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?

Showing comments and forms 31 to 51 of 51

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 41628

Received: 20/09/2021

Respondent: SEETEC

Representation Summary:

We refer you to our comments and sites outlined at Q6.

Full text:

Seetec – Introductory Comments
With our head office in the Rochford district, we are one of the UK’s largest employee owned businesses, employing over 2,000 people and committed to building our history of service.
We help people in the UK and Ireland to increase their social and economic stake in society. We do this by providing skills, training and support services that people need to reach and exceed their ambitions, creating positive change for the communities we serve
Our aim has always been to change lives for the better. Founded more than 35 years ago as a small charity, we first taught IT skills to 30 unemployed young people at a former primary school in Hockley. From these humble beginnings, we now help hundreds of thousands of people find work, learn new skills and take ownership over their lives.
We understand the needs of the people we support. As employee owners, we now want to drive further improvements and continue to generate enduring positive outcomes for the people and communities we service.
As a B-Corp organisation we are business committed to social value by reducing inequality, working toward lower levels of poverty, a healthier environment, stronger communities and the creation of high quality jobs with dignity and purpose.
We care passionately about the District, its environment, open spaces, heritage and sustainable living. Our business has made a long term contribution to the District and this response is intended to reflect our on-going ambition to make Rochford district a first class place for health & wellbeing, work, learning and leisure. The choices the Council makes over the next 35 years will be key to this ambition.

Consultation Representations
Our responses and representations to the questions from the above consultation are set our below. We have replied to some specific questions and used cross references where appropriate to avoid duplication.
• Introduction
o
 Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
Agree
 Q4. Do you agree with the strategic priorities and objectives we have identified?
Agree
• Strategy Options
 Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
We prefer taking forward Option 4 Balanced Combination with the following comments, preferences and concerns regarding risks.
In general, the preference is for a ‘selective’ ‘Strategy Option 4’ approach by combining Strategy Option 1 Urban Intensification; Option 2 Urban Extensions and Option 3a Concentrated Growth in the west of Rayleigh. This would need to be in specific sites and it will be easier to quantify for housing targets if we were to identify sites that we would not support.
We would not support Option 3b North of Southend and 3c Focused East of Rochford and the land allocations from Rochford to Hockley in the 2017 Strategic Housing and Employment Land Availability as well as some other sites in Lower Hockley and Rayleigh. These are transport infrastructure and risk related objections whilst there are others that negatively impacting heritage, character and setting.
The specific areas of allocations of concern are listed below:
CFS035 land west of Rochford hall 1.25 hectares
CFS041 Lee valley farm 2.54ha
CfS074 land south of Mount Bovers Lane 14.22ha
Cfs077 land north of Great Wheatley’s Road 7.5ha
CFS084 land south of hall road 7.16
CFS085 land west and north of Hall Road 2.22
CFS087 land between Western Road and Weir Farm Road 3.08
CFS121 land north of A127 38.48
CFS150 land on the north side of Victor Gardens 1.73
EXP12 land adjacent 44 Great Wheatley Road 0.12
These will exacerbate the B1013 ‘rat run’ causing huge congestion and comprised emergency evacuation with the potential risk of:
• global warming repeating ‘1950’s scale flooding’ in South East Essex,
• nuclear contamination (Bradwell) and
• airport / rail disaster.
Any development must be matched by adequate transport solutions. Until this document is available then it is difficult for consultees to make informed representations and the Council to make evidence based decisions. The whole approach is somewhat ‘chicken and egg’. The transport solution should be the first document given the historic challenges and earlier consultation responses. Once this is available, the context of spatial options can be evaluated on sound evidence as community and population safety will be of paramount concern.
Assuming there is no radical bypass, which we would not support anyway given the intrusion into Crouch Valley conservation, solutions must be found to the key rail bridges and Rayleigh Weir underpass. These are high risk pinch points for local population and egress in particular:
Rochford Bridge / Hall Road
Hockley Bridges (Greensward Lane & Church Road)
Rayleigh station (London Road)
A127 Weir underpass
As a minimum, solutions must be found to these bottle-necks - widening the bridge underpasses, flyovers etc. If certain developments were to go ahead, flooding and the increased congestion of Options 3a, 3b and the proposed allocations along B1013 will potentially lock-in and lock-out population from their homes, shops, work and living in safe communities.
• Employment and Jobs
 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?
Any growth must be contingent on the transport infrastructure comments in this representation, without this future growth is limited. In addition, it is important for quality of living that night flights are stopped and pollution and noise controls are enhanced.
• 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?
We refer you to our comments and sites outlined at Q6.
• 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?
Remove allocations that threaten the key heritage sites in the District e.g. CFS035, CFS084, CFS085
 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?
Grade 1 Rochford Hall and setting.
Rochford Conservation Zone
Crouch Valley
• Town Centres and Retail
 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]
As regard Hockley town centre we have previously stated our preference to develop an imaginative town setting that brings Hockley Woods into the town e.g. shop ‘timber’ facades, woodland street furniture etc thus celebrating the setting of Hockley in its ancient woodlands and Spa.
• Transport and Connectivity
• We refer you to our responses under Q6 and Q28

 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?
We refer you to our responses under Q6 and Q28
 Q52. Are there areas where improvements to transport connections are needed?
We refer you to our responses under Q6 and Q28
 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.]
We refer you to our responses under Q6 and Q28

• Planning for Complete Communities

Rayleigh
 Q56d. Are there areas that require protecting from development?
CFS77, CFS087 and EXP12
Rochford and Ashingdon
 Q57d. Are there areas that require protecting from development?
CFS035, CFS084, CFS085 (see Q43 response above)
Hockley & Hawkwell
See representations at Q48
 Q58d. Are there areas that require protecting from development?
CFS041, CFS074, CFS150

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 41700

Received: 22/09/2021

Respondent: Southern and Regional Developments Ltd

Agent: Claremont Planning Consultancy

Representation Summary:

The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

Full text:

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

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

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

3. Spatial Themes
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?

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

4. 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?

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. 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?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

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?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 41722

Received: 22/09/2021

Respondent: Southern and Regional Developments Ltd

Agent: Claremont Planning Consultancy

Representation Summary:

The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality green and blue infrastructure is valuable to the wellbeing of Rochford residents, this must be balanced against
the region’s need for growth. It is therefore recommended that identifying general objectives for
strategic green and blue infrastructure (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements.
The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on site improvements to be delivered. Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy established in Chapter 3 of the Framework the role those strategic
policies should play, which is to set out the overall strategies for the pattern, scale and design quality of such places. As such, policies relating to the site specific provision of green and blue infrastructure would be more appropriately dealt with through the preparation of non-strategic level Plans and Policies, such as those in Neighbourhood Plans.
5.3. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas, and waterfronts. Whilst Option 3, requiring certain new developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development. Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy in meeting that criteria for soundness as identified in the NPPF.

Full text:

Rochford District Council – Land to the north of Sutton Road, Rochford
Representations to the Spatial Options Consultation
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local Plan.

Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
1.2. Claremont Planning on behalf of Southern and Regional Development’s Ltd are generally supportive of the settlement hierarchy proposed. Rochford is identified as a ‘Tier 2’ settlement within the hierarchy recognising the settlement’s sizeable population and comprehensive local service base. Whilst it is acknowledged that Rochford has a considerably smaller population than
that of Rayleigh, meriting its location below Rayleigh within the settlement hierarchy; the placement of Hockley and Rochford within the same ‘Tier’ in the hierarchy is disputed. Although the populations are of a similar size, the proposed settlement hierarchy fails to account for the
strategic location of Rochford adjacent to London Southend Airport. The close proximity of Rochford to the airport provides the settlement with key transport infrastructure which connects Rochford to the wider South Essex region and rest of the country. As such, it is considered that Rochford should be distinguished from Hockley within the proposed settlement hierarchy by
virtue of its local and nationally strategic location.
1.3. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy In accordance with the provisions of Paragraph 16 of the National Planning Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is
advisable that the overall distribution of growth is informed by this imperative and larger quantum of growth apportioned to those settlements which are identified by the hierarchy as being most sustainable. The proposed settlement hierarchy acknowledges the sustainability of Rochford for development, whilst these representations have also sought to illustrate the strategic location of
the settlement due to the presence of the London Southend Airport and its planned continued expansion to provide additional employment floorspace and associated employment opportunities.

