administrative boundaries.
The objective of the plan making process is to be able to put forward a plan that is ‘sound’ and meeting the
requirements set out in paragraph 35 which are:
1. Positively prepared – to meet the area’s objectively assessed needs; and is informed by agreements
with other authorities, so that unmet need from neighbouring areas is accommodated;
2. Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on
proportionate evidence;
3. Effective – deliverable over the plan period, and based on effective joint working on cross-boundary
strategic matters that have been dealt with rather than deferred, as evidenced by the statement of
common ground; and
4. Consistent with national policy – enabling the delivery of sustainable development in accordance
with the policies in this Framework and other statements of national planning policy, where relevant.
Whilst we note that the plan is at a very early stage, we do not consider that the plan is heading in a direction
where it is likely to be considered to accord with the four requirements of soundness and therefore is not
likely to be found ‘sound’.
Our overarching concern is that the Council does not appear to be discharging its responsibilities under the
duty to co-operate in respect of strategic/ cross boundary matters and specifically in relation to my clients’
interests, with SoS Council in respect of housing and infrastructure.
At this stage we would note the number of plans that have been rejected by Inspectors at submission/
examination stage on this very issue, including Sevenoaks District Council, St Albans City and District Council
and Wealden District Council.
We would urge the Council to review its approach to ensure that the Local Plan that gets put forward for
examination accords with the requirements of paragraph 35 of the NPPF.
Our comments below focus on the high-level strategic issues, although, my client will wish to comment on
policies not addressed below at later stages in the plan making process.
The National Picture
The Council are bringing forward their Local Plan at a time of significant challenges facing the country,
particularly because of the Covid-19 pandemic which has exacerbated historic issues of under-delivery of
housing over the past few decades.
This lack of supply is causing substantial issues in the housing market, particularly in relation to affordability
and suitability. The government has estimated that housing need in England is 345,000 homes per year.
The government has therefore set its ambition to achieve 300,000 homes per year.
Whilst the supply of housing has been increasing year on year, only 244,000 homes were delivered in 2019-
20, according to a Government research briefing, ‘Tackling the under-supply of housing in England’.
Housing Need in the Region
At a regional level, there are six South Essex authorities, which are listed below, along with their performance
against the Governments Housing Delivery Test, which measures delivery against housing requirement over
the previous three monitoring years:
1. Basildon – 45%;
2. Brentwood – 69%;
3. Castle Point – 48%;
4. Rochford – 95%;
5. Southend – 36%; and
6. Thurrock – 59%.
Not one of the six authorities have met their target and these delivery rates are amongst the lowest in the
Country and, on average, are delivering only slightly more than half (59%) of the regions housing need.
Clearly this is an issue that needs addressing urgently to avoid disastrous social and economic consequences
for the region.
We note from the SOC that Rochford is likely to have sufficient available land to accommodate its OAN which,
for now, we take at face value, albeit that we are aware of a recent refusal of planning permission on an
allocated site. It may be the case that my client decides to challenge the Council’s supply against the tests
set out in Annex 2 of the NPPF.
It is very clear from the draft SoS Local Plan, that they do not have a supply of homes that gets anywhere
close to meeting their OAN without the release of Green Belt land within their own administrative boundary,
see further commentary below. For SoS’s OAN to be met in full, neighbouring authorities, would need to
accommodate the shortfall estimated to be in the region of 3,550 to 4,300. However, given the historic
undersupply within the neighbouring authorities, who have their own challenges, it is difficult to see how
this could realistically be accommodated.
Clearly radical steps are required to address this issue.
Strategic Plan Making
It is not clear what the latest position is with the South Essex Plan. It is disappointing that this doesn’t appear
to be moving forward to allow strategic policies and growth requirements across the six neighbouring
authorities to inform and lead Local Plan production.
We are also disappointed that the Joint Part 1 Local Plan between Rochford and SoS appears to have now
been abandoned. We do not believe that an update to the November 2019 Statement of Common Ground
(SoCG) with SoS has been prepared setting out what the approach is in relation to cross boundary strategic
matters and this clearly should have been agreed before publication of the SOC.
We would particularly note the statements made at 4.3 and 4.5 of the November 2019 SoCG, which stated:
Providing Sufficient Homes – housing need is high across the area and a large amount of land is being
promoted for development either side of the Rochford/Southend administrative boundary. There is a need to
ensure that preparation of a spatial strategy, site assessment and selection is consistent across both authority
areas;
Transport Infrastructure and connectivity - Developing appropriate integrated and sustainable transport
networks to support the efficient movement of people and goods, including strategic transport corridors
(including A127, A13 and A130) recognising the requirements of both Essex and Southend local transport
plans, including modal shift, sustainable travel, new technology, rail franchisee investment plans, footpath
and cycle networks, and any access mitigation to enable strategic scale development across administrative
boundaries, and future proofed internet access to all new development;
We consider these to be two fundamental parts of the plan making process which require cross boundary
co-operation and yet seem to have been abandoned.
In the absence of this plan moving forward to take an overarching view of growth requirements for the
region, we would strongly contend that the Council should re-engage with SoS to update the SoCG as
required in paragraph 27 of the NPPF. These statements will need to demonstrate how strategic policy
making is being addressed and what steps are being taken to accommodate the significant un-met housing
need, because it is not at all clear how this requirement is satisfied in the draft version of the plan.
These statements should be updated and made publicly available for review at each stage of the plan making
process.
Release of Green Belt Land
Paragraph 140 of the NPPF sets out the tests for the release of Green Belt land and confirms that it should
only be altered where ‘exceptional circumstances are fully evidences and justified, through the preparation
or updating of plans’.
Paragraph 141 goes onto set out the steps that need to be undertaken as part of the justification for
‘exceptional circumstances’. These are:
1. makes as much use as possible of suitable brownfield sites and underutilised land;
2. optimises the density of development in line with the policies in chapter 11 of this Framework,
including whether policies promote a significant uplift in minimum density standards in town and city
centres and other locations well served by public transport; and
c) has been informed by discussions with neighbouring authorities about whether they could accommodate
some of the identified need for development, as demonstrated through the statement of common ground.
Given the scale of housing need in the region, it must be the case that there are exceptional circumstances
that would justify the release of Green Belt land.
Within the context of the above, we have set out our comments on the SOC below.
Spatial Options Map
The Spatial Options Map put forward with the SOC shows my clients land, and neighbouring sites, designated
as Regional Park, which is an interpretation of a concept set out in the South Essex Green and Blue
Infrastructure Study.
Whilst, my client would be content for some of their land to be provided as parkland as part of a
comprehensive masterplanned approach to release their site from the Green Belt for housing led
development, they would not release it solely for the purpose of it being used as parkland.
Critically, the failure to allocate their site would seriously compromise the ability for SoS to deliver homes to
be able to meet their Objectively Assessed Need.
The Spatial Options Map therefore fails all the tests set out in paragraph 35 of the NPPF in relation to the
allocation for my client’s site at parkland as it would not be deliverable.
Rochford in 2050
We agree with the thrust of the Draft Strategic Priorities and Objectives, particularly:
1. Strategic Objective 1 – provision of sufficient homes to meet local community needs in partnership
with South Essex neighbours;
2. Strategic Objective 2- provision of a mix of homes to support current and future residents;
3. Strategic Objective 9 – provision of infrastructure; and
4. Strategic Objective 10 – working with neighbouring authorities and the County Council to deliver
infrastructure.
The objectives identified above are consistent with the requirements of the NPPF, particularly in its
requirements to work strategically with neighbouring authorities to meet housing need and provide
appropriate supporting infrastructure.
However, for the reason set out below, we do not consider the SOC provides the necessary framework to
deliver on these objectives. We consider the reverse is likely to be the case and, as drafted, it would prevent
the current and future need of the area being met.
Strategy Options
It is difficult to properly understand what is proposed within this chapter. The spatial plans (Figures 18-21)
lack clarity and in the absence of a key we cannot be certain what the Council are proposing.
We would ask that at the next stage, much improved plans with a meaningful key are provided to make it
clear what is proposed and where to avoid ambiguity.

