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?

The council needs to restore a housing department and build council houses.

Many low income, leaving care, disability struggle with travelling. So this needs to be taken into consideration when building. And new transport links placed in and not relying on the current ones to support growth

More affordable housing to the East of Huulbridge

More affordable housing to the East of Hullbridge

More affordable housing to the East of Hullbridge

More affordable housing to the East of Hullbridge

The plan identifies that there is a ageing population which will impact on the type of housing. I am not talking about care homes but more houses that older people who have no care needs could downsize into which would free up the family homes. This could be communities that have age restrictions, e.g. 50+.

Your table shows that the greatest demand is for 3-bedroom or less semi-detached properties so plan for those only. The larger properties are on the market too long which shows that the demand for those houses is not intense. Concentrate on the homes that people really want and need - as you have identified.

More sheltered housing for older people also for disadvantaged residents.

As before involve housing associations and prevent developers from building large estates of large homes.

work with those who assist those seeking homes to ensure those being built meet the needs of those seeking homes and ensure developers build homes that meet the needs of those looking to get on the housing ladder.

You state that there will be 40% increase in the population over 70 years of age but the list of types of housing required does not include accommodation for this demographic - eg bungalows, care homes, retirement villages, warden controlled homes. You also state that there will be higher requirement for care but there is no mention of providing homes with an annex for elderly relatives/older teenagers/younger people in their 20’s. To enable families that can/are able to provide care to their elderly relatives would reduce the burden on state provision. You are not matching your expected demographic to the homes you are intending to supply.

None that I am aware of.

A number of bungalows for those who prefer / require them in each development would fit with your research on housing needs and future needs.

Housing is rarely 'affordable'. More part-buy schemes for local residents are needed. Priority to lower income, council workers etc.

Rochford District Council should also be preparing for the provision of its elderly residents, as the district (like the UK) has an ageing population. Any sites proposing Assisted Living facilities or care homes should take precedent above others.

Rochford District Council should also be preparing for the provision of its elderly residents, as the district (like the UK) has an ageing population. Any sites proposing Assisted Living facilities or care homes should take precedent above others.

Just much better quality houses

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.

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

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.

One thing I have noticed over the years, is that one whenever plans are made for older people - there is RARELY any consideration taken for the pets, it’s like get older and throw away all pets, totally wrong, some people live for their pets and making the get rid of them is unfair and 100% wrong.

Places for elder people have one of two things, either no form of garden they can even sit in or a garden so big they can’t cope – need to be considered.

Dear Sir / Madam,

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

Thank you in advance for your attention to this matter.

Kind Regards,
Jane

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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


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


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


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

Q5. Do you agree with the settlement hierarchy presented?


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


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

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

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

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

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

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


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

Spatial Themes

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


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


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


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


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


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


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


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


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

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


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

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

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


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

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

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


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

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

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

Housing for All

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


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

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

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

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


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

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


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

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


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

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

Employment and Jobs

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


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

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

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

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


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

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

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


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

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

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

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


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

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


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

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

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


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

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

Biodiversity

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


YES

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

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

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


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

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

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

Green and Blue Infrastructure

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


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

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


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


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

Community Infrastructure

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


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

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

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


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

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

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

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


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

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

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

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


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

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


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

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


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

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


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

Heritage

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


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

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


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


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

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


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

Town Centres and Retail

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


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

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

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


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

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

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

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


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

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


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

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

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


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

Transport and Connectivity

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


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

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


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

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

Green Belt and Rural Issues

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


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

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

Planning for Complete Communities

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


N/A


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


N/A


Q56d. Are there areas that require protecting from development?


N/A


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


N/A

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



N/A

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


N/A


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


N/A


Q57d. Are there areas that require protecting from development?


N/A



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

N/A

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

N/A

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

N/A

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


N/A

Q58d. Are there areas that require protecting from development?


N/A



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


N/A


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

N/A

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


N/A




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


N/A





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


N/A


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


N/A


Q60a. Do you agree with our vision for Hullbridge?