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

Strategy Option 1: Urban Intensification
1.4. It is advised that Strategy Option 1: Urban Intensification is not advanced. The current standard
method identifies a housing requirement of 7,200 dwellings in the district across the next 20 years however the consultation document establishes that approximately only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
1.5. It is recognised that Strategy Option 2, which seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would therefore see the largest quantum of growth apportioned to the most sustainable settlement settlements within the District as established by the proposed settlement hierarchy and it is therefore recommended that growth at sustainable settlements such as Rayleigh and Rochford should be prioritised if this option is taken forward.
1.6. Moreover, the land north of Sutton Road at Rochford as promoted by Southern and Regional Developments, has been identified within the initial appraisal undertaken by the Council as making a potential contribution to Strategy Option 2. It is agreed that the promoted land off Sutton Road could make an effective contribution to the delivery of this Strategy Option where the land abuts established areas of residential development at the settlement and is located in close proximity to employment opportunities at the Purdeys Industrial Estate. As such, the land at Sutton Road is considered to represent a logical location for the further expansion of Rochford should Option 2 be advanced by the Authority.
Strategy Option 3: Concentrated Growth
1.7. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead-in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond. As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of these allocations arise. Topic Paper 9: Housing prepared in support of the
Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing completions to meet the local housing need identified for the new Local Plan. The
Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider allocating sites of a variety of sizes which can be builtout relatively quickly and make a more immediate contribution to housing supply.
Strategy Option 4: Balanced Combination
1.8. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2). Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s
housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not adversely affect housing delivery in the District.
1.9. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing
that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. As established, the land at Sutton Road as promoted by Southern and Regional Developments has been assessed by the Council under reference CFS067 within their 2021 Site Appraisal Paper prepared in support the Spatial Options consultation. Within this assessment, the land at Sutton Road is positively considered by the Authority and its availability and deliverability for residential development recognised.
Moreover, Claremont Planning assert that the Council should recognise that the land at Sutton Road performed strongly through this assessment in relation a wide variety of criteria including but not limited to flood risk; landscape harm; site hazards and conditions; and access to facilities and services. As such, the land at Sutton Road should be strongly considered for allocation
through the emerging Local Plan, given both its environmental, and social sustainability.

2. Spatial Themes
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?

2.1. National policy, chiefly paragraph 161 of the NPPF is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the District is influenced by high flood risk that is likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rochford and Rayleigh which are the areas within the District
at lower risk of flooding.
2.2. The land at Sutton Road promoted by Southern and Regional Developments represents a suitable location for development if the sequential approach to flood risk is adopted. Although an inappreciable area to the extreme south east of the land is located within Flood Zone 3, the
Environment Agency’s flood map for planning identifies that this area of the site also benefits from flood defences; whilst the rest of the land promotion is located within Flood Zone 1, being at low probability of flooding. 2.3. Within the 2021 Site Appraisal Paper, the Council identified that the promoted land at Sutton Road performs very strongly in relation to flood risk, recognising that this small area of flood risk on site is not detrimental to the land’s deliverability. The pragmatic approach advanced by the Council in relation to flood risk on site is therefore supported. Moreover, any development scheme proposed on the site would be designed such to sensitively respond to the risk of flooding on site, through the promotion of this area as public open space. This would ensure that flood
risk on site can be suitably accommodated whilst also enhancing the quality of any development scheme pursued through the provision of high quality public open space. Given that the vast majority of the promoted land at Sutton Road is sited within Flood Zone 1, alongside the Council’s recognition that the site performs strongly in respect of flood risk, Claremont Planning consider that the development of this land would be in accordance with the recommend sequential approach to flood risk in the Plan.

3. 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?

3.1. Meeting the need for different types, sizes, tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2 is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and mid-sized semi-detached and detached dwellings.
Claremont Planning consider that the release of Green Belt land, including the promoted land off Sutton Road should be strongly considered by the Council whereby the release of this land will both assist the Council in meeting their overall housing need, and facilitate the delivery of an appropriate mix of housing. In particular this will assist the delivery of family sized housing which
is better suited to delivery on greenfield land than constrained urban sites.

4. Future of London Southend Airport
Q28. With reference to the options listed above, or your own opinions, how do you feel we can best manage the Aiport’s adaptations and growth through the planning system?
[please state reasoning].

4.1. Following the adoption of the current Joint Area Action Plan for the London Southend Airport in 2014, the context for the Airport’s future growth has altered substantially. The consultation document establishes that the Airport’s development will need to respond to the emerging Government Aviation Strategy. Moreover, the COVID-19 pandemic has substantially impacted the Airport, with planned growth now envisaged to take place over a much longer time period than initially anticipated. Claremont Planning therefore agree that it is prudent to prepare an updated Joint Area Action Plan which accounts for both the changed policy, and economic
context of the Airport’s growth.
4.2. The regional importance of the airport, alongside its strategic cross-boundary location within Southend but adjacent to Rochford necessitates that a joint approach for the Airport’s growth is advanced in accordance with a coherent vision. Although Option 2 would satisfy the need for a joint, cross boundary approach to the Airport’s growth, national policy is clear that strategic policies should be focussed on setting overall strategies for the pattern scale and design. As such, development at London Southend Airport would more appropriately be considered within a detailed Area Action Plan rather than through Local Planning Policy. As such, Claremont
Planning would support the pursuit of Option 4, where this Option will ensure that any resultant Area Action Plan can be prepared in accordance with policies contained within the new Local Plan.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality green and blue infrastructure is valuable to the wellbeing of Rochford residents, this must be balanced against
the region’s need for growth. It is therefore recommended that identifying general objectives for
strategic green and blue infrastructure (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements.
5.2. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on site improvements to be delivered. Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy established in Chapter 3 of the Framework the role those strategic
policies should play, which is to set out the overall strategies for the pattern, scale and design quality of such places. As such, policies relating to the site specific provision of green and blue infrastructure would be more appropriately dealt with through the preparation of non-strategic level Plans and Policies, such as those in Neighbourhood Plans.
5.3. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas, and waterfronts. Whilst Option 3, requiring certain new developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development. Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy in meeting that criteria for soundness as identified in the NPPF.

6. 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 ensure our village and neighbourhood centres remain vibrant?

