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 agree housing sites should be split to a degree.
First time buyers and affordable housing are considered similar. I young person or couple buying a home for the first time should meet the expect average wage standards / expectations. Simpler designs will help lower the price, which must be in the plan.
All designs must think about parking as the household evolves. Single parking space ideas create neighborhood issues when one person uses more than their share. Be sensible, 4 bed house must have space for 4 vehicles, either on / off street. Average the off-street for the site.

The analysis is good but the options are not! According to the RSA 'affordable housing is not affordable for young people. Private rented housing is also not affordable with rents jacked up and section 21 evictions growing, Housing associations have been unable to meet the need and often provide a substandard service as is the case with Sanctuary. The council needs to build Council houses within our communities to provide low rent secure homes for young residents so that they can stay within our communities and slow the ageing of the population. This would also help to reduce child poverty.

LOCATION
Hawkwell West is away from the existing centres. Road congestion and the lack of public transport is an issue.Bus Service is inadequate.
It is a green belt productive farmland and a nearby brownfield would be ignored.
HIGHWAY ISSUES
The development could increase traffic movements by nearly 50% on the current 2019 counts which further could represent an increase of over 90% since 2008.
Improvements were made to the junction at Nursery Corner in relation to Clements Gate. No further junction improvements are possible so material congestion will result.
EDUCATION
From a review of the “10 Year Plan – Meeting the demand for school places in Essex 2019 – 2028 prepared by The Essex School Organisation Service”, we note the following:
The Report confirms that “the significant increase in demand for school places in Essex is predicted to continue” (page 4).
The Report states that the figures endeavour to account for possible future developments, and therefore, the additional demand on the schools in the area (page 7).
However, the school place forecast figures for Reception for the local area on pages 55-57 show that in some areas in the latter years covered by the Report there is already insufficient capacity.
In addition, the school place forecast figures for Secondary Schools for the local area, specifically Rochford/Hockley, on page 58 confirm that throughout 2019/2020 up to 2028/2029, there are insufficient school places to cope with current demands and development.
Any additional new developments, such as this potential development of up to approximately 500 dwellings, would certainly place increased pressure on the schools in this area and only exacerbate this issue.
Pre- School - There is only one, Clever Clogs at Hawkwell Village Hall, within one mile and there is no info on capacity.
The other junction on Rectory Road is at a Railway Bridge where no improvements can be made so material congestion will result.
Both unacceptable and unsustainable for further development.
INFRASTRUCTURE ?
Residents have great concerns that a standard charge or levy for infrastructural components (CIL) will be insufficient to meet the real costs of making this location sustainable.
The location is likely to generate more private car journeys and it is unlikely that bus or walking or cycling will prove a via viable alternative.
The location is currently inaccessible and any new road created from the demolition of houses in Rectory Road will be a bottleneck.
Rectory Road is on the Speedwatch list because of continuing speeding problems revealed. Given the volume of traffic, often released in batches from one end by traffic lights and the other by a mini roundabout this leads to driver frustration and speeding occurs giving rise to the potential for multiple vehicle accidents and with those trying to emerge from side roads at high traffic volume periods.
LOSS OF GREEN CORRIDOR FOR WILDLIFE
There has been an increase in some wildlife from the displacement of habitat at Clements Gate. Where will it go now?
PUBLIC FOOTPATHS AND BRIDLEWAYS
A rural footpath and a bridle path are in the area these may be lost – even if retained their attractiveness will be lost. Residents also walk the field boundary which will no longer be possible. Loss of informal recreational areas.
BROWNFIELD LOCATION NEARBY
The Magees general location, a brownfield location very nearby could be used instead.
This area of Hawkwell West is low lying and prone to flooding, fog and freezing fog.
FLOODING
Reference - South Essex Level 1 Strategic Flood Risk Assessment - April 2008
Page 37 - Hawkwell Brook - Flood Zones apply to this Site.
Page 38 - Local knowledge disputes the claim that the Hawkwell Brook defences have protected against the 100 year flood event. Only 30 year protection maximum.
Indeed there were significant Hawkwell Brook flood events in 1953 (the water course was moved as a result), 1968, and 2013. These have been ommitted from the Flood Record on Pages 40 and 41.
Being in the highest risk Flood Zone – there must be no building.
It is likely that the site risk itself would be potentially reduced by the 1 in 100 year calculations but there is no control or checks on these systems and they are unproven. As the site is adjacent to a tidal river the risk would remain and probably increase flooding risk on adjacent areas
AIR QUALITY
Air quality will decrease further. Traffic volumes have increased by 34.5%. This has increased air pollution. Residents have noticed that lichens on roof's have reduced which is a well known ecological marker of increased pollution.
FLOOD ZONE
The area nearby is in a flood zone.
Reference - South Essex Level 1 Strategic Flood Risk Assessment - April 2008
Page 37 - Hawkwell Brook - Flood Zones apply to this Site.
Page 38 - Local knowledge disputes the claim that the Hawkwell Brook defences have protected against the 100 year flood event. Only 30 year protection maximum.
Indeed there were significant Hawkwell Brook flood events in 1953 (the water course was moved as a result), 1968, and 2013. These have been ommitted from the Flood Record on Pages 40 and 41.
It is a greenfield and a nearby brownfield would be ignored.
ACCESSIBILITY TO SERVICES
Walking Distances using a midpoint on Rectory Road
Hockley Railway Station 33mins
Hockley Spa/shops 31+ mins
Hawkwell Parade 21mins
Shorter routes use unmade paths and alleyways that are not suitable for all, even the main road
route uses narrow footpaths that are unsuitable for some prams/buggies/mobility aids. All routes are uphill.
Golden Cross Parade 18mins
Rochford Railway Station 39 mins
Rochford Square 41mins
All routes necessitate crossing Rectory Road and include a narrow footpath under the railway bridge.
Again the narrow footpath is unsuitable for some prams/buggies/mobility aids.
The only cycle path is along Ashingdon Road but there is no linkage to it.
General issues with suitability of walkways for elderly/infirm and young
Hockley Car railway car park already at capacity at 9.30am Railway Company promised 4 trains per hour but only delivering three.
Limited capacity of Rochford Station Car Park
Taxi fares about £8.00 to Rochford
If travelling to Rochford station possible congestion due to early start time at King Edmund School
No safe bike route as the road width does not even incorporate a safe footway in Rectory Road on one side and none on the other. A cycle path could not be included.
No and not feasible – in the other direction the railway bridge would preclude this.
There is a growing issue at Nursery Corner which is concerning residents right now and could be exacerbated in the future by a major development.
Basically there are long tailbacks at rush hour times in Rectory Road and it is impossible for pedestrians to cross the B1013.
And there is a bottleneck at St Mary’s Bridge.
And at Golden X
And at Hockley Spa
... to be continued in next section:

We don't want anything built at all but especially not flats or appartments.

with an aging population what about bunglows

If the statistics above are correct than developments should include the above percentages in their builds. That way they are built to purpose

More affordable housing to the East of Hullbridge

the community itself should dictate its needs not central government. the area does not need more housing it needs better investment into its existing infrastructure.

the existing community will move away if this plan goes ahead and you will see a signficant change in demographics which will mean the plan will then be obsolete.

You stated that the need for more housing is to stop future generations leaving the area if they cannot find affordable housing; I’m not sure how you can come up with projection numbers at this time, wouldn’t it be better to wait for the census results to better inform this before making decisions to built this massive amount of homes.

large quantities of large houses seem to be being built Hall Road, Rawreth Lane, Hockley there is minimal what was council housing left so we should be telling the developers what they can build not allowing them to build expensive homes which don't meet the needs of the majority. More homes for the elderly should only be built if we can offer the support they will need from outher services.

work with housing associations to ensure homes being built meet the needs of those wanting to rent and ensure developers are building to meet needs rather than making hugh profits and building properies not required by the majority of those seeking accommodation.

I feel that there is little statistical clarity for the need for housing and the sort of housing types needed. I would expect all national busiliding guidelines and modern and modern builds with energy efficiency but I think that the community needs appropriate facilities to fit these demands and haven't seen any growth in these despite numerous projects in recent times.

We need a good range of housing to meet our local need but not in Rochford as we have had a lot of housing recently!

