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

Showing comments and forms 1 to 18 of 18

Support

New Local Plan: Spatial Options Document 2021

Representation ID: 38181

Received: 25/08/2021

Respondent: Miss Jessica Clarke

Representation Summary:

Yes older or unused buildings can be renovated and re classified to other employment needs such as offices

Full text:

Yes older or unused buildings can be renovated and re classified to other employment needs such as offices

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 38893

Received: 15/09/2021

Respondent: Mrs kathryn Gilbert

Representation Summary:

as my previous comment

Full text:

as my previous comment

Object

New Local Plan: Spatial Options Document 2021

Representation ID: 39073

Received: 19/09/2021

Respondent: Mrs Gill Hind

Representation Summary:

Your plan only caters for more of the same type of business. To assume all business wants to be located in industrial parks, away from transport links, away from its client base is absurd, and narrow minded. You want to encourage a skilled workforce to the area you need to create the environments that these business want. I, for one, would not work in an industrial park.

Full text:

Your plan only caters for more of the same type of business. To assume all business wants to be located in industrial parks, away from transport links, away from its client base is absurd, and narrow minded. You want to encourage a skilled workforce to the area you need to create the environments that these business want. I, for one, would not work in an industrial park.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 39735

Received: 22/09/2021

Respondent: Cllr Michael Hoy

Representation Summary:

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.

Full text:

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.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 40068

Received: 22/09/2021

Respondent: Star UK Rayleigh Propco Limited

Agent: Quod

Representation Summary:

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 jobs. It is for the reasons outlined above that the GT1 site should be allocated for employment uses rather than Gypsy and Traveller Accommodation.

Full text:

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.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 40156

Received: 22/09/2021

Respondent: Jane Carvalho

Representation Summary:

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.

Full text:

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.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 40415

Received: 22/09/2021

Respondent: Essex County Council

Representation Summary:

Spatial Strategy Options 3b / 3c, may provide the opportunity for a new mixed-use area including high-productivity employment uses, given their relationship to the Airport and existing employment areas.

Full text:

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]

Support

New Local Plan: Spatial Options Document 2021

Representation ID: 40484

Received: 22/09/2021

Respondent: Southend-on-Sea Borough Council

Representation Summary:

Yes, land north of Temple Farm Industrial Estate.
Land north of the existing Temple Farm Industrial Estate provides the opportunity for an extension of the estate to meet future employment needs as part of strategy option 3b: concentrated growth north of Southend.

Full text:

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

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 40545

Received: 04/10/2021

Respondent: Kevin O'Brien

Number of people: 2

Representation Summary:

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.

Full text:

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.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 40636

Received: 22/09/2021

Respondent: Mr Stephen Tellis

Representation Summary:

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.

Full text:

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.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 40880

Received: 22/09/2021

Respondent: Rayleigh Town Council

Representation Summary:

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.

Full text:

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

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 41088

Received: 22/09/2021

Respondent: Cogent Land LLP

Agent: Iceni Projects

Representation Summary:

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

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

03. REGIONAL POLICY MATTERS – CONTEXT FOR GROWTH.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

[SEE ATTACHED DOCUMENT FOR TABLES DETAILING LANDSCAPE CHARACTER ATTRIBUTES]

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

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

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

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

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

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

08. RESPONSE TO QUESTIONS RAISED IN THE CONSULTATION.

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

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

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

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

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

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

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

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

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

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

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

09. ECONOMIC BENEFITS TO ROCHFORD
OF OPTION 3B

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

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

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

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 42495

Received: 19/09/2021

Respondent: Vanessa Irwin

Representation Summary:

Building a whole new community or “garden village” would provide not only the houses but would generate the need for additional services. Potentially doctors, clinics, nurseries, shops perhaps even schools creating a significant number of local jobs instead of pushing even more people onto the commuter trains that are already over subscribed.

