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?

We have to support all manufacturing & agriculture needs, not just in our area but across the country.
If Brexit and COVID has tough us nothing, but the need to be able to lead and not follow. We must try to be self-sufficient where possible. So encourage start ups. Encourage business to buy from the UK where possible, which pushes the need for skilled workers in the UK.
We need to support business, sort the high streets with common low ground rent similar to factories etc.

your plans are already floored with the Airport what else have you got wrong in your calculations?

Meeting future needs by prioritising the delivery of new employment space alongside any new strategic housing developments (e.g. start-up business centres/co-working spaces or planning for live-work units) and securing the delivery of ultra-fast connectivity across the District are great ways to enable opportunity.

Identifying land for higher- or further-education facilities to address current and future skills shortages has my support.

Prioritising the expansion of existing employment sites, combined with the requirement for new employment developments to set aside a certain proportion of ‘grow-on’ space, to meet identified additional needs relies on good supporting infrastructure.

If the demand is there for office space and the demand continues for industrial space than this should be greatly considered first before homes are built to ensure that's jobs are available first

All the analysis of employment issues seems to ignore the fact that a large proportion of the Rochford population do not work in the district but commute to Southend, Basildon, London. This has implications for housing affordability, transport, shopping etc Have these been considered?

working with local businesses and business organisations to ensure that their needs are met as said coronavirus has changed the landscape offices may become largely redundant and ways of working are changing more rapidly so plans need to be regularly reviewed with those who are in business not by those who think they know.

I would assess that the community in the district is primarily concerned with farming or housing for people who commute by rail or vehicles to nearby urban areas. We should not be allocating farming land or rural areas to industrial activity. We should concentrate on ensuring maximum occupancy of current industrial sites by allowing more flexible repurposing. Most of the industrial sites in the district detract from the look of the area. We should promote or rural areas for tourist purposes.

Specific areas to be allocated

The new Local Plan needs to be changed, to deflect the need for employment land and inward investment. More local jobs = more need for housing = destruction of our countryside and welfare due to increased local congestion.
Move jobs away from the area, and people will follow, reducing the pressure for housing and the need for valuable countryside to be taken to support both jobs, housing and roads.

Your Modelling suggests that over the next 15-20 years, the most likely scenario for employment land demand, to support over 1,200 additional local jobs. Rochford has considerable potential to support business growth , with strong transport links to London, strategic transport infrastructure at London Southend Airport and the region's ports, .
Rochford District has the highest demand/lowest supply of office space across South Essex, with property spending less time on the market than in other areas. Demand for industrial space was similarly high.
My question - should you remodel as post Covid commercial requirements have changed

1 – Meeting future needs by allocating existing and new employment sites for specific employment uses (although this may become difficult under the new use classes).

4 – Meeting future needs by prioritising the delivery of new delivery of new employment space alongside any new strategic housing developments (start-up businesses centres/ co-working spaces or planning for live-work units).

10 – working with partners to secure the delivery of ultra-fast connectivity across the district, including fibre-to-the-premises and mobile networks.

11 – Working with neighbouring authorities to identify land for higher/ further education facilities where this would address current and future skills shortages.

1 – Meeting future needs by allocating existing and new employment sites for specific employment uses (although this may become difficult under the new use classes).

4 – Meeting future needs by prioritising the delivery of new delivery of new employment space alongside any new strategic housing developments (start-up businesses centres/ co-working spaces or planning for live-work units).

10 – working with partners to secure the delivery of ultra-fast connectivity across the district, including fibre-to-the-premises and mobile networks.

11 – Working with neighbouring authorities to identify land for higher/ further education facilities where this would address current and future skills shortages

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.

Consultation on the New Local Plan: Spatial Options
Reponses to Questions 20, 22, 23 and 25
Representations made on behalf of Star UK Rayleigh Propco Limited
These representations are submitted on behalf of our client and owner of the Michelin Farm site, Star
UK Rayleigh Propco Limited, following publication of the New Local Plan: Spatial Options (Regulation
18) Consultation Document. This follows our previous submissions to Rochford District Council’s
(RDC) Planning Policy (correspondence dated 8th June 2021, 18th June 2021, and 1st September
2021) copies of which appear at Document 1.
By way of background, Quod has been involved in the Michelins Farm site since January 2018, acting
as planning consultant to the current landowner – who acquired the site in September 2020, the
previous landowner – who acquired the site in 2018 and the development manager, Equation
Properties, who facilitated the acquisition of the land.
Star UK Rayleigh Propco Limited’s freehold ownership extends to c. 11 hectares and broadly
encompasses the land identified under Policy NEL1 (West of the A1245, Rayleigh) and Policy GT1
(Gypsy and Traveller Accommodation) of the Rochford District Council – Local Development
Frameworks Allocation Document (adopted February 2014). A Site Location Plan indicating the extent
of Star UK Rayleigh Propco Limited’s ownership appears as Document 2.
It is in this context that the representations have been prepared.
1 Michelin Farm
As the Council will be aware, the land in question has been the subject of numerous planning
applications over the past 3 years.
Outline planning permission for c. 45,000 square metres of Classes B1(c), B2 and B8 floorspace was
granted on 14th July 2020 (ref. 18/01022/OUT). This permission related to land broadly identified under
Policy NEL1. Phase 1 of this development for c. 11,500 square metres of industrial warehouse
floorspace is currently under construction.
An application for full planning was also submitted on part of the site in December 2020 (ref.
20/01196/FUL). The proposed development extends from Star UK Rayleigh Propco Limited’s
landholding to the land allocated under GT1. The application is pending determination and proposes
the development of a single warehouse building of c. 30,000 square metres. At the time of writing, the
planning application remains undetermined. The application seeks to provide a high-quality industrial
development for which a significant need has been identified. It is estimated that the development – if
approved – will generate between 500 and 920 full-time equivalent jobs.
The intentions of the current and previous landowner, along with the development manager, have
been consistent over the past three and a half years, namely, to promote all the land at Michelins
Farm for employment development. As will be outlined in this representation, Star UK Rayleigh Propco
Limited have not developed the land allocated under Policy GT1 for Gypsy and Traveller
accommodation for clear commercial reasons. Furthermore, there is clear deliverability issues
preventing Gypsy and Traveller accommodation at the site.
The intention of the landowner is to continue to promote and develop the site for high-quality
employment floorspace.
2 Planning policy for traveller sites
It is important to summarise the relevant national policy framework for traveller sites, as set out in the
Department for Communities and Local Government August 2015 document, Planning policy for
traveller sites. This sets out (para. 3) that it is the Government’s overarching aim to ensure fair and
equal treatment for travellers, in a way that facilitates the traditional and nomadic way of life of
travellers while respecting the interests of the settled community. To help achieve this the
Government’s aims in respect of traveller sites are (para. 4):
a. “that local planning authorities should make their own assessment of need for the
purposes of planning
b. to ensure that local planning authorities, working collaboratively, develop fair and effective
strategies to meet need through the identification of land for sites
c. to encourage local planning authorities to plan for sites over a reasonable timescale
d. that plan-making and decision-taking should protect Green Belt from inappropriate
development
e. to promote more private traveller site provision while recognising that there will always be
those travellers who cannot provide their own sites
f. that plan-making and decision-taking should aim to reduce the number of unauthorised
developments and encampments and make enforcement more effective
g. for local planning authorities to ensure that their Local Plan includes fair, realistic and
inclusive policies
h. to increase the number of traveller sites in appropriate locations with planning permission,
to address under provision and maintain an appropriate level of supply
i. to reduce tensions between settled and traveller communities in plan-making and planning
decisions
j. to enable provision of suitable accommodation from which travellers can access
education, health, welfare and employment infrastructure
k. for local planning authorities to have due regard to the protection of local amenity and local
environment”
It goes on to set out when local planning authorities should do, in producing their Local Plan (para.
10):
a. “identify and update annually, a supply of specific deliverable sites sufficient to provide 5
years’ worth of sites against their locally set targets
b. identify a supply of specific, developable sites, or broad locations for growth, for years 6
to 10 and, where possible, for years 11-15 5
c. consider production of joint development plans that set targets on a cross-authority basis,
to provide more flexibility in identifying sites, particularly if a local planning authority has
special or strict planning constraints across its area (local planning authorities have a duty
to cooperate on planning issues that cross administrative boundaries)
d. relate the number of pitches or plots to the circumstances of the specific size and location
of the site and the surrounding population’s size and density
e. protect local amenity and environment.”
The relevant Spatial Options should be viewed in this national policy context.
3 Issues and Options Document Consultation (Regulation 18)
Before we respond to the Regulation 18 Spatial Options Consultation it is first important to summarise
the representations we made to the Issues and Options consultation in March 2018 (our letter dated
7th March 2018) which appear as Document 3. Those representations were made on behalf of
4/15
Equation Properties (Equation) who were acting on behalf of then prospective purchaser of Michelin
Farm, Lash Capital. The representations focused on the part of the Michelin Farm site that is allocated
under Policy GT1 of the Site Allocations DPD, with Equation:
▪ Objecting to the retention of Michelins Farm for Gypsy and Traveller Accommodation (SP1.5
Option B);
▪ Supporting the allocation a number of smaller Gypsy and Traveller pitches / sites to meet the
needs of the local area (SP1.5 Option C);
▪ Supporting the relocation of Rawreth Lane Industrial Estate for employment uses (SP1.8 Option
B);
▪ Supporting the continued allocation of Michelins Farm given the strong commercial interest in
developing the site for a range of employment uses (Classes B1(c), B2 and B8) (SP1.8 Option
C); and
▪ Supporting the allocation of new employment land to meet the identified demand for new
employment floorspace across the district (SP1.8 Option D).
Equation remaining the appointed Development Manager for the Michelin Farm employment
development, now acting on behalf of the current owner, Star UK Rayleigh Propco Limited. The views
of the DM and the new owner are completely aligned in respect of the Michelin Farm site including its
suitability for employment development and fundamental unsuitability for gypsy and traveller
accommodation given the significant constrains surrounding its delivery, as we will reiterate below.
4 Objectively Assessed Needs
The consultation document sets out the options for meeting the District’s objectively assessed needs.
Pertinent to our client’s landholding is the proposed strategy surrounding the District’s Gypsy and
Traveller accommodation needs. This is dealt with under the “Spatial Themes” heading of the
consultation document, forming part of “Housing for All”.
The evidence base (in the form of the GTAA1
) identifies a requirement for 19 pitches by 2033 (for
those meeting the policy definition of Gypsy or Traveller) but with the need significantly front- loaded.
There is also a requirement of 11 pitches for those who no longer travel. Of the required pitches, 25
are required in the period 2016-2021. The consultation document states:
“The Council’s current policy position on traveller needs is to prioritise the delivery of a new permanent
traveller site at Michelin Farm, which has capacity for 15 or more pitches, which would be sufficient to
meet most of Rochford’s needs. Feedback from the Issues & Options consultation was generally supportive of delivering a permanent site at Michelin Farm in preference to authorising or allocating
alternative sites. However, this site is not being delivered as expected and there now exists significant
doubt as to when or if the delivery of this site is likely to be possible.” (our emphasis)
First, it should also be highlighted from the outset that whilst feedback from the previous Issues &
Options consultation is identified as being “generally supportive” of delivering a permanent site at
Michelin Farm in preference to authorising or allocating alternative sites, as summarised above, our
representations were not supportive. Our representations requested that the site be de-allocated for
Gypsy and Traveller accommodation and instead be allocated for employment development,
consistent with the adjacent NEL1 allocation.
Secondly, of the Spatial Options consulted upon, RDC have outlined the following options to assist in
meeting the objectively assessed need:
“Non-exclusive options for addressing permanent accommodation needs of Gypsies, Travellers
and Travelling Showpeople include:
1. Retaining the current policy position of delivering a permanent site at Michelin Farm, if it can
be established that this site is deliverable within the plan period.
2. Prioritising the regularisation of existing unauthorised sites where any environmental,
transport and amenity impacts of doing so are outweighed by the benefits.
3. Prioritising the regularisation and expansion of existing unauthorised sites where any
environmental, transport and amenity impacts of doing so are outweighed by the benefits.
4. Allocating new areas of land for permanent traveller sites, informed by a specific Call for Sites
and site assessment process for potential locations for new traveller sites.
5. Requiring new strategic housing allocation to set aside areas for permanent traveller sites
within the general boundary of any allocation.
6. Working with neighbouring authorities to meet permanent traveller accommodation needs in
other local authority areas if it is established that needs could be better met by permanent sites
located elsewhere.
The deliverability issues associated with the existing allocated Policy GT1 site have persuaded the
Council of the need to consider alternative options for meeting the assessed need which is supported.
However, as we will come on to discuss, there is no apparent consideration of the ability of the
allocated site to meet the increased need which the GTAA has identified or of the reasoning of several
inspectors2 who have recently questioned whether the Council’s approach could be justified by
reference to Government policy3
. Both these factors indicate that the Council needs to reconsider its
existing policy approach and that continuing with the present allocation either alone, or at all, may not
be an appropriate strategy. There also appears to date, to have been no consideration of how the
GT1 site would be accessed in the event that the threat of its development prejudices the further
development of the adjoining employment allocation (Policy NEL1), consistent with longstanding
concerns raised with current and previous landowners. As we will come on to discuss, both the
ownership and access constraints are significant issues indicating that the GT1 site not deliverable.
5 Current Policy Approach
The Council’s Allocations DPD was adopted on 25 February 2014. Policy GT1 was included because
of the assessed need to provide 15 pitches by 20184
. Any post 2018 pitch requirement was said to
be a matter for a subsequent review (Allocations Plan para. 3.296). The Local Plan thus anticipated
delivery of the allocated site by 2018 in order to meet the assessed needs. This has not happened.
This lack of delivery was in part anticipated in the Allocations Plan itself which identified that there
were constraints to be addressed, not least access which was dependent upon the adjacent
employment site coming forward (para. 3.307). Other issues included the potential need for
decontamination (para. 3.300) and the need to provide services to the site (paras.3.318 & 3.319).
It is also clear that the Allocations Plan did not anticipate that the allocated site would be either
appropriate or attractive for private pitch provision. The Council clearly saw the site as a solution to
the pressure for pitch provision elsewhere within its Green Belt and, in consequence, the Allocations
Plan provides:
“It is essential that the site is managed in a way that ensures it is open and accessible to the
traveller community. Specifically there will be a need to ensure that travellers in appropriate
circumstances, can be offered a pitch when required as part of the process of dealing with
unauthorised sites in the district. On that basis, the Council’s preference is for the creation
of a new municipal site that will be positively managed for the benefit of the traveller
community and will ensure that a pitch can be offered when required in a simple and
straightforward way. To this end the Council will seek to acquire this land will ensure that it
is appropriately managed by or on behalf of the Council” (para.3.306).”
Consistent with this, Chapter 10 of the Allocations Plan states that:
“The Council will seek to acquire the land and will ensure that it is appropriately managed by
or on behalf of the Council”.
The risk of no allocation is recognised in the same Chapter and the mitigation is said to be:
“The Council will work with landowners’ representatives, developers, local representative
groups and other stakeholders to ensure that the site is delivered”.
As a matter of fact, the Council has not worked with anyone in order to deliver the site by 2018 or at
all.
This is the current policy approach which has clearly failed to meet the needs of the travelling
community.
6 Relevant Appeals
RDC’s current policy approach – including its compatibility with national policy5
, has been the subject
of much debate on appeal, as summarised below. Copies of the appeal decisions are enclosed and
appear as Document 4.
Appeal 1 (ref. C/16/3162651)
The first appeal was allowed on 3rd November 2017 and related to land at a Pumping Station, Watery
Lane, Rawreth. The appeal was against an enforcement notice regarding the change of use of the
land for use as a Gypsy and Traveller site without planning permission.
The Inspector’s Report concluded that in relying wholly on the Policy GT1 land at Michelins Farm,
RDC provided nothing in the way of choice and were not promoting more private traveller site provision
as envisaged by national policy.
Appeal 2 (ref. C/17/3174424)
The second appeal was allowed on 28th February 2018 and related to land adjacent to Woodville,
Hullbridge Road, Rayleigh. The appeal was against a refused application (ref. 15/00448/FUL, refused
2
nd July 2015) which sought permission for the stationing of caravans for residential purposes.
The Inspector’s Report confirmed that the possible development of Michelins Farm has encountered
various difficulties, including tipping of waste and issues of land ownership. It was also confirmed that
development was yet to commence, and no planning permission for Gypsy and Traveller
accommodation had been granted. The Hearing was told that there was no programme for
development.
Appeal 3 (ref. C/18/3209439)
The third appeal was allowed on the 10th February 2021. This related to land adjacent to St. Theresa,
Pudsey Hall Lane, Canewdon. Part of the appeal was against a refused application (ref.
18/00318/FUL, refused 29th March 2018), which sought permission for a proposed Gypsy and
Traveller accommodation comprising two mobile homes.
The Inspector noted in the decision that it had been confirmed that the landowner of the Michelin Farm
site had secured a committee resolution from RDC to grant planning permission (ref. 18/01022/OUT)
for a business park on the adjacent land (ref. NEL1). The Appellants agent suggested that the
approved employment scheme meant that it was even less likely that the Gypsy and Traveller
accommodation was to come forward, given the general incompatibility of residential and general
industrial uses alongside each other. Significantly, RDC did not contest this point.
Furthermore, RDC recognised that they could not compel the landowner to bring forward a further
planning application for a Gypsy and Traveller site on Michelins Farm, nor can they compel the sale
of the land to a third party who might be willing to provide Gypsy and Traveller accommodation. RDC
also confirmed at the time of inquiry, that they were not intended to exercise their powers of
compulsory purchase and operate Michelin Farm as a public site.
RDC accepted that the delivery of Michelin Farm for Gypsy and Traveller accommodation had not
materialised in the manner they had anticipated and as a result, the Council have now decided that
the identified need would best be met through a comprehensive Local Plan (i.e. Option 4 of the Spatial
Options document).
The Inspector concluded that in placing reliance wholly upon the Michelin Farm allocation, RDC had
failed to promote private traveller site provision. The Inspector also confirmed that RDC had failed to
provide any choice for Gypsy and Traveller accommodation and this had resulted in RDC failing to
meet the needs of the Gypsy and Traveller community. These criticisms are consistent with the
conclusions of the Inspector in respect of Appeals 1 and 2.
In the 2017 and 2018 appeals, the respective Inspectors noted that there were issues surrounding the
deliverability and suitability of Michelin Farm for Gypsy and Traveller accommodation. This view has
since been compounded by the recent decision at Pudsey Hall Lane where the Inspector made it clear
that Michelin Farm is not a suitable, available or deliverable site for Gypsy and Traveller
accommodation. This point was not contested by RDC throughout the inquiry. There has also been
consistent criticism that RDC’s current policy approach to meeting its objectively assessed gypsy and
traveller needs is inconsistent with national policy.
7 Reliance on Policy GT1
The Gypsy and Traveller Issues Paper (GTIP) – which was never formally published for consultation
due to Full Council intervention – stated in relation to the GT1 allocation:
“In practice, the delivery of the site has been challenging for a number of reasons, including
prohibitive site acquisition costs, lack of interest shown from the traveller community in
acquiring the site, a potential conflict with the emerging business uses on the remainder of
the site and the impacts of proposed highway improvements at the nearby Fairglen
interchange”.
Policy GT1 placed full reliance on meeting the identified Gypsy and Traveller need in the Borough
through the allocation of Michelin Farm.
The Inspectors for the above referenced appeals (ref. C/16/3162651 and C/18/3209439) have
criticised the approach taken by Policy GT1 as being inconsistent with Government policy in not
making provision for ‘private’ pitch provision or offering any choice to the Gypsy community. The
Government policy referred to is the Planning Policy for Travellers Sites (2015) (PPTS).
The Inspectors considered that the in placing reliance wholly upon the Michelin Farm allocation in
Policy GT1, RDC has failed to promote more private traveller site provision in accordance with the
Government’s aim in Paragraph 4(e) of the PPTS. It is also considered by the Inspectors that in placing
full reliance on GT1, there is insufficient choice particularly as there are no specific criteria based
development policies that allow for unallocated gypsy and traveller sites to come forward.
Option 1 of the Spatial Options document places full reliance on the delivery of Michelin Farm for
Gypsy and Traveller accommodation. This option does not promote private traveller site provision and
as such, it is considered that the proposed option is a departure from the PPTS and should not be
taken forward.
8 Responses to Questions 20 and 22
The key questions relating to Gypsy and Traveller need within the District are set out below.
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.
Option 1
6
is wholly inappropriate. The existing allocation under Allocations Plan Policy GT1 is not
deliverable.
Notwithstanding most of the assessed need for Gypsy and Traveller accommodation needs to be
provided before 2021, Option 1 clearly states that a permanent Gypsy and Traveller site at Michelin
Farm is dependent on the site’s deliverability.
There are clear issues relating to the site’s deliverability for Gypsy and Traveller accommodation.
Since the site’s allocation in 2014, it has not been delivered for Gypsy and Traveller accommodation.
Furthermore, no formal attempt has been made by RDC or any other party in terms of attempting to
bring it forward to meet the identified need, as set out above.
As outlined in our letter dated 1st September 2021 (Document 1), there are clear issues in terms of
current service and utilities provision at the GT1 site. The following documents have been prepared
by Goodrich Consulting LLP and accompany this representation to assist RDC’s understanding.
▪ Michelin Farm GTS Land – Note on Utilities, prepared by Goodrich Consulting LLP;
▪ GTS Land Service Costs – Budget Costs; and
▪ Services & Utilities Constraints Plan – Consented Masterplan Overlay (RDC ref.
18/01022/OUT).
The Note on Utilities confirms that there are no existing services servicing the GT1 site. It also confirms
that there is no additional capacity on the wider site and any further development of the residual areas
(i.e. the Phase 2 land) will provide only the specific requirements of that development, given the
investment needed to bring forward those utilities. Further commentary is provided on future services
and utilities provision which we have summarised below.
▪ Electricity – the power on the site has been provided for the Phase 1 development, which has
already been completed and is fully allocated. To provide the power for Phase 1 new cables
were installed over a 4km distance. Those cables and transformers are sized for the reserved
power of the current proposed development and no further capacity is available. As such, any
additional power needed for GT1 may require the installation of further cables. This work would
not be funded by the landowner.
▪ Foul connections - the nearest available connection is 4km from the site. At present, only a foul
treatment plant has been installed for the Phase 1 development and this has been sized to
accommodate that development only. Any new foul connections on the GT1 site would either
need to connect to the available foul connection 4km away or would have to have its own foul
treatment plant installed.
▪ Water, gas, and telecommunication – despite services being available in the road, the capacity
and necessary reinforcement of the network to support any future development on the GT1 land
is unknown and would need to be assessed via an application to the relevant statutory authority.
In addition, the Constraints Plan further demonstrates the extremely limited area for accessing
services due to the existing services and below ground drainage systems which are already installed
as part of the Phase 1 works. Goodrich confirm that any available service routes will likely be reserved
and utilised during Phase 2 of the development.
The enclosed summary of Service Costs should be used by RDC as a reference and guide only. The
total estimated cost for service provision on the GT1 land is more than £1.3m. Any developer seeking
to bring forward the GT1 land would need to apply and obtain their own quotes for utility provision to
this section of the Site.
In line with the above, Option 1 should be removed as a spatial option for future Gypsy and Traveller
accommodation. Instead, RDC should proceed with a combination of Options 2 to 6 in order to meet
the objectively assessed need, including for private pitch provision and offering choice to the Gypsy
community, in accordance with national policy. This approach would directly address the criticisms
levied by inspectors in respect of recent appeals (see Document 4 - The Pumping Station, Rawreth
and Canewdon).
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.
The now revoked Good Practice Guidance on Designing Gypsy and Traveller Sites (CLG, 2008)
provides specific guidance for designing Gypsy and Traveller sites for both permanent and transit
sites and also temporary stopping places. The guide considers that sites identified for Gypsies and
Travellers should not be in locations that would be inappropriate for ordinary residential dwellings. The
guide refers to a number of criteria which should be considered when selecting sites for Gypsies and
Travellers, these include:
▪ Good access to major roads and/or public transport services
▪ Good access to local services including employment, education, health and shopping facilities
▪ Co-existence between the site and community should be promoted
▪ Consideration should be made to the ground conditions and levels on the site
▪ Sites should provide visual and acoustic privacy for the residents
▪ Sites should not be located in areas of high flood risk
▪ Sites should not situated near refuse sites, industrial processes or other hazardous places
We would therefore advocate the following criteria based approach.
▪ Proximity to settlements with access to employment, education, health, shopping and other local
services and infrastructure
▪ Consideration can then be given to more rural locations, particularly where they are well located
in relation to major roads and/or public transport
▪ Avoidance of sites on or near Source Protection Zones, contaminated land and sites on or near
refuse tips
▪ Avoidance of Functional floodplains and Flood Zones 3a and 3b
▪ Avoidance of SACs, SPAs, Ramsar sites and other nationally recognised designations
▪ Satisfactory means of vehicular access and the local road network is adequate
▪ Local environment and residential amenities will not be adversely affected
▪ No adverse impact on landscape character
▪ Level land
▪ Availability of services and site deliverability
▪ Suitability in terms noise/pollution/potentially incompatible use
▪ Site size
9 Need for Employment Floorspace
Whilst the need for Gypsy and Traveller is not contested, Option 1 is not a suitable choice in providing
future Gypsy and Traveller accommodation, given that Michelin Farm is not a deliverable or suitable
site for such uses. Conversely, the development of much needed employment floorspace is
deliverable and proposes a land use on the GT1 site that is compatible with the wider employment
allocation.
As previously outlined, the majority of the site benefits from an extant planning permission for
employment uses (ref. 18/01022/OUT). A Market Report prepared by CBRE accompanies this
representation and provides a holistic and commercial view of the demand across the sector, the
supply of existing and pipeline sites and achievable lease terms.
CBRE’s Market Report makes it clear that there is a compelling need for units of the size proposed in
accessible locations such as Arterial Park.
Given the above, Option 1 should be removed as a spatial option for future Gypsy and Traveller
accommodation and the site should instead be allocated for employment uses.
10 Response to Questions 23 and 25
The key questions relating to employment land need within the District are set out below.
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 need through the plan?
We consider that the Council should progress with a combination of the proposed options – particularly
Options 17
, 2 8
, 3
9 and 510
The Economic Development Topics Paper 2017 ‘combined scenario’ suggests that there is a need for
a minimum of 7 hectares of ‘new’ employment land between 2016 and 2036. This figure is also quoted
in the Spatial Options document. It is anticipated that over this period, there will be a reduced demand
for warehousing in the District and a greater demand for manufacturing / industrial (B1c/B2) uses on
6 hectares and higher office density (B1) developments on a further 1 hectare of land. This
requirement equates to a total employment creation of 1,242 jobs over the projection period (2016-
2036), which equates to job creation of approximately 62 jobs per year.
This additional requirement highlights that a combination of the options outlined in the Spatial Options
document should be progressed. In particular, the Council should allocate existing and new
employment sites for more general employment uses to allow flexibility. This will ensure that sites are
not constrained in terms of what uses can be provided, meaning that development can be maximised
on the site. Furthermore, the Council should look to prioritise the expansion of existing employment
sites, where adjacent plots can be easily developed. This will ensure a joined-up approach in terms
of land use.
Q25. With reference to your preferred Strategy Option, are there any opportunities for growth
to delivery new employment facilities or improvements to existing employment facilities.
As previously outlined, the land currently allocated under Policy GT1 could be delivered to provide
new employment facilities. The redevelopment of the site would constitute a logical extension to the
existing employment development permitted at Michelin Farm (i.e. Phase 1).
The Spatial Options document makes it clear that one of the key findings from the Economic
Development Topics Paper (2017) and the South Essex Grow-On Space Feasibility Study (2020) is
that rental rates in Rochford District are below average, implying overall quality of stock in the District
is of secondary / poor quality. It also states that in recent years, the supply of vacant industrial and
office floorspace has fallen drastically across South Essex, due to rising business occupier demand,
but also due to pressure to redevelop existing employment land for housing. The redevelopment of
the GT1 site would result in the provision of high-quality, modern employment floorspace – as
illustrated through the scheme proposed as part of application ref. 20/01196/FUL. This would assist
Rochford District in improving their overall quality of employment stock.
Furthermore, the redevelopment of the site would result in a number of economic and social benefits
as well as supporting the aims of both local and national policy. Significantly, the redevelopment of
the site would help achieve the Council’s Strategy Policy of meeting the need for homes and jobs11
.
It is for the reasons outlined above that the GT1 site should be allocated for employment uses rather
than Gypsy and Traveller Accommodation.
11 Conclusion
The land allocated under Policy GT1 at Michelin Farm has long-standing deliverability issues. Those
issues, coupled by clear commercial aspirations of the previous and current landowner and the need
for employment land demonstrate why Option 1 of the spatial options for Gypsy and Traveller
accommodation should not be included as a Regulation 19 preferred option. Michelin Farm is not a
deliverable option as clearly illustrated from its allocation nearly 8 years ago.
We trust these representations will be taken into account when preparing the next version of the New
Local Plan.