Provide affordable housing and not cheap “new builds” which are more hassle once the builders leave site

"Local needs" is the root cause of the requirement for more development in the area. If anything, the council need to be concentrating on reducing the amount of jobs in the area, and moving them away from the South East, to help reduce the need for accommodation in the area.
RDC need to think radically to help the welfare of the existing residents, rather than be attracting more people to the area, as currently most housing seems to be being bought be people from outside of the local area.

Builders / developers are obviously in that business to make money. When a builder puts in plans currently these will normally try to maximise the return for the shareholders. This means the numbers of properties suggested is high and the type of property is normally houses as they sell for more than single storey housing. There is consideration for potentially affordable housing, but in your research the number of properties more appropriate for some older people, or those with disabilities is highlighted, however bungalows are seldom built, which doesn't appear in line with the research on types of property required..

It's pretty obvious. You need to become a housing developer and build your own homes. These would be a mixture of affordable (even though the current definition is still not really affordable for most people) and rental properties. This would cut out the property developers and allow the council to make a profit margin on the sold homes and a guaranteed income, essentially forever, on the rental properties.
Yes it requires certain skillsets to achieve this in a successful manner but they are available in the market.
Any other option is just going to be window dressing and fail as developers are experts at finding ways around the rules.

Of the options listed, Persimmon Homes would support:

• Option 2 – requiring a suitable or negotiable mix of housing that is response to the type or location of development;
• Option 5 – all homes to meet NDSS;
• Option 6 – all homes to meet M4(2); and
• Option 7 – a proportion of homes to meet M4 (3).

Option 1 listed proposes a non-negotiable mix to be provided on all housing developments. Clearly, this option is unworkable in practice as certain sites are unable to deliver certain types of housing. For example, Brownfield sites in the urban areas are unlikely to be able to deliver suitable proportions of larger dwellings; likewise, heritage constraints in certain areas may influence the size of dwellings that a site could deliver to satisfy historic environment consultees. It is therefore more appropriate to require housing mix to be agreed during pre-application discussions, having regard to site and location characteristics, with the latest SHMA evidence used as a broad guide to inform those pre-application discussions.

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

2 – Meeting our need for different types, sizes, and tenures of housing (including affordable and specialist housing) by requiring a suitable or negotiable mix of housing that response to the type or location of the development

2 – Meeting our need for different types, sizes, and tenures of housing (including affordable and specialist housing) by requiring a suitable or negotiable mix of housing that response to the type or location of the development.

Build houses of a better mix on new developments
Mix the sizes

I think options 2, 3.3, 3.4 and 5 are preferable. Regarding standards of building - every dwelling should have 1 off road parking space plus 1 more for each bedroom.

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.

Please find below my response to the RDC Spatial Options Consultation.

Consultation Process -The volume of information contained in the consultation was difficult to access and view online. Some links did not work properly. RDC are not reaching residents who have no internet.

Spatial option 3b North of Southend is most feasible site.

Spatial Themes not included - Cultural and Accessibility.

Employment – District is lacking in Environmental services - woodland conservation and management.

Improve Long-term Economic growth - Better road networks, gigabit broadband and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training. The council should stop developing existing commercial land into housing.

Local generation of low-carbon and renewable energy - New developments should be able to source some or all of their energy from renewable sources. Solar in all new development as standard. Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs; there are many flat roofed buildings all over the district that could accommodate solar panels without damaging the landscape. Explore tidal energy and seek out suitable locations in order to ascertain whether it is viable. Retrofitting existing housing and commercial buildings.

Settlement Hierarchy: Rayleigh is the largest town in the district, but care needs to be taken to maintain the integrity of the existing settlements with respect to green boundary between Rayleigh and its neighbours.

Planned Forms of Housing: Mix of housing for “affordable“ properties with higher standards for gardens and recreational space. Consideration should be given to the provision of Lifetime Homes specifically adapted homes for the disabled and elderly, bungalows and other potential buildings for downsizing families. Housing for the hidden homeless – those “sofa surfing” & Emergency housing. The plan makes no reference to social housing quotas which should be included in all new developments. By working closely with planners and developers, as well as different charities and communities, residents and businesses. You will then get a better understanding as to what you need and what will be achievable.

From 1st August it was announced that empty buildings and brownfield sites should be converted rather than build new. This alternative should be evaluated first.
Many development proposals would also mean a further reduction in air quality, light pollution and the loss of trees, farming, and arable land at a time when food production and supply is becoming a cause for concern.
Enforcement on unauthorised development is not adequately managed.

Infrastructure - The Council cannot comment on the suitability of sites in the plan without completion of Infrastructure Delivery & Funding Plan, Level 2 Strategic Flood Risk Assessment and Local Cycling & Walking Infrastructure Plan.
This is a continuing concern to residents due to the volume of recent and proposed development causing additional pressure on roads, education, social services, health facilities and local employment opportunities all of which gives a sustainable balance for our communities. The Infrastructure Funding Statement states all financial and non-financial developer contributions relating to Section 106 conditions should be completed but this is not the case when larger sites are split up. If developers do not honour the conditions the money reverts to ECC and RDC who should use this to improve our existing facilities, especially on our roads and cycle paths which are in a pitiful state of repair and will only worsen with further development if funding is not used where it was intended.

Balancing access against increased congestion will be the issue for a lot of the sites in Rayleigh. If you keep adding small developments to the boundaries of the town, it will overcrowd existing houses and add to urban sprawl.
i. Rayleigh has taken the brunt of development without significant infrastructural improvement.
ii. Commercial development should be supported in town centres, secondary shopping facilities and on approved industrial estates (the latter should not become retail / entertainment locations and residential development should not encroach on them to avoid conflict). Community Improvement Districts should be established
iii. Community infrastructure should be preserved and extended. Access to town centres and secondary shopping by bicycle and foot should be made easier and safer.

Rayleigh like other towns that have suffered from overdevelopment in recent decades and should be protect from large scale private development during the forthcoming Plan Period. Only development or local needs should be permitted. Local facilities like Mill Hall would be saved and car parking retained and made cheaper to assist local town centre business to survive what will be a challenging period. Secondary shopping facilities in Rayleigh would be supported and encouraged with public finance where required. Sites within the existing Rayleigh Conversation Area should not be considered under any circumstances.
Public transport would be supported and encouragement, especially when given for children to reach school without parents’ vehicles. Renovation and refurbishment of historic buildings with modern green energy would be promoted over demolition and intensification. Public services would be encouraged to return/expand to Rayleigh, in existing buildings like Civic Suite, Police Station and Library etc. The town centre should be the heart of our community not just something you drive through to reach somewhere else. This could be our vision and our aim for the future.
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.
Rayleigh is clearly already overcrowded; it has a road network no longer fit for purpose, some schools are at or near to capacity, it is difficult to obtain a GP or dental appointment. The majority of the town is inaccessible for wheelchair users. There is little to no disabled play areas or play equipment. There are always issues with waste collections, drain and road cleaning and verge trimming. The District Council does not have the staff to deal with all these issues. The council should either build another waste recycling site, or develop a better waste collection program which allows extra waste to be collected next to the bin. The current recycling site at Castle Road is no longer capable of expanding to meet the needs of an ever-growing population. The plan should also identify a site to accommodate commercial waste facilities to stop fly tipping.
Good public transport links are crucial for our villages, neighbourhoods and town centres. The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian, and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a complete review of sustainable transport.
Ensuring that public rights of way are not blocked by landowners and are kept free from debris. Assess paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look at offering this in the larger spaces. For example, a small toilet block and hand washing facilities in a car park.

Open Spaces - The value of our open spaces and the issues with climate change has become a priority. People will continue to reduce travel and split time working from home. Our open spaces are essential for wellbeing, exercise and relaxation. We are on an overpopulated peninsular surrounded by water with one way in and one way out and there is a proven risk of flooding. Open space is at a premium. 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. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets.
All Conservation areas, green belt and sites subject to the exclusion criteria (i.e. Sites of Special Scientific Interest) on the call for sites must be protected from Development.

Local Wildlife Sites review: RDC policies for protecting wildlife areas need to be updated. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was. Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. The plan should create new wildlife meadows to encourage the pollinators to future proof our own existence.