6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in continuing to support the viability and vitality of town centres. It is considered important however, that the Council recognise the important of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can
increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need, and confirms that early discussions with adjacent authorities have not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed that the
emerging Local Plan will be able to demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) supporting this consultation contains detailed site assessments of the contribution made by promoted sites to the purposes of the Green Belt, including an assessment of the promoted land north of Sutton Road at Rochford that is within a wider Parcel 63. The assessment of the land presented within the Green Belt study is supported, where the assessment recognises the diminished contribution
made by the site to the purposes of the Green Belt, particularly safeguarding the countryside from encroachment and preventing coalescence, by virtue of the site’s relative enclosure by the established Rochford settlement. When the harm of the Parcel’s release was assessed at Stage 2 of the Study, it was concluded that moderate harm to the Green Belt would result. Claremont
Planning contest this conclusion, and assert that instead the harm resulting from the Parcel’s release is instead low, or low-moderate. The Stage 2 assessment undertaken recognises that this parcel of land is weaker performing Green Belt due to its high level of containment, going on to establish that by virtue of this containment the release of land in this area would be of no harm to adjacent Green Belt parcels. Due to the recognition within this assessment that the release of
this land from the Green Belt would not be detrimental to the wider Green Belt, the subsequent conclusion that moderate harm to the Green Belt would result, is not considered to be robustly justified.
7.3. National planning policy, chiefly paragraph 142 of the NPPF, sets out that where exceptional circumstances are demonstrated, a pragmatic approach to Green Belt release, giving first consideration to land which is previously developed and/or well-served by public transport, should be advanced. Claremont Planning support the assertion made within the Joint Green Belt
Study paper that the environmental and sustainability effects of Green Belt release need to be considered alongside the harm to the Green Belt of release, where the most sustainable locations for development may not be the areas which would result in the least harm to the Green Belt. Where this nuanced approach to Green Belt release is considered, Claremont Planning contend
that the merits of releasing the promoted land off Sutton Road are especially evident where it has been established that the site represents a both a highly sustainable location for development at one of the District’s main settlements, and a location at which harm to the Green Belt arising from the land’s release is limited. In light of both the limited contribution made to the Green Belt by this parcel, alongside the negligible harm arising from the land’s release and highly sustainable location, it is strongly recommended that the Council consider the promoted land at Sutton Road
for Green Belt release.

8. Planning for Complete Communities
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you
feel is missing?
8.1. The proposed vision statement for Rochford and Ashingdon is generally supported by Claremont
Planning, where it proposes the further growth and development of the settlement. In particular, the vision statement’s recognition of the settlement’s strategic location close to key employment sites and London Southend Airport, and intention to bolster its regionally significant role is strongly supported. However, it is considered that the proposed vision statement places too great an emphasis on economic growth at the settlement. Instead, Claremont Planning recommend
that the proposed vision statement be amended to include a more balanced and holistic approach
to growth, where it is considered that the Council should recognise the role that residential development has in supporting both the vitality and viability of town centres, alongside a recognition that economic and jobs growth must be supported by sufficient housing provision to
support the local workforce. Moreover, as a ‘Tier 2’ settlement in the District, Rochford represents a highly sustainable location for residential development and should therefore represent a location for significant growth through the emerging Local Plan to assist in meeting the District’s housing needs. As such, it is advised that the vision statement be revised to recognise the role of residential, alongside economic development in realising the growth ambitions of the district.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other
8.2. Promoted site CFS067 as identified on Figure 45: Map of Rochford and Ashingdon, should be made available for residential development. Through these representations to the Spatial Options consultation, Claremont Planning have sought to identify that the central location of the promoted land at Sutton Road within the Rochford settlement establishes the land as both a highly sustainable, and logical location for further residential development. This assertion is complemented by the 2021 Complete Communities Topic Paper prepared by the Authority within with the promoted land is located within an area identified as having a high walking completeness score of 11-13, meaning that there are a large number of services and facilities located within walking distance of the site. However, the Complete Communities Topic Paper also identifies that whilst the most complete areas in the settlement are located near the town centre, there are areas of low population density in and around the centre where future growth might optimise proximity to services. As established, the land off Sutton Road is entirely enclosed by the established Rochford settlement, and abuts existing residential development and employment
land at all elevations. Given the high walking completeness score of the land, the development
of the site represents an opportunity to both locate development at the most sustainable locations
within the settlement, whilst increasing the number of residents living in ‘complete’ areas.
8.3. The Complete Communities Topic Paper demonstrates that Rochford has good levels of
completeness in respect of access to education, health, civic, and sport and leisure facilities whilst only 8% of the settlement is located within the walking catchment of green infrastructure. It is considered that the release of the promoted land off Sutton Road for residential development represents an opportunity to address this shortfall. Within the south of the site at Sutton Road is
a small area of Flood Zone 3 which is promoted for use as public open space / access arrangements through any development proposal advanced. Moreover, the north-easternmost corner of the land is located within the Southend Airport Public Safety Zone within which
development potential is restricted. As such, this area is also promoted for and provides an opportunity to deliver public open space and ecological enhancement. Through careful scheme design it is therefore considered that any proposed development on site will deliver a connected series of public open spaces and green infrastructure, supporting both recreational activities and
delivering biodiversity gains. Given the relative enclosure of the site by established development, it is considered that both future occupants and residents of the wider site area will benefit from this enhanced green infrastructure provision.
Enclosed : Site Location Plan

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 41752

Received: 20/09/2021

Respondent: RSPB

Representation Summary:

The RSPB would like to see a strategic approach adopted for the delivery of new and enhanced green and blue infrastructure. We are currently working with a number of partners in Essex to establish a Local Nature Partnership
(LNP) as well as the evolving process of Local Nature Recovery Strategies (LNRS) which have recently been piloted elsewhere in the UK.
Protecting and enhancing the established network of designated sites is the fundamental first step. It is widely
recognised that much of the land surrounding our coastal SPAs and SSSIs is functionally-linked to these sites (i.e. it is unprotected land that supports numbers of birds such as dark-bellied brent geese in significant numbers). Identifying and mapping these areas at a spatial-level would assist the council in maximising the benefits to the natural environment

Full text:

New Local Plan: Spatial Options Document 2021
Thank you for this opportunity to respond to the latest consultation. Our comments follow those made on previous
consultation documents, namely:
1 July 2015 – Draft Environmental Capacity Study
18 May 2016 – Draft Statement of Community Involvement
8 March 2018 – Issues and Options consultation.
Please find our responses to particular questions below.
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?
As mentioned in our letter responding to the draft Environmental Capacity Study, full consideration should be given
to the Environment Agency’s Essex and South Suffolk Shoreline Management Plan.
Q4: Do you agree with the strategic priorities and objectives we have identified?
Yes. We welcome and commend the Council’s clear priority in Strategy Priority 5 to conserve and enhance the natural
environment as well as a clear ambition to create habitat networks. This is consistent with national planning policy.
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?
Mandatory biodiversity gain (BNG) should go beyond mitigating and compensating the impacts of development by
enhancing natural capital, supporting the recovery of nature and meeting future environmental challenges. Done
correctly, it should help to deliver sustainable development, restore nature, and create and enhance places where
people live and work.
The council’s approach to BNG should be underpinned with clear targets for protecting and restoring biodiversity and
its effectiveness evaluated on a regular basis. BNG must be in addition to, and not instead of existing statutory
biodiversity protection and it should only apply to developments that do not have an impact on protected areas, e.g.
Special Protection Areas (SPAs), Special Areas of Conservation (SAC), Ramsar sites and Sites of Special Scientific
Interest (SSSIs).
A fundamental risk of BNG, is that it will be considered a licence to trash habitats as destruction of a habitat can be
offset by creation of another. To avoid this, the net gain approach must apply and enforce the mitigation hierarchy,
so all efforts are made to avoid and mitigate harm through appropriate location and design choices. Compensation (offsetting) of residual impacts on habitats and species should be a last resort. Re-creating or restoring complex
natural processes is inherently difficult and full of risk so in-situ conservation is always preferable. Once the mitigation
hierarchy has been strictly applied, the development should be achieving no net loss of biodiversity. Net gain
approaches can then be explored as additional
To answer the question specifically, where new habitat is created, it is normally preferable to do so on the
development site. If this is not possible or desirable due to unavoidable impacts, it should be in an area identified in
a local or strategic biodiversity enhancement plan (e.g. the evolving Local Nature Recovery Strategies [LNRS]).
Q32. With reference to the options above, or your own options, how do you feel that we can best deliver a quality
green and blue infrastructure network through the plan?
The RSPB would like to see a strategic approach adopted for the delivery of new and enhanced green and blue
infrastructure. We are currently working with a number of partners in Essex to establish a Local Nature Partnership
(LNP) as well as the evolving process of Local Nature Recovery Strategies (LNRS) which have recently been piloted
elsewhere in the UK.
Protecting and enhancing the established network of designated sites is the fundamental first step. It is widely
recognised that much of the land surrounding our coastal SPAs and SSSIs is functionally-linked to these sites (i.e. it is
unprotected land that supports numbers of birds such as dark-bellied brent geese in significant numbers). Identifying
and mapping these areas at a spatial-level would assist the council in maximising the benefits to the natural
environment
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?
The RSPB supports the recognition giving to the network of coastal sites in the “island wetlands” complex which are
reflected by their suite of national and internationally important nature conservation designations.
However, it is critical that the sensitivity of the internationally important species and habitats is accounted for
rigorously in the planning of any such proposals. A Habitats Regulations Assessment (HRA) of the plan should be
instigated at the earliest opportunity in order to achieve this. Responding to the Issues and Options consultation in
March 2018 in relation to HRA, we said:
“We recognise that a number of HRAs relating to previous development plans and strategies have been
provided as part of the evidence base. Whilst informative, these are not up to date. However, we note and
welcome your commitment to presenting a draft HRA at the next stage of the plan process (per paragraph
1.12) and we look forward to commenting on this document. If you require any assistance in its formation,
we would be happy to assist.”