Our overarching concern with this chapter is that none of the development options set out in this chapter
take account of the development options that are being put forward within SoS’s ‘Refining the Plan Options’
version, which includes the release of my client’s land, and neighbouring parcels, from the Green Belt for a
residential led development.
Indeed, it would appear that it will only be possible for SoS to meet its OAN through the development of my
client’s land along with neighbouring parcels promoted by Cogent Land LLP and a neighbouring authority
(potentially Rochford) accommodating any shortfall. However, there may be pressure from the other three
South Essex Council’s for housing shortfalls to be accommodated beyond their administrative boundaries.
In order for SoS OAN to be fully addressed, section 2.3i – Requirement for New Homes of the SoS draft Local
Plan identifies that between 3,550 to 4,300 new homes would need to be accommodated either in Rochford
or another neighbouring authority.
At the very least the SOC should include this within its options, including taking account of provision of
strategic infrastructure, particularly roads.
Strategy Option C of the SoS draft Local Plan shows the development of my client’s land, with neighbouring
sites and associated infrastructure.
Strategy Option D shows this growth extending into Rochford, which would allow SoS’s housing OAN to be
met in full.
At the very least, the Council ought to be fully engaging with SoS about its housing need and under its duty
to co-operate required by paragraph 35 a) of the NPPF and testing these options at consultation stage as
part of its SOC. Not to do so is a serious failure of proper planning in this region.
The options currently being promoted within the SOC would likely prevent SoS being able to deliver Options
C or D within its draft Local Plan and therefore prevent it from getting anywhere close to meeting its OAN.
Spatial Themes
My client is generally supportive of the thrust of this chapter and the principles to guide development coming
forward. In particular, the requirements for new development set out in ‘A Place-Making Charter for
Rochford’. We believe the 13 (or 14) points identified will enable the provision of good quality development
consistent with the NPPF.
We don’t have specific comments to make in respect of the questions raised, other than in respect of 16a to
16c. Whilst we feel that design codes will be helpful, these should be kept high level and not specific, unless
in relation to areas of very strong character or of heritage or landscape value. More specific design codes
could be readily formulated at outline permission stage.
Overly prescriptive codes at this stage in areas that are not constrained potentially stifle innovative design.
Housing for All
In relation to questions 17 to 19 It is important that the Council’s policies relating to housing units within
schemes are not overly prescriptive and take a flexible approach. We would expect a definitive policy is
likely to result in most developments being unable to meet that policy for a variety of reasons, such as site
constraints, viability, location, access to services/ public transport etc.
It is our experience that the unit mix that comes forward on each site, should be tailored to the individual
circumstances of that site, having regard to identified need.
We would therefore agree that a combination of Options 2 and 4 would be the most appropriate.
We agree that all homes should meet, or exceed, Nationally Described Space Standards, unless exceptional
circumstances prevent that from being possible, such as conversions or co-living schemes.
We agree that all homes should meet M4(2) of the Building Regulations, again, unless exceptional
circumstances prevent that from being possible.
Finally, we also agree that a ‘suitable’ proportion of new homes should be built to M4(3) of the Building
Regulations. However, we would strongly suggest that evidence ought to be produced to identify and justify
any prescriptive requirement set out in policy to ensure is is not overly onerous and proportionate to the
likely level of need.
Green and Blue Infrastructure
Our comments in relation to this chapter concern my clients’ landholdings which are shown in Figure 32 as
providing Regional Parkland. As the majority of this land is within the administrative area of SoS, we would
recommend that the Council’s immediately look to co-ordinate their approach. Not to do so, risks any
positive conclusions in respect of the duty to co-operate. The approach suggested within the SOC is at odds
with that shown within SoS’s draft plan, particularly in relation to the options that show my clients land being
released from the Green Belt for housing led development.
At no stage has my client put forward its land for regional parkland and, even if it is not released from the
Green Belt for development, it would remain in private ownership. This proposal is therefore not deliverable
and not consistent with paragraph 35 of the NPPF.
We would therefore strongly suggest that the Council review this chapter with the relevant landowners to
understand what is capable of being delivered.
My client would however be prepared to dedicate some of their site to parkland as part of a wider master
planned approach, but only as part of a residential led scheme.
Community Infrastructure, Questions 35 to 37
We agree with the Council’s approach, that it is critical that appropriate infrastructure if planned for to take
account of future growth. However, where we do not agree with the approach taken by the Council is in
relation to the concerning apparent lack of cross boundary discussions with neighbouring authorities about
their future growth and how infrastructure provision may need to be planned for to take account of those
requirements.
Consistent with comments made above, we would strongly urge the Council immediately engage with its
neighbouring authorities so that a cross boundary approach is taken to infrastructure provision that will
address future needs.
Infrastructure should be provided for as part of a cross boundary approach and as part of ‘walkable
neighbourhoods’ to ensure communities have facilities on their doorstep.
Transport and Connectivity
We enclose comments from Arup who are my clients transport and highways advisors in respect of this
chapter of the SOC.
The Wakerings and Barling, Questions 59a to 59e
We do not agree with the vision for The Wakerings and Barling shown in the SOC for reasons previously
explained. It would prejudice the ability for SoS to meet its housing need and the Council should be
discussing the potential release of surrounding Green Belt sites and other strategic cross boundary matters
to facilitate this.
Summary and Recommendations
Thank you for allowing us the opportunity to comment on your SOC. Whilst there are a great many aspects
of the plan that my client fully supports, for the reasons set out above, it does not meet the requirements
for plan making set out in national guidance. If it were to move forward on this basis, we do not believe it
would be capable of being found ‘sound’ in accordance with the tests set out in paragraph 35 of the NPPF.
Chiefly amongst our concerns is that the Council appear to have abandoned its engagement with SoS, and
taking a co-ordinated approach to strategic policy making to meet the need for the region, particularly in
relation to housing growth.