Promoted Sites - Reasons against Development
CFS105 (Land North of Hambro Hill) would negatively impact the openness of the Green Belt between Rayleigh & Hockley. Rochford Green belt study states this parcel of greenbelt has a ‘Moderate’ rating for Purpose 1, and a ‘Strong’ rating for 2 & 3. It checks the unrestricted sprawl of large built-up areas, prevents Rayleigh & Hockley merging into one another, and assists in safeguarding the countryside from encroachment.

It was put forward by an Agent or Developer, not the Landowner. Legal constraints already identified. Landowner recently had planning application (20/00826/FUL) approved so extremely unlikely to support any development: Change of use of land from Commercial to combined Agricultural and Equine use. Site was originally used as part of a landfill tip by the former Rayleigh Urban District Council which ceased around 1960.

Grade 1 Agricultural Land Successfully farmed family business for over 50 years (wheat, barley & rape crops.) Fallow agricultural land, equestrian related grazing & woodland. Portion diversified for Equestrian Centre & agricultural barn for storage.

Infrastructure / Transport Overloaded road with a dangerous junction & poor visibility. Low bridge impact public transport – no double decker buses. No cycle paths or means to incorporate one. No pavements near the access road. Public right of way (PROW 298_48) poorly maintained at entrance to the site.

Heritage Assessment by Place Services ECC Minor Adverse / development of this site will cause harm to a heritage asset. The Historic Environment Record notes various finds from the pre-historic period.

Hockley Woods is the largest remaining wild woodland in the country RDC should be doing EVERYTHING it can to save it from development, either adjacent to or close by. RDC should also actively be adding to it by planting more trees to future proof its existence and status. RDC must protect any thoroughfares that access Hockley Wood.

Rayleigh Civic Suite & Mill Hall Arts & Events Centre
Dr Jess Tipper (Historic England)
Rayleigh Castle survives well both as earthwork and buried archaeological remains. It survives as a prominent earthwork in the centre of the town, with wide views across the landscape to the west. The inner bailey is located to the east of the motte and the outer edge of the inner bailey ditch forms the west boundary to the proposed development site.
The proposed development site is within the outer bailey of the castle, which is believed to have been constructed in the late 12th century AD. This is (currently) a non-designated heritage asset with high potential for below-ground archaeological remains; previous archaeological evaluation within the outer bailey had defined evidence of occupation dating between the 10th and 13th centuries, i.e. pre-dating the construction of the outer bailey. Bellingham Lane follows the outer edge of the outer bailey ditch.
The development has the potential to cause substantial harm to below-ground archaeological remains within the development site. The remains of occupation deposits in this area, functionally related to the castle, may be of schedulable quality. Buried artefacts and palaeoenvironmental remains will also have potential to increase our knowledge of the social and economic functioning of the castle and its relationships with the surrounding medieval town and landscape.
We have, therefore, recommended that the Council commissions an archaeological evaluation, to be undertaken by a specialist archaeological contractor, at the earliest opportunity to establish the significance of surviving archaeological remains in this area. Essex CC Place Services provide archaeological advice on behalf of the District Council on non-designated heritage assets and we would expect them to lead on the brief for this work.
The impact of any proposed development at this location on the setting and significance of the designated heritage assets, including the Grade II Listed windmill, will also require robust assessment - to assess the significance of heritage assets, their settings and the contribution their settings make to the significance, and to assess the impact of the proposals on the significance of the designated heritage assets.

Essex CC Place Services High-Level Heritage Assessment for Rochford District (Oct-2020)
The development of these sites will cause substantial harm to a heritage asset. There are likely no options for mitigation. Proposals causing this level of harm to the significance of a heritage asset should be avoided.
Built heritage - Lies within the Rayleigh Conservation Area and & medieval town extent. Civic Suite site contains GII Listed Barringtons [1168536]
Archaeological impact - The Civic Suite needs archaeological investigation & any development on the Mill Hall Site impacts the scheduled Monument of Motte and Bailey

The Mill Arts & Events Centre is situated within Rayleigh Mount Conservation Area, between main entrance to Rayleigh Mount (National Trust Scheduled Ancient Monument) & Rayleigh Windmill (Grade II Listed Building.)



It has been a hub of the community in Rayleigh Town for 50 years up until the time it was closed in March 2020 due to the COVID 19 pandemic Lockdown. This year is the Mill Halls’ Golden Jubilee, built in 1971, paid for by the Community.

RDC must approve nomination for the Mill Hall to be classed as an Asset of Community Value.

The Mill Hall showcases local Artworks within its Foyer, and has a permanent mosaic completed by children of our schools. From the first step within the building, visitors can immediately feel the sense of culture and creativity. A large noticeboard of all events, shows and clubs available is straight ahead, plus the ‘tourist board’ style information desks is immediately welcoming and accessible for all.
The Mill Hall is popular with residents and visitors to Rayleigh, with a coffee shop and facilities to use after a visit to the many Heritage sites within the Town Centre. This includes the Windmill (open for weddings & tours), Rayleigh Mount, The Dutch Cottage, Rayleigh Museum, and King George’s park when Fair arrives in Town.
The Mill Hall has the performance provision for staging Theatre, Musical Concerts, Comedy shows, Live Bands etc. The venues’ size is ideal for large scale events in the main hall including Professional Wrestling, Dances, Boxing, Children’s exercise classes (Jumping Beans). Upstairs, the smaller hall has capacity and versatility to cover social events including art exhibitions, Exercise Classes, craft fairs. The Mill Hall is frequently used for wedding receptions, birthday parties, funeral wakes, Charity social nights (including Rayleigh British Legion) and local school Proms.

It is utilised as a social meeting place by a significant number of community organisations, groups, clubs, and exercise classes. They make regular use of the Mill Hall throughout the day, as well as evenings and weekends. Consequences of the decision by the Council to keep the Mill Hall closed, some organisations have dis-banded and others have become less well supported.
The Mill Hall helps to put the town on the map as a tourist destination, improving the local economy and supporting other businesses including the many restaurants & pubs in the area prior or after an Event.


Rayleigh’s position within the District - and its proximity/travel links to Southend-on-Sea and Chelmsford - mean it is well placed to attract tourists and visitors who want to visit, eat out and then enjoy an event/show at the Mill Hall, without a long train journey home. The free parking after 1pm on Saturdays already brings in visitors to Rayleigh for shopping, so this would be ideal for evening shows/events at the Mill Hall.
The Mill Hall has excellent potential once renovated & refurbished. More focus/marketing placed on its Theatre staging ability. It could be a magnet for touring theatre groups and become part of the East of England theatre circuit, much like Chelmsford & Norwich.
Objections have been raised throughout the Asset Strategy Delivery Program by non-Administration District Councillors and residents with Rochford District Council over plans to demolish the Mill Hall and redevelop the site with housing. More than 4,000 people from the District have signed a petition opposing the demolition of the Mill Hall and building housing in the Rayleigh Conservation Area.
The Theatre’s Trust - the national advisory body for theatres and a statutory consultee within the planning system, has written to RDC in support of maintaining the Mill Hall performance venue.
Sustainable development as defined through the NPPF (2019) includes a social objective to support social and cultural wellbeing. Paragraph 92 seeks planning decisions to plan positively for facilities and to guard against unnecessary loss.
We do not consider there to be sufficient justification demonstrating the existing Mill venue and the live events it hosts are no longer required.

We would also suggest the economic impact on the town should be considered in terms of loss of audience spend in other businesses when attending shows and events. There will be significant harm to social and cultural wellbeing through the loss of existing events held at the Mill Hall.

Local Authorities are the biggest funder of arts and culture in England. They support cultural activity in their areas in order to provide their residents with a better quality of life, to promote tourism, stimulate the local economy, and build their area’s reputation – creating a unique sense of place. The Partnership Panel meeting earlier this year requested Officers research funding for the Mill Hall via Arts Council. Has this been completed and what opportunities are there to support this fantastic venue?

At the moment, it appears that the Council are attempting to force development on to the existing residents of the district so that our once beautiful area makes us feel like we are hemmed in from all sides with no consideration for our needs or wellbeing.