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 42223

Received: 06/09/2021

Respondent: Environment Agency

Representation Summary:

We generally agree with the vision and proposals for biodiversity and blue / green infrastructure included in the plan. The following link could be added as a resource
regarding green infrastructure http://www.biogeomorph.org/greengrey

Full text:

Dear Sir/Madam
SPATIAL OPTIONS DOCUMENT 2021 .NOTIFICATION OF CONSULTATION UNDER REGULATION 18 OF THE TOWN AND COUNTRY PLANNING (LOCAL PLANNING) (ENGLAND) REGULATIONS 2012, AS AMENDED.

Thank you for the opportunity to comment on the Spatial Options Document 2021. We have reviewed the document and have provided comments in regards to Water Resources, Flood Risk and Ecology. In our response we have commented on specific questions raised in the consultation, where we feel the plan can be
enhanced or strengthened.

Water Resources
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?
There needs to be consideration of the South Essex Joint Strategic Plan and the water cycle study. This can highlight where they may be restrictions on development.

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?

Strategic Priority 3 mentions providing ‘sufficient provision of infrastructure’. There needs to consideration of this for wastewater/foul water in a strategic objective. Strategic Objective 9 could be amended to cover this: ‘To ensure that all new homes and commercial premises are supported by appropriate, timely and necessary infrastructure to mitigate potential impact, including those relating to transport, utilities, telecommunications (including broadband), open spaces and greenways, flood risk, wastewater treatment capacity, education, health and other community facilities.
This is required in order to ensure development is phased in line with treatment capacity to protect the water environment. If sufficient capacity is not available this can affect the locations of development.
Strategic Objective 20 mentions protecting the ‘natural environment’. This could be strengthened by the addition of rivers and other freshwaters’. This is because the
Water Framework Directive (WFD) requires protection of all waters; rivers, lakes and coastal/estuarine waters.
Options - The options include possible development at several towns. These are served by Water recycling centres, the main ones being Rochford, Rayleigh East,
Rayleigh west. All have some capacity at the moment for development but we recommend early discussions with AWS and use of a water cycle study to ensure
that developments are located and phased with wastewater treatment capacity.

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?
Page 37 talks about protecting a natural environment and about protected areas. But all water environments are protected under the requirements of the WFD. Assessment of large developments need to consider the main requirements of this directive – that there will not be a deterioration in the water environment and that required improvements in quality are not compromised. The river roach and its tributaries are within the Rochford area, and tributaries of the River Crouch.

Flood Risk
Q2 Do you agree with the draft vision for Rochford?
It would be good to see something in here regarding flood risk, it could maybe fit under the Environment heading and state: We will aim to manage flood risk and
look to sequentially site development out of the flood zone to try to reduce flood risk both now and with the effects of climate change.

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 from flooding and coastal erosion where possible?
Yes we agree sequentially siting development out of flood zones. This in itself is the best way that they can best protect their communities from flood risk.
You should also note that since the previous consultation regarding the local plan climate change allowances have been updated, the latest guidance can be found
at: https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances.

Ecology
We generally agree with the vision and proposals for biodiversity and blue / green infrastructure included in the plan. The following link could be added as a resource
regarding green infrastructure http://www.biogeomorph.org/greengrey/

We trust this information is useful.

Yours faithfully

Mr. Pat Abbott
Planning Advisor
Direct dial 0208 4748011
Direct e-mail pat.abbott@environment-agency.gov.u

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 42302

Received: 20/09/2021

Respondent: Essex Bridleways Association

Representation Summary:

the main issue which appears not to be included is accessibility for all users. We broadly agree with the options, but it is vitally important that ALL user groups are catered for within the green infrastructure particularly, as the usual default option is to cater for walkers and cyclists only. We would ask that equestrians are also included within this default when green infrastructure is considered.
Public rights of way networks and other accessible green infrastructure is frequently fragmented and this Plan needs to be bold and aspirational to enhance the connectivity of existing and new open spaces so that the network becomes a useable active travel option for all users, both for utility and leisure.

Full text:

Please see below our response to the above consultation; an acknowledgement of safe receipt would be appreciated, thank you.

Page 22 Strategic Priority 4 Objective 15: we note the objective and broadly agree with its content; however, we would prefer to see ‘access for all’ embedded into the strategic objectives of the new Plan and this followed throughout the lower levels. We suggest that it is amended to read: 'To protect and enhance leisure, sport, recreation and community facilities and to support the delivery of a fully accessible multi-functional green infrastructure network’.
Page 38 Place-Making Charter for Rochford: whilst we broadly agree with this Charter, we ask that again access for all is embedded within it. We suggest that the fourth bullet point is amended to read: ‘Improve health and wellbeing by encouraging active travel and securing access to multi-functional, connected green and blue spaces, including parks and coastal areas, which is accessible to ALL user groups – walkers, cyclists, equestrians and the less mobile’.
Page 54 Green and Blue Infrastructure: the main issue which appears not to be included is accessibility for all users. We broadly agree with the options, but it is vitally important that ALL user groups are catered for within the green infrastructure particularly, as the usual default option is to cater for walkers and cyclists only. We would ask that equestrians are also included within this default when green infrastructure is considered.
Public rights of way networks and other accessible green infrastructure is frequently fragmented and this Plan needs to be bold and aspirational to enhance the connectivity of existing and new open spaces so that the network becomes a useable active travel option for all users, both for utility and leisure.
Page 58 Open Spaces and Recreation: Similarly, the need for open spaces to include full accessibility is also very important – and where new open spaces are proposed that access for ALL user groups is the default so that equestrians are not omitted.
Page 67 Transport and Connectivity: we are very pleased to see equestrians being included in the transport hierarchy diagram but we are disappointed that further on reference is made to preparing a Local Walking and Cycling Infrastructure Plan to identify further need for improvement. We ask that this is a ‘Sustainable Travel’ Plan which includes all modes of transport – walking, cycling and horse riding (bearing in mind that the Government has confirmed that horse riding is absolutely a form of active travel) otherwise equestrians could lose out on any potential access opportunities on an enhanced network. We suggest that this aspiration is amended to include equestrians.
Potential Site Allocations: we note the various sites that have come forward under the Call for Sites in preparation for this Plan and we are not intending to comment on the suitability or otherwise of specific sites at this stage. We ask though that when a site is considered, any existing public rights of way network is both protected and enhanced, and the opportunity is taken to upgrade footpaths to bridleway status where possible within new developments, thereby ensuring access by walkers, cyclists and equestrians.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 42659

Received: 08/09/2021

Respondent: Mr Ken Wickham

Representation Summary:

Taking the easiest section first Green and Blue Infrastructure , via the RCCT I have along with the CHA ( I am a trustee of the CHA) and Angela Hutchinson raised the current issues of water safety on our rivers. Not only are we really concerned about issues afloat but the now have regard to an asset of the “Coastal Foot Path”. No real thought has been made for those who walk the path for leisure but don’t really realise the dangerous state of some section which are no longer maintained by the Environmental Agency. We have a coastline made up of mainly mud flats and deep inlets, the rivers have a fast flowing currents and are narrow and have areas of deep dangerous mud flats. Many sections are in areas of difficult access by road if there is an incident, being a long way from population areas, some areas don’t have good mobile phone coverage.
I believe there is a 106s Charge for new estates and new builds which concerns developments near to protected areas. I don’t know much about this but I think its been brought into play at South Woodham Ferries on a new estate extension. This looks like a conflict of ideas, in one case give the right to roam, in the other charge for it via the 106 system.
Just looking at one area of the “Green and Blue Infrastructure” it appears the foot path around the RSPB site at Wallasea Island is incorrect, they have made islands by breaching the sea wall in 3 places thus its not as shown continuous? RSPB also are changing policy to start charging for carparking. Thus limiting access to non-member general public, who will pay once but a good percentage won’t pay twice? Access to that area will be heavily restricted and to reach the much advertised and subsidised “Beagle Platform” you will have to pay? Thus “verge parking” like many other access points will be the order of the day. Small villages such as Canewdon, Paglesham, South Fambridge have access to the rivers but no parking. Bus services are no existent. Theory is sound but in practice something has yet to be thought through.

Full text:

Taking the easiest section first Green and Blue Infrastructure , via the RCCT I have along with the CHA ( I am a trustee of the CHA) and Angela Hutchinson raised the current issues of water safety on our rivers. Not only are we really concerned about issues afloat but the now have regard to an asset of the “Coastal Foot Path”. No real thought has been made for those who walk the path for leisure but don’t really realise the dangerous state of some section which are no longer maintained by the Environmental Agency. We have a coastline made up of mainly mud flats and deep inlets, the rivers have a fast flowing currents and are narrow and have areas of deep dangerous mud flats. Many sections are in areas of difficult access by road if there is an incident, being a long way from population areas, some areas don’t have good mobile phone coverage.
I believe there is a 106s Charge for new estates and new builds which concerns developments near to protected areas. I don’t know much about this but I think its been brought into play at South Woodham Ferries on a new estate extension. This looks like a conflict of ideas, in one case give the right to roam, in the other charge for it via the 106 system.
Just looking at one area of the “Green and Blue Infrastructure” it appears the foot path around the RSPB site at Wallasea Island is incorrect, they have made islands by breaching the sea wall in 3 places thus its not as shown continuous? RSPB also are changing policy to start charging for carparking. Thus limiting access to non-member general public, who will pay once but a good percentage won’t pay twice? Access to that area will be heavily restricted and to reach the much advertised and subsidised “Beagle Platform” you will have to pay? Thus “verge parking” like many other access points will be the order of the day. Small villages such as Canewdon, Paglesham, South Fambridge have access to the rivers but no parking. Bus services are no existent. Theory is sound but in practice something has yet to be thought through.

Turning to employment, this would possible be best connected to transport as well. As I said in my reply this area has a net figure of around 75% of the working population moving out for work each day. A census / population study many years ago showed this and the trend has grown. The only hold back is the Covid pandemic factor, but latest TfL figures for use of their systems show we are beginning to migrate back to London with workers.
Thus we have to make available if you are to progress with more housing a good supply of cheap day commuter parking or reliable surface transport to bring you near to the main transport hubs, so people can use the new invigorated transport systems to carry on their journeys. Park and ride would be a boon but not just to town shopping centres but industrial and out of town shopping areas, in many cases over the borders into Basildon, Castle Point and Southend.
We no longer are a growth area of industrial/ commercial concerns. We have in Rochford possibly 2 or 3 main employers of over 150 people , we have very few official business parks for small to medium companies. As said the industrial areas around Cherry Orchard Way were on one side to become a excellence of Avionics or Medical research but that’s gone and its heading for low tech warehousing employing far few. The original proposed “Enterprise Centre” is no more. The Toomey’s site originally was at its western edge designated for small to medium sized units for small companies, no more? Cllr Webster a once leader of RDC said we are coming a dormitory area and that has manifest its self. But for some of the population to get from Wakering to the Fairglen Intersection can take over an hour in the commuter rush. To get from the never ending of proposed expansion of Canewdon, it takes some 25 mins to get into the stations of Hockley and Rochford, with very limited cheap parking on arrival.
Many years ago, we as the FSB, were asked to comment on many proposals and to suggest our own. Sadly the strength of the various Business Representative Organisations has gone. But I am glad to see at least one of my suggestions placed at that time for a new commercial park has been taken up of late and placed at the junctions of the A127 and A130, this leads to further developing an area each side of the old A130 and A127 which is on the fringe of the residential area stopping heavy transport entering our area. But we still have areas such as Foulness, Baltic Wharf, Shoeburyness and the airport needing a sensible routing to their destinations for heavy lorries. The route to the hopefully expanding Baltic Wharf needs desperate up grading throughout. The number of movements per day on just this section makes this a real safety issue as well as it’s the same route an anticipated 100,000pa visitors to the RSPB site. The route at this moment suggested uses one of the most congested roads in the area Ashingdon Road, passes 4 schools and its proposed additional housing developments feeding into it. It crosses 5 roundabouts to get down to the A127. You can’t widen it, playing with roundabouts and junction is a short term cheap fix.

Additional mass housing or just infills just brings more issues as many have discussed and this become an endless discussion on infrastructure. Using out of town experts is not always the answer, they may have grand plans and have used them else where but they don’t understand the demographics of the locality.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 42716

Received: 09/09/2021

Respondent: Emma Mountain

Representation Summary:

CFS216

I thought the first site was on Coastal Protection Belt and shouldn’t be built on? As agricultural land it has been successfully farmed since anyone can remember.
Building on this land would ruin the visual amenity of the area.

Full text:

CFS216/CFS133 promoted sites
I’ve found the website/links a bit tricky to navigate so I’m hoping that I can e mail my objections to the above promoted sites?

I thought the first site was on Coastal Protection Belt and shouldn’t be built on? As agricultural land it has been successfully farmed since anyone can remember.
Building on this land would ruin the visual amenity of the area. The school has always been semi-rural and this proposed development site would ruin that.

It would also cause issues with traffic at an already busy and dangerous junction that is subject to discussion already.

The second site is opposite the school (CFS133) has again been successfully farmed for years, and regularly floods at the bottom. This again is an inappropriate location, again ruining the visual amenity of the area, would again compromise the planning framework for urban sprawl.

For both sites, in terms of transport, there is an overloaded Roman Road with a dangerous junction, speeding drivers with a previous serious accident site too. Adding another road junction in there is unsafe. There are no cycle paths or means to incorporate one. The pavements remain to be overgrown and have been for the last 40+ years, narrowing to a ridiculous point which remains dangerous for the children walking to school. Today I witnessed a lady with a pushchair having to cut back over growing brambles etc to be able to walk past safely.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 42941

Received: 10/09/2021

Respondent: Ms Deborah Mercer

Representation Summary:

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 (i.e. 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.

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: 43171

Received: 14/09/2021

Respondent: Hullbridge Parish Council

Representation Summary:

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.