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.

We live in Barling Magna and have done so for 35 years and never have we been so concerned about an issue.

I have serious concerns around the consultation document itself, it uses place names like ‘Stonebridge’ rather than a ward name, it has omissions of current ongoing developments , which when completed will add to the general congestion on some roads. Because, I was informed, they have consent they do not need to be shown as this reflects a call for new land. But surely we need to now about them to assess the overall amount of development in an area before we can assess if we can accept more.

It says, and Rochford has confirmed, ‘infrastructure first’, but there is no indication as to how or where this infrastructure would be - whether it be first or last, so how can one assess a site without knowing where the new road would go to get there?

The Council should not reach any conclusions until Government Housing Policy and numbers to be found has been confirmed.

The consultation has divided large swathes of offered land up into small parcels and invites comments on the parcels rather than the overall principal of a development in that area. This contributes to a very difficult to follow consultation made far worse by poor software running the consultation.

On the above points alone I question the validity of this consultation.

The consultation invites comments on the future categorisation of land, residential, employment, green etc. However, most of the land that has been put forward is currently green belt land, and it’s development would be against current RDC policies.

“The land in question forms part of the Metropolitan Green belt. Such land can only be developed for ‘Exceptional circumstances’ as detailed in the Planning Policy Guidance Note 2 (PPG2), and states in para 143 that Inappropriate development is by definition harmful to Green Belt’’ and in Para 145 that ‘’A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt.” There are exceptions but these do not include house building on anything other than a minor scale.

I suspect that most of the residents would wish it to remain green belt. What is the point of having green belt land if, just because it is easier to build on than brownfield it becomes an option in the next consultation etc. Government policy has indicated that the use of green belt land should not be assumed and indeed this classification could be sufficient to rule out its use other than for minor applications.

Now, more than ever, development should look to be sustainable, indeed it is beholden on our Cllrs and our Council Planning Dept to ensure that it is.

Sustainability comes in many shapes, from the loss of a land use, through the materials used for building plus a plethora of issues like heat pumps, solar, glazing etc and this must include the sourcing of such items, through to accessibility, congestion, new roads needed and reliance on various forms of transport, easy access to work, education, health etc. Economic sustainability must also be assured and this goes beyond economic delivery but also includes the longer term economic viability for both new and current residents.

Based upon the above I would make the following comments-

• No housing development, from Rayleigh eastwards, in the current green belt or on agricultural land should be permissible on sustainability grounds other than small infill of ribbon development areas, extension to existing dwellings in green belt and ‘granny flats’ where space and neighbour privacy permits etc. Allow residents to make the most of their properties rather than needing to move.
• All current green belt land adjoining woodland, parkland, ancient copses etc should be retained and reinforced as protected green space and backfill towards these important wildlife havens and CO2 catchments should be prohibited.
• The destruction of arable land should not be permitted. We need to be as self sufficient in food matters as we can be, importing from Canada or France for example is far less sustainable and could become more difficult in the future.
• Access to and through Hockley, Ashingdon and Rochford is beyond capacity and cannot be expected to take any more traffic. A journey that 15 years ago took 15 mins now takes 30 minutes minimum and often more. Traffic around Rochford is often at a standstill due to parking, deliveries etc and at the morning and afternoon busy times it is totally snarled up.
• Brown field sites and intensification of existing dwelling areas should only be developed with a very light touch unless easy access to jobs, schools etc without adding to road congestion can be imposed and maintained.
• Rochford should not accept development that is accessed by highways that are not within the district or where necessary facilities including jobs are not able to be provided within close proximity preventing the need for more vehicle movements on already over congested roads.
• Reliance on Southend facilities, the A127 within Southend and Bournes Green Chase etc. should not be countenanced. Southend has high unemployment in many wards and high deprivation in the central wards, good jobs that provide good incomes are scarce in Southend, Shoebury, Rochford, Wakering, Barling, Paglesham etc. Thus any new residents moving into the area will be driving in and out each day or trying to access trains with limited parking.
• The lack of suitable employment the further east you go is also a major factor in the sustainability of the economic issues. Barling on good run is 30 mins from Rayleigh Weir, more development can only slow this even more.
• All construction materials will have to get to the east of Rayleigh via already tired and congested roads causing yet more delays, polluted air and disruption for residents and importantly businesses in the east of Southend. The greater the congestion into Southend the fewer returning tourists and the fewer jobs in Southend!

On a more positive note and in recognition that RDC, BDC and SBC all have to provide some new dwellings that will probably not be able to be fully accommodated within the town centres or brown field sites there are a few areas where I consider development would be sustainable,
• Along the north side of the A127, accessed by a new slip road off the A127.
• Land adjoining or close to the A130 in the south Rawreth area, (CFS146,147,167,144,168,145,137,055,121 ) here sufficient development could take place in conjunction with Basildon and Southend to absorb much of the dwelling numbers currently required by Government whilst at the same being large enough to sustain education facilities, healthcare, small retail and supermarkets etc alongside leisure and sports. Good access is here for work with A130 to Chelmsford, A127 to Basildon and Rayleigh, A13 to Thames corridor etc and those commuting by train can access Rayleigh Station relatively easily (or even a new station). As when and if the A127 is ever upgraded into Southend adequately and as when and if their unemployment rates improve then more work opportunities will open up.

• I support strategy option 3a a massed development west of Rayleigh, indeed I see a small new garden town as the only sensible, sustainable and long term economic option. This would not destroy the country side around existing villages nor lead to more traffic and congestion issues east of Rayleigh. It also allows for co-operation from different authorities to work together for benefit of their residents.
• I do not support the other strategy options as a means to provide any significant numbers of dwellings.

More specifically


CFS064, CFS264, CFS040, CFS161, and any further development along or requiring access to the roads Church Road, Folly Lane, Folly Chase, High Road, Main Road, Aldermans Hill etc and all the way through to Rochford Town Centre via Hall Road and Stroud Green should be considered as over-development and an undesirable change of use.
These roads cannot be improved to accommodate the already excessive traffic. Some sites along or close to these roads are encroaching on potential wildlife areas and others are on the periphery of woodland etc. None of these sites would generate enough to provide the necessary highway improvements, even assuming this were possible, Rayleigh has singularly failed to sort out its traffic congestion problems despite many attempts to do so. Nor would they generate sufficient for the other infrastructure contributions that would be needed to make these areas better, more attractive areas to live in for both new and existing residents. The result would be a significant loss of amenity and worsening living conditions for the existing residents.

CFS004, Barling, this site could take a few houses as extension of ribbon development but the land would be better suited to be used as woodland or wild flower meadow to the rear, and form parking for the school to the front of the site if agriculture is no longer viable. The numbers suggested to be built on this site are way more than sensible, not least due to the location near a school, the specifics of the road there, the very difficult parking in the area and the risk of flood. 29 new homes means at least 29 if not far more vehicles going into and out of the village each day, more school places etc,.

All development in Barling, Little and Great Wakering on greenfield or agricultural sites should not be considered further. I have already discussed the sustainability of areas to the east of the district and here more than ever that is important. Also, however, this land offers a real buffer against the muddling of Southend and Rochford, which is intrinsic to the identity of the 3 areas and also offers open space and leisure for Southend residents in the east of the borough . Green space is hardly prolific in this sector of Southend. I also disagree with the ‘convenient’ adding of these three areas together to form a tier, Barling is not part of nor similar to the Wakerings and should be considered along with tier 4 villages.

The roads in the Barling area are small narrow roads often without pavements, there are sharp bends and ditches etc, these are rural roads and should remain so.

Most of us live in these areas and especially in Barling because we like the rural feel of the area. We want to preserve that way of life and major developments
taking years to build and then thousands of residents with cars causing congestion and poorer air quality will destroy it forever. Given the way the estuaries divide up our district we need to preserve the countryside within each estuary sector. Thames - Roach and Roach - Crouch.

I trust you will carefully consider the above points when deciding the outcome of the consultation and that you realise the strength of feeling of residents.

Thank you for taking the time to read our concerns and suggestions

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.

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

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

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

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

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

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

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

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

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

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

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

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

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

Consultation Process -The volume of information contained in the consultation was difficult to access and view online. Some links did not work properly. RDC are not reaching residents who have no internet.
Spatial option 3b North of Southend is most feasible site.
Spatial Themes not included - Cultural and Accessibility.
Employment – District is lacking in Environmental services - woodland conservation and management.
Improve Long-term Economic growth - Better road networks, gigabit broadband and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training. The council should stop developing existing commercial land into housing.
Local generation of low-carbon and renewable energy - New developments should be able to source some or all of their energy from renewable sources. Solar in all new development as standard. Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs; there are many flat roofed buildings all over the district that could accommodate solar panels without damaging the landscape. Explore tidal energy and seek out suitable locations in order to ascertain whether it is viable. Retrofitting existing housing and commercial buildings.
Settlement Hierarchy: Rayleigh is the largest town in the district, but care needs to be taken to maintain the integrity of the existing settlements with respect to green boundary between Rayleigh and its neighbours.
Planned Forms of Housing: Mix of housing for “affordable“ properties with higher standards for gardens and recreational space. Consideration should be given to the provision of house for life, Adapted homes for the disabled, bungalows and other potential buildings for downsizing families. Housing for the hidden homeless – those “sofa surfing” & Emergency housing. The plan makes no reference to social housing quotas which should be included in all new developments. By working closely with planners and developers, as well as different charities and communities, residents and businesses. You will then get a better understanding as to what you need and what will be achievable.
From 1st August it was announced that empty buildings and brownfield sites should be converted rather than build new. This alternative should be evaluated first.
Many development proposals would also mean a further reduction in air quality, light pollution and the loss of trees, farming, and arable land at a time when food production and supply is becoming a cause for concern.
Enforcement on unauthorised development is not adequately managed.
Infrastructure - The Council cannot comment on the suitability of sites in the plan without completion of Infrastructure Delivery & Funding Plan, Level 2 Strategic Flood Risk Assessment and Local Cycling & Walking Infrastructure Plan.
This is a continuing concern to residents due to the volume of recent and proposed development causing additional pressure on roads, education, social services, health facilities and local employment opportunities all of which gives a sustainable balance for our communities. The Infrastructure Funding Statement states all financial and non-financial developer contributions relating to Section 106 conditions should be completed but this is not the case when larger sites are split up. If developers do not honour the conditions the money reverts to ECC and RDC who should use this to improve our existing facilities, especially on our roads and cycle paths which are in a pitiful state of repair and will only worsen with further development if funding is not used where it was intended.