The development on Hall Road is an example, where a loop hole was found to get away with not building the relevant facilities such as doctors and schools that were originally advertised.

The Developer gets rich from selling the properties, the council get rich from the additional revenue (which as a side note makes it disgusting that you are cutting your services) and the only people who lose out are the people who already live here.

The following points need to be considered:

- Suitable roads, doctors and school facilities must be incorporated into these developments without any loop holes that stop this from happening.

- Green belt land to be left well alone. We are a peninsula that should be encouraging wildlife, not killing it and scaring it away.

- buildings should fit in with the historical content of our area.

- affordable houses should be given to local people and not people shipped in from other areas.

How can this area possibly take the amount of housing proposed!
Green belt disappearing, gridlocked roads , appointments impossible to obtain at doctors surgeries . Houses and gardens on top of each other.
It’s crazy

I am writing to object to the recently released housing planning document under the new area plan.

The sheer volume of housing proposed risk damaging the look and feel of our community and the village feel we all love.

Additionally I object based on the lack of infrastructure investment on both the new area plan and the handling of the queen Elizabeth development. The lack of embarrassment clauses and section 106 orders was negligent.

I also object as an area of the greatest of concern; being the level of pollution and congestion that the new developments will exacerbate. The council is already aware of the main road Hockley being above EU legal limits and main roads in the area being some of the most congested in the country. What is the legal position should the general public challenge these developments on the grounds of already high levels of pollution?

Reading through your proposals i have no faith what so ever that the local people will be listened too. Rayleigh and Hullbridge has already sustained mass building, where infrastructure has been completely ignored.

Why has the council made these things so difficult to make comments ? Why havent you created an online form with everything proposed for each area and a space for people to list their comments.

Rayleigh has nothing to offer people when you look at what other councils do for their tax payers.

Why are you not building council housing for local people ? You sold off a lot of the council housing but never replaced it.

We all know affordable housing isnt actually affordable and the current housing list is 12yrs plus, thats even if you qualify to go on there.
Its more like ethnic cleansing of the locals as no one can afford the housing, its all being taken by people from London as they have sold there propertys for loads of money and can afford to buy the housing being built locally, we should not be Londons dumping ground.

With crime increasing we have no walk in police station.

My brother in law needed an ambulance and they had been sent from chelmsford and needed directions for southend hospital.

Rayleigh needs a proper small injurys unti that runs 24hrs a day including dental, no one can get nhs dentists or appointments at the doctors now, southend hospital has the longest waiting lists in the country do you honestly think by mass building in this area it will help. Rayleigh desperatly needs a medical center.

The traffic in rayleigh is at a standstill in rush hour a lot of the time, the air pollution is already awful and not meeting guidelines.

Have you seen the state of the roads and pavements they are too small and dangerous for older people.

Leave our greenfield sites and parks alone, rayleigh is in danger of loosing what was good about it, you dont keep our parks looked after, there is no swimming pool in rayleigh, i could never understand why you didnt build a pool behind rayleigh liesure center liads of room less cars on the road as people could walk there and it would be used.

If you need anything medical or liesure you have to travel out of rayleigh, putting more traffic on the roads, its irressponsible to put peoples health and wealthfare after mass building of the wrong sort.

Infustructure has to come before building the people of Rayleigh have already been pushed to their limits over the mill hall now this, its unacceptable and seems to be greed over wealthfare.

Theses builders will be claiming all the government bonuses get the land cheap build the houses and make them so expensive, rayleigh becomes over crowed, the locals are forced out the area as they cannot afford to live here. It has to stop.

1.1. On behalf of our client Pigeon Investment Management Ltd, Savills (UK) Ltd has been instructed to prepare a response to the Rochford New Local Plan: Spatial Options Consultation Paper (July 2021).
1.2. Pigeon Investment Management Ltd are promoting Land north of Greensward Lane (also known as ‘Woodside Park’), Hockley, on behalf Pigeon (Hockley) Ltd; Graham Pattrick, Jill Newman and Jacqueline Strong; Ann Harris; and Chris Short (the ‘landowners’ of Woodside Park). The site is located to the north west of Hockley, and is bound by built development to the south, east and west and Beckney Wood to the north. Whilst the site is currently located in the Green Belt, it is well contained by its existing environment and it is considered its allocation will play an important role in meeting the District’s housing needs and importantly the affordability issues identified in Hockley.
1.3. The concept for Woodside Park is for a high-quality landscape-led sustainable scheme of approximately 100 new homes of a variety of different sizes, types and tenures, together with associated supporting infrastructure, amenity greenspace, and landscaping. The site is located within a highly sustainable location with access to key services and facilities including primary and secondary schools, a doctors surgery and the train station within walking distance of the site.
1.4. There are no significant landscape, ecological, heritage, utilities or drainage constraints that would prevent the scheme being delivered. The site would make a valuable, and sustainable, contribution to meeting housing needs, and could do so in the short-term.
1.5. The site, as shown on the submitted Location Plan, is formed of a number of sites submitted to the HELAA as follows:

• CFS023 (Land north and east of Malvern Road, Hockley)
• CFS197 (Land r/o 185 Greensward Lane, Hockley)
• CFS199 (Land r/o 155 Greensward Lane, Hockley)
• CFS201 (Land adjacent 41-45 Crouch View Crescent, Hockley)
• CFS204 (Greensward Lane, Hockley)
1.6. In addition to these, a parcel of land to the east of CFS023 is also included within the Woodside Park site, which has not previously been submitted to the HELAA Call for Sites.
1.7. We have responded to the following questions in the consultation, in the order that they are asked (we have sought to not be repetitive and thus cross-refer when a matter relates to more than one Question):
• Question 1: Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
• 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?
• Question 5: Do you agree with the settlement hierarchy presented?
• Question 6: Which of the identified strategy options do you consider should be taken forward in the Plan?
• Question 7: Are there any reasonable alternatives to these options that should be considered instead?
• Question 8 Are there any key spatial themes that you feel we have missed or that require greater emphasis?
• Question 14: 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?
• Question 17: With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing
• Question 18: 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?
• Question 58a: Do you agree with our vision for Hockley and Hawkwell?
• Question 58b: 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?
• Question 58c: Are there areas in Hockley and Hawkwell that development should generally be presumed appropriate?
1.8. In support of this submission, the following documents are enclosed:
• Site Location Plan

• Woodside Park Delivery Statement
This sets out our vision for the site including deliverability objectives, key constraints and opportunities and design objectives for the site.
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?

1.9. Yes. As discussed in our response to other Questions, we consider that further work is required in relation to the following:
1. The housing requirement, including to: i) understand the implications of the proposals contained within the emerging Southend-on-Sea Local Plan; ii) a suitable deliverability buffer; and iii) establish a housing requirement (see our response to Question 6).
2. An update to the Strategic Housing Market Assessment (SHMA). The South Essex SHMA was prepared in 2016 and updated in 2017. The SHMA is thus out of date with national policy, and does not factor in the impact of either Brexit, or the Covid-19 pandemic, and unless updated will become increasingly out-of-date as the preparation of the new Local Plan progresses.
Green Belt Study

1.10. The Green Belt Study Part 1 (2020) should be further updated to include a finer grained approach to key settlement edges. Some parcels (i.e. P19) are so large in scale it is not considered balanced and accurate conclusions can be drawn with the regards to the contribution the land makes to the Green Belt.
1.11. P19 extends to over 1,000 hectares from the north eastern edge of Hockley to the south western corner of Rayleigh (see Figure 1 below). It is difficult to comprehend how the Green Belt on the edge of Hockley can play the same role as land west of Rayleigh or south of the village of Hullbridge.
1.12. Figure 1: Extent of P19