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: 43275

Received: 13/09/2021

Respondent: Mrs Ane Bates

Representation Summary:

. In your 20 year plan I would like you to consider:

-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

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: 43282

Received: 27/09/2021

Respondent: Natural England

Representation Summary:

IIA Theme – Health and Wellbeing
Natural England’s previous consultation response recommended the adjustment of the Appraisal
Question “Enhance multifunctional green infrastructure networks throughout the plan area?” by
adding a reference to neighbouring authority areas. The amended wording would be:
“Enhance multifunctional green infrastructure networks throughout the plan area and neighbouring
authority areas?”
This adjustment is still considered advisable as green infrastructure networks may well involve land
that extends beyond the District boundary and restricting the provision to the District boundary
could exclude the scope for landscape scale provision. This could be particularly important given
the location of some of the growth options now being considered. It is of note that the
recommended adjustment to the appraisal question was made in the Final Scoping report dated
March 2017.
There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question
features in the “Climate Change” theme, it would still be a relevant consideration in assessing the
extent to which a proposal meets the Health and Wellbeing IIA Objective.
Lastly it may be worth reviewing the recently published Essex Green Infrastructure Strategy 2020
as this could provide a relevant addition to the evidence base for this aspect of the emerging Local
Plan.

Full text:

Dear Strategic Planning Team

Rochford District Council New Local Plan Spatial Options document consultation

Thank you for your consultation on the above dated 28 July 2021 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

The following comments are principally focussed on the Integrated Impact Assessment that accompanies the Spatial Options document. They also reflect Natural England’s response to the previous consultation on the Draft Sustainability Appraisal Scoping Report (our letter dated 31 January 2017, reference 204441).

IIA Theme – Health and Wellbeing

Natural England’s previous consultation response recommended the adjustment of the Appraisal
Question “Enhance multifunctional green infrastructure networks throughout the plan area?” by adding a reference to neighbouring authority areas. The amended wording would be:

“Enhance multifunctional green infrastructure networks throughout the plan area and neighbouring authority areas?”

This adjustment is still considered advisable as green infrastructure networks may well involve land that extends beyond the District boundary and restricting the provision to the District boundary could exclude the scope for landscape scale provision. This could be particularly important given the location of some of the growth options now being considered. It is of note that the recommended adjustment to the appraisal question was made in the Final Scoping report dated March 2017.

There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question features in the “Climate Change” theme, it would still be a relevant consideration in assessing the extent to which a proposal meets the Health and Wellbeing IIA Objective.

Lastly it may be worth reviewing the recently published Essex Green Infrastructure Strategy 2020 as this could provide a relevant addition to the evidence base for this aspect of the emerging Local Plan.

IIA Theme – Landscape

Natural England supports the inclusion of an appraisal question that considers the relationship and potential impact of any option/proposal on existing areas of tranquillity.

IIA Theme – Climate Change

As in its previous response, Natural England recommends the addition of an appraisal question
which will ensure that options are considered in terms of their compatibility with the Essex and Suffolk Shoreline Management Plan which is specifically referenced in the Spatial Options document. The following wording is suggested for the appraisal question:

“Support the priorities identified in the Essex and Suffolk Shoreline Management Plan?”

IIA Theme – Biodiversity

Paragraph 179 of the NPPF (Habitats and Biodiversity) is directly relevant to this particular theme and should be referenced and adjustments are recommended to the appraisal questions to better reflect the NPPF policy advice in that paragraph.
As indicated in our previous response, Natural England would advise that specific reference is made to nationally or locally protected sites. In addition, in light of the updated NPPF text, there will be an increased emphasis on the delivery of biodiversity net gain. The following wording is suggested for the first appraisal question:

“Avoid, or if not possible, minimise impacts on biodiversity, nationally or locally protected sites, and
pursue opportunities for securing net gains for biodiversity?”

We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.

For any queries regarding this letter, for new consultations, or to provide further information on this
consultation please send your correspondences to consultations@naturalengland.org.uk.

Yours sincerely

Tessa Lambert
Lead Adviser – Land Use Planning
West Anglia Area Team

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43324

Received: 28/09/2021

Respondent: Hawkwell Parish Council

Representation Summary:

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.

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: 43490

Received: 20/09/2021

Respondent: Mr David Butcher

Number of people: 2

Representation Summary:

We understand that in the previous plans for development - Allocates DPD Reg. 25 it was stated that there would be public parkland providing a buffer between the built development and the A1245, but this proposal shows large areas, probably containing over 1000 dwellings right up to the A1245.

Full text:

Dear Sirs

We have looked at the proposed sites for development and are concerned that it seems as though Rayleigh will be at least a third bigger than it is presently, with, we guess if recent developments are anything to go by, few properties that first time buyers like our grandchildren would be able to afford.

Surely it would be better to build new developments away from existing towns and villages with new facilities purpose built for the amount of dwellings rather than stretching the resources which are already not coping with demand.

As there are constant traffic jams through the centre of Rayleigh particularly bad at peak times earning it the dubious reputation of having extremely bad air quality it makes us fearful of the health of Rayleigh residents if this development was to take place.

We understand that in the previous plans for development - Allocates DPD Reg. 25 it was stated that there would be public parkland providing a buffer between the built development and the A1245, but this proposal shows large areas, probably containing over 1000 dwellings right up to the A1245.

We fail to see how these proposals would enhance or conserve the natural and historic environment. Indeed, we feel that once dwellings are built near to them it would have the opposite effect of encroaching on them and eventually swallowing them up. Hence we do not support the demolition of The Mill, a recreational building, for more apartment blocks.

it would be very unlikely that the residents of these developments would bring new life to the High Street and other existing commercial properties as the queues of traffic to get into the town and parking fees would make the choice of shopping in out of town where parking is free would be much more attractive.

We both agree that Rayleigh is a lovely town but are becoming increasingly frustrated with the amount of traffic that runs through it (particularly if there is trouble on the A127 when it becomes a 'rat run'). Recent development has not enhanced the High Street apart from encouraging new eating places. Please don't let it be destroyed forever!

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43589

Received: 20/09/2021

Respondent: Hullbridge Residents Association

Number of people: 17

Representation Summary:

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

Full text:

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

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

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

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

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

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

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


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

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

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

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

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

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

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


Stakeholder Ref: CP15678E Community Representative Ref: 29007


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

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

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

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

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

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

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


Stakeholder Ref: CP15678E Community Representative Ref: 29007

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


Stakeholder Ref: CP15678E Community Representative Ref: 29007

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

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

Brownfield and Greenfield land.

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

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

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

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

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


Stakeholder Ref: CP15678E Community Representative Ref: 29007

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


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

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

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

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

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



Stakeholder Ref: CP15678E Community Representative Ref: 29007


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

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

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

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

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


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

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

Stakeholder Ref: CP15678E Community Representative Ref: 29007


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

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

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

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

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

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

Stakeholder Ref: CP15678E Community Representative Ref: 29007

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

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

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

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

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


End of Appeal For Withdrawal.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43721

Received: 23/09/2021

Respondent: Mr K W Meeks

Representation Summary:

There was a statement made in the past by Rochford council there you intended to keep a green buffer between Rochford's towns, now you appear to plan to build on green belt, regardless of what you designate it, and even on some of Hockley woods, again to the detriment of everyone's environment.

Full text:

[re all sites, but in particularly CFS098, 053 & 027]

I object in the strongest terms to ALL the proposals in your spatial plan.

There is insufficient infrastructure in existence to support the huge increase in housing that you suggest, even the housing that been built over the last few years, e.g. Hall Road area, which apparently included schooling, medical and shopping but was allowed to be built without any of them due to builders being allowed to get around not being made to include them. There was no improvement to road access either.

Our roads are already congested with grid lock often being achieved in and around our town centres. The condition of our road reflects their overusage.

Our doctors' surgeries and local hospitals are already over loaded, it is hugely difficult to get an appointment and our schools appear to be full.

There was a statement made in the past by Rochford council there you intended to keep a green buffer between Rochford's towns, now you appear to plan to build on green belt, regardless of what you designate it, and even on some of Hockley woods, again to the detriment of everyone's environment. ]]You seem intent on blindly following the government demands, which are now under review, and have no interest in improving the area to the benefit of your current residents without adding additional housing. Rochford council seems to have a mercenary and blinkered approach to residents, in spite of actually putting out this plan for public opinion.