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

Rayleigh like other towns that have suffered from overdevelopment in recent decades and should be protect from large scale private development during the forthcoming Plan Period. Only development or local needs should be permitted. Local facilities like Mill Hall would be saved and car parking retained and made cheaper to assist local town centre business to survive what will be a challenging period. Secondary shopping facilities in Rayleigh would be supported and encouraged with public finance where required. Sites within the existing Rayleigh Conversation Area should not be considered.
Public transport would be supported and encouragement, especially when given for children to reach school without parents’ vehicles. Renovation and refurbishment of historic buildings with modern green energy would be promoted over demolition and intensification. Public services would be encouraged to return/expand to Rayleigh, in existing buildings like Civic Suite, Police Station and Library etc. The town centre should be the heart of our community not just something you drive through to reach somewhere else. This could be our vision and our aim for the future.
Proposed sites within Rayleigh and on the Western side should not be considered for development. Only an infrastructure plan would provide evidence that the chosen sites are sustainable in the long term, and greenbelt and environmental policies should be adhered to in relation to open spaces on the edge or within the town.
Rayleigh is 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.
Good public transport links are crucial for our villages, neighbourhoods and town centres. The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian, and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a complete review of sustainable transport.
Ensuring that public rights of way are not blocked by landowners and are kept free from debris. Assess paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look at offering this in the larger spaces. For example, a small toilet block and hand washing facilities in a car park.
Open Spaces - The value of our open spaces and the issues with climate change has become a priority. People will continue to reduce travel and split time working from home. Our open spaces are essential for wellbeing, exercise and relaxation. We are on an overpopulated peninsular surrounded by water with one way in and one way out and there is a proven risk of flooding. Open space is at a premium. All green spaces, no matter how small, hold some significance, especially to those who use them for recreation. They are of particular community value and should not be developed. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets.
All Conservation areas, green belt and sites subject to the exclusion criteria (i.e. Sites of Special Scientific Interest) on the call for sites must be protected from Development.
Local Wildlife Sites review: RDC policies for protecting wildlife areas need to be updated. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was. Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. The plan should create new wildlife meadows to encourage the pollinators to future proof our own existence.
Promoted Sites - Reasons against Development
CFS105 (Land North of Hambro Hill) would negatively impact the openness of the Green Belt between Rayleigh & Hockley. Rochford Green belt study states this parcel of greenbelt has a ‘Moderate’ rating for Purpose 1, and a ‘Strong’ rating for 2 & 3. It checks the unrestricted sprawl of large built-up areas, prevents Rayleigh & Hockley merging into one another, and assists in safeguarding the countryside from encroachment.


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


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

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

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

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

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

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

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

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

RDC must approve nomination for the Mill Hall to be classed as an Asset of Community Value.
The Mill Hall showcases local Artworks within its Foyer, and has a permanent mosaic completed by children of our schools. From the first step within the building, visitors can immediately feel the sense of culture and creativity. A large noticeboard of all events, shows and clubs available is straight ahead, plus the ‘tourist board’ style information desks is immediately welcoming and accessible for all.
The Mill Hall is popular with residents and visitors to Rayleigh, with a coffee shop and facilities to use after a visit to the many Heritage sites within the Town Centre. This includes the Windmill (open for weddings & tours), Rayleigh Mount, The Dutch Cottage, Rayleigh Museum, and King George’s park when Fair arrives in Town.
The Mill Hall has the performance provision for staging Theatre, Musical Concerts, Comedy shows, Live Bands etc. The venues’ size is ideal for large scale events in the main hall including Professional Wrestling, Dances, Boxing, Children’s exercise classes (Jumping Beans). Upstairs, the smaller hall has capacity and versatility to cover social events including art exhibitions, Exercise Classes, craft fairs. The Mill Hall is frequently used for wedding receptions, birthday parties, funeral wakes, Charity social nights (including Rayleigh British Legion) and local school Proms.
It is utilised as a social meeting place by a significant number of community organisations, groups, clubs, and exercise classes. They make regular use of the Mill Hall throughout the day, as well as evenings and weekends. Consequences of the decision by the Council to keep the Mill Hall closed, some organisations have dis-banded and others have become less well supported.
The Mill Hall helps to put the town on the map as a tourist destination, improving the local economy and supporting other businesses including the many restaurants & pubs in the area prior or after an Event.
Rayleigh’s position within the District - and its proximity/travel links to Southend-on-Sea and Chelmsford - mean it is well placed to attract tourists and visitors who want to visit, eat out and then enjoy an event/show at the Mill Hall, without a long train journey home. The free parking after 1pm on Saturdays already brings in visitors to Rayleigh for shopping, so this would be ideal for evening shows/events at the Mill Hall.
The Mill Hall has excellent potential once renovated & refurbished. More focus/marketing placed on its Theatre staging ability. It could be a magnet for touring theatre groups and become part of the East of England theatre circuit, much like Chelmsford & Norwich.
Objections have been raised throughout the Asset Strategy Delivery Program by non-Administration District Councillors and residents with Rochford District Council over plans to demolish the Mill Hall and redevelop the site with housing. More than 4,000 people from the District have signed a petition opposing the demolition of the Mill Hall and building housing in the Rayleigh Conservation Area.
The Theatre’s Trust - the national advisory body for theatres and a statutory consultee within the planning system, has written to RDC in support of maintaining the Mill Hall performance venue.
Sustainable development as defined through the NPPF (2019) includes a social objective to support social and cultural wellbeing. Paragraph 92 seeks planning decisions to plan positively for facilities and to guard against unnecessary loss.
We do not consider there to be sufficient justification demonstrating the existing Mill venue and the live events it hosts are no longer required.

We would also suggest the economic impact on the town should be considered in terms of loss of audience spend in other businesses when attending shows and events. There will be significant harm to social and cultural wellbeing through the loss of existing events held at the Mill Hall.
Local Authorities are the biggest funder of arts and culture in England. They support cultural activity in their areas in order to provide their residents with a better quality of life, to promote tourism, stimulate the local economy, and build their area’s reputation – creating a unique sense of place. The Partnership Panel meeting earlier this year requested Officers research funding for the Mill Hall via Arts Council. Has this been completed and what opportunities are there to support this fantastic venue?

Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options (RLPSO) on behalf of Mr G Marshall and in relation to Peggle Meadow, Rochford (‘the Site’).
1.2 The Site has previously been submitted in response to the Council’s the Call for Sites, and is reference CS095 in the Council’s plan-making process.
1.3 Representations were submitted to the Local Plan Issues and Options consultation in 2018 to further promote the allocation of the Site to help meet development needs
through a sustainable, proportionate extension to the south of Rochford, capable of delivering numerous benefits.
1.4 This representation should be read alongside the Vision Document that has been prepared in respect of the development of the Site, and which accompanies the
representations at Appendix A.
2.0 Response to Local Plan Spatial Options Question 4
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 We consider that Strategic Objective 1 could be clearer that the provision of homes to meet local needs entails providing housing close to existing communities. As currently drafted, it could be inferred that the priority is working with neighbouring authorities, rather than trying to meet local housing needs and support existing communities within the District per se.
2.2 Providing homes through extensions to existing settlements ensures local residents can remain within their local community and close to family, friends, and other informal social networks that form an important part of everyday life. It also ensures greater choice for
existing residents, and reduce the risk that existing members of the community may have to move elsewhere due to a lack of suitable housing.
2.3 We suggest that Strategic Objective 1 should be amended to:
To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs, through providing homes close to existing communities, utilising previously developed land and working with neighbouring authorities if required.
2.4 In addition, we suggest that objectives of the Local Plan should include to improve the affordability of housing for people of Rochford District.
2.5 The RLPSO notes (page 12) that:
“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times to average
annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”
2.6 We agree that affordability of housing is a very real local concern, and an issue the Rochford Local Plan must seek to address. The most recent data available1
reports that the median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’).
2.7 The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average.
2.8 In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69
– significantly below the District’s 11.57.
2.9 Additionally, and whilst empirical data is currently limited, the longer term impact on housing demand resulting from the Covid-19 pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Early indications
are that there has already been an increased desire to move from more to less urban areas, driven by what has been dubbed the ‘race for space’ – the desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.
2.10 At the same time, the situation has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely anticipated that there will be a degree of return to office-working, it is expected that the need for employees to be physically present within a particular office will be substantially reduced.
2.11 As a consequence, it is anticipated that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London. As a consequence, the area may well prove an increasingly popular destination for those migrating out of higher density areas in and around London. This in turn is likely to put considerable pressure on the housing market. If insufficient homes are provided, it is also likely to result in a significant worsening of affordability. Ensuring a sufficient supply of homes will be imperative if the Council is to tackle the issue of housing affordability in the District.
2.12 Strategic Objective 3 is proposed to be:
“To facilitate accelerated growth in our local economy through supporting the delivery of suitably located land which meets businesses needs at each stage of their lifecycle (including delivering grow-on space to enable local businesses to flourish), the continued functioning of London Southend Airport as a thriving regional airport,
serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park”
2.13 We support this and, in addition, suggest this objective should recognise that the critical role house-building plays in supporting the local economy, and the economic benefits house building would have for the District.
2.14 As the Local Plan Spatial Options recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.
2.15 Employment relating directly to the construction industry will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.
2.16 Development of additional homes in the District will also engender sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of new homes on first occupation, on home set up cost, and on an ongoing basis in local shops and services in the area.
2.17 Conversely, failure to deliver sufficient homes for the District would not only result in a failure to support the local construction industry and failure to realise the potential opportunities outline above, it would also likely significantly deter inward investment by potential employers, if insufficient, affordable accommodation was not available locally to provide a local workforce.
3.0 Response to Local Plan Spatial Options Question 6
Which of the identified strategy options do you consider should be taken forward in the Plan?
Growth of Rochford
3.1 It is important to recognise that Rochford District contains a number of settlements, each with their own character and communities. Whichever growth strategy is ultimately pursued, the Local Plan should ensure a proportionate level of growth is directed to the
District’s various settlements, having regard to their characteristics and sustainability to accommodate additional growth.
3.2 For the Local Plan strategy to be sound, we consider that it will need to direct a relatively large proportion of housing growth to Rochford.
3.3 As the RLPSO recognises, Rochford and Ashingdon together form a functionallyconnected settlement home to around 18,000 residents. Between Rochford town centre and a number of neighbourhood centres located throughout the wider settlement, Rochford provides for a wide range of services and business spaces, including a number of specialist employment areas supporting nearby London Southend Airport.
3.4 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.
3.5 Rochford / Ashingdon is characterised as a top tier settlement within the current Development Plan, i.e. one of the most sustainable settlements to which to direct
additional growth.
3.6 It is one of only three settlements in the District that benefits from a railway station.
3.7 In addition, it is also one of only three settlements in the District that benefits from a defined town centre.
3.8 The Local Plan strategy should direct a significant proportion of housing development to Rochford.
3.9 In respect of RLPSO Option 1 (urban intensification) we note that the RLPSO suggests this would involve no loss of Green Belt land, would minimise loss of greenfield, and would deliver 4,200 homes over the next 10 years.
3.10 The RLPSO describes Option 1 as “the minimum expectation of national policy” and states it is “likely to be required within every strategy option”.
3.11 It goes on to state that this option would entail making best possible use of our existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations).
3.12 The RLPSO suggests that at least 4,200 homes will be built over the next 10 years under Option 1 and that 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.
3.13 Whilst elements of Option 1 may be capable of being incorporated into a sustainable strategy for growth, it is clear that Option 1 cannot alone result in a sound Local Plan strategy.
3.14 Firstly, it is important to note that national policy places great emphasis on the need to
significantly boost the supply of housing and to meet local housing needs. Indeed, it is an express requirement of a sound Local Plan (as per paragraph 35 of the NPPF) that it seeks to meet the area’s objectively assessed needs, as a minimum. The RLPSO suggests a need to plan for at least 7,200 additional homes, and Option 1 would fall significantly short of meeting this.
3.15 Secondly, we consider that it is highly unlikely that 4,200 dwellings could be delivered through this option within the next 10 years. Such delivery would equate to an average of 420 dwellings per annum (dpa). The Council’s Annual Monitoring Report 2019/20
states that between April 2010 and March 2020, the District achieved a total of 1,768 dwelling completions – an average of 177 dpa. This figure included homes that had been delivered on large allocations made through the Rochford Allocations Plan, and did not rely solely on redevelopment of previously developed land / urban intensification, yet was still significantly short of delivering 420 dpa.
3.16 Furthermore, the Council’s Annual Monitoring Report 2019/20 noted that of the 347 net dwelling completions achieved in 2019/20, 268 of these were from major schemes. A significant proportion of these were delivered on allocated settlement extension sites in
the adopted Development Plan. It reports that 55% of dwelling completions were on greenfield land and, separately, that only 81 net dwelling completions in 2019/20 were from windfall sites.
3.17 In addition, it must be remembered that there is only a finite supply of previously developed land suitable and viable for residential development, and it is likely that a
significant proportion of this has already been exhausted.
3.18 Thirdly, it cannot be assumed that such a level of urban intensification would be suitable or sustainable. To achieve such a level of urban intensification to deliver the number of new homes that the RLSPO suggests through Option 1 would likely result in densities of development vastly greater than existing, to the potential detriment of the amenity of existing residents and character of the District’s settlements; and / or requiring the
redevelopment of existing employment / retail / community uses for housing, with resultant negative social and economic impacts.
3.19 Fourthly, it is not clear where in the District such intensification / redevelopment of previously developed land would deliver housing, and what spatial distribution of homes this would provide. As noted earlier within this representation, it is important to recognise that Rochford District comprises multiple settlements, each with their own communities, and each with their own needs. Option 1 is unlikely to address such needs, and instead would simply focus housing where there happened to be opportunities to redevelop previously developed land.
3.20 Fifthly, it is unlikely that a strategy reliant on urban intensification / redevelopment of previously developed land will deliver the types of homes required or infrastructure improvements. It is unlikely, for example, that such approach would deliver as many affordable homes as alternative strategies, or be accompanied by any substantial infrastructure improvements, due to the likely limited scale of individual developments and potential viability challenges they would face.
3.21 It is manifestly clear that if the Local Plan is to be a sound plan that meets development needs in a sustainable manner, then it cannot rely wholly on RLPSO Option 1.
3.22 The NPPF confirms (at paragraph 136) that Local Plans are the appropriate vehicle through which to make alterations to the Green Belt boundary. The NPPF also states that such alterations 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.
3.23 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.
3.24 Given the scale of objectively assessed need faced by the District, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green
Belt through the Rochford Local Plan.
3.25 We also note that there are potential options for the District to explore designation of additional, new Green Belt – land on the eastern side of the District, at Foulness, is very much open and rural in character, and in addition subject to multiple constraints that
make it unsuitable for any significant scale of development. However, this area of the District is not currently allocated as Green Belt.
4.0 Response to Local Plan Spatial Options Question 9
Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?
4.1 We agree that the Local Plan should seek to direct development to Flood Zone 1 (land least at risk of flooding from tidal or fluvial sources).
4.2 In doing so, however, it is important that sites, part of which lie in Flood Zone 2/3, but which are perfectly capable of accommodating a quantum of development in Flood Zone 1, are not rejected on flood risk grounds. To do so would be patently unjustified, giving rise, ultimately, to soundness concerns.
5.0 Response to Local Plan Spatial Options Questions 32 and 34
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?
5.1 It is considered that the allocation of additional sites for development gives rise to the potential to make significant enhancements to green and blue infrastructure.
5.2 For example, in respect of proposals for Peggle Meadow, Rochford, and as set out in the Vision Document that accompanies these representations, green and blue infrastructure enhancements are proposed.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
5.3 The development of Peggle Meadow, Rochford (CFS095) gives rise to the potential for green and blue infrastructure enhancements to be delivered, as set out in the Vision Statement that accompanies this representation.
6.0 Response to Local Plan Spatial Options Question 46
With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How
can we also ensure our village and neighbourhood centres remain vibrant?
6.1 It is critical that the Local Plan seeks to direct sufficient growth to the District’s various
settlements such that inter alia local services and facilities can be sustained and supported.
6.2 We consider that the Local Plan should seek to support and enhance the vitality and vibrancy of the District’s town centres; and to sustain village and neighbourhood centres.
6.3 It should be recognised that towns such as Rochford contain smaller neighbourhood centres, as well as a town centre, and that these often perform an important function for the local community which planning should seek to support.
6.4 The town centre and neighbourhood centres both have important roles in such settlements, and the Local Plan should look to support both. In respect of South
Rochford, for example, it is considered that the Local Plan should seek to ensure that neighbourhood shopping along Southend Road is sustained, as well as acting to
enhance the vitality of the town centre. Support for both is not mutually exclusive – the direction of growth to South Rochford can help support local neighbourhood shops, as well as the town centre.
7.0 Response to Local Plan Spatial Options Question 57b
With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How
could that improve the completeness of Rochford and Ashingdon?
i. Housing
7.1 The Site (CFS095) is considered suitable, available and achievable for residential development in a highly sustainable location for additional growth, and without
undermining the strategic purpose of the Green Belt. This is discussed in further detail in response to this question.
7.2 In addition, the Vision Document for Peggle Meadow that accompanies this representation (Appendix A) details the sustainability and deliverability of the Site for
housing, and demonstrates how a high-quality development will be delivered on the Site.
South Rochford as a location for growth
7.3 The adopted Core Strategy (2011) identifies Rochford as a tier 1 settlement, noting that it is a local centre. Rochford is one of the largest settlements in the District and is home to a range of services, facilities, employment opportunities, and is well served by public transport. It clearly represents a sustainable location to which a proportion of the District’s growth should be directed.
7.4 The general location South Rochford was considered through the Council’s previous Local Development Framework process and Core Strategy as a general location for growth.
7.5 The Council’s reasons for rejecting South Rochford were set out in the Core Strategy Sustainability Appraisal Addendum (2011) and were as follows:
“Location 2 [South Rochford] was not selected as it has the potential to engender coalescence with Southend, performed less well in sustainability terms compared with
West Rochford and would be less likely to deliver community benefits than development in South East and East Ashingdon”.
7.6 It is important to note that these concerns related to the general location of South Rochford, and not to any specific site.
7.7 The other reason to reject South Rochford as a general location was not that it was an unsustainable area for growth per se, but rather there were other areas that were considered more sustainable.
7.8 Firstly, it should be recognised that these areas have subsequently been developed, or their development is already been accounted for, and that there is still an outstanding need for housing.
7.9 Secondly, since adoption of the Core Strategy, Rochford District – jointly with Southendon-Sea Borough Council – adopted the London Southend Airport and Environs Joint Area Action Plan (JAAP). The JAAP directs significant employment growth and
infrastructure improvements into the area commensurate with the general location of South Rochford.
7.10 In addition, a railway station has been delivered at London Southend Airport. This is accessible from a number of locations within South Rochford, and significantly enhances the sustainability of this area for growth.
7.11 Having regard to the above, it is clear South Rochford is considered a sustainable location for growth.
Peggle Meadow (CFS095)
7.12 Peggle Meadow, Rochford is site reference CFS095 in the Council’s current plan-making process.
7.13 It is located off Southend Road, at the southern end of Rochford. Peggle Meadow is a mall site on the edge of an existing urban area, with development immediately to the north and west.
7.14 The Site measures c.3.9 ha, is mostly grassland, resembling a horse paddock, and contains several storage sheds no longer in use.
7.15 Historically, the land was farmed as market gardening. However, it has not been in productive use for c.25 years and has been uncultivated during this time. The land is not currently in use and, indeed, is no longer viable for agricultural use.
7.16 The Site is located to the south of Rochford, and is subject to a significant degree of containment due to the existing residential development immediately to the north and west; and watercourses and their accompanying dense vegetation to the south and east.
Views into and out of the Site are very much restricted.
7.17 The Site is close to the District boundary with Southend Borough Council, with Warners Bridge Park to the south providing a substantial and robust green buffer between it and the built form of Southend-on-Sea.
7.18 Arable fields are located to the east of the site, though it should be recognised that the Site does not project any further eastwards than the existing built form to the north of the Site.
7.19 There are a range of shops, services and facilities within close proximity to this Site.
7.20 As set out in the Vision Document (Appendix A) that accompanies this representation,
the Site is within walking distance to a range of facilities, services, public transport connections, and employment opportunities; and benefits from excellent access to rail
and bus services, providing sustainable links to larger centres.
7.21 A retail park including both convenience and comparison shops is located approximately 400m from the site – well within walking distance. Additionally, a neighbourhood shopping parade is located to the north of the Site, and also within walking distance.
7.22 London Southend Airport and Southend Airport railway station (which provides links to Southend, Rochford centre, and London Liverpool Street), are located opposite the site and within walking distance.
7.23 In addition to being accessible to future employment growth at London Southend Airport, the site is well located in relation to existing employment areas at Temple Farm Industrial Estate and Purdeys Industrial Estate.
7.24 The Site is accessed via Southend Road – which provides a direct connection with Southend to the south; and Rochford town centre to the north, negating the need for vehicles travelling from the site to either of these centres to navigate through existing residential areas / the non-strategic highway network within the District.
7.25 Development of the Site is presents a number of opportunities, which are discussed in details within the Vision Document. In summary, these opportunities / benefits of the Site’s development include:
 Creation of a more robust and defensible Green Belt boundary.
 Minimal impact on the Green Belt, and would not engender coalescence.
 Landscape enhancements.
 Provision of homes in a location well related to facilities, services and employment opportunities; and with excellent accessibility to public transport services.
 Enhanced sustainable transport links for the wider area.
 Avoidance of impact on the District’s local highway network.
7.26 In relation to the Site’s ability to deliver improved sustainable transport links to the benefit of the wider area, the cycling and walking charity, Sustrans, have confirmed they expressly support development of the Site due to the sustainable transport
improvements it will enable. A copy of Sustrans’ letter is provided as Appendix B. We consider this is a factor that should be afforded significant weight in favour of the Site’s allocation.
7.27 Further to the Site’s excellent accessibility to public transport services (including rail and bus) it is important to note that the NPPF states:
“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been
previously-developed and / or is well-served by public transport”. (Paragraph 142, emphasis added)
7.28 The Site has been considered by the Council through its Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017) (as site referenceCFS095).This noted that the Site is not subject to any constraints that would prohibit its development.
7.29 The SHELAA (2017) considered the Site’s proximity to educational facilities; healthcare facilities; open space / leisure facilities; retail facilities; public transport facilities; and existing residential areas. Against all of these, with the exception to education, it found that the site’s proximity was ‘good’.
7.30 In respect of proximity to education it was rated as ‘medium’.
7.31 In respect of proximity to education, we note that the SHELAA (2017) does not consider that this renders the site unsuitable, but would nevertheless wish to emphasise that the Site is in close proximity to Southend Road along which run regular bus services which
connect the site to a number of schools (and, considering accessibility beyond educational facilities, to the town centre).
7.32 The SHELAA (2017) acknowledged that the vast majority of the Site is within Flood Zone 1 – land least at risk of tidal or fluvial flooding. Development of the site can be delivered without residential development taking place within Flood Zone 2 or 3.
7.33 The Site has been subject to a Flood Risk Assessment (July 2020), provided as Appendix C to this representation. Key conclusions of this Flood Risk Assessment include:
 All proposed dwellings will be located within Flood Zone 1. NPPF states that all uses of land are appropriate in this zone and the Sequential Test has been applied within
the site boundary and can be deemed as being passed.
 All built development and SUDS features will be located outside of the design climate change (35%) 1 in 100 year floodplain and climate change (65%) 1 in 100 year floodplain.
 Proposed dwellings will be set above the extreme climate change 1 in 1000 year flood level.
 Safe access/egress can be achieved during the peak of the event.
 It is considered that there is a low risk of groundwater flooding.
 There is a very low to high risk of surface water flooding which will be mitigated by ensuring that the proposed dwellings are set above the flood depth. 7.34 The SHELAA (2017) confirmed that the Site can be delivered without requiring significant infrastructure upgrades.
7.35 Vehicular access to the site can be achieved, as confirmed through an Access Appraisal
that has been undertaken, and previously submitted to the Council.
7.36 There are no physical constraints that prohibit the development of Peggle Meadow for housing.
7.37 The SHELAA (2017) concluded that the Site’s suitability for development will be dependent on a Green Belt assessment.
7.38 Subsequently, the Council published the Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’).
7.39 The Green Belt Study (2020) suggested that development of the Site would result in ‘moderate-high’ level of harm to the Green Belt.
7.40 Within this study, the Site forms a small part of the a larger parcel that was assessed as P65.
7.41 The Green Belt Study (2020) concluded that Parcel P65 makes a strong contribution to purposes 1, 2, 3 and 5 of the Green Belt (to check the unrestricted sprawl of large builtup areas; to prevent neighbouring towns merging into one another; to assist in safeguarding the countryside from encroachment; and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land). It concluded that it makes a weak contribution to purpose 4 (to preserve the setting and special character of historic towns).
7.42 It is important to recognise the need to treat the results of any assessment of a larger parcel with caution when seeking to apply them to a smaller site within such a parcel. Clearly, smaller sites within a larger parcel may make a different level of contribution to the purposes of the Green Belt, and the harm their development may cause to the purposes of the Green Belt may well be different to that of the larger parcel in which they
have been incorporated for the purposes of assessment. 7.43 A note provided by the Local Plan Examination Inspector to Welwyn Hatfield Borough Council in relation to its Local Plan and the approach to the review of the Green Belt underlines this issue, stating:
“The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by
development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might
reasonably be considered further”. (EX39 of the Welwyn Hatfield Local Plan
Examination, December 2017).
7.44 As such, it is imperative to consider the Site itself: its contribution to the purpose of the Green Belt, and the extent of any harm to the purposes of the Green Belt that its development would entail.
7.45 In addition, case law confirms that in considering whether exceptional circumstances apply that justify alterations to the Green Belt, it is necessary to not only consider the potential harm to the purposes of the Green Belt development would engender, but also the degree to which such harm could be mitigated. The Green Belt Study (2020) fails to consider potential mitigation measures, and this will be something that the Local Plan
will need to consider.
7.46 A Green Belt Report (2020) has been prepared and submitted previously to the Council, and provided again as Appendix D to this representation. In addition, a site-specific Landscape and Green Belt Statement (2021) has been undertaken by James Blake Associates and provided as Appendix E.
7.47 As these studies confirm, when one looks at the Site in detail, it is clear that it only make a limited contribution to the purposes of the Green Belt.
7.48 The Landscape and Green Belt Statement (2021) considered the Site specifically, and in detail. In relation to Purpose 1 of the Green Belt (to check the unrestricted sprawl of large built up areas) it noted that the Site is located in close proximity to the built up area of Rochford and would not result in encroachment. Rather, its development would result in limited ‘infill’ of the previous brownfield land. It also noted that the Site is well contained by strong physical features including the built-up area of Rochford, the Prittle Brook and the Harp House Ditch. Overall, it concluded the Site was of low importance to Purpose 1 of the Green Belt.
7.49 In relation to Purpose 2 (to prevent neighbouring towns merging into one another) the Landscape and Green Belt Statement (2021) found that the Site is physically and visually separated from Southend and as such would not result in any physical or visual
encroachment. Furthermore, it noted that Warners Bridge Park provides a gap between Rochford and Southend which is of substantial permanence, and that the gap which exists now between the two settlements will exist to no greater or lesser degree whether or not Peggle Meadow is developed. It concluded the Site is of zero importance to Purpose 2.
7.50 Regarding Purpose 3 of the Green Belt (to assist in safeguarding the countryside from encroachment), the Landscape and Green Belt Statement (2021) found that the Site is well contained by strong man-made features to the north and west, and and dense and mature green infrastructure to the east and south. It also noted that the proposed strategic green infrastructure will provide further containment. As the Landscape and Green Belt Statement (2021) noted, it is also relevant that the Site has a degraded / neglected character. It concluded that the Site is of low importance to Purpose 3 of the
Green Belt.
7.51 In relation to Purpose 4 (to preserve the setting and special character of historic towns) the Landscape and Green Belt Statement (2021) concluded that the Site is not considered to form part of the landscape setting of a historic town, nor does it impact on any Conservation Areas or Listed Parks and Gardens. It went on to conclude the Site is of zero importance to Purpose 4.
7.52 In summary, the Landscape and Green Belt Statement (2021) provided by James Blake Associates concludes the Site is of low importance to Purpose 1 and Purpose 3 of the Green Belt, and of zero importance to Purpose 2 and Purpose 4. It provided clear and
robust justification for reaching such conclusions.
7.53 In respect of the need to consider the potential to mitigate impacts on the Green Belt in addition to considering a site’s contribution to the purposes of the Green Belt, it is relevant to note mitigation measures are proposed as part of the development of the
Site.
7.54 These include enhanced landscaping to reinforce the existing mature vegetation towards the southern boundary; and a loose-grained layout of dwellings towards the south and east of the Site (proposed to take a traditional form, and will be a scale and massing
which reflect the existing residential development in the locality, in order to minimise visual impact).
7.55 Additionally, and still in relation to the issue of Green Belt, the NPPF states that where Green Belt is released to meet development needs, as well as prioritising locations close to public transport links, plans should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. The PPG3
sets out the compensatory improvements that strategic plan-making authorities should seek to deliver in the event that it is necessary to release land from the Green Belt. These include the following:
 New or enhanced green infrastructure;
 Woodland planting;
 Landscape and visual enhancements (beyond those needed to mitigate the immediate impacts of the proposal);
 Improvements to biodiversity, habitat connectivity and natural capital;
 New or enhanced walking and cycle routes; and
 Improved access to new, enhanced or existing recreational and playing field provision.
7.56 A number of such compensatory improvements can be delivered through development of the Site. 7.57 In terms of new or enhance green infrastructure, in addition to the enhanced landscaping that is proposed, the proposed development also incorporates the creation of a new public open space to the north of the Site. This will also provide a recreational benefit.
7.58 Through development of the Site, ecological benefits will be delivered, with ecological enhancements to be delivered as part of the additional landscaping enhancements,
SuDS and open space provision.
7.59 In terms of cycle and pedestrian link enhancements, the Site represents a unique opportunity to deliver a cycle link which the Core Strategy (2011) promoted.
7.60 This link is discussed further within the accompanying Vision Statement, and to reiterate,
is supported by Sustrans.
7.61 This link will facilitate a safe and attractive pedestrian and cycle access to Warners
Bridge Park, Temple Farm Industrial Estate, and to Southend-on-Sea more generally,
for existing and future residents of Rochford.
7.62 It should be noted that this new link will also provide a safe and convenient pedestrian / cycle access for existing and future residents of Rochford to recreational facilities and playing fields at Warners Bridge Park.
7.63 The ability of the Site to deliver the above compensatory measures called for by national
guidance in instances where land is removed from the Green Belt, are factors which weigh very much in favour of removing this Site from the Green Belt.
7.64 The Site is clearly a suitable and sustainable site for residential development, and one through which a number of additional benefits, in addition to the provision of housing, can be delivered.
7.65 Turning In relation to deliverability, the Site is not subject to any legal or ownership constraints to its delivery for housing, and is being actively promoted for development by the owner. It is an available and achievable site for residential development, in addition
to being a sustainable one.
7.66 A Landowner’s Vision Statement has been prepared by the landowner, and accompanies this representation as Appendix F. This sets out the landowner’s desire for an exceptionally high quality development at Peggle Meadow, to provide a legacy for this Site, which has been in his family’s ownership for generations.