1.13. Rayleigh and Hockley are identified as Tier 1 and 2 settlements in the settlement hierarchy respectively, and it is assumed both settlements could accommodate a significant proportion of required growth over the emerging plan period. Both settlements are tightly constrained by the Green Belt and thus it is considered inevitable that land will need to be released from the Green Belt adjacent to both settlements to help meet the District’s housing needs.
1.14. Whilst Stage 2 of the Assessment looks at specific areas on the edge of settlements in more detail, this simply draws on the conclusions of Phase 1 and if the contribution was high, then the harm was also considered high. These smaller edge of settlement areas (i.e. those that fall within parcel P.19) have not been appropriately assessed against the purposes of the Green Belt as advised by numerous planning inspectors as advised by Planning Inspectors (i.e. Welwyn and Hatfield, Cambridge and South Cambridgeshire).
1.15. Turning to the assessment of the area of land to the north east of Hockley (i.e. land north of Greensward Road), Stage 2 of the Green Belt Assessment concludes:
"The majority of the assessment area makes a strong High contribution to preventing encroachment into the countryside and a moderate contribution to checking sprawl from the large urban area and preventing the merging of towns. The north western corner of the assessment area which is more contained by the urban edge of Hockley and the woodland block makes a moderate contribution to all of the aforementioned purposes. Apart from a couple of isolated, detached dwellings which are not urbanising, the assessment area is open and undeveloped. With the exception of the north western corner the wooded Harrogate Drive along the south western edge of the area maintains distinction from the inset urban area, although its relationship with the wider countryside to the north is restricted by woodland. Release of the assessment area would impact adjacent Green Belt to the east due to the weaker boundary features at the edge of the assessment area and it would reduce the justification for retaining the existing washed over development in the Green Belt"

1.16. The assessment states that the area is open and undeveloped. The dwellings which front Greensward Road are within the parcel and given their number, it is incorrect to refer to them as being ‘isolated’.
1.17. Furthermore, the relationship with woodland to the north is the same for all these ‘high harm’ parcels as it is for P46 which was identified as having moderate harm. The woodland to the north and road to the south are narrowing on plan, providing more containment, and the boundary to the west edge of P198 is strong, defensible and permanent by virtue of the existing strong wooded vegetation. As a result the degree of containment becomes greater.
1.18. In conclusion, whilst it is appreciated that it is not the purpose of the Green Belt assessment to assess every site submitted for inclusion in the Local Plan, it is not considered that the conclusions drawn for the land within P19 can be used to determine which sites should be released from the Green Belt. Please see our response to Question 58b for an assessment of Woodside Park against the purposes of the Green Belt.

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?

1.19. Yes. See also our response to Question 6.

Q5. Do you agree with the settlement hierarchy presented?

1.20. Yes. We fully support the proposed settlement hierarchy. In particular, we support the identification of Hockley as a Tier 2 settlement.
1.21. Hockley is a wholly sustainable settlement with key services which include a train station, a secondary school, three primary schools, numerous employment sites and a town centre.
1.22. Its identification as a Tier 2 settlement reflects the important role it currently plays in servicing existing communities, including those in neighbouring villages, and the role it can play in supporting new growth. The distribution of a significant proportion of the proposed growth to Hockley will be essential to ensure the identified affordability issues can be addressed through the provision of new market and affordable homes. We discuss this matter and the quantum of housing in our response to Question 6.

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

1.23. Prior to discussing the four strategy options set out in the consultation, we have discussed the following matters, which provide important context to the options proposed:
• The Implications of the Emerging Southend-on-Sea Local Plan Consultation;
• Local Housing Need and the Housing Requirement;
• Housing Provision and the Spatial Distribution of Housing, and in relation to this:
• Implications of the Proposed Distribution of Growth for Hockley
The Implications of the Emerging Southend-on-Sea Local Plan Consultation
1.24. This representation is to the consultation on the emerging Rochford Local Plan only, and not to the Regulation 18 ‘Refining the Plan Options’ consultation on the emerging Southend-on-Sea Local Plan. However, given the content of the Southend-on-Sean consultation documentation, that consultation is very pertinent to the consultation on the Rochford Local Plan. In short, the Southend-on-Sea consultation concludes (Table 12) that, of the four strategy options considered, the only way that Southend-on-Sea can meet its identified housing needs is via the provision of 4,900 new homes to the north of the Borough, within Rochford.
1.25. The ‘proposed’ location of these 4,900 new homes (as an extension of the 7,200-home new neighbourhood within Southend-on-Sea), extending eastward from the immediate environs of the airport and southern point of Rochford town-centre has direct implications on what will be an appropriate and sustainable approach to the distribution of growth within Rochford itself.
1.26. Strategy Option 3 is stated as being:
“… to concentrate growth in one or more locations of 1,500+ dwellings. Option 3 has three sub-options based on locations where there is likely to be sufficient land being promoted to deliver this scale of growth in a co-ordinated way:
• Option 3a: Concentrated growth west of Rayleigh
• Option 3b: Concentrated growth north of Southend
• Option 3c: Concentrated growth east of Rochford”
1.27. Option 3b is essentially what is proposed within the current Southend-on-Sea Local Plan consultation, albeit that proposes a much higher level of growth in that location. With this location being proposed to accommodate growth from within Southend-on-Sea, it cannot also accommodate growth from within Rochford. Whilst the quantum of new homes within this area could be increased further to accommodate growth from within Rochford, with the Southend-on-Sea consultation already proposing 12,100 new homes in the area, it is considered that further increasing this number would be neither sustainable nor deliverable within the plan period. Option 3b is thus essentially negated as a viable option by the Southend-on-Sea proposals.
 
1.28. In this context, Option 3c would constitute further strategic development within just a few km of the Southend-on-Sea proposals. As above, it is considered that further increasing this number would be neither sustainable nor deliverable within the plan period. It would result in a more than significant impact on that part of the District and whilst larger-scale development does offer the ability to deliver more major infrastructure, it is considered that the social, economic and environmental impact of over 13,600 new homes, on that part of the District would be dramatic.
1.29. In addition, both Rochford and Southend-on-Sea fall within the same Housing Market Area (HMA). If the Rochford Local Plan were to focus the delivery of a major proportion of its housing needs within the same geographic area as the Southend-on-Sea Local Plan, this would undoubtedly result in a local imbalance between housing need and supply (noting the need for different sizes, types and tenures), and increase the risk of under-delivery resulting from the saturation of the local housing market. The emerging Rochford Local Plan notes at various points within the consideration of the Strategy Options that the risks of under-delivery can be mitigated by “… having a more diverse mix of sites and locations …”.
1.30. In summary, given the conclusions in the current Southend-on-Sea consultation, of the three sub-options to Strategy Option 3, only one – concentrated growth west of Rayleigh is thus considered to remain a viable, sustainable and deliverable possibility.
1.31. This not only has implications for Strategy Option 3, but also for Strategy Option 4, which is proposed as a ‘balanced combination’ “… making best use of urban capacity (Option 1), building one or two large growth areas (Option 3) and a number of smaller urban extensions (Option 2)”.
Local Housing Need and the Housing Requirement
1.32. The Spatial Options consultation explains (p. 12):
“Rochford is a district that is home to around 87,000 people across a mix of urban and rural settlements. Our population has grown around 4% over the last 10 years and is projected to grow by a further 12% over the next 20 years. This would make our population around 98,000 people by 2040.”
1.33. It proposes five ‘strategic priorities’, the first of which is (p. 21):
“Strategic Priority 1: Meeting the need for homes and jobs in the area”
under which it proposes six ‘strategic objectives’, the first two of which are:
“Strategic Objective 1: To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs, through working with our neighbours in South Essex and prioritising the use of previously developed land first.
Strategic Objective 2: To plan for the mix of homes needed to support our current and future residents, in particular viably addressing affordability issues and supporting our ageing population, including the provision of private and social care schemes.”