Full text:

I have studied the planning suggestions and do not believe that planning a number of individual developments is the solution to the current housing needs.
Anyone who lives in Rayleigh (I have for 51 years) will know that are roads are already terribly congested and services stretched. Also a plan that just provides houses but no new infrastructure, jobs etc is not the complete answer to the problems.
Dotting houses around the town, slotting in 50,100,500 houses in areas that will use the existing roads and services will only cause more problems.
The needs of the existing people in our towns, as well as the welfare of new residents should be considered very carefully.
Building a whole new community or “garden village” would provide not only the houses but would generate the need for additional services. Potentially doctors, clinics, nurseries, shops perhaps even schools creating a significant number of local jobs instead of pushing even more people onto the commuter trains that are already over subscribed.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 42934

Received: 10/09/2021

Respondent: Ms Deborah Mercer

Representation Summary:

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.

Full text:

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.)

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43161

Received: 14/09/2021

Respondent: Hullbridge Parish Council

Representation Summary:

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.

Full text:

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.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43185

Received: 13/09/2021

Respondent: Mrs Ane Bates

Representation Summary:

More sustainable small businesses to provide employment.

Full text:

Although I do not live in Rochford I am very concerned about any future developments because I believe that the climate emergency must be the overriding consideration and must be at the basis of all decisions. In your 20 year plan I would like you to consider:
-housing developments with only passive houses i.e. carbon neutral and with water saving features
-also to include social and family starter houses so young people can afford to live in Rochford
-more sustainable small businesses to provide employment
--cycle routes to schools
-charging points for electric cars
-commercial organic small holdings for fruit and vegetables (food resilience)
-an adventure playground
-more trees and open green spaces for the mental health and well being of residents
-green corridors for wildlife and biodiversity
-forest schools
-no concreting over front gardens and gardens and fields with hedges
As a nation we are hoping to become carbon neutral by 2050. This is vital for the wellbeing of us all. Please be innovative and courageous in your decisions.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43317

Received: 28/09/2021

Respondent: Hawkwell Parish Council

Representation Summary:

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.”

Full text:

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

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 44031

Received: 17/09/2021

Respondent: Mrs Lee Savill

Representation Summary:

[re Hullbridge]

There is no large scale employment here. Again more traffic to travel to work.

Full text:

1. ROAD INFRASTRUCTURE - The village of Hullbridge is served by ONE ROAD. Just one road to serve the village and all outsiders who use it as a rat run to avoid the congested A127. Building the BULK of RDC's housing target on Hullbridge's promoted sites will add approx 8,000 plus extra cars to this ONE ROAD. Access to schools, supermarkets and employment will all be outside the village and result in our ONE ROAD being at a stand still. Access to the rumoured new park will also require car travel as the bulk of the proposed housing is situated at the opposite end of the village.

Due to road congestion the Air Ambulance has landed here at least six times this year to avoid the road systems around Hullbridge. An increase in public transport is not viable and will only add to the traffic issues surrounding Hullbridge and Rayleigh.

2. HEALTH CARE - Hullbridge has a small GP surgery which has already taken on the David Wilson housing estate. The money received from David Wilson Homes cannot pay for expansion as the surgery does not have the footprint or parking to allow this. It cannot take on the patients from an extra 4,298 homes.

3. SCHOOLING - All secondary schooling is in Rayleigh, requiring pupils to travel out of Hullbridge on its ONE ROAD.

4. SHOPS - Hullbridge has three small food shops and limited parking. This volume of housing will result in traffic to supermarkets outside or delivery vehicles coming into Hullbridge. ONE ROAD.

5. EMPLOYMENT - There is no large scale employment here. Again more traffic to travel to work.

6. ENVIRONMENT - The promoted sites are all green spaces with ancient trees and hedgerows, and farmers fields. The native wildlife will be completely devastated by such plans for 4,298 homes. The rumoured new park is situated to the West and is outside the original boundary of Hullbridge. It will be no use to the bulk of housing being built to the East. There will be no open space this side.

7. AGRICULTURE - Majority of promoted sites are fields and woodland. Brexit was about this country being self-sufficient and self-reliant. Concreting over fields does not support this and is a lazy way to build.

8. CARBON FOOTPRINT - This volume of housing will concrete over fields, green spaces, trees and hedgerows. It will turn our ONE ROAD into a car park for cars with engines running. Pollution levels will soar. Wildlife will be trapped and devastated between the River Crouch and our ONE ROAD.

Hullbridge does not have any of the infrastructure for 4,298 homes out of the 7,000 RDC has been told to build. Choosing Hullbridge to ease this total number is both lazy and easy. It is counter-productive to environment and all who live in this corner of Rochford.