Local Plan Spatial Options Consultation
Please find below the comments from Hockley parish Council regarding the Spatial Options consultation.
The need for housing is understood but many of the proposals in the Local Plan Consultation and the impact of over-development in Hockley are a major cause for concern, especially without evidence of supporting infrastructure. This initial consultation informs residents of landowners who have put forward sites for future development so there is a personal gain aspect here. Rochford District Council has a duty to actively support residents needs in all communities and influence
Government policies.
Consultation Process -The volume of information contained in the consultation was difficult to access and view online. Some links did not work properly. RDC are not reaching residents who have no internet.
Spatial Themes not included - Cultural and Accessibility.
Vibrant Town Centres: Work actively with premises owners to assist in the re-letting of any empty shops. Maybe offer a reduced rent to new businesses as a start-up scheme for “local” business only – allowing the entrepreneurs in the Rochford District a chance to showcase their businesses. Discuss with 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.
Employment – District is lacking in Environmental services - woodland conservation and management. 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/apprenticeships to train all ages get back into work or upskill (with jobs at the end of training.) Developers should be encouraged to use local labour. 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 to future-proof our residents’ opportunities Improve Long-term Economic growth - Better road networks, gigabit broadband and Wi-Fi. The council should stop developing existing commercial land into housing.
Planned Forms of Housing: Young people/couples do indeed find it difficult to purchase property in Hockley. It is hoped that the new developments proposed will cater for their needs with more semi-detached properties than is now the case. The growing elderly population requiring
specialist/suitable accommodation need assistance. Many elderly single people are living in familysized homes when they would prefer more suitable accommodation such as bungalows or purpose-built flats. Mix of housing for “affordable“ properties with higher standards for gardens and recreational space. Consideration should be given to the provision of house for life, Adapted homes for the disabled, bungalows and other potential buildings for downsizing families. Housing
for the hidden homeless – those “sofa surfing” & Emergency housing. The plan makes no reference
to social housing quotas which should be included in all new developments. By working closely with planners and developers, as well as different charities and communities, residents, and businesses. You will then get a better understanding as to what you need and what will be achievable.
From 1st August it was announced that empty buildings and brownfield sites should be converted rather than build new. This alternative should be evaluated first.
Many development proposals would also mean a further reduction in air quality, light pollution and the loss of trees, farming, and arable land at a time when food production and supply is becoming a cause for concern.
Care needs to be taken to maintain the integrity of the existing settlements with respect to green boundary between Hockley and its neighbours. Essential green belt is being allowed to erode further (suggested land at north of Merryfields Avenue, Turret Farm, Church Road, land north east of Folly Lane, a number of sites on Greensward Lane, Lower Road and High Road) which will be impossible to replace.
Enforcement on unauthorised development is not adequately managed.
Local generation of low-carbon and renewable energy – It is encouraging to learn of Rochford
District Council’s intention to provide housing to meet the needs of both young and old that are
carbon neutral and energy efficient. New developments should be able to source some or all their energy from renewable sources. Solar in all new development as standard. Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs; there are many flat roofed buildings all over the district
that could accommodate solar panels without damaging the landscape. Explore tidal energy and seek out suitable locations to ascertain whether it is viable. Retrofitting existing housing and commercial buildings.
Infrastructure - The Council cannot comment on the suitability of sites in the plan without completion of Infrastructure Delivery & Funding Plan, Level 2 Strategic Flood Risk Assessment and Local Cycling & Walking Infrastructure Plan. This is a continuing concern to residents due to the volume of recent and proposed development causing additional pressure on roads, education, social services, health facilities and local
employment opportunities all of which gives a sustainable balance for our communities. The Infrastructure Funding Statement states all financial and non-financial developer contributions relating to Section 106 conditions should be completed but this is not the case when larger sites
are split up. If developers do not honour the conditions the money reverts to ECC and RDC who should use this to improve our existing facilities, especially on our roads and cycle paths which are in a pitiful state of repair and will only worsen with further development if funding is not used where was intended. The volume of traffic has increased to an unacceptable level on the B1013
causing noise, air pollution and disturbance; Is the traffic survey up to date?. The main access to Hockley and on to Southend is via the B1013; one of the busiest ‘B’ roads in the country. It is difficult to understand how this already congested road could cope with the vehicles from another 1,000 houses in Hockley, let alone those from adjacent villages and towns. Rochford District is on
a peninsular: traffic can go no further than Southend especially with limited access to the north of the county via Battlesbridge. It is suggested the Council undertake a road traffic survey before continuing with the District Plan.
Good public transport links are crucial for our villages, neighbourhoods, and town centres. Hockley
benefits from being on the main Southend Victoria/Liverpool Street train line. Unfortunately its bus
service is not so efficient with the nos 7 and 8 services passing through the village from Southend to Rayleigh and vice versa twice an hour. Services to other parts of the district/county have to be accessed from these two termini. The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian, and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a complete review of sustainable transport. Cycling infrastructure and other sustainable transport methods should be prioritised over a car-centric highway use.
Balancing access against increased congestion will be the issue for a lot of the promoted sites in Hockley. If RDC keep adding small developments to the boundaries of the town, it will overcrowd existing houses and add to urban sprawl.
Ensuring that public rights of way are not blocked by landowners and are kept free from debris. Assess paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look at offering this in the larger spaces. For example, a small toilet block and hand washing facilities in a car park.
Community infrastructure - Community infrastructure should be preserved and extended.
Access to town centres and secondary shopping by bicycle and foot should be made easier and safer. Hockley 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. Hockley is served by two GP practices, as has been the case for 50 years or more. Hockley’s health clinic closed in the last few years and
young mothers and the elderly have to travel to Rayleigh for medical attention. What are the plans for additional health services in line with the vastly increased population should the plan be enforced?. 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 current recycling site at Castle Road, Rayleigh 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.
Open Spaces - The value of our open spaces and the issues with climate change has become a priority. People will continue to reduce travel and split time working from home. Our open spaces are essential for wellbeing, exercise and relaxation. We are on an overpopulated peninsular surrounded by water with one way in and one way out and there is a proven risk of flooding. Open
space is at a premium. Unfortunately for the youth of Hockley, there is no sports field they can use in the village. The District Plan does mention the use of the Greensward Playfield and it is to be hoped this will be progressed. The District Plan places great emphasis on health and wellbeing. Fortunately Hockley is well served with a network of footpaths. It is important that they
are maintained and not encroached upon by development All green spaces, no matter how small, hold some significance, especially to those who use them
for recreation. They are of community value and should not be developed. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets. RDC must protect all recreational spaces
and improve them, where necessary.
Conservation areas, Green Belt & sites subject to the exclusion criteria (i.e. Sites of Special Scientific Interest) on the call for sites must be protected from Development.
Local Wildlife Sites review: RDC policies for protecting wildlife areas need to be updated. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was. Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. The plan should create new wildlife meadows to encourage the pollinators to future proof our own existence.
RDC to focus on concerns and consideration to wildlife, birds, animals, and insects. Alongside plants and endangered species. Surrounded by Green Belt, Hockley is lucky in having access to a number of open spaces. It is noted that the Marylands Nature Reserve is included in The District Plan but not Plumberow Mount Open Space or St Peter’s Road Open Space – all maintained by the Parish Council. Marylands Woods, Plumberow Woods, Crabtree Woods, Hockley Hall Woods and nearby
Beckney Woods are all ancient woodland but in private hands. It would be of great benefit to the community if they were included in the Local Plan and protected for the future. Betts Wood and, of course, Hockley Woods are in the care of the RDC. With so much development, it is obvious that flora and fauna will suffer. Consideration should be given to identifying further green spaces (not just play areas) for public use. Efforts should be
made to ensure wild-life corridors are incorporated into developments near to woods and open countryside.
Heritage
The District Plan contains a list of conservation areas. It is disappointing to note that St Peter and Pauls’ Church, Church Road and adjacent buildings (the old school house, Hockley Hall, Mill House and the former rectory) does not appear. In the surrounding green belt, it is constantly under threat and it would be a tremendous loss to the community should this historic part of the
village be developed.
Plumberow Mount (a Romano/British tumulus) does not appear in the document as an ancient monument.
Promoted Sites (Hockley)
The plan proposes around 1000 additional houses in Hockley with other developments on land bordering the parish. This density will have a major detrimental impact on the quality of life for the settlements.
• CFS105 (Land North of Hambro Hill) would negatively impact the openness of the Green Belt between Rayleigh & Hockley. Rochford Green belt study states this parcel of greenbelt has a ‘Moderate’ rating for Purpose 1, and a ‘Strong’ rating for 2 & 3. It checks the unrestricted sprawl of large built-up areas, prevents Rayleigh & Hockley merging into one another, and assists in safeguarding the countryside from encroachment.
• The Merryfields Avenue (green belt) proposal has been previously rejected by residents due to access issues as the land borders on the Nature Reserve and footpath 13. Consideration should be given to incorporating it into the Reserve rather than releasing it for development. The owner of the tract of land has made a few unsuccessful planning applications in the past on account of the threat to local wildlife, impact on ancient woodland, lack of access, the danger of flooding from the nearby stream and run off from the road. The cost effectiveness of providing access and services could prove to be exorbitant along with any damage incurred on the nearby
Nature Reserve, better that the land become part of the Reserve.
• Proposals for Folly Chase and Church Road will increase density and give further traffic problems on a busy county access road which has light industry and equestrian centres but does not have footways for pedestrian safety; vehicles are also subject to dangerous line of sight restrictions. The Folly Chase proposal was previously rejected by residents and supposedly dismissed by RDC but still appears in the Local Plan for development. The land to the north east of Folly Chase is adjacent to ancient woodland with protected trees (Betts Wood).
To the west of the site there is a green lane bordered with ancient trees which should be protected if development takes place. There is no public access to the site and there is concern that the adjacent community centre could be sacrificed for this purpose. What are the plans for the Community Centre and public footpaths which must be retained?
• Sheltered accommodation is in danger of being lost at Lime Court and Poplar Court.
• The proposal for development on land at Belchamps is particularly contentious due to the lack of open space for activities available to youngsters and community groups in the Rochford District. Any considered development would be a detrimental impact to the Historical
woodlands. This site has been a very valuable well used resource and it is important this is retained for our future generations.
• As Hockley Woods is the largest remaining wild woodland in the country RDC should be doing EVERYTHING it can to save it from development, either adjacent to or close by. RDC should also actively be adding to it by planting more trees to future proof its existence and status. RDC must protect any thoroughfares that access Hockley Wood.
These comments will be publicised on the Parish Council website, I would be grateful if you could do the same on the Rochford District Council website.