1.34. The first of these objectives thus relates to the number of new homes to be provided, whilst the second relates to the mix (i.e. size, type and tenure) of homes.
1.35. The NPPF requires (para. 61) (our emphasis):
“To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance – unless exceptional circumstances justify an alternative approach … . In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.
1.36. The PPG expands on this, explaining (ID: 2a-002-20190220) (our emphasis):
“What is the standard method for assessing local housing need?
... The standard method … identifies a minimum annual housing need figure. It does not produce a housing requirement figure.”
and (ID: 2a-010-20201216) (our emphasis):
“When might it be appropriate to plan for a higher housing need figure than the standard method indicates?
The government is committed to ensuring that more homes are built and supports ambitious authorities who want to plan for growth. The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.
This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of:
• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or
• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground; …”
1.37. The consultation reflects this guidance, stating (p. 24):
“National policy … requires Local Plans to provide strategies that accommodate unmet need from neighbouring areas where it is practical to do so and is consistent with achieving sustainable development. Whilst the scale of unmet housing need from others’ plans, including those from elsewhere in South Essex and London, is not fully known, it is possible that building more than 360 homes per year, if sustainable to do so, could help to accommodate some of this need.”
1.38. In this context, the consultation discusses a range of growth scenarios, which are summarised in Figure 15 as:
1. Current Trajectory
“Approximately 4,500 new homes by 2040 can be delivered by maximising urban and brownfield capacity and windfalls. …”
2. Standard Methodology
“7,200 new homes by 2040 would meet the Council’s housing needs based on the current standard method …”
3. Standard Methodology + 50% Buffer
“10,800 new homes by 2040 would meet the Council’s housing needs based on the current standard method, with an additional 50% buffer which could help to drive local economic growth or address unmet need from elsewhere”
1.39. It should be noted that whilst the Standard Method Local Housing Need is approximately 360 homes per year (362.6 dpa based on the latest available figures), this is ‘capped’ – the cap being applied at a level of 40% above the projected increase in households. The uncapped housing need figure would be approximately 380 homes per year, which over the 20-year plan period would equate to a need for 7,600 new homes.
1.40. In addition, as we discuss later in this representation, it is evident that Southend-on-Sea cannot meet all of its housing need within its own boundary and is now proposing that the only way it can meet its need is to accommodate approximately 3,950 new homes within Rochford (over the period 2020 to 2040). Adding this to the (capped) minimum housing need for Rochford results in the need for the emerging Local Plan to provide for at least 11,150 new homes.
1.41. As such, we do not support the ‘Current Trajectory’ growth scenario, nor do we support the ‘standard methodology’ growth scenario unless Southend-on-Sea are able to demonstrate an alternative means of accommodating their need. We do support the ‘Standard Methodology + 50% Buffer’ growth scenario, albeit we consider that this should provide for at least 11,150 new homes, not 10,800. We also consider that the reference to a ‘buffer’ should be deleted as this is misleading given that the scenario would only meet Rochford’s own needs plus unmet needs from Southend-on-Sea; it would not meet any other unmet needs from elsewhere in South Essex or London (as the consultation moots), nor would it include any more housing than the minimum to ‘help drive local economic growth’.
1.42. In order that sufficient sites are identified to ensure that the minimum housing need is delivered, it is good practice to add a ‘buffer’ of 5 or 10% when establishing the amount of housing to be provided for in a Local Plan. Adding such a buffer to the minimum need identified above would result in the Rochford Local Plan having to identify sufficient sites for between 11,700 and 12,300 new homes (including that to be provided as part of the unmet need from Southend-on-Sea), or between 11,500 and 11,900 if the 5 to 10% deliverability buffer is only added to Rochford’s own minimum need.
1.43. Overall, we consider growth of between 7,500 and 7,950 new homes over the plan period would, assuming an average occupancy of 2.4 people, equate to an increase in the population of the District of between 18,000 and 19,000 people – approximately a 20% increase on the existing population of 87,000.
Housing Provision and the Spatial Distribution of Housing
1.44. The consultation explains (p. 24):
“Our Housing and Economic Land Availability Assessment (HELAA) 2020 identifies a supply of over 4,300 homes that are already planned for. This includes existing allocations, sites with planning permission and an allowance for windfall development of around 45 homes a year.”
1.45. The June 2020 HELAA is now over a year old but provides a helpful breakdown of the 4,300 figure, as it applies to the 20-year period 2019/20 to 2038/39 as follows:
1. Extant permissions: 2,397
2. HELAA sites (deliverable in accordance with existing policy): 239
3. Unimplemented allocations and other: 1,019
4. Windfall allowance: 765
Total: 4,320
1.46. The HELAA identifies that 285 homes were expected to be delivered during 2019/20. Whilst these homes should now be removed from the projected supply for the plan period (which commences with the year 2020/21), it is considered likely that a similar number of homes will have been permitted, meaning that the existing projected supply over the plan period probably remains at approximately 4,300 homes.
1.47. With reference to the ‘Current Trajectory’ growth scenario, the consultation notes (p. 25):
“Approximately 4,500 new homes by 2040 can be delivered by maximising urban and brownfield capacity and windfalls. …”
1.48. This would suggest that, in addition to the sites identified in the HELAA (including windfalls), there is the scope to accommodate just 200 additional dwellings through the maximisation of urban and brownfield capacity. However the HELAA identifies no supply in terms of additional ‘urban capacity’ thus it is assumed that the 4,500 figure referenced is either a rounding up of the 4,320 figure in the HELAA, and/or a rolling forward of this to account for more recent permissions. In either case it is considered reasonable to assume that the available, suitable and deliverable supply in Rochford at the time of writing is approximately 4,300 to 4,500 homes.
1.49. Given this, the ‘Standard Methodology’ and ‘Standard Methodology + 50% Buffer’ growth scenarios would require the identification of new sites sufficient to provide for between 2,700 and 6,300 new homes. However, as we have discussed above, a deliverability buffer should also be included such that new sites sufficient for between 3,000 and 3,450 new homes should be identified, plus the 3,950 proposed in the Southend-on-Sea Local Plan.
1.50. As we discuss above, we consider that Strategy Option 1 ‘Urban Intensification’, is unsound as it will not deliver the required quantum of housing. We also conclude that the proposals contained within the Southend-on-Sea consultation mean that only one of the potential locations identified in Strategy Option 3 ‘Concentrated Growth’, and thus also Strategy Option 4 ‘Balanced Combination’ (of Options 1, 2 and 3) – i.e. land west of Rayleigh, is considered to remain a viable, sustainable and deliverable possibility. Overall, it thus seems apparent that the only sound approach to accommodating Rochford’s housing need is to make best use of existing commitments and urban intensification to deliver approximately 4,500 new homes, and to identify additional small and medium sized sites across the District, with reference to the settlement hierarchy, potentially including the land west of Rayleigh .
1.51. The Strategy Options Topic Paper 2021 includes at Figure 1 a map showing the results of the ‘clustering’ exercise carried out with regard to the sites promoted for development. We consider this to have been a useful exercise to enable a better understanding of how the promoted sites ‘fit’ in the context of existing settlements and the context of other promoted sites. The clustering exercise identified 12 clusters, which we have ordered in Table SAV01 below as per the proposed settlement hierarchy (from Figure 14), insofar as this is possible. To this we have added the existing population (from Figure 7), and then converted this to establish approximately the number of existing homes in each area (utilising a conversion factor of 2.4 people per dwelling as per Figure 14 in the consultation).
1.52. We have then, extrapolated a 20% increase in the number of homes in each area. This approach, which is relatively simplistic, does not factor in the extent of land promoted for development, constraints or settlement / site specific factors, sustainability considerations, or extant commitments / windfall capacity, broadly reflects what is proposed in Strategy Option 2b ‘Urban extensions dispersed to settlements based on hierarchy’, albeit it applies an across-the-board percentage increase in housing.
1.53. We have then weighted aspects of this to more closely reflect an approach that is based on the settlement hierarchy, with a higher proportionate growth applied to settlements in the higher tiers – this also more closely reflects what is proposed in Strategy Option 2a ‘Urban extensions focused in the main towns’, which is considered likely to be a more sustainable approach.
1.54. In doing this we have also:
1. Included figures for the unmet need from Southend-on-Sea.
2. Given (1), reduced slightly rather than increased the proportionate growth at Rochford and Ashingdon (as discussed above).
3. Included for the potential of concentrated growth west of Rayleigh.
4. Given (3), not increased the proportionate growth at Rayleigh.
1.55. This approach results in a growth of 7,850 new homes (excluding the unmet need from Southend-on-Sea), well within the 7,500 to 7,950 range identified above.
1.56. If it is concluded that concentrated growth to the west of Rayleigh cannot be supported, then this approach would direct that growth to a combination of Rayleigh (e.g. increasing to c. 30% growth / 4,000 new homes) and Hockley (increasing slightly to nearly 2,000 new homes).
1.57. As noted, the above is relatively simplistic, does not factor in the extent of land promoted for development, constraints or settlement / site specific factors, sustainability considerations, or extant commitments / windfall capacity. Whilst a useful starting point, it will be for the Council to take all of these matters into account in identifying suitable sites for allocation and confirming the distribution of growth.
Implications of the Proposed Distribution of Growth for Hockley
1.58. As noted above, the June 2020 HELAA identifies existing housing supply, for the period from 2019/20, as follows:
1. Extant permissions: 2,397
2. HELAA sites (deliverable in accordance with existing policy): 239
3. Unimplemented allocations and other: 1,019
4. Windfall allowance: 765
Total: 4,320
1.59. The Council’s 2019/20 AMR identifies a similar, also for the period from 2019/20, supply as follows:
1. Extant permissions & resolutions to grant: 2,312
2. HELAA sites and other: 240
3. Unimplemented allocations: 900
4. Windfall allowance: 765
Total: 4,217
1.60. Of these sites, only sites for approximately 250 new homes are within Hockley and Hawkwell. On this basis it is considered that the emerging Local Plan should seek to make allocations at Hockley / Hawkwell sufficient for at least a further 1,550 new homes, and that these should be spatially balanced and include sites to the west, north and south-east of Hockley.
The Strategy Options
Option 1: Urban Intensification
1.61. As discussed above, this Option will not be able to meet the Councils growth needs. Option 1 is thus unsound, is contrary to national guidance, and should thus be discounted.
Option 2a: Urban extensions focused in the main towns
1.62. This option is supported, so long as a mix of sites and sizes are proposed. In accordance with the draft Settlement Hierarchy, Rayleigh, Rochford and Hockley are the most sustainable settlements in the District and thus the most sustainable locations for growth.
1.63. However, if such a strategy is proposed, it is essential that in addition to large scale urban extensions, a sufficiently high proportion of small to medium sized sites are identified. Such sites are more likely to be available in the shorter term, offer a suitable location for development in the shorter term, and be achievable with a realistic prospect that housing will be delivered on site in the short term. This is essential if the Council is to deliver a rolling five year housing land supply across the plan period.
1.64. In summary, Option 2a is considered sound. It would result in new homes being delivered consistently across the plan period in the most sustainable locations, close to existing services and facilities. New development on settlement edges (i.e. at Woodside Park on the north eastern edge of Hockley) will also provide the opportunity to enhance existing areas and communities and gateways into the towns.
Option 2b: Urban extensions dispersed to settlements based on hierarchy
1.65. As with Option 2a, this option is supported so long as a mix of sites are proposed including a high proportion of small to medium sized sites.
1.66. We welcome that this option would base the distribution of development based on settlement hierarchy. As discussed above, as the most sustainable settlements in the District, it is considered a higher proportion of growth should be distributed to the main towns of Rayleigh, Rochford and Hockley which are the most sustainable locations for development in the District.
1.67. In summary, Option 2b is considered sound. As with Option 2a, it would result in new homes being delivered consistently across the plan period in the most sustainable locations, such as at Woodside Park.
Options 3a, 3b & 3c: Concentrated Growth
1.68. We strongly oppose Strategy Option 3 for a number of reasons.
1.69. Firstly, there are significant challenges associated with the delivery or large scale sites which mean they are highly unlikely to come forward in the first five years of the plan. Such challenges include:
a) Large sites containing concentrated growth take a significant time to deliver due to their complex nature and long preparation, planning and overall lead-in times before development starts.
b) Such sites rely on a significant amount of upfront infrastructure. The upfront costs associated with sustainable urban extensions means they tend to make lower contributions to affordable housing, of which there is a significant shortage in Rochford.
c) If the new Local Plan were to be reliant on effective delivery of a small number of large schemes, and the failure of just one extension to deliver will result in a shortfall of housing throughout the Plan period.
1.70. Furthermore, this strategy would limit growth to Rayleigh and Rochford, such that the needs of other communities would not be met.
1.71. For example, pursuance of Option 3 will result in no planned growth at Hockley, a Tier 2 settlement which is wholly capable of accommodating new homes. As noted on page 77 of the consultation, housing availability and affordability is a key issue in this part of the District. Thus, in order to address this, a significant amount of new growth should be directed to Hockley, which would not occur with Option 3.
1.72. In summary, Options 3a, b and c are not considered sound, and should be discounted at this stage.
Option 4: Balanced Combination
1.73. This option is broadly supported, in principle, and noting the discussion above provided the Council are realistic when it comes to the distribution of growth. Development on brownfield sites and, as set out above, large scale urban extensions can take a long time to come forward and it is therefore essential small to medium sized sites are allocated to ensure a supply of homes across the plan period.
1.74. We would therefore support Option 4 providing a significant proportion of required growth is allocated to Hockley. Hockley is one of the least affordable areas in the District, and new growth is essential to address the worsening availability and affordability crisis.
Summary
1.75. Overall, we advocate a balanced, weighted distribution of growth, that takes into account the proposals in the emerging Southend-on-Sea Local Plan, similar to that set out above at Table SAV01.
Site Appraisal Paper (2021)
1.76. As noted above, Woodside Park (see site Location Plan) is formed of a number of sites submitted to the Call for Sites as follows:
• CFS023 (Land north and east of Malvern Road, Hockley)
• CFS197 (Land r/o 185 Greensward Lane, Hockley)
• CFS199 (Land r/o 155 Greensward Lane, Hockley)
• CFS201 (Land adjacent 41-45 Crouch View Crescent, Hockley)
• CFS204 (Greensward Lane, Hockley)