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

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

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


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

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


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

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


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

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


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

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


N/A


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


N/A


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


N/A


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

N/A

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

N/A



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


N/A


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


N/A


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

N/A



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

N/A



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


N/A





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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A

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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A






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


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

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


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

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


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

Create a Country Park to the west of Hullbridge.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Dear RDC,

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

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

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

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

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

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

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

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

1.0 Introduction

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

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

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

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

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

2.0 Response to Spatial Options Consultation Questions

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2.46 However, this should include housing for older people.

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

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

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

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

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

And;

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

3.0 Response to Integrated Impact Assessment

Assessment Framework

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

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

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

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

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

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

And

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

I want to send my objections to the following local planning options that are being put up for consideration:
CFS045 (Hawkwell, 152 houses)
CFS064 (Hockley, 214 houses)
CFS160 & CFS161 (Hockley, 124 houses)
CFS194, CFS169, CFS150 & CFS020 (Hawkwell, 801 houses)

My objections to these local planning options are as follows:

Infrastructure/Highway issues – they all would be leading out to the same main road (B1013) which already gets severe traffic, especially during rush hour. The roads are already unable to handle the existing traffic so adding a major amount of additional housing would cause even further issues. In addition, the state of the roads are also bad in some more heavily used areas and are damaged on a regular basis needing regular repair whether temporary or permanent. Due to where the sites are, it’s likely many households would drive to get to any workplace locally, or to stations/schools as none some to be on local public transport routes as of yet bar the main road.

Wildlife/nature issues – something noticeably seen since the pandemic stated was the amount of nature we have in the local area, and the animals and other creatures that live in it. Even more noticeable is the amount of animals that now are having to venture further out of the woodland/fields and are subsequently injured/killed by the increased traffic since lockdown ended. I feel that further building in these areas would displace the animals further, reducing the amount of natural wildlife in the area and the beauty of living in the ‘countryside’. It would also cause further local pollution in the area, both whilst building and with the additional traffic so for nature it’s a lose-lose situation.

Location/loss of public footpaths – as a large number of houses are being put forward in some of these areas, it’s going to cause areas of localised congestion before it gets onto the main road (B1013) causing further congestion there. The large fields being considered are currently used as public areas for dog walking, running, horse riding etc so takes away these areas causing more people traffic in other areas on top of adding further people traffic to the shops and high street. It puts more pressure on the local shops as well, which can be very busy in peak times. Areas around Clements Hall are regularly used by pedestrians, cyclists, horses etc as well as outdoor exercise activities at the leisure centre which is quite enjoyable, but would be less so with more housing in this rea.

Affordability/schooling – always a concern is the ‘affordability’ of the houses being built, what the split is on type of housing being built (flats, maisonettes, terraced, semis and detached, bungalows etc) and whether this is actually affordable for not only the people already living locally but also others looking to move away from London for a better standard of living. Are the houses truly going to be affordable, or will they sit vacant for a long time like other developments in the area as they realistically arent affordable for the majority? This is a sought after area many families want to live in for the good schools and the local amenities and ease of access to London as well as countryside/beach areas. Putting in more housing is likely to cause an influx of families who are looking to upgrade, potentially young professionals as first time buyers who eventually will have families of their own.. is this housing really going to be affordable for them? The amount of houses being built may cause a huge supply/demand issue that effects the price of other housing in the area for those that already live here and may want to move elsewhere, likely for the worse as supply becomes greater than demand for specific ‘affordable’ housing. Schools are only going to be more and more populated and in high demand, are there also new schools being built alongside all this housing?

All in all, the amount of housing being suggested is not going to maintain the village life that Hockley, Hawkwell and other villages around truly enjoy and appreciate, as well as cause even further traffic issues than the area already has. It’s going to ruin the area for local wildlife, take away public areas for leisure activities, cause greater air and noise pollution and put greater strain on the schools and nurseries, potentially increasing prices to make them unaffordable for families due to high demand.

Please accept this email as objectives to the planning options listed, as well as others in the Hockley/Hawkwell area that I may not have mentioned.