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

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

Spatial Options Consultation

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

Response of London Southend Airport Company Ltd to Rochford Local Plan: Spatial Options Consultation 2021

LSA is delighted to respond on the new local plan.
Our focus is primarily in relation to establishing a positive policy framework for continued growth and development of London Southend Airport (LSA), in accordance with up to date national policy that supports airport’s making best use of their existing runways, and in recognition of the important role and highly positive contribution the development of LSA can make to the District.

In addition, our response also makes suggestions to be considered for improved connectivity to the airport to the east of the railway line.

We would be keen engage with the Council on the drafting of policies and supporting text and urge the
continued close cooperation with Southend Borough Council on their new local plan.

Your sincerely
Glyn Jones
Chief Executive Officer

Rochford Local Plan: Spatial Options Consultation Paper 2021
Response of London Southend Airport Company Ltd
Policy Approach in Relation to Future of London Southend Airport
We are pleased to note the Consultation includes a section on the future of London Southend Airport (LSA).

National Aviation Policy
The section on the Future of LSA refers to current national policy which supports airports making best use
of their existing runways.
The text on page 91 refers to The Aviation Policy Framework (2013) and the Beyond the Horizon – The
future of UK aviation (2018) policy. It is also worth noting that in response to the challenges of tackling climate change, the government has also recently published its Transport Decarbonisation Plan and commenced consultation on its ‘Jet Zero’ strategy.

In the Transport Decarbonisation Plan (TDP), published by the Department for Transport in July 2021, the
Government explains that:
“International connectivity is a vital part of Global Britain and everyone should continue to have access to affordable flights, allowing them to go on holiday, visit family and do business.”
The Jet Zero consultation sets out how Government intends to preserve the benefits of air travel and deliver clean growth consistent with its 2050 net zero target. It also confirms that the international connectivity provided by UK’s aviation sector is vital to the country’s long term economic prosperity, and subject to the aviation sector playing its role in decarbonising the UK economy and delivering net zero aviation by 2050, that:
“everyone should continue to have access to affordable flights, allowing them to enjoy holidays, visit friends and family overseas and to travel for business”.
The TDP and Jet Zero represent the most recent expressions of policy, set out the Government’s position
that growth in aviation is compatible with meeting the UK's greenhouse gas reduction targets and reaffirm specific support for making best use of existing runways.
Growth and Development of London Southend Airport
Prior to the outbreak of the COVID pandemic, passenger numbers at LSA had increased to 2.2m in 2019
and some 1,500 people were employed at the airport. More broadly, the airport supported 2,200 direct,
indirect and induced jobs, over 1,400 of which were in South Essex, and contributed £77m per annum to
South Essex economy.

The pandemic has had a devastating impact on the global aviation industry in 2020. Southend, along with
all other UK airports, has experienced a significant reduction in passenger traffic, as a result of both Government imposed restrictions on air travel and reduced passenger demand at this time.
Whilst it is expected that Government travel restrictions will continue to impact on passenger demand and traffic levels throughout 2021 and into 2022, we expect traffic levels will start to recover as Government restrictions ease and that material recovery from the pandemic is anticipated by 2023-4.
By 2026, we expect LSA’s passenger throughput to have surpassed Pre-COVID levels and that the airport will be welcoming some 3 to 3.5 million passengers per year through the existing infrastructure. With investment to construct the developments permitted by existing planning consents, and operating within the existing Section 106 movement cap of 53,300 movements, we consider that the airport could serve some 7 to 8m passengers by the end of the 2020s.
During the local plan period, and with further investment in new facilities it is possible that passenger traffic could grow beyond 7-8m passengers and serve up to 12mppa. Growth to this level will require new planning consents, including a relaxation of the current movement cap on the number of aircraft operations.

These levels of growth reflect the fact that LSA is very much part of the London aviation “system”, with over 60% of LSA’s departing passengers self-identifying as originating in London in 2019, and the widely recognised position that airports in London and the South East are increasingly facing longer term capacity constraints where demand for travel will outstrip capacity.
An economic assessment carried out by PA Consulting on behalf of LSACL, forecasts that LSA would then be the location for 6,600 jobs with a further 3,300 indirect and induced FTEs jobs. Over 6,100 of these would be in South Essex and valued at over £0.5bn in South Essex economy.
We have also now commenced studies to understand what the implications of further growth of LSA would be, including on noise, transport and air quality. These studies will form part of our plan to consult on un updated Masterplan. The outputs form the studies and the development of the masterplan can be used to inform the preparation of the new Rochford Local Plan (as well as the new Southend Local Plan).

Policy for London Southend Airport
Planned in the right way, the development of LSA can make a highly positive contribution to the vision for the District, and a number of the strategic objectives set out in the Consultation Paper.
As noted in the “Economy” section of the draft Vision, the connectivity offered by a successful LSA will support the attractiveness of the area for business and investment. The success of LSA is vital to the economic prosperity of Southend, Rochford and the surrounding area and we are pleased that the text on page 91 recognises the important role LSA plays in supporting employment and the local economy.
Whilst the COVID pandemic has seen job numbers at the airport reduce to less than 900 from a peak of over 1,500 in 2019, we are expecting employment levels to return as passenger growth recovers. Job growth at the airport would support the objective of reducing levels of out commuting from the district as well as supporting skills development. Transport infrastructure at the airport could also support objectives related to improved local transport and connectivity.
The growth of the airport will have implications for the local area, and we agree that that the characterisation of these (on page 91) is fair representation of the range of positive impacts to be encouraged and environmental matters that would need to be addressed in future development plans.

Response to Question 28 Future of London Southend Airport
Question 28 of the Consultation seeks views on policy options available for the future planning of LSA.
LSACL consider that whichever options is followed, cooperation on the policy with Southend BC will be
important, and it would be helpful if both authorities adopted similar approaches.
We consider that the current Joint Area Action Plan (JAAP) has served the area well. Equally, with consent
now having been granted for the new business park (which formed a major component of the JAAP), we
do not consider there is now a need for an updated formal statutory Joint Area Action Plan to guide the
future planning of the airport and its surroundings.
We consider that the Local Plan should contain a section and policy or policies for the development and growth of LSA. We support a combination of Options 2 and 3:
i) Policy Supporting Development of London Southend Airport
In accordance with national policy, there should be a clear policy expressing support in principle of LSA’s
growth and development, subject to the normal local environmental safeguards, including noise, air quality and transport being acceptably addressed and mitigated in any new proposals. We would envisage the Local Plan defining the boundary of the airport and supporting development and redevelopment within the boundary of facilities that support the airport’s operation, growth and development. The policy would refer to the updated masterplan being prepared by LSACL which would be used to guide development of the airport.
This is the most common approach adopted by other planning authorities which contain a commercial
airport in their area.
Any proposals for development at the airport that would require the alterations to the current terms of the Section 106 agreement, would require the agreement of both Rochford and Southend Councils.
Therefore cooperation on the revised policy is essential.
We would be keen to engage with both Councils on the drafting of this policy and supporting text.
ii) Policy on Airport Related Parking
We consider it would be appropriate for a policy to be included in the Plan that airport related parking should only permitted within or immediately adjacent to the airport boundary. This is an approach that a
number of local authorities have adopted, and has been found to be sound and justified at local plan
examinations. In particular, it is the approach that recognises that whilst many passengers will drive to the
airport, it reduces the length and number of journeys by avoiding passengers parking more remotely and having to take extra journey’s via shuttle buses or valet parking operatives.

Response to Question 28 Future of London Southend Airport and Q52 (Transport Connections)
Question 52 of the Consultation asks where improvements could be made to transport connections and what could be done to improve connectivity.
Access to the London Southend Airport Rail Station
We consider that the Local Plan should consider how access to LSA’s rail station could be made more
convenient for local residents. At the present time a number local residents walk to the station, but the
route to the station, particularly from the residential areas to the east of Southend Road could be made shorter and more direct if an access was provided to the east side of the station through the “green buffer” (currently protected by policy ENV6 of the Joint Area Action Plan). It is recognised that such an improvement would also probably require the extension of a parking control schemes to prevent ‘fly parking’.
We consider the new local plan presents a timely opportunity to review whether the “green buffer” land
east of the railway could be more effectively used in connection with the railway and the airport, whilst
retaining and potentially enhancing the quality and effectiveness of the buffer for local residents. This site
could for example provide an excellent opportunity for improved local bus connectivity / interchange to the railway station and airport. Planned and designed in a sensitive way, and with higher quality landscaping, the buffer could be enhanced, whilst at the same time facilitating improved connectivity.

RDC/Spatial Consultation 2021 Questions

Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
A: Evaluate the impact of the current developments, especially in Rayleigh and Hullbridge.
Q2. Do you agree with our draft vision for Rochford District? Is there anything missing from the vision that you feel needs to be included? [Please state reasoning]
A: Mostly, although I do not feel you have included enough information on how you might achieve housing for the hidden homeless or those on low incomes, emergency housing provision, schemes to allow the elderly in large houses to be able to downsize or how you plan to provide suitable commercial units of varying sizes, to allow businesses to up or downsize into a suitably sized premises without them needing to relocate into another area.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making? [Please state reasoning]
A: Yes, as each settlement has its own characteristics and needs.
Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included? [Please state reasoning]
A: Don’t know.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required? [Please state reasoning]
A: Yes. Rayleigh is the largest town in the district but you need to maintain the green boundaries between the surrounding areas.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan? [Please state reasoning]
A: A combination of 3 and 4.
Creating a new town would enable all the infrastructure to be put in place, allowing more scope for cycling routes and pedestrianised areas. This will stop the urban sprawl which is currently happening in the larger town (and proposed in option 1), creating traffic havoc and pollution. Combining this with option 4 could help with spreading the balance of housing needs, traffic, etc. across the whole of the district and not just in one place.
Q7. Are there any reasonable alternatives to these options that should be considered instead? [Please state reasoning]
A: Windfalls should be included in the housing quota.
Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis? [Please state reasoning]
A: Yes: Cultural and Accessibility.
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change? [Please state reasoning]
A: Yes. We need to ensure we have a suitable plan to protect not only our towns and village communities (houses/businesses) but also the natural areas as well. We need adequate defences to limit flooding in all areas, protecting people and wildlife. Maybe these could be incorporated in the “natural” landscape theming so as to deflect any water away from these areas. New developments not only need to address their carbon footprint but also the design of the housing they build so that they limit flood damage.
Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character? [Please state reasoning]
A: Yes. I feel all of our coastal areas and areas of special interest, where there is a significant risk of flooding and harm to the environment needs careful consideration. Our ancient woodlands also need to be protected and well managed.
Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
A: Vast swathes of land being used for solar panels or unsightly wind farms should not be allowed. I do not feel we have used the potential of tidal renewable energy themes. We have potential in some areas to explore this without defacing our district. All new homes should be fitted with solar, either on their roof or windows and commercial properties could be encouraged to fit solar panels to their roof.
Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at? [Please state reasoning].
A: I believe that we should aim to achieve a higher standard if possible and encourage developers to put forward new ways of achieving this. We are planning for future generations and should not be stuck in the past. Why go for minimum standards? Always aim higher!
Q13. How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported? [Please state reasoning]
A: Solar in all new development as standard. Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs (there are many flat roofed buildings all over the district that could accommodate solar panels without damaging the landscape). Explore tidal energy and seek out suitable locations in order to ascertain whether it is viable. No wind turbines! They would ruin the landscape.
Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas? [Please state reasoning]
A: The district has some very distinct areas and a “one shoe fits all” would be detrimental to some smaller communities. The place-making charter should be bespoke, with each area being considered in its own right. The rules on building should be strict so as to enhance the areas of development and needs to consider the wider picture in respect of amenities, open spaces, retail, schools, services, pollution, character and accessibility (to name but a few). There should not be deviation of plans unless there are exceptional circumstances. Time and time again out SPD2 documents are ignored and ugly extensions and dormers are built to the detriment of the area.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included? [Please state reasoning]
A: They are, as long as they are adhered to.
Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
A: Yes.
➔ Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas? [Please state reasoning]
A: You need different design guides/etc as our district is unique and diverse and the “one shoe fits all" would be detrimental to its character and charm.
➔ Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting? [Please state reasoning].
A: You need to ensure that the character and heritage of our settlements are adhered to whilst allowing for some growth, in order to rejuvenate the smaller settlements if needed.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing? [Please state reasoning]
A: By working closely with planners and developers, as well as different charities and communities, residents and businesses. You will then get a better understanding as to what you need and what will be achievable.
Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas? [Please state reasoning]
A: The district has a large number of houses, existing and approved that have 4 or 5 bedrooms. The number of homes available with 2 or 3 bedrooms is minimal, which increases their price and availability. The smaller properties are the ones that need to be affordable for families. We should ensure that our “affordable“ properties are not all flats and that the minimum (or higher) standards are met for gardens/recreational space. There are sure to be single, elderly residents that would like to downsize from their large family homes, into a smaller, more manageable one but do not wish to go into an assisted living/residential /retirement home. They may want a 1 or 2 bedroomed property, maybe one storey, or low rise apartment that they own freehold. We also need to consider that some of our residents may need residential care and we should be looking at ways to cope with the rising number of elderly and provide accommodation for them also. We desperately need to meet the needs of the hidden homeless. The adult children on low wages that have no hope of starting a life of their own away from their parents. By living in these conditions, even if the family unit is tight and loving, it will cause mental health issues, stress and anxiety. We also need accessible properties for our disabled members of our community, where they are assisted in order to fulfil a normal as possible life. Emergency and social housing also need to be addressed.

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

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

Q23. With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan? [Please state reasoning]
A: The council needs to stop developing existing commercial land into housing. Too many sites have already been lost and many more are planned to go. They can then concentrate on helping those businesses wanting to expand to be able to do so. They should look to working with local schools and colleges, as well as businesses and the job centre, to see what sustainable employment is needed in the district. They then need to assist in schemes to train all ages get back into work or upskill.
Q24. With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the Green Belt? [Please state reasoning]
A: No. The current employment site allocations on Figure 30 do not provide enough space to meet the District’s employment needs through to 2040. We have around 87,000 people in the district. There is no data on the form to suggest how many of these are in employment and how many are looking for work but the council need to reassess its future needs in order to future-proof our residents’ opportunities. We only need to formally protect sites that have a future and a potential to expand or continue effectively. Green belt sites should be assessed separately and decisions made on merit.
Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?
A: Option 3 could deliver new opportunities for employment as it would be a new site completely. Industrial units of various sizes, with room for expansion plus retail, hospitality and other employment could be included in the criteria for the development. Option 4 could assess existing sites across the district and the options to be able to expand, as well as areas for new sites.
Q26. Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?
A: Environmental services - woodland conservation/management. (We need to find funding for this as it is important!) HGV training school.
Q27. Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g. skills or connectivity?
A: Better road networks and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training.
Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system? [Please state reasoning]
A: Unsure, but I feel there is not enough room for too much expansion ie. add another run way. The council could consider a park and ride park, to divert some traffic away from the residential area, which could create jobs for security services, bus drivers, attendants, cleaners, etc. Expansion of the airport may affect the Grade 1 listed St Laurence and All Saints Church and this needs careful consideration.
Q29. Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
A: We all should be doing everything in our power to protect wildlife sites. All wildlife is important and we have been neglecting them, and slowly chipping away at them for years. Wildlife now enter suburban areas as their own habitats have diminished and they can no longer fend for themselves adequately from nature. We have a decline in Badgers and hedgehogs as well as rabbits, frogs, newts, voles and shrews. Ask yourselves: when did you last see a live hedgehog or badger? Most (especially badgers) are usually dead (along with foxes and deer) by the side of our roads. We have removed places that have housed bats and now we do not see them flying around the district in the numbers they did. Designating initial sites is a step in the right direction but we have to do more. It is proven that our mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was. Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. You mention that Doggett Pond no longer meets the standard but are there no steps to improve its status instead of dismissing it? It is obviously an important site for the wildlife in that area. To lose it would be to our detriment. We should be looking at creating new sites with every large housing development, and adding them to our protected list in order to improve our district and our own wellbeing. We should no allow private households to take over grass areas and verges (or concreting the verges over for parking and cost savings). These areas, although small are still areas for wildlife (bees and butterflies - also in decline, as well as bugs which feed our birds). We should create new wildlife meadows to encourage the pollinators in order to future proof our own existence. We should be exploring smaller sites that we could enhance, manage and protect in order to give future generations something to look back on and feel proud that we have given them a legacy. Something that we can be proud of.
Q30. Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
A: Yes. We need to protect them for future generations and teach our children their history and importance so that they can continue to keep them safe.
Q31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?
A: On site. You can then assess in real time and sort out any issues you would not have known about off site.
Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan? [Please state reasoning]
A: You need to enhance and maintain what we already have by ensuring the necessary links are in place to link as many as possible, and ensuring that public rights of way are not blocked by land owners and are kept free from debris. You also need to assess some paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look into offering this in the larger spaces (ie in the car park – a small toilet block and hand washing facilities). Obtaining funding from large (and medium) developments for enhancement of existing areas as well as providing new spaces and facilities is a step in the right direction.
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
A: They are a step in the right direction but you need to assess periodically in order to be able to add further links to any new parkland that may be created in the future. The map is unclear as it does not show exact routes. There is a large open space to the South West of Rayleigh (on the border), South of Bardfield Way and The Grange/Wheatley Wood, which could be enhanced.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure? [Please state reasoning]
A: Enhancing the areas we have and ensuring developers include green space/recreational facility areas within their developments. A new, separate development would be able to deliver this within their plan layout. Ensuring there are suitable links, access and footpaths. Making sure some of these footpaths are accessible for the disabled.