As identified above, the South Essex region is catastrophically failing to deliver homes to meet need and has
produced only slightly more than half of its requirement. It is difficult to see what further ‘exceptional
circumstances’ would be required to justify the release of Green Belt land and to use the plan making process
to take a co-ordinated approach to housing and infrastructure delivery.
We would strongly encourage the Council engage with its neighbours and key stakeholders, including my
client, to agree a strategic approach to accommodating housing need in the area and associated
infrastructure. This is a requirement confirmed in paragraph 25 (and elsewhere) of the NPPF. Ideally, the
Council should re-engage with SoS and produce a joint Part 1 plan to deal with cross boundary strategic
issues. Failing that, we would request that the Council provide an up-to-date Statement of Common Ground
prior to the publication of each plan making stage (in accordance with paragraph 27 of the NPPF) to clearly
set out how it is looking to work with its neighbour on cross boundary strategic issues moving forward.
We note that the Council plans to undertake a transport study that will look at, amongst other things, any
requirements for new road infrastructure. It is essential that this happens only once there is a better
understanding of cross boundary issues, particularly housing, so that this infrastructure can be planned in a
way that facilitates the growth required for the region.
We would very much welcome an opportunity to discuss my client’s land and the strategic growth in the
region with officers at a meeting in the near future. As currently formulated – this plan is seriously flawed
and requires amendment.