With specific interest to myself and references CFS098, CFS053 and CFS027 you have wrongly designated this land as non-flooding which wrong. I live in Nelson Road and believe the source of the Prittle Brook to be between the ends of the gardens and the fields there. We back onto the field and we have slow worms in our gardens and any building works in those fields could damage their protected environment.

It is a shame that you have made the information available on line difficult to read, negotiate and understand even for those who are computer literate.

With respect to the plans for the Mill Hall, the actual construction of the building originally contravened the laws regarding ancient monuments and unless you actually knocked it all down to restore the site to what it was originally, prior to any building, then any new building would cause further damage to that ancient site.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43810

Received: 02/09/2021

Respondent: Ms G Yeadell

Representation Summary:

Proposals are acceptable, but shouldn't be used as excuse for developers to grab existing/homes/gardens.

Full text:

NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION PAPER: 2021

Rochford in 2021- District Profile p.12
Our Social Characteristics

Rochford expected to shift to higher age groups. Housing affordability is an important issue. "..economically active individuals likely to decrease..fewer residents between ages 18-70..".

This is due to :-

Sale of Council houses, by Government dictat in 1980s. Said homes were for 2 classes: 1. Families who could never afford own homes; 2. Families unable to afford initially, but with cheap rent, could ultimately save deposit to buy own home.

Developers don't want to build "affordable", but have built eg luxury flats and "executive" mansions bought by "nouveau riches", usually middle aged, whose children long grown up and moved on. Thus unwealthy economic age groups with their children had to move to more affordable districts, hence current and possibly future age imbalance.

Many homes have been demolished to accommodate above expensive dwelling dwellings. Wealthy Londoners have sold up and moved to eg Rochford District to buy similar for less.

Cultural Characteristics

Most of them noted in Rayleigh and Rochford. But there are listed and heritage building in Hockley and Hawkwell and Ashingdon. There are the 3 mediaeval churches also. Many heritage items in said area have been demolished to accommodate flats and expensive homes. an example was at 1 Southens Road, formerly Blacks Farm, earliest from 17th century, on Local List. Developer planned replacement with flats: a former official at Planning Policy said Government now "frowned on" Local List. (Other councils claimed no knowledge of said Government dictat and didn't plan to abolish their Local List.) Plan for 13 flats was refused but no mention made of the house, demolition of which was included in application. Once house was demolished, said officer said Government now approved of Local Lists. New List omits several Hockley items on the earlier one. Many Hockley area heritage items have gone same way.

Environmental Characteristics

As you say 40% of Rochford area is at flood threat and the coastline also. This would preclude the area so designated as unsuitable for further development. It is known that insurance companies refuse to include cover against flood risk for homes in flood risk areas.

Economic Characteristics

The 2 main rail lines from Southend to London, one passing through Rochford District, are helpful for commuter traffic to London and for cargo purposes. It is risky that some airlines have withdrawn from Southend Airport. The nuclear station at Bradwell could be more of a risk than asset. Present road connections have served well in the past, but are getting inadequate now and won't support extensive future development.

Draft Strategic Priorities/Objectives for 2050 p.21

Strategic Priority 1: Meeting need for homes/jobs in the area

This states need to meet community need, working with South Essex neighbours, using already developed land first.

But increasingly, Londoners eg are selling for high prices and getting similar or bigger, for less, down here - eg new development in Hall Road (former agricultural land).

South Essex neighbours - be careful how much of their housing number needs aren't pushed into Rochford District.

Prioritising use of previously developed land first. Example - so-called "garden grab" - homes not in Green Belt have been called "land". Where two or three are adjacent - they are grabbed for "executive" houses (mansions), or luxury flats, others finally forced to move for price needing mortgage to move, when they don't want anyway. Others not moving are punished with 'executive' (big) development may be south of them - impacting them, so they become unviable.

Strategic Objective 2

"affordability" - as elsewhere, council houses were sold off in 1980s under "Right to Buy". Developers don't want to do affordable - one told me that at a meeting. Those builders with large estates to develop (requiring a percentage 'affordable') try to evade the rules, perhaps saying more than one firm involved.

"ageing population" - care homes are costly, the old don't want them. If pressured, their homes are sold off to pay for them.

Strategic objective 4

"accelerated growth" - avoid over-substantial Area Action Plans threatening retail centres - with jobs and businesses then lost. Southend Airport may struggle to survive from impact of Covid.

Strategy Options

Hierarchy of Settlements

Re Fig.14, Hockley is equivalent to Hawkwell and Ashingdon - village. Rochford is a market town.

Growth scenarios

Before any substantial growth can occur, a new motorway would be needed for Rochford District to overcome inevitable inadequacies of eg. Southend, Main, Greennward, Ashingdon and other B and C roads, which is doubtful unless a new large settlement occurs in Green Belt for most new housing-? behind Rpchford, to cross River Crouch somewhere near Hullbridge - unlikely and probably not tolerated by staff or residents.

Masterplan for towns etc centres - eg Hockley Area Action Plan more than a decade ago, involving replacement of some existing and erecting large supermarket and may be major store (? Unneeded with on-line shopping). Plan would have involved loss of businesses, jobs. It was unacceptable to traders and residents - a more limited HAAP was agreed.

Significant new community facilities - schools, primary care. These have been promised by developers of large estates, who then found excuses for not doing.

Re 'Important Note' - I'm relieved proposals aren't decided. Much gone already.

Planning for housing growth

HELLA 2020 identifies supply of 4,300 homes planned for, including sites with planning permission. Unfortunately some such have been overcome by huge mansion developments adjacently.

Planning for economic and retail growth

Completed Area Action Plans have provided enough retail space.

Levels of growth needed to deliver infrastructure

Section 106 doesn't always work. As earlier, huge new estate in hall Road (for which farming land sacrificed) developer promised new primary school, GP surgery, then found reasons not to do, causing pressure on existing.

Spatial Strategy Options

1. Urban intensification

There is no available space in any centres near stations. First issue of HAAP proposed building on parking area near Hockley Station, which would have been a mistake and didn't happen. Any intensification done already has often sacrificed existing dwellings, sometimes of heritage character. Others would be threatened. Blocks of flats have done likewise. Another proposal for latter is underway in Southend Road, Hockley, with potential disastrous results for many adjacent homes and would exacerbate a serious traffic problem.

2. Urban extension Would sacrifice Green Belt

Option 4

Your comments at CONS say it all.

Owners of house/garden, to protect themselves from building predators, obtained consent for 2 small homes additionally to their own - just resulted in massive adjacent demolition, replaced by huge dwellings, removing daylight and making light pollution.

Q6 and 7 I cannot agree to any of the 4. Only solution is small dwellings added to properties with large curtilages. This could still give problems re traffic access, neighbour resistance. problem is developers don't want "affordable", only mass demolition replaced by huge "executive" houses, block of luxury flats, making neighbours unviable. Mass sale of council houses -Right to Buy- 1980s was unfortunate.

Climate change and resilient environments

Development agreed in our district must be very limited due to flood risk and existing, expected coastal change.

Green Belt and heritage sites and homes/gardens need largely to be protected from Development. In fact, seeing your Diagram page 36, Rochford District can't accommodate substantial development/redevelopment even with need to provide co-operation needs of nearby districts. (one does realise big new buildings bring more council rates).

As earlier, companies won't five flood insurance in flood risk areas.

One agrees new development should provide energy from carbon neutral/renewable sources, but it's costly and in early stages. Those with gas heating feel threatened. Car reliance is unlikely to be reduced, but also electric cars instead of petrol driven will need plenty of energy-providing points in centres and elsewhere.

Place-making and design Q14-16

It would be very difficult, knowing developer wishes (and need for council rates to come from somewhere), but a design guide if possible, should now exclude further development of executive mansions, luxury flats, especially as Government now requires more affordable homes.