Q35. With reference to the options above, or your own options, how can we address the need for sufficient and accessible community infrastructure through the plan? [Please state reasoning]
A: Ensuring that funding for existing facilities comes from new developments and making sure that these facilities are built during the time of the development (not like the London Road/Rawreth Lane development where a site was “provided” for healthcare but has not been built). Assess the shortfall of facilities and networks before plans are approved so that adequate planning and funding can be secured before any building takes place.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure? [Please state reasoning]
A: A new town would have this infrastructure built into its plans. Funding for improvements must otherwise come from developers if an area is already overpopulated.
Q37. Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these? [Please state reasoning]
A: Rayleigh is overcrowded. It has a road network no longer fit for purpose. The schools are almost full. It is difficult to obtain a GP or dental appointment. There is little to no disabled play areas/equipment. There is always issues with waste collections, drain & road cleaning and verge trimming. The council does not have the staff to deal with all these issues. The council needs to either build another waste recycling site (as the one in Castle road is no longer capable of expanding and meeting the needs of its ever growing population) or develop a better waste collection program which allows extra waste to be collected next to bins. It also needs to find a site to address/install commercial waste facilities to stop fly tipping.
Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan? [Please state reasoning]
A: Improve what we already have. The tennis courts on Fairview Park need improvement. Safeguard our open spaces to ensure we have wildlife and recreation. Develop different types of sporting facilities – not just football pitches. There is a need for a larger skateboard park and BMX track. We need to offer free recreation for our teenagers.
Q39. Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering? [Please state reasoning]
A: The development of 3G pitches seems to be the trendy thing to do but they are plastic grass at the end of the day and we should be looking at ways to reduce our plastic use. If there is an area that already exists that is in a poor start of repair then it may be an option – especially if the “grass” is made from recyclables, but we should be thinking outside the box and not covering our parks with it.
Q40. Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering? [Please state reasoning]
A: They look suitable. They will probably need funding.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
A: A new development would be able to deliver this in their plans or fund improvements for existing facilities.
Q42. Are there particular open spaces that we should be protecting or improving? [Please note, you will have an opportunity to make specific comments on open spaces and local green spaces in the settlement profiles set out later in this report]
A: The sites will be specific in each parish. You need to protect all of these recreational spaces and improve if necessary as once lost to development, they can ever come back.
Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan? [Please state reasoning]
A: You need to reassess your policies on planning regarding alterations made to the buildings on your list, especially in our conservation areas. There have been a few occasions where buildings of “interest” (or other) have been altered, and that places in conservation areas have been allowed canopies, shutters and internal illumination of signage without challenge. Any building work (if any) needs to be sympathetic to the area and you should be able to request amendments to frontage, even if they have had it up for some time. Shop fronts are huge areas of uninteresting glass with garish colours. Signage and advertising (‘A’ board’s litter our pavements without challenge and large barriers are erected onto the pavements – totally out of character with a conservation area in a heritage town. Stick to your policies.
Q44. Are there areas of the District we should be considering for conservation area status beyond those listed in this section? [Please state reasoning]
A: Unsure although we need to stop taking areas of our precious woodland to make way for housing.
Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets? [Please state reasoning]
A: Don’t know. Mill Hall? Over 50 years old. Cultural centre in a conservation area. Needs massive investment and management. A new survey needs to be taken to ascertain whether there are any other areas that should be considered. There are many buildings along the High Road into Rayleigh (but not in the conservation area) which should be considered.
Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state reasoning]
A: You can only have a vibrant town centre if there are shops to go to. If these units are subsequently changed to residential then our town centres will be fractured and uninviting. The new Use Class E will mean it will be even more important for the council to protect our retail outlets. You need to work actively with premises owners in order to assist in the re-letting of any empty shops. Maybe offer a reduced rent to new businesses as a start-up scheme (you could contain this as a “local” business only – allowing the entrepreneurs in the Rochford District a chance to showcase their business). You also need to be able to negotiate with the owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows (ie. photos of the old towns or useful information) to make them more attractive.
You will need good access links with an excellent road and cycle network and reliable public transport that links effectively from all the villages to all the towns.
Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]
A: Yes.
Q48. With reference to Figures 38-40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
A: Yes
Q49. Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]
A: Yes. We do not want rows of hairdresser or rows of takeaways etc. as this would eventually kill off our high streets. We need to have a balance of outlets. You would lose the vibrancy you are hoping to achieve if you allowed this. You should also consider restricting use to giant chains as these tend to be the first to go in a crisis and make high streets lose their individuality by them all looking the same.
Q50. With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]
A: Unfortunately, some of our smaller retail areas have been sold off and housing development has been allowed (eg. Rayleigh - rear of Marks & Spencer and Dairy Crest plus Lancaster Road [builders’ yard]). In a new development there would be scope to add a small/medium/large precinct of retail etc. depending on the development size.
Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan? [Please state reasoning]
A: The council needs to address the “No development before infrastructure” mantra! Too many houses are being built without adequate road networks in place (including walking and cycling routes). A new road could be built from the A1245 to Hullbridge, limiting the traffic on Rawreth Lane. More work need to be done (and quickly) on the A127 and The Carpenters Arms roundabout. The feeder lanes proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions need to be done ASAP as this is a bottleneck. Hockley needs another access although I am unsure how that can be achieved. New developments should put in cycle paths and walkways and they could be made to link up with existing paths (which need updating and attention).
Q52. Are there areas where improvements to transport connections are needed? What could be done to help improve connectivity in these areas?
A: More work need to be done (and quickly) on the A127 and The Carpenters Arms roundabout. The feeder lanes proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions need to be done ASAP as this is a bottleneck. Hockley needs another access.

Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [Walking, cycling, rail, bus, road etc.]
A: A new road from A1245 to Hullbridge is needed as Watery Lane is too narrow and winding, and is closed on a regular basis due to flooding. More (smaller) buses to link our towns and villages. Trams, although they seem a good idea, would cause congestion on our narrow roads and be unsustainable. Designated cycling paths (not on the roads or pavements) adjacent to our road networks would help improve traffic flow and these would need to be linked to be efficient.
Q54. Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided? [Please note you may wish to comment on the use of specific areas of land in the next section]
A: Yes, but if they are to be affordable only, then they should be offered to local residents first and not anyone from afar who wants a cheap house or for those with a buy to let mortgage.
Q55. Are there any other ways that you feel the plan should be planning for the needs of rural communities? [Please stare reasoning]
A: Improve public transport.
Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing? [Please state reasoning]
A: Yes but you also need to include a reduced volume of traffic and air pollution. The High Street is usually grid locked and this causes dangerous pollution for our pedestrians/shoppers/residents. An active Police presence.
Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Access and increased congestion is going to be an issue with a lot of the sites in Rayleigh. If you keep adding small developments to the boundaries of the town we will create an overcrowded impacting on the developments already there and an urban sprawl effect. CFS 121 has potential for a new woodland area which could soak up some of the carbon emissions from the A127 traffic.
Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: We should be restricting any further large developments in Rayleigh and need to assess the impact of the current developments first.
Q56d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: CSF027 – The access road (Bull Lane) is a known rat run and is extremely busy. Any further traffic, which will also compete with large agricultural vehicles, could be a danger to the residents already there. Bull Lane near this point has also been flooded several times recently. CFS023 – Access to this road is via Wellington Road. It can be extremely difficult, especially at peak times (non-pandemic) to access to and from Hockley Road. Adding a large development here will have an adverse impact on existing residents and car users alike. Also, if these 2 developments are linked to Albert Road, the installation of a through road to Bull Lane will cause issues in parking, access and wellbeing as the road would become another rat run!
Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
The green space north of CFS121 could be linked by a new bridge over the railway and create a new habitat for wildlife, with meadows and woodlands, walks and a lake/pond. A car park with facilities could be created and a small retail space could be offered for snacks etc.
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]
A: I feel CFS261 would cause great harm to the area, with a potential of over 4,000 houses on the site. The road network is not sufficient to cope with half that amount of dwellings and new schools would need to be built.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q57c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q57d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q57e. Do you agree that the local green spaces shown on Figure 45 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold some significance, especially to those who use them for recreation, and have community value. These should be protected.

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

Q61c. Are there areas in Canewdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q61d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Don’t know.
Q61e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q62a. Do you agree with our vision for Great Stambridge? Is there anything you feel is missing? [Please state reasoning]
A: Yes.
Q62b. With reference to Figure 50 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Great Stambridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Any development needs to be sensitive and sympathetic to this small village.
Q62c. Are there areas in Great Stambridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q62d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Don’t know.
Q62e. Do you agree that the local green spaces shown on Figure 50 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q63a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state reasoning]
A: Don’t know.
Q63b. With reference to Figure 51 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rawreth?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know.
Q63c. Are there areas in Rawreth that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Yes. Those that border the main roads as this makes easy access.
Q63d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Those that change the dynamics of the village and those areas that border Wickford. There needs to be a significate amount of green belt land left to separate the 2 areas to prevent urban sprawl.
Q63e. Do you agree that the local green spaces shown on Figure 51 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q64a. Do you agree with our vision for Paglesham? Is there anything you feel is missing? [Please state reasoning]
A: I think the 30 houses is the maximum you should build to keep this hamlet special. Maybe less. The community should be consulted for their requirements.
Q64b. With reference to Figure 52 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Paglesham?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: The 30 proposed houses should reflect the history of the area and should be modest in size and scale. These does not seem to be scope for any other building project with exception to open space. Any development should be sympathetic to the design and scale of the areas history.
Q64c. Are there areas in Paglesham that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Those proposed seem appropriate subject to local knowledge and support.
Q64d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: No building anywhere where it is liable to flood. No building near the waterfront in order to protect its charm and history.
Q64e. Do you agree that the local green spaces shown on Figure 52 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q65a. Do you agree with our vision for Sutton and Stonebridge? Is there anything you feel is missing? [Please state reasoning]
A: Yes. These areas should remain low key but have better access to services.
Q65b. With reference to Figure 53 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Sutton and Stonebridge?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare, allotments, other]
iv. Other
A: Don’t know, but mass development should not go ahead. The potential of building thousands of houses, retail etc would be devastating. If any form of development was to go ahead then this should be in the way of a nature reserve/woodland etc.
Q65c. Are there areas in Sutton and Stonebridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
A: Don’t know.
Q65d. Are there areas that require protecting from development? Why these areas? [Please state reasoning]
A: Most of the area unless it is the creation of new woodland, ponds, meadows, etc.
Q65e. Do you agree that the local green spaces shown on Figure 53 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
A: All green spaces hold significance, especially to those who use them for recreation, and have community value. They should be protected. Green belt borders should be protected from development in order to prevent urban sprawl.
Q66. Do you agree that our rural communities do not require individual vision statements? Are there communities that you feel should have their own vision? [Please state reasoning]
A: At this time – yes, but I feel they should have some consideration in the future in order to protect them.
Q67. Do you agree with our vision for our rural communities? Is there anything you feel is missing? [Please state reasoning]
A: Yes. Nothing missing I can think of.
Q68. Are there other courses of action the Council could take to improve the completeness of our rural communities?
A: Survey and listen to the residents to see where they would like to go next. See if they require anything specific (travel links, facilities, affordable housing, etc.)

CCC Response to Rochford Spatial Options Document 2021

Part 1 - Background and Context to the consultation

Chelmsford City Council (CCC) welcomes the opportunity to comment on Rochford District Council’s Spatial Options document 2021 to help influence the emerging plan and monitor the key cross-boundary and strategic issues that affect CCC's administrative area.
The Spatial Options document is a consultation paper that forms the latest stage in the production of Rochford District Council’s new Local Plan. It follows on from the Issues and Options consultation carried out in late 2017/18.

The new Local Plan will cover the period up to 2040.

The Spatial Options document sets out the key spatial issues and puts forward four strategy options:
1. Urban Intensification
2. Urban Extensions
3. Concentrated Growth
4. Balanced Combination

The document also reviews specific issues that have emerged since the last consultations, from new evidence or changes introduced by national policy.

The Spatial Options document does not recommend a particular course of action but seeks feedback on a range of different options. Further work and consultation will be required on the new Local Plan as it progresses.

Part 2 – Consultation Response

The document sets out a number of strategic priorities and objectives that Rochford District Council (RDC) consider will help deliver its new Local Plan.

Strategic Priority 1 addresses meeting the need for homes and jobs in the area, with strategic objective 1 addressing housing delivery which is to be achieved by working with neighbours in the South Essex and prioritising the use of previously developed land first.
The Plan outlines that 7,200-10,800 new homes of different sizes and tenures, will be needed to meet growth needs.

It is noted that the Local Housing Need methodology calculates a need of 360 homes per annum for Rochford District. Over the 20 years plan period this equates to 7,200 homes. The Housing and Economic Land Availability Assessment (HELAA) 2020 identifies a supply of over 4,300 homes that are already planned for, including existing allocations, sites with planning permission and an allowance for windfall development of around 45 homes a year.

It is also noted that using the standard methodology plus a 50% buffer, would require 10,800 new homes by 2040. It is noted that different growth scenarios are being reviewed to inform the four strategy options.

The City Council is clear that Rochford District Council should meet its own local housing need in full. The City Council has received a formal letter from Rochford with regard to capacity for accommodating additional development needs and will be responding accordingly.

The Spatial Options document also states that the Economic Development Needs Assessment (EDNA) identified a potential need for up to 7 hectares of employment land by 2036, which rises to 16 hectares when making an allowance for changes and windfall.
Rochford District Council should seek to meet employment and retail needs of the district in full over the next 20 years.

It is noted that a Gypsy and Traveller and Travelling Showpeople Accommodation Assessment has been undertaken which identifies a need in Rochford for 18 additional pitches for travellers known to meet the planning definition of a traveller, 1 additional pitch for
unknown travellers and up to 11 additional pitches for those that fall outside the planning definition and there was no requirement for additional travelling showpeople plots. Previously this was thought to be covered by a current allocated site, however this is no longer being
delivered as expected. CCC expects that Rochford must meet this need in full over the plan period.

On transit sites, CCC acknowledges the Essex-wide GTAA’s recommendations to engage, through the Duty to Cooperate, with other Essex authorities in the future to review the need for transit sites and notes that the Gypsy and Traveller Transit Site Assessment is now under
preparation across Essex.

In regard to the four strategy options, CCC notes that Option 1 is the minimum expectation of national policy and is likely to be required within every strategy option, making the best possible use of our existing planned developments, previously developed (brownfield) land
and other under-utilised land.

Options 2 and 3 review different scales of growth with a number of smaller urban extensions (Option 2) and concentrating growth in particular one or two larger growth locations (Option 3). Option 4 is presented as being a mix of all 3 options based on the most appropriate balance to meet development needs.

From a City Council perspective, CCC would only support an option which accommodates all of Rochford’s growth needs in full for homes, employment and infrastructure ideally with an appropriate buffer for delivery flexibility whilst protecting and enhancing the natural and built environment. As stated above, the options should be explored in detail. Areas of Chelmsford with the relevant relationship to Rochford also fall within the Green Belt, therefore Rochford should be coordinating with their own housing marking area to fully
assess the options.

CCC welcomes the recognition of adjoining districts own growth needs, and that there is some relationship with Chelmsford for employment and other facilities (such as hospitals and retail). CCC notes that the South Woodham Ferrers has been suggested to be similar in size and role to other Tier 2 settlements within Rochford.

Significant growth is proposed is South Woodham Ferrers in Chelmsford City Council’s own Local Plan in proximity to Rochford District. Growth in Rochford District should not have adverse impacts on planned growth in South Woodham Ferrers by placing additional pressure on existing and proposed facilities, including education.

CCC concurs with the spatial themes presented in the spatial options document.

CCC will continue to work with Rochford District Council on cross-boundary issues and engage with the Local Plan preparation.

Statement of Community Involvement Consultation Response

Thank you for also consulting Chelmsford City Council (CCC) on the Statement of Community Involvement (SCI) 2021 Review.

CCC considers that the SCI review is generally clear and comprehensive. The SCI explains how the Council will involve the community and stakeholders in the planning process and the consultation methods proposed are supported by CCC.

CCC notes the recognition that as part of the statutory Duty to Cooperate, neighbouring councils and other relevant organisations must work together on strategic cross boundary issues.

Chelmsford City Council will continue to actively engage with Rochford District Council on each other’s respective Local Plans.

Integrated Impact Assessment of the Spatial Options Document

Thank you for also consulting Chelmsford City Council (CCC) on the Integrated Impact Assessment (IIA).

It is noted that the IIA fulfils the requirements and duties for the Sustainability Appraisal (SA), Strategic Environment Assessment (SEA), Equalities Impact Assessment (EqIA) and Health Impact Assessment (HIA).

CCC is supportive of the proposed topic headings for the assessment and has no further comments to make at this stage.

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

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

Hullbridge Parish Council feels strongly that a local highways study needs to take place. The document only refers to a study of the main roads in the south Essex infrastructure position statement. This states in 4.2.4 that much of the main road network which leads to our district is operating at, or near, capacity in peak periods.

We cannot understand why Rochford District Council would base its planning upon the 2025 flood risk area when developments could reasonably be expected to be in place for more than 100+ years. All evidence from the IPCC and other scientific institutions demonstrate that global sea level rise is a real and presently accelerating threat. In addition, the British Geological survey shows that the Eurasian tectonic plate is tilting along an axis between the Wash and the Bristol Channel, this means
that Essex is sinking at a rate of 0.4 to 0.7mm per year (ref. research carried out at Durham University and published in the Journal ‘GSA Today’). These projections are not the worst-case scenario, and the sea level rise could be much worse if climate change continues raising
temperatures beyond 1.5 degrees centigrade.

The map generated by Coastal Climate Central for 2050 shows that all of the promoted sites to the west of Hullbridge will be in the flood risk area, and that those to the North East of Hullbridge are also in the flood risk area. Rochford District Council needs to ensure that no site at risk of flooding by 2050 is developed.

The Coastal Climate Central 2050 map shows large part of Rochford including Hullbridge below flood
levels:
https://coastal.climatecentral.org/map/15/0.6252/51.6246/?theme=sea_level_rise&map_ type=year&basemap=roadmap&contiguous=true&elevation_model=best_available&fo recast_year=2050&pathway=rcp45&percentile=p50&refresh=true&return_level=return_
level_1&slr_model=kopp_2014

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

Hullbridge Parish Council believes that the vison should take into consideration the differences in towns and villages; for example, Rayleigh or Rochford may have a more business focus, whereas Hullbridge may be more of a rural community with a greater need to cater for its older population who do not need employment but do need more health services. In principle, the results of this
consultation need to feed into it to make specific plans for each settlement.

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

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

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

Strategic Option 2 fails to address the problem of the aging population within the district. This is in large part due to the failure to provide adequate low rent social housing to enable young people to remain in the district and to develop stable family units. The failure of Housing Associations to meet this need is well documented nationally, and locally the largest Housing Association (Sanctuary) has a poor record of maintaining properties and honouring contractual promises made when the council’s housing stock transferred. The strategy should provide council housing (preferably directly managed) with genuinely affordable rents and secure tenancies in small local exception sites. There also needs to be provision within these sites for social housing accommodation for elderly residents.

With regard to objective 12 we are concerned that Rayleigh tip has been put forward for development.
If so there still needs to be a site for waste disposal close to Rayleigh. The restrictions on vans needs to be lifted to prevent fly tipping.

We believe that sufficient primary school places should be provided within local communities, and steps should be taken to minimise the use of cars to transport children to schools; we are concerned that this is currently not the case.

Q5. Do you agree with the settlement hierarchy presented?

Yes, the hierarchy seems logical. We feel the strategy should take into account that many more people are working from home, reducing the need to commute to employment centres.

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

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

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

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

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

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

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

Using option 3a as a starting point, other areas could be developed in future using option 1 when the
infrastructure is planned and/or in place.

Restrict overdevelopment in rural and village communities to protect the character of village life.

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

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

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

We agree that it is imperative that both flood risk and coastal change should be central to any development plans going forward; for us in Hullbridge, many of the proposed sites to the west of the existing settlement are projected to be deep within flooding territory by 2050, as are numerous ones in the east as well. With 2050 now less than three decades away, and no sign of any imminent alteration in the path of climate change, development in any of the areas identified to be in potential flood plains today and in the near future must not be considered.

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

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

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

Providing that the development is affordable and deliverable, and the cost is not lumped onto the buyer for many years to come then this is the right decision as the future rests in renewable energy. Suggestions from councillors regarding other opportunities to supply renewable energy ranged from a solar farm in a place that will not impact its surroundings to solar panels and/or wind turbines on Foulness Island.

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

Again, this is something that is a fantastic plan providing the brunt of the cost is not rested on the shoulders of the buyer and that these homes are affordable.

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

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

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

Yes, these should be settlement specific, to allow for the maintenance of the integrity and specific characteristics of each area, sufficiently detailed to avoid confusion, and widely distributed.

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

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

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

Yes, providing that each individual settlement is at the heart of it and considered as their own entities with their own individual characteristics. It is imperative that certain areas are protected completely, and that any future developers are aware of the identified characteristics of each area.

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

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

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

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

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

Meet the need for different types, sizes and tenures of housing (including Affordable, Social, Council and
Specialist Housing) by requiring a standard non-negotiable mix of housing to be provided on all housing
developments.

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

There is too much focus currently across the district on the provision of 4/5 bedroom properties. This focus needs to shift towards 2/3 bedroom properties which would benefit more local residents/families in search of their first home. "Affordable" homes should not only be flats/apartments but other property types also.

1/2 bed bungalows (or similar) should be a priority, as with an ageing population, there will be increasing
demand for such properties when elderly residents are looking to downsize. RDC should actively discourage bungalows being converted into larger properties. Additional provision for residential care is also a priority.
These can all be accommodated within Strategy Option 3a.