1.77. A parcel of land to the east of CFS023 is also included within the site boundary, which was not previously submitted to the HELAA Call for Sites.
1.78. In light of the above, it is requested that the sites are reassessed as a single site so that a full assessment of the site and suitability for development can be assessed. For the purposes of this response, however, we have reviewed the assessment of each of the above sites as contained in the Site Appraisal Topic Paper; our comments are set out at Appendix 1 to this response.

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

1.79. Further to our response to Question 6, it is considered that the Council should assess a fourth growth scenario that does include a buffer to ‘help drive local economic growth’ as a ‘reasonable alternative’. Failure to do so would mean that the growth scenario that is proposing to meet the highest quantum of growth is only providing for the minimum need, plus a small buffer to ensure deliverability. Not proactively considering a higher level of growth than this minimum could jeopardise the progress of the Plan.

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

1.80. See our response to Question 6.

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?

1.81. Yes. We consider that ‘place-making’ is crucial to the creation of well-designed and socially-inclusive communities. Whilst many of the same principles apply to all sites, any place-making charter should recognise that every site, and every solution, will be different.
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?
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?

Housing Mix
1.82. The NPPF requires (para. 65):
“Within [the context of the overall identified housing need], the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to, those who require affordable housing, families with children, older people, students, people with disabilities, service families, travellers, people who rent their homes and people wishing to commission or build their own homes).”
Self / Custom Build
1.83. The 2016 Housing and Planning Act introduced the so-called ‘Right to Build’ requirement, requiring local authorities to grant sufficient permissions for self and custom build plots to meet local demand.
1.84. As noted in the Government’s self and custom build action plan (April 2021),
“The self and custom build sector is under-developed in the UK. In Europe and North America, the sector delivers a much higher proportion of housing output. Only 7% of homes in UK are built via self and custom build, delivering an estimated 13,000 units in 2018. Nonetheless, even at this underdeveloped scale, this level of output is enough to make the sector the equivalent of UK’s fourth largest housebuilder. There is capacity to expand and if we increased to levels similar to the Netherlands, we could see 30-40,000 self and custom build homes built annually.
The government is committed to increasing the number of self and custom build homes in this country and to establish it as a mainstream option for people to choose to get on the housing ladder or when moving home. The government has previously brought forward initiatives to tackle the barriers to the growth of the sector, and now we are bringing these initiatives and new ones together under one self and custom build action plan.”

and with regard to access to land:

“This legislation created a duty on local authorities to keep a register of demand for self and custom build in their area and permission serviced plots suitable to meet that demand within 3 years. Since April 2016, all local authorities have established a register.”
1.85. Demand is measured by the number of people registering on Right to Build registers. This legal requirement came into force after the publication of the 2016 SHMA and the matter was not addressed in the 2017 addendum. For data protection purposes, Rochford’s register is not publically available. However, as part of a new/updated SHMA, existing and future need for self and custom build homes would be assessed, providing evidence to determine future need in Rochford.
1.86. The Housing Topic Paper published alongside the consultation notes (para. 10.20):
“… Currently the Rochford District Custom and Self build register has 83 entries as of April 2021.”
1.87. However this is only a statement of current, existing, need, not an assessment of likely need over the plan period.
1.88. We are proposing that the Woodside Park site include approximately 12 to 15 self / custom build plots, alongside bungalows and other specialist accommodation.