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]

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

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

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


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


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


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


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

Q5. Do you agree with the settlement hierarchy presented?


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


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

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

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

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

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

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


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

Spatial Themes

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


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


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


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


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


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


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


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


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

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


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

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

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


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

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

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


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

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

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

Housing for All

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


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

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

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

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


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

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


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

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


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

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

Employment and Jobs

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


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

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

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

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


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

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

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


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

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

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

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


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

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


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

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

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


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

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

Biodiversity

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


YES

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

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

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


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

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

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

Green and Blue Infrastructure

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


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

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


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


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

Community Infrastructure

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


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

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

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


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

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

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

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


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

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

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

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


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

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


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

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


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

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


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

Heritage

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


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

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


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


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

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


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

Town Centres and Retail

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


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

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

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


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

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

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

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


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

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


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

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

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


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

Transport and Connectivity

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


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

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


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

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

Green Belt and Rural Issues

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


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

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

Planning for Complete Communities

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


N/A


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


N/A


Q56d. Are there areas that require protecting from development?


N/A


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


N/A

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



N/A

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


N/A


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


N/A


Q57d. Are there areas that require protecting from development?


N/A



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

N/A

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

N/A

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

N/A

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


N/A

Q58d. Are there areas that require protecting from development?


N/A



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


N/A


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

N/A

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


N/A




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


N/A





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


N/A


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


N/A


Q60a. Do you agree with our vision for Hullbridge?


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

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

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


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

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


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

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


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

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


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

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


N/A


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


N/A


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


N/A


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

N/A

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

N/A



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


N/A


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


N/A


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

N/A



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

N/A



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


N/A





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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A

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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A






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


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

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


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

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


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

Create a Country Park to the west of Hullbridge.

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

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

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

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

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

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

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

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

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

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

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

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

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

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