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

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

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

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

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

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

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

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites?

Locate sites close to main roads to enable easy access for large vehicles, so that residential roads are not congested and nearby residents are not disturbed. Allow a little room for expansion and limit the likelihood encroachment onto neighbouring land.
Locate away from spaces of national, regional, local or community interest or recreation, so as not to spoil the visual amenity of the landscape.
The sites should not be closed and available to the whole Traveller community.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Provide appropriate schools and colleges to serve the increase in population due to high development, but locate with public transport links and accessibility by walking or cycling in mind. Also work with neighbouring authorities to identify land for higher or further education facilities where this would address current and future skills shortages as stated in employment option 11.
Work with bus companies and Essex County Council to make our existing employment sites as accessible as possible. Improve footpaths and cycle tracks using government funding applied for by Rochford District Council. Move away from planning employment sites in places that are designed to be accessed by car use. Some employment is going to have to be close to settlements. This of course would have to be take into account paragraph 83 of the NPPF which requires policies and decisions to accommodate local business needs in a way which is sensitive to the surroundings and prioritises the reuse of existing sites and buildings.

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

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

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

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

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

The lower Crouch Valley, the River Crouch and its banks are important habitats for fauna including birds that are on the endangered species red list. This includes curlews, whimbrels, and other wading birds. The pasture land flanking the Crouch towards Battlesbridge is an important habitat for skylarks and other species; these areas should be protected.

Restrict development in all other green belt areas, in order to protect nature. Alongside this, provide protection for nature reserves, parkland and areas fronting rivers.

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

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

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

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

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

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

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

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

Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?

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

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

Build property where there is existing infrastructure or where infrastructure can be expanded without
encroaching on green belt etc.

A survey needs to be carried out on local roads to determine what is needed to be upgraded to achieve
any sustainable way for traffic, both domestic and that which uses these as through roads.

With reference to Hullbridge much of it is unadopted roads and cannot support any development, let
alone be able to accommodate the use of these roads as through roads for both building access and ultimate through road access to any development. Provide schools for development areas and provide transport links to these schools. Local schools, both primary and secondary, are already struggling with the increase in pupil numbers coupled with limited capacity.

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

Funds were given via section 106 to expand Hullbridge Healthcare Centre and provide more school places - neither of these has happened. This section 106 money was instead given to RDC in respect of the existing Malyons Farm development. More development would make the situation untenable, particularly if further section 106 monies were withheld by RDC and not allocated to benefitting the local community where new developments are built.

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

Even with section 106 grants, if made available, healthcare facilities in Hullbridge are severely restricted, especially since the pandemic due to doctor shortage. Further development in Hullbridge would worsen healthcare provision and, even with section 106 grants if released by RDC, will not improve the situation.

Whilst this is outside the control of RDC, developments would cause serious issues particularly as Hullbridge traditionally has an ageing population - one which is obviously more reliant on healthcare, alongside the inevitability of new patients from current and any new developments.

There are currently inadequate or no existent bus and footpath links to areas east of Hullbridge, such as the Dome Area. Any development to the east of Hullbridge would have transport difficulty and also the impact on Lower Road would be unacceptable; this would be the case even bus links were improved.

The same approach needs to be taken with schools and highways and new residents could be short changed without easy access to schools, healthcare and employment.

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

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

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

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

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

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

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

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

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

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

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

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

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

Protect village and rural areas from over or inappropriate development through careful planning considerations.
Compose a list of sites with local consultation. Then look maintain them with local residents and organisations

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

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

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

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

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

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

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

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

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

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

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

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

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

Some existing ok but links to, e.g., Clements Hall from Hullbridge non-existent. Businesses cannot be forced into staying unless benefits outlined in Q47 are adhered to which may encourage some business opportunities and current business to remain.

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

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

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

Certainly, prepare an Infrastructure Delivery Plan that would deliver meaningful improvement to transport networks, including but not exclusively, cycle routes, walking pathways, public transport and roads. However, all these modes are currently completely stretched; modernisation and improvements to all need to happen before future housing developments are built. It should be noted that following the last developments in the Core Strategy, as far as Hullbridge is concerned (and almost certainly elsewhere also), the promised improvements have either not materialised, been completed or proven
to be inadequate.

The plan needs to deliver improvements to public transport by working with bus companies to reestablish bus routes to isolated communities that have been either been terminated or severely curtailed. For example, ‘The Dome’ has a bus service twice a week. Residents regularly complain that they are isolated from everywhere else. It is also claimed that Hullbridge has its own bus service that runs 4 - 7 times a day. This is not the experience of Hullbridge residents and it only needs the slightest issue along Hullbridge Road for the service to either be even further curtailed or suspended entirely.
RDC need to continue to work with Government, Highways England, Essex CC etc to deliver meaningful
road improvements to both the main road arteries and to the local road network. However, any large-scale bypass scheme such as the "Southend Outer Bypass" scheme needs to be opposed. Not only would it cut directly through the Green Belt but it would increase development along its course, which in turn would have enormous negative impact on the Green Belt itself, natural habitats and the environment generally.

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

Whilst some improvements are shortly to commence at the Fairglen Interchange and A130, further improvements are needed to the Junction of Rawreth Lane and the A1245. Perhaps also the A127 could be widened along its length from four lanes to six lanes.

Additionally, the bus service between Hullbridge and Rayleigh can be cut with the slightest issue along
Hullbridge Road and this needs to be addressed urgently. When this happens it consequently results
in more vehicles using Hullbridge road, which in turn exacerbates traffic congestion and leads to other
problems such as pollution.

A bus service between Rochford and Rayleigh via Hullbridge and Hockley and Rayleigh via Hullbridge
would serve to reduce traffic congestion along Lower Road, especially at "rush" hours. This would benefit residents of the Dome as well as properties along the length of Lower Road. It would also serve to provide access for Hullbridge students to access the Greensward Academy that does not exist currently.

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

Improvements to existing road networks. Large scale bypass schemes, such as the “Southend Outer”
bypass would be unacceptable because of the hugely detrimental impact on the Green Belt and its
physical and natural environment.

Small low top busses to link smaller communities with larger ones. Trams not a viable option for the more rural areas as roads are too narrow and winding; additionally, would increase congestion on existing roads.

Improvements to the cycle path network, extending and linking the network as and where appropriate and safe.

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

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

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

Support changes that would require developers of 10 units or less to pay something akin to s.106/CIL
monies, that would go towards infrastructure improvements, particularly those affecting rural communities.

Q60a. Do you agree with our vision for Hullbridge?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Q2. Do you agree with our draft vision for
Rochford District? Is there anything missing
from the vision that you feel needs to be
included? [Please state reasoning]

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

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

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

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

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

STRATEGY OPTIONS

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

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

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

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

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

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

SPATIAL THEMES

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Yes, provided that individual settlements are consulted,
and they are adhered to.

Q16.
a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?

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

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

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

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

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

HOUSING FOR ALL


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

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

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

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

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

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

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

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

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

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

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

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

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

EMPLOYMENT & JOBS

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

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

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

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

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

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

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

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

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

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

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

Careful consideration should be given to the growth of
the airport; it would bring additional jobs and business
opportunities, but it would also put more strain on the
existing transport network and would bring additional noise and air pollution. It would also require more land.
Improvements to the public transport system and road
network would be required to enable growth and jobs
linked to the airport industry. Airport linked transport
adjacent to both the existing airport industrial park and
Saxon Business Park should be included in the strategy.
Given the ongoing uncertainty surrounding the impact
of Climate Change on the aviation industry (e.g., urgent
carbon reduction), we should continue to make
decisions based on the existing JAAP for the time being,
but to consider developing a new Area Action Plan, or
masterplan, after the new Local Plan is adopted or
when the need arises.

BIODIVERSITY

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

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

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

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

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

On-site.

GREEN AND BLUE INFRASTRUCTURE

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

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

Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]

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

Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure? [Please state reasoning]

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

COMMUNITY INFRASTRUCTURE

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

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

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

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

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

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

OPEN SPACES & RECREATION

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

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

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

All-weather facilities should be considered where
appropriate.

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

The potential sites seem acceptable.

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

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

Q42. Are there particular open spaces that we should be protecting or improving? [Please note, you will have an opportunity to make specific comments on open spaces and local green spaces in the settlement profiles set
out later in this report]

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

HERITAGE

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

Villages and rural areas need to be protected from over
and/or inappropriate development through careful
planning considerations. A list of sites should be
composed with local consultation and those sites
maintained with local residents and organisations.

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

Areas of precious woodland should not be taken for
housing.

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

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

TOWN CENTRES AND RETAIL


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

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

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

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

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

N/A

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

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

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

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

TRANSPORT & CONNECTIVITY

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

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

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

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

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

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

GREEN BELT AND RURAL ISSUES

Q54. Do you feel that the plan should identify rural
exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided? [Please note you may wish to comment on the use of specific areas of land in the next section]

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

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

There should be support for the requirement of
developers of 10 units or less to pay something akin to
s.106/CIL monies. That would go towards infrastructure
improvements, particularly those affecting rural
communities.

PLANNING FOR COMPLETE COMMUNITIES

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

N/A

b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses?

N/A

How could that improve the completeness of Rayleigh?

N/A

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

N/A

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

N/A

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

N/A

iv. Other

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

N/A

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

N/A

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

N/A

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

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

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

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

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

N/A

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

N/A

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

N/A

iv. Other

N/A

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

N/A

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

N/A

e. Do you agree that the local green spaces shown on Figure 45 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]

N/A

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

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

b. With reference to Figure 46 and your preferred strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Hockley and Hawkwell?

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

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

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

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

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

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

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

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

e. Do you agree that the local green spaces shown on Figure 46 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]

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

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

N/A

b. With reference to Figure 47 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of the
Wakerings and Barling?

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

N/A

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

N/A

d. Are there areas that require protecting from
development? Why these areas? [Please state reasoning] Q59e. Do you agree that the local green spaces shown on Figure 47 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]

N/A

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

N/A

b. With reference to Figure 48 and your
preferred Strategy Option, do you think any
of the promoted sites should be made
available for any of the following uses? How
could that improve the completeness of
Hullbridge?

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

N/A

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

N/A

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

N/A

e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

e. Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]

N/A

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

N/A

b. With reference to Figure 50 and your
preferred Strategy Option, do you think any
of the promoted sites should be made
available for any of the following uses? How
could that improve the completeness of
Great Stambridge?
N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

b. With reference to Figure 51 and your
preferred Strategy Option, do you think any
of the promoted sites should be made
available for any of the following uses? How
could that improve the completeness of
Rawreth?

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

N/A

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

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

N/A

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

N/A

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

N/A

b. With reference to Figure 52 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Paglesham?

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

N/A

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

N/A

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

N/A

e. Do you agree that the local green spaces
shown on Figure 52 hold local significance?
Are there any other open spaces that hold
particular local significance? [Please state
reasoning]

N/A

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

N/A

b. With reference to Figure 53 and your
preferred Strategy Option, do you think any
of the promoted sites should be made
available for any of the following uses? How
could that improve the completeness of
Sutton and Stonebridge?

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

Dear Sir,
Re: Stakeholder: Reference CP15678E. Community Representative No. 29007.

New Local Plan 2021 Consultation. Issues and Options Documents & Statement of Community Involvement and the Spatial Options documents.

We request Rochford District Council to invite the Government Planning Inspector to find that the New Local Plan 2021 must be withdrawn for reasons mentioned below.
In our consideration the Map A, on the basis of the relevant Legislation Guidance in the National Planning Policy Framework is not:
Positively Prepared
Justified
Effective
Consistent with National Policy

There are sufficient clauses in the NPPF, LDF and Localism Act which stipulate that all issues must be considered including Infrastructure and in areas environmentally threatened as shown in the Environment Agency and the Insurance Company data (Flood maps). It is imperative proper assessments be made in accordance with the NPPF regulations such as Flood, Road Network, Proximity to rivers and all issues set out below. Our experience from the current Malyons Lane large development that our SCI will be ignored again unless we have support from our MP Mark Francois and all the Councillors who are continually proud to state they are Community minded.

The Hullbridge Residents Association have viewed the Local Development Framework Evidence Base and note that the contents are a repeat of the documents issued in 2015 as are the documents mentioned above
Along with the accompanying Integrated Impact Assessment.

Section 1. Introduction
1.1 States this is a review document of the original adoption in 2016, now presented in repetition but revised in 2015 and 2017 (for 2021).

We understand the need for additional homes, but we are concerned that ‘Infrastructure is not given priority as stated by our MP Mark Francois and indeed Government directives, particularly the existing infrastructure but continually being ignored.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

HRA produced and delivered to RDC a 45-page document on the Core Strategy, Land Development Framework (LDF), National Planning Policy Framework (NPPF) and Localism Act for a development in progress and submitted some 525 issues in the planning documents presented by RDC without a proper response.
The clauses about Community Consultation being important is just a paper exercise to convince the Planning Inspector that the community support all the data produced.

HRA 9 years of experience has shown RDC and Councillors lack of the understanding or interpretation of Community Involvement, proper consultation and transparency, and fear another regretful experience with all sites being put forward for possible development. Having spoken to some Councillors they state that these site will not necessarily be approved to allow planning applications, but past experience does not provide any confidence that the community issues will be taken into account..
We make a plea to the Government Planning Inspector to investigate reasons why the community are ignored in proper consultation.

36 Sites.
We demonstrate our reasons for our rejection of many sites (stated in our document marked “Exhibit B- Issues and Options”) until the subject of the infrastructure (in all aspects- including existing) are reviewed This is an important subject and we extend our Plea to the Planning Inspector to set this review in motion and allow full participation by the Community Representative.

We consider the following clauses of the NPPF and Core Strategy must be applied:

NPFF 3– Core Planning Principles. Pages 1, 5-6, Clauses 1-2, 6-17.
NPPF 4 – Promoting Sustainable Transport.
NPPF 5 – Supporting high quality communications infrastructure. With roads/transport a priority.
NPPF 6 – Delivering a wide choice of high quality homes.
NPPF 7- Requiring Good Design.
NPPF 8 – Promoting Healthy communities.
NPPF 9 - Protecting the Green Belt land.
NPPF 10- Meeting the Challenge of Climate Change, Flooding & Coastal change.
NPPF 11- Conserving and enhancing the future environment.
NPPF Plan Making – Local Plans (p. 37).
NPPF Using a Proportionate evidence base- (p. 38).
NPPF Ensuring Viability and Deliverability- ( p. 41).
NPPF Decision taking – Pre-application engagement & front loading, (p. 45).
Technical Guidance to the NPPF- Flood risk on page 2. Sequential and Exceptional Tests p. 3 to 7.
NPPF - Sequential and Exceptional Tests –

Drainage
Sustainable drainage systems;
We have submitted documents in respect of the existing drainage system needing substantial improvements prior to any links being provided to the new developments and should be part of the necessary required Infrastructure works we have continually highlighted that the present system is not ‘fit for purpose’, but this was ignored. RDC are duty bound to inform ECC (RDC state that this is not their responsibility.


Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 2.
Clause 1.7 Statement of Community Involvement.
Having been disappointed with the first Statement of Community Involvement document in 2013 and 2016 we take the clause 1.7 on page 2 seriously and look forward to proper ‘consultation’ by RDC, and not use our submission purely as a ‘tick-box’ exercise to prove to the Planning Inspector that the regulations are observed and, our views have been taken into account but we have not seen these issues progressed to amendments in the Local Plan. HRA represent the Hullbridge community and have the right for engagement as stated in the NPPF and the Localism Act.

Clauses 1.8 & 1.9.
A plan indicating 36 additional sites on Map A in Hullbridge along with a further 6 sites not identified on Map A. Please refer to our Exhibit A on pages 14 and 15.

Clause 1.10 is of special interest as it mentions “on-going consultation” at every stage. We did not have the opportunity to discuss ‘The Draft Scoping Report’ which was published on the RDC websites, and the residents, businesses and other ‘stakeholders’ on the RDC mailing list were not consulted (HRA is a Stakeholder and Representative)- continually ignored by RDC- indeed HRA have correspondence relating to this issue that “if we did not like it we should consider litigation’.

Clause 1.14 on page 4 is of special interest to us as we placed emphasis on the Localism Act (2011) with the Managing Director of RDC and were told that the Localism Act was irrelevant. Why is it now more relevant than before? We request this ‘Act’ to be included as it supports Human Rights.

Clause 1.16. Only one ‘drop-in session’ was set up at Hullbridge Community Centre on 24/8/21. The attendance was low, HRA committee had 9 committee members present who asked questions and had responses which do not reflect the issues put forward in this ‘Plea’. One answer took us by surprise, that the Essex Design Guide which we have referred to throughout has been replaced by Rochford own Design Guide. When we consider the reduced staff levels with some unqualified planning staff it leads us to believe that this design guide will be subject to much criticism. We hope the Government Inspector will take this into account.

Planning law requires that “Call for Sites” which falls part of the development plan in accordance with the Regulations Governing Neighbourhood Planning Laws- NPPF 6 - Plans and Strategies – Part 6, Chapter 1, clauses 109 to 113, allows for Neighbourhood Planning – Part 6, chapter 3, clauses 116 to 121., and gives the community the right to Consultation – Part 6, chapter 4, clause 122. We challenge RDC to approve our application for this Neighbourhood Planning Group and a Statutory Consultee status which will also be an asset to the Hullbridge Parish Council. No explanation is given for reasons why we are not allowed to have consultation to give us good reasons why the regulations are not being properly debated and a conclusion found. This attitude denies community skills and professions adequately proven over 9 years of hard work, not acknowledged.

The four principles that follow imply that the core strategy should be relevant, sustainable and ‘Fit for Purpose’ and become part of the NPPF and LDF:
• Positively prepared.
Our observation on the previous Local Plan that insufficient forward planning had been carried in accordance with the Core Strategy which should have been adhered to and we will not be surprised if the same ‘policy’ will prevail. We look forward to the Planning Inspector requesting a coordinated approach and consultation with the community representatives, as the present system is not fit for purpose.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

• Justified.
In view of the aforesaid we do not believe there was any justification to allow more sites to be put forward without clear thinking on assessments being made in respect of the “existing Infrastructure”, and the use of Green Belt land being used instead of Brownfield land and the other issues stated in this document.
The Core Strategy, NPPF and LDF and Localism Act all express that Green Belt land should only be used as a last resort and only under exceptional circumstances, many issues which we have demonstrated have not been addressed sufficiently. Can RDC demonstrate why they are unable to adhere to the rules and regulations designed to safeguard the community.
According to the Localism Act 2011, we have demonstrated that transparency and consultation were lacking with the community. This has to be rectified and included within the proposed Local Plan.
• Effective
The conditions for the development of the 36 Hullbridge sites will not be satisfied for the reasons given above, therefore we consider a complete review of these possible proposed developments and the Core Strategy allows for the community to raise these issues and get into meaningful dialogue with RDC.
• Consistent with National Policy
National policy insists that all the policies stated should be transparent, proper consultation pursued in relations to all the development criteria. We do not believe that proper feasibility studies, risk analysis have been conducted in order to satisfy the requirements of the NPPF and LDF. Most subjects referred to in this presentation will imply reasons for withdrawal, in view of Government directives and regulations listed above.
The Localism Act 2011 Chapter 20. suggested meaningful dialogue with the HRA. Our residents asked what guarantees will be given to HRA that we will be listened to, not merely placing this document on RDC website to satisfy the Planning Inspector requirements. We require RDC Planning/Legal department to clarify.

Clauses 1.18 and 1.19 speaks of ‘community-led planning’ which is of interest to HRA but all our applications and requests for clarification are ignored. We have consistently placed great emphasis on ‘community cohesion’. Which makes for good public awareness. We can produce correspondence to the Parish Council for cohesion in respect to the whole community and help to remove the divisions which exist at present.
HRA have requested support from the Hullbridge Parish Council and indeed our rights should be upheld in accordance with the Localism Act..