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

1.89. The consultation proposes the following ‘vision statement’ for Hockley and Hawkwell:
“In 2050, Hockley and Hawkwell should be the District's gateway to the green lung of the Upper Roach Valley, making the most of its access to ancient woodland and a network of nature reserves. Its town and neighbourhood centres should be vibrant places with an emphasis on independent businesses and providing for a diverse range of jobs. Deprivation should continue to be largely absent from Hockley and Hawkwell however housing affordability should have been addressed to ensure that local first-time buyers can greater afford to live locally.”
1.90. We support the Council’s proposed vision for Hockley, and welcome the acknowledgement that access to the surrounding ancient woodland should be enhanced. Access to nature plays an essential role in promoting health and wellbeing, whilst well managed and planned trails can ensure appropriate use and management.
1.91. We also welcome the aspiration to address housing affordability which is identified as a key issue for Hockley. It is vitally important a mix of homes are provided to meet the needs of all. At Woodside Park, we are proposing a wide mix of homes including policy compliant affordable housing and self / custom-build plots.

 
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?

1.92. We fully support the allocation of land to the north of Greensward Lane (see Site Location Plan), Hockley which comprises:
• CFS023 (Land north and east of Malvern Road, Hockley)
• CFS197 (Land r/o 185 Greensward Lane, Hockley)
• CFS199 (Land r/o 155 Greensward Lane, Hockley)
• CFS201 (Land adj 41-45 Crouch View Crescent, Hockley)
• CFS204 (Greensward Lane, Hockley)
And also land to the east of CFS023 which was not previously submitted to the Call for Sites.
1.93. This response is accompanied by a Delivery Statement which provides further details of the site, and demonstrates that the site is deliverable and there are no known technical constraints which could prevent the delivery in the first five years of the Plan.
Site Overview
1.94. Woodside Park would include a high-quality landscape and design-led sustainable scheme of new homes of a variety of different sizes, types and tenures, together with associated supporting infrastructure, amenity greenspace, and landscaping. The SHELAA sites all received positive assessments in the 2017 SHELAA assessment, which concluded the sites are available, suitable (subject to release from the Green Belt), and achievable to which we concur.
1.95. The land is located to the north east of Hockley, to the north of Greensward Lane and south of Beckney Wood. It is located within a highly sustainable location with access to key services and facilities with primary and secondary schools, doctors surgeries and the train station, amongst others, all within walking distance of the site, as can be seen from the Facilities Plan included in the Delivery Statement.
1.96. The concept for Woodside Park is for a high-quality landscape and design-led sustainable scheme of approximately 100 new homes of a variety of different sizes, types and tenures, including self/custom build homes and bungalows together with associated supporting infrastructure, amenity greenspace, and landscaping. It is envisaged the site could deliver:
• Family homes
• Policy compliant affordable homes
• Bungalows
• Self-build
• Custom-build
• Housing for older people
• Housing for those with specialist needs
1.97. The Delivery Statement accompanying this response demonstrates that Woodside Park could include provision for substantial new areas of:
• Amenity greenspace
• Play facilities
• Community orchard planting
• Wildflower meadow planting
• Ecological habitat
• Landscaping
• Woodland
together with street trees and extensive areas of new planting throughout.
1.98. Initial technical studies have concluded there are no landscape, ecological, heritage, utilities or drainage constraints that would prevent the scheme being delivered.
Green Belt
1.99. The site is currently located in Green Belt, however, it is considered to make a limited contribution as set out below.
1.100. The Rochford and Southend Green Belt Study is a two part study which identifies the site as falling within two parcels of land, P19 and P46. The results of the assessment show that the Council recognise that overall, the Site does not contribute very strongly to the Green Belt Purposes and is one of the weaker performing Sites.
1.101. A summary of the Council’s study in respect of Parcel P19 reveals the following:
[see document]

1.103. As noted in our response to Question 1, Part 1 of the Green Belt Study should be further updated to include a finer grained approach to key settlement edges. By way of an example, P19 extends to over 1,000 hectares stretching from north east Hockley to south west Rayleigh. Accordingly, an assessment relative to a small part of that larger parcel is very likely to result in a different outcome and the assessment of P19 should be treated with caution.
1.104. In this instance, the assessment relating to Purpose 3: Openness, is skewed by the huge scale of the parcel, such that when the very small part of the Site is considered in isolation, the Purpose 3 Openness score of ‘Strong’ is incorrect, and should be no greater than Moderate – the Site is influenced strongly by the built up area to the south and west, but is also contained by rising landform and woodland to the north, resulting in a reduced relationship with the wider countryside (than the wider parcel).
1.105. Similarly, it is considered in respect of the individual site that the score of ‘Moderate’ for both Purpose 1 (Sprawl) and Purpose 2 (Merging of Towns) are overstated. The Site is located on the north side of Hockley and does not lie in the area between Hockley, Rayleigh or Southend on Sea. Consequently, it can have no effect on the outward sprawl towards any of these towns, and it would also not result in any merging or coalescence of a settlement.
1.106. For the same reasons as P19, the P46 score of ‘Moderate’ for both Purpose 1 (Sprawl) and Purpose 2 (Merging of Towns) are overstated.
1.107. It is appreciated that the purpose of the Green Belt assessment is not to critique individual sites. Therefore, using the same methodology and criteria as outlined in the Green Belt Assessment (2020), we have undertaken our own assessment of the site as follows:

[see document]

Site Assessment
1.108. All five sites which comprise land north of Greensward Lane have been assessed in the Council’s Site Appraisal Paper 2021. It is noted at paragraph 3 of this document that this paper is not itself out for consultation, but as it forms part of the Councils current evidence base and will help inform the Council’s site selection process, it is essential any errors are corrected. We disagree with a number of conclusions drawn in respect of the five sites submitted and our assessment of these are contained at Appendix 1 to this response.
1.109. The purpose of the paper is to assess sites which have been submitted for allocation. Its purpose is not to assess parcels of land identified in, for example, the Green Belt Assessment or the Landscape Character, Sensitivity and Capacity Study. Thus when identifying the impact a site could have on the Green Belt or on the surrounding landscape, it is not enough to rely on the conclusions of these respective studies. The impact individual sites could have on their surroundings should be assessed on individual merit. Consequently as part of our comments on the site, we have sought to provide our own assessment Woodside Park could have on the Green Belt and landscape.
Preferred Spatial Option
1.110. As noted in our response to Question 6, it is considered that Options 2 and 4 are the only suitable options for the Council to take forward, in order to provide a sustainable strategy which meets the District’s needs.
1.111. In particular we support Options 2a and 2b as both will see a proportion of growth distributed to the Tier 2 settlement of Hockley. As acknowledged by the Council a key issue in Hockley is housing availability and affordability. The population is also slightly older than the local average. Thus, it is essential housing sites are allocated across the town to meet its local housing needs.
1.112. As can be seen from Figure 46 (Map of Hockley and Hawkwell), the majority of sites submitted to the Council’s Call for Sites are considered to be of small to medium scale (i.e. up to 250 dwellings). As set out in our response to Question 5, the allocation of small and medium scale sites will make an invaluable contribution to Rochford’s overall housing needs as such sites are more likely to be available in the shorter term, offer a suitable location for development in the shorter term, and be achievable with a realistic prospect that housing will be delivered on site in the shorter term.
Conclusion
1.113. Woodside Park has the potential to make a valuable, and sustainable, contribution to meeting housing needs, and could do so in the shorter-term. It is therefore considered that the site should be allocated in the forthcoming Rochford Local Plan.

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.