Page 5.
Clauses 1.20 and 1.21
How can the RDC ensure that our proposals can be supported for the benefit of the community.
Clause 1.21 Infrastructure Delivery Plan (IDP) and the Community Infrastructure Levy (CIL) will be prepared to set out the circumstances that the CIL will be applied and the key infrastructure that the CIL will seek to fund. The Council will seek to fund this through a ‘Community levy’. This implies that the RDC are not protecting the community. ECC financial planning administration needs reviewing on the subject of ‘contingencies’ which should apply to all categories of infrastructure and other important categories to allow for future planning, maintenance and improvement.

The Essex County Council document “Greater Essex Growth” states that Greater Essex Growth and Infrastructure Framework 2016 is not listed or discussed. The Executive Summary says that Section 106 and ‘Community Infrastructure Levy’ (CIL) will fall way short of expectations and other Government Funding will be in ‘shortfall’ to the tune of £ Billions (report produced by AECOM) who also produced the RDC “Sustainability Analysis”, please explain why they did not cite this issue.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

HRA study of funding under section 106, particularly to fund the local Clinics (£164k recently) which was put to the NHS and RDC fell short of the required sum in view of the increased population. HRA requested consultation to allow co-ordinated conclusions. No surprise this was ignored by all concerned.
The normal LA practices are that a 10 year plan allowing the income to be divided into categories of funding allowing for contingencies for each element of Infrastructure to satisfy needs as they arise, so the question is what have you done with those budgets, as we keep being informed of shortage of funds, perhaps the auditors are allowed to explain how that money was spent. We ask, under ‘The Freedom of Information Act’ why the Hullbridge infrastructure was allowed to deteriorate over at least 50 years.
HRA object to the IDP and CIL because these should be RDC, ECC and Agency obligations to use the contingency funds and not produce more rules which allow the LA to cover up their own accountability inadequacies and should not be an ‘extra’ burden to the community.
If approved, this will set a precedent for other forms of funding from the communities. The community are concerned by this new statement lacking in the Core Strategy and the Land Development Framework. Can you blame the community for showing concern that LA mismanagement of funds fall to the communities having to make good the shortfall wherever they occur.

Page 9. Item 3.2. 36 Sites additional development Land.
The Land Mass measured and stated in this clause we find is out of date because several hectares have already been built on since 2012 which should have been taken into consideration, thus reducing the Land Mass area. Your review and consultation is necessary and we look forward to open discussions in
accordance with the Localism Act.

Section 3. Please refer to our Exhibit A- Development density comparison on pages 14/15.
The total measure of 36 sites = 124 hectares (approximately) which will provide a capacity of 3720 dwellings at minimum 30 dwellings per hectare. The minimum density of 30/60 dwellings per hectare can provide 3720 to 7440 dwellings.

Boundary Line.
Further examination of the same map A indicates that 30.5% of the land lies in the adjoining Rawreth Parish. Please refer to our Exhibits A and B on pages 14-15 and 16 – 20 consecutively.
The result provides the following information:
In our examination of the New Local Plan Document, we are unable to find any explanation for dealing with this ‘division’. Using our previous submission in relation to the Boundary Line indicated on the Ordnance Survey shown and confirmed by the Local Boundary Commission, our correspondence with Rochford District Council requesting clarification on the Parish Council division and the financial implications, they refused to accept the existence of this Boundary line. At a meeting with the developer, we were informed that RDC will allow Council Tax collected by Hullbridge on behalf of Rawreth Parish. Have RDC made the necessary application to LBC for the necessary changes to the Boundary Line and whether or not Rawreth will be amalgamated with Hullbridge at some future date.
The same principle applies with the Boundary Commission England and the National Planning Policy Framework regulations, again we ask for specific dialogue to satisfy the regulations. One of the Green Belt policy purpose is to prevent neighbouring towns/villages from merging into one, Can RDC explain why they seem to have abandoned this policy.

Page 10. Clauses 3.6 to 3.8, Figures 2 and 3. “Travel to work outflows and inflows”.
The travel patterns have changed since 2011 by about 18% with the increase of population. We request a review of the information being given, affecting transport congestion and lack of proper infrastructure.

Page 11. Clauses 3.9 to 3.12. Employment statistics.
We suggest a review is necessary. What guarantees will the prospective developers give to employ local skills.
Stakeholder Ref: CP15678E Community Representative Ref: 29007

Pages 12 and 13. Our Environment. Clause 3.13
Previous Statements made by the Environment Department, Highways & Water Agencies and the HSE suggesting assessments made in 2011 and 2014 were ‘insufficient’ and all future assessments will also fall short of efficiency with funding being used as an excuse to minimise costs giving rise to lack of obligations to this community and to blame Government pressure to satisfy the development quota being used as an excuse to limit the scale of assessments, thus breaching the clauses in the LDF, NPPF and Localism Act.
The same agencies gave evidence to the Planning Inspector that Hullbridge is a ‘sparsely populated’ area. This can be classified as a false statement knowing that Flood water has been a major concern for many years including surface and foul water discharges onto roads and gardens, due to lack of improved drainage facilities and gardens constantly under water. Further land being put forward for development will exacerbate the infrastructure issue. We are informed that RDC do not keep records of ‘Public health’ issues, any complaints are ignored. Foul sewers are grossly overloaded. A full upgrade of the drainage system has always been overdue. This issue should be investigated rigorously by the RDC and it is their responsibility to inform the ECC.

Page 14. Our Communities.
The Hullbridge population count for 2011 census states a population of 6858. HRA support from the community in 2017 suggests 7000 and in 2019 = 7400.
The current development of 500 homes proves an annual population increase from 2019 to 2023 = 9400 population. The growth in the previous 3 decades (census) indicated an average of 2.2% increase. This indicates an average annual increase of 2% per census. This is contrary to the Core Strategy, LDF and the NPPF and the Localism Act that any increase in population should follow the historical line. Hopes rise for a new climate of close Community Consultation.

Page 15 Table 1. Breakdown of 2011 Population Census.
These possible developments will increase the Hullbridge population (see Exhibit B- Population) to 35,900 which will be close to the present Rayleigh population within 15 to 20 years.

Hullbridge, presently with a ‘village status’ will become a Town with a population probably second only to Rayleigh. The Portfolio Holder (Councillor Ian Ward) stated that the Local Plans have changed and it was now paramount to ‘listen’ and closely ‘consult and engage’ with the community, but most people are sceptical that our voices will be heard, and the necessary amendments put forward by the HRA ‘professionals’ will not be heeded. Hullbridge presently consider all verbal utterances are not considered in favour of the community, and no changes are evident except for many of our issues on planning which HRA had to investigate without any RDC help to satisfy the community q & a meetings.

Clause 3.20 Using HRA figures given above we are unable to reconcile with your statement that “the proportion of residents in all demographic ranges will remain ‘stable’. We advise the RDC to review their information and observe the contents of our Exhibit A and B on pages 14/15 and 16-21 provides the necessary calculation, showing exceptional over-population.

Page 16
Clauses 3.21 to 3.25 needs to be reviewed in respect of the statements made being out of date, as the document is prepared using data prescribed in 2011 without fact-finding surveys being conducted to carry out ‘forward planning’ especially with the owner-occupation criteria becoming financially unreliable. With experience of the Public Finance Initiative (PFI) being suspect it will be necessary to return to Council House Building with participation between Local Government and Housing Associations being a prime ‘home provider’ but all motives are suspect.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 4
Page 17 – Spatial Challenges.
Great emphasis is placed on the laws governing the National Planning Policy Framework. We highlight the following to allow you to respond to the Hullbridge Residents Association.
We request you uphold the clauses requiring Consultation with the community Representative such as the HRA with and allowing replies to issues of importance to the community, before finalising the New Local Plan.

Consultative Objections.
We submit our “Consultative Objections” and conform to the NPPF policy namely – that the Local Authority and the ‘Applicants’ must work closely with those directly affected by their proposals to evolve designs that take account of the views of the community.

Brownfield and Greenfield land.

The allocation DPD Document (Feb 2010)- Discussion & Consultative Document on page 1 states that the Council Statement of Community Involvement is committed to Regulations 25 Public Participation in the preparation of Planning for the District (revised 2017). We ask for the right to be properly consulted on this issue that the allocation document has no brownfield sites identified as given in our Exhibit B.

Section 5.
Page 24. Clause 5.1. Our Vision and Strategic Objectives.
HRA experience gained over 9 years of deliberations over the Hullbridge ‘developments’ and Local Plans, that this has not been a success as the majority of the 185 issues submitted in 2014, not being satisfied, and with alliances formed with other localities the same view is expressed. The fact that you did not respond indicates that we are right on all the issues submitted to you and hope the Planning Inspector will take this into account in respect of all future “Consultation”.
We hope that the Planning Inspector takes into account the atmosphere of distrust by the community.

Clause 5.4 Our current Vision
HRA disagree that what is being prescribed on the Hullbridge Plan will allow the community to have the best quality of life, when there is at least 20 years of disruption to look forward to, which will blight our lives. Whole sale development is taking place with major clauses in the NPPF being disregarded.
A “Considerate Contractor Scheme Notice must be a requirement for all contractors to observe the rules towards the community.

Page 26. Clause 5.10. Rochford District 2037. Our Society
We disagree with the statement made that’ the green infrastructure network across the district has been enhanced to support our population. Many hectares of Green Belt Land are being allowed to be developed disregarding all the clauses which are supposed to protect the Green Belt and Government directives. Articles written by the Campaign to Protect Rural England (CPRE) bear witness to the contrary and the community remain sceptical about the final outcome.
The community believe that the homes will be for the over- burgeoning populace of London, not of Essex. We fail to see how you can demonstrate the indigenous population expansion taking priority.

Page 28. Cl. 5.11. Strategic Objective 13. Flood.
Experience gained by the lack of proper assessments on flood, disregarding all the issues provided to you in 2013. Decisions are being made according to financial constraints.


Stakeholder Ref: CP15678E Community Representative Ref: 29007

RDC now have a recipe for disaster in an area naturally susceptible to surface water discharge from the ‘Rayleigh Heights’ about 65m above ground level and surrounding areas of vulnerable Watery Lane.


Page 29. Strategic Priority 5. Climate change.
The Hullbridge community are concerned that the information provided by various Agencies and Insurance Companies that the 1:100 flood incident is flawed and is more likely to be a maximum 1:25 due to Climate change. There is scepticism that the LA will help change the law and this will be detrimental to the community at large. Sea levels have officially been recorded as rising some 150mm above sea level from the beginning of this century and are forecast to rise by 500mm before the end of this century.

Section 6.
Pages 32 to 38. Clauses 6.8 to 6.29. Tables 2 to 4.
Advance notice. Property Insurance.
The potential Property Insurance costs against ‘flood risk’ and ‘subsidence in these areas, can range from £2500 to £5000. per household depending on the risk analysis.
An exercise on Post Codes SS5 reveals that using the ‘Hawkeye’ system determining the level of associated risks such as flood, subsidence etc., the combined results show that in both instances, subsidence is Red, meaning these are perils which will either be excluded or a large excess applied in respect of subsidence – usually £2,500.00 (£1000.00 being ‘Standard’) and for any areas susceptible to flood, without protection barriers or flood defences will increase the Cost Risk to £5,000.00 per property making ‘flood excess’ a priority and no claims accepted by the Insurance Companies if this is applied to development in flood areas.

Page 38 to 40. Clauses 6.29 to 6.33. Homes for purchase and Affordable Homes.
This document was obviously written before the changes which have taken place in the financial industry and Government policies. The change in ‘affordability’ has not been fully considered. We advise you to review and amend this statement accordingly.
How can you demonstrate the ‘affordability’ during this financial climate, which are likely to continue for the next 10 years, irrespective of the incentives given on stamp duty and directives to the lending institutions? Most younger adults will have great difficulty to purchase homes and maintain mortgage payments.

Table 5 Rochford District- Settlement Hierarchy.
We have always had an issue with the infringement of the Green Belt. Most of the present developments recently completed or under construction are being built on Green Belt land disregarding brownfield sites. We suspect that the new Land Development Framework document questions the need to build on the green belt land. Our Exhibit B presents you with our statements on your LDF

Page 45. Clause 6.48. Housing Density Options .
Earlier we provided calculations for the lowest density of development per hectare, It is evident that the option may be for up to 60 homes per hectare which will increase the incentive provided by the Government and risk the long term harmony in the community and will cause even greater strain and stress on the Hullbridge infrastructure and the community.
RDC must take advantage of requesting funds from the Government announcement of £866m funds from the Housing Infrastructure Fund (HIF) to enable the existing Hullbridge infrastructure be brought up to standard, on the grounds that the previous planning regime’s over the last 30 years have been negligent in dealing with the existing infrastructure as suggested on page 6. Clause 1.21.



Stakeholder Ref: CP15678E Community Representative Ref: 29007


Section 8.
Local Highways Capacity and Infrastructure. Clause 8.3 LDF Development Management Submission Document- Section 5- Transport page 73. Improvements to local road network
The only access points to get to Hullbridge is Lower Road and Hullbridge Road. Watery lane should not be considered as a main thoroughfare and we despair that the Essex County Council, Rochford District Council and the Agencies seem to ignore this fact. We want the Planning Inspector to review his statement in the ‘Planning approval’ given in 2014 that RDC consult with HRA on the feasibility for improvement of this Lane, as it is not ‘fit for purpose’.

Highways Risk Analysis.
HRA are concerned that a proper Highways Risk Analysis has not been carried out by the Core Strategy, NPPF and LDF documents. Further consideration must be given for ‘transparency’ as stated in The Localism Act (2011). Recent replacement of 50 years old Gas services emphasises the disruption which
will be caused by both existing and future construction work. County and Local Authorities please take note.

Watery Lane, is in urgent need of improvement and HRA have corresponded with RDC, ECC and all the Agencies showing Watery Lane and Hullbridge Road are identified as traffic congestion points, in clauses 8.13 to 8.15.
We request that RDC/ECC/Agencies contact the SAT NAV services to remove Watery Lane as a general thoroughfare and emphasise this is “weight restricted” and ‘width restrictive’ and speed limits reviewed with adequate signage..
This lane is too narrow for any vehicles over 30 cwt. The lane is without a public footpath making this lane a health and safety issue which needs urgent rectification. HRA suggest that this section of the document should be reviewed, particularly as the Planning Inspector acknowledged HRA argument that Watery Lane is not ‘fit for purpose’, we reject the statement that Watery Lane is NOT part of the “Strategic Highways Network” please review, amend and highlight for the Planning Inspector to view..

Accessibility to Services. Hullbridge has many un-adopted, single lane and unmade roads making access difficult for the Fire, Police, Refuse, Ambulance and general delivery services and will not be suitable for constant construction site traffic for next 20 years a covenant should be inserted to allow the ECC and their Agencies to make urgent contingencies before the matter gets worse as expansion proceeds..

Fire Hydrants. Hullbridge only has 8 Fire Hydrants to serve the whole village, which is considered inadequate for the fire services.


Page 85 - 90. Clause 8.22 to 8.37. Sustainable Travel.
The transport system is being overhauled to reduce the number of buses serving the communities and the frequency, if this carries on, there will be future major problems. Please refer to LDF Allocations Submission Document Page 60 Cl 3.177/178.

Page 87. Clause 8.31 Rayleigh Air Quality.
Reading this clause we are not confident that something will be done to provide good quality air. It was reported in the media, that dangerous levels of nitrous oxide caused by diesel fumes are being recorded in and around the Rayleigh area. Air quality is lacking in both depth and detail which means the RDC ‘evidence base’ on the subject of traffic, is lacking. Please explain your remedy? This pollution has been apparent for many years but ignored. The community now demand action to remedy this issue.

Stakeholder Ref: CP15678E Community Representative Ref: 29007


Page 92 to 96. Clause 8.45 to 8.58. Water and Flood Risk management.
Flood
At times of flood (frequent - 25 times in 5 years), in Watery Lane, has resulted in many accidents, causing ‘gridlock’ to the whole local traffic system in Hullbridge and surrounding areas. Drainage is unable to cope with excess flood water resulting in overflow of excrement and water into roads and gardens and cross-surging foul water and surface water services

Page 96- 98. Clause 8.59 – 8.66. Renewable Energy Generation.
We agree about the ‘renewable energy’ ‘dream’ from all sources and accept there is natural course of events to be taken for the sake of the concerns on Global Environment. It is the political challenges which become the difficult part to address. Perhaps Political will may help.

Page 98-100. Clause 8.67- 8.75. Planning Obligations and Standard Charges.
Local Authorities ignore the observations and pleas made to review and observe the standards laid down by the NPPF, Core Strategy and LDDF to allow ‘proper’ consultation with the community representatives.
The NPPF guidelines on all planning obligations suggest that the 3 tests as set out, must pass:
1 Necessary to make the development acceptable in planning terms.
2 Directly related to the development.
3 Fairly and reasonable related in scale and kind to the development.
The community want an action plan to allow meaningful consultation with the community.

Section 9 Supporting Health, Community and Culture.
Page 101- 120. Clauses 9.1 – 9.61. Health Impact assessment- Cl 3.186
We (HRA) brought to the authorities’ attention various anomalies in the financial accountability in assessing the “Contributions” without giving considerations to contingency for increases in inflation and time related uplift. HRA are happy to be consulted in the future.
HRA investigated the Health Provision indicated in Section 106 ‘contributions and concentrated on the sum stated to be for the Riverside Medical Centre on Ferry Road and found the sum stated to be inadequate. We fear the same decisions may be made for the foreseeable future. As HRA have been active on this issue it would be in the interests of all parties to consult and agree a course of action.

Section 10 Protecting and Enhancing our Environment.
Page 121 - Clause 10.1 to 10.4
General planning policy of the NPPF suggests minimising vulnerability and provide resilience to climate change impacts. RDC and ECC must provide a course of actions.

Page 121 – 141. Clause 10.5 – 10.72 Green Belt
We agree the purposes of the NPPF clause 10.7-10.8 in that the 5 purposes of the Green Belt set out to:
1. Check the unrestricted sprawl of large built up areas
2. Prevent neighbouring towns merging into one another.
3. Assist in safeguarding the countryside from ‘encroachment.
4. Preserve the setting and special character of historic towns.
5. Assist in urban regeneration, by encouraging the recycling of derelict and other urban land ie Brownfield Sites. Inappropriate development. (Page 122. Clause 10.8) Specifically states that the construction of new buildings in the Green Belt is generally considered to be inappropriate development.
The Hullbridge Residents Association respectively request that Rochford District Council adhere to these policies and review the New Local Plan Document. It may be appropriate to classify this as “Special Measures” and allow the intervention of a Planning Inspector to adjudicate.

Stakeholder Ref: CP15678E Community Representative Ref: 29007

Section 11. Detailed Policy Considerations. Pages 142- 165
Page 142. Clause 11.2 Mix of Affordable Homes

In HRA discussions with a developer we were advised that the RDC stated that the Core Strategy and the Land Development Framework were ‘out of date’ therefore some clauses were not applicable.
The same situation applied to discussions when applied to the Localism Act. The Core Strategy and the NPPF are evident in many statements in this new Local Plan document, so, we consider there has been no change in the above main documents, action is necessary.

Page 155. Clause 11.45 Brownfield Sites. HRA have taken into account clauses 11.45/ 46 and taken into consideration that all Brownfield sites must have priority. NPPF paragraph 89 and Policy DM10 on brownfield development should be an over-riding factor when producing these documents. We refer you to the ‘ambitious’ clauses stipulated in the LDF Management Submission Document- Clause 3 page 33- The Green Belt and Countryside – Vision. Short term. The first paragraph stipulates the “openness and character” of the Rochford Green Belt continues to be protected. Constant reference by our MP Mark Francois has been ignored which places him in an awkward position.

Page 164. Contaminated land. Cl 11.77 to 11.81. Specific example of for
Nevendon Yard Breakers Yard, Lower Road, Hullbridge. Proposed 90 units.
This site is contaminated over a 70 year period and the costs of eradication will be high. The outline application plans are presently delayed for that reason while a historical document is being prepared.

LOCALISM ACT 2011 chapter 20. Item 2.1 (5th bullet point)
The ‘Localism Act’ was brought into force in 2011, the community did not have the opportunity to apply the clauses of this act. This act stipulates that the Local Community has: the ‘right to challenge’ (Part 5, Chapter 2, Clauses 81 to 86).


End of Appeal For Withdrawal.