We need to exclude development involving further demolition of existing dwellings, replace by mansions, multi-storeyed units out of height/area with locale, causing daylight loss and night-time light pollution and outside incomes of most locale.

Housing for all

Lack of homes for locals. As before, developers erect executive houses, sometimes in big estates. Local families can't afford, but they are bought by eg Londoners who sell theirs for high prices and buy big ones here for less.

It could be said, in the past young adults lived with their parents, paying their "keep" towards household costs, because they couldn't afford to buy. They only left home on:- marriage, or getting a better paid job elsewhere.

Surely these problems need sorting as housing still "locally driven". Locals cannot afford and there is limited council housing, why they leave the district to find homes they can afford.

It's stated SHMA paper outline need for smaller dwellings, but recognises size is market driven. Developers build mansions for nouveau riches - normally middle-aged, their children grown up and have left. Difficult to change that.

Rented housing - "families with children who cannot afford to buy..ineligible for social housing" (?why). Reverts to social housing lost to Right to Buy of 1980s.

Need for affordable housing

Council housing (largely sold off as above). There are also homes acquired by housing associations charging social rent. it isn't true gardens are sold for inflated sums. Persons with home and garden are often pressured by developers to eave and get demolished for sums that they'd need mortgage in order to move. Developers charge inflated sums to erect outsized houses.

Employment and Jobs

Doubtful. Southend Council demolished much of Victoria avenue, replaced with office buildings c.1970s, may be in expectation of business chances arising from Britain joining European Union. Some firms, such as C E Heath, Norwich Union, opened up there. But it didn't last - both moved away, others likewise. Avenue is now largely re-residential.

Southend Airport was expected to thrive. But recent pandemic caused several airlines to move away.

Traditionally, office staff in S E Essex have commuted to the City and elsewhere in London to work. Arrival of new technology was expected to do away with most office and factory workers. Executive staff would work from home on computer, occasionally attending head office. But commuter trains to London continued to be packed since. Briefly pandemic led people to work from home, but this isn't lasting. Some are again commuting.

Employment land, Eldon way, Hockley was allocated by HAAP but results are limited apparently.

Future of Southend Airport

Probably restricted by loss of airlines, due to effects of pandemic. Further expansion in activity difficult to foresee, due to effect on local community of noise, night flights etc - the photo on p.50 in Spatial Options Local Plan issue shows how vast an area of housing is already affected, without further extension.

Biodiversity As side comment, Hockley isn't an "urban area" - on Wikkipedia it's a large village.

Qu.29-30 I agree in Local Plan wildlife Review. There are some protected species residing in some private gardens. These should be protected under the system. If some neighbours find them a nuisance, it could be explained to them how their boundaries can be safeguarded. However, while some resent eg their lawns dug into by creatures, some so-described objections arise from developer designs on other's properties, as transfer of protected species involves getting licence from DEFRA - complicated and expensive. They are determined to get the ground, regardless of owners' wishes, but don't want complications - they've been known to attack setts.

Green/Blue Infrastructure

Proposals are acceptable, but shouldn't be used as excuse for developers to grab existing/homes/gardens.

Q.35-37

Education As earlier, proof exists where developers of gigantic expensive estates have promised new school, surgery. When estate practically built, they said eg 2 builders involved, so failed to meet promises. result - school c.3 miles away has to take pupils from new estate. Developers of big 'executive' estates must be made in advance to provide, or be denied plan consent.

Healthcare Side comment - I'm concerned by your view of future GP clinics - no appointments, just on-line digital consultations. GP appointments are curtailed to eg phone ones during pandemic, just to avoid infection. This is ok sometimes, but other times impractical. Not all have computers by the way.

Early years/childcare There are plenty of nurseries, but private. I don't know how sate funding can be provided.

Secondary education Where shown this is already full locally, builders for big estates could combine to contribute additionally, if space can be found, or else contribute to extend existing, if area available.

Further education Locally provided by Southend branch of Essex University and other universities over UK. But may be builders of large estates could contribute to a national fund for this use.

Community, Open Spaces One can only suggest big developers contribute likewise and/or designate some of their land, if available.

Heritage

Q43-45 I fear heritage in Rochford has been somewhat selective. Several items in Hockley have been demolished, some in fact of widespread opposition. Your article in Spatial Options sets out straightaway with items presumably to be kept in Rayleigh/Rochford. Recent uproar over plan to remove Mill House has led to the matter going under review.

As earlier, plan to demolish 1 Southend Road for flats caused widespread rage (details earlier). Hockley councillor had flats refused, but nil said re the house, down for demolition on proposal.

It was on the Local List, so Plan Policy official said Government didn't approve that, so Rochford's was abolished. Once house demolished, officer said Government changed its mind. New Local List omitted some Hockley items on it earlier. spa pump house now on national list. May be St Peter & Paul church and Bull pub are listed. Others could be added to Local one, eg Hockley Cottage Southend Road, China Cottage Spa Road. Other items are demolished: Kent View Cottage, 2 Victorian Houses Southend Road, Manor at Plumberow, 17C house and forge opposite entry to Hockley woods.

Town centres and retail

Plan Objectives

"..retail - dominant town centre..struggling in light of on-going structural changes..in high streets/centres". On-line shopping has caused closure of eg clothing stores in towns, accelerated by pandemic. But, eg Hockley centre continues to provide basis needs successfully. Attempt to change it by original HAAP was unsuccessful.

If developers want to introduce residential in addition, it must not be at expense of businesses and be preferably 2 storey, not to threaten nearby low level dwellings.

[Figures 8, 25 and others eg 31-5 make clear Rochford District not suitable for drastic residential increase on grounds of flood risk particularly.]

Using Class E, allowing transfer from retail to residential without planning permission must not be allowed to threaten retail and not everyone has a car to do retail shopping elsewhere.

Q.46-50 Hockley Centre and its environs does not have space to provide additional facilities, residential (except as above) etc. You couldn't put a new supermarket in Eldon way, off the main road, and we have enough provision now. There are 1 or 2 stores in Southend Road, but remainder is residential, mostly 1 or 2 storey and basic needs shopping is adequate in the centre, food, hairdressing, ETC. Larger items, such as clothes, shoes, apart from on-line, people just bus to Southend. Hockley isn't big enough for more.

Transport and connectivity

"National Planning Policy states transport issues should be considered from the earliest stages of plan-making, so the impacts of development on transport networks can be addressed".

That is exactly the local problem. over-enthusiastic profiteering developers have been allowed forward, with often huge estates, without a major district motorway having been formulated and inserted first. Local main roads, particularly in Rochford District - an agricultural area - are former narrow, winding country lanes, later tarmacked over for motor traffic. I think Southend Council planned at one time for access from rear of Shoebury to reach the Crouch, traversing green belt area behind Rochford. Understandably I believe Rochford didn't agree.

Suggestion has been made for one huge development centre, served by one new motorway through green belt, but probably impractical in this rural, flood risk area and rising sea levels

Walking and cycling in preference to private car are excellent for leisure and short distance basic needs, but not eg commuting to work nor eg weekly shopping for families.

Bus services have suffered from increased private car use by middle classes, especially Nos. 7 and 8. Arrival of costly new estates are unlikely to change that.

Maps with your plan show how much of the district is flood threatened, including rising sea level. So I can't see answer to travel needs and extensive new development foreseen in plan.

Green Belt - Rural Issues

Q.54 Rural exception sites. Developers have said they don't want to do affordable. (One told me that at a meeting).

Planning for Complete Communities

Description of centres is accurate. But one must accept that provision for new motorways is largely out of the question. The main roads that have been suitable in the past cannot cope with endless new development and its attendant motor traffic - as earlier, main B C roads in district are former narrow winding country lanes, later tarmacked for motors. But motorway to any large new centre would contend with c.50% flood risk, rising sea levels and the district still has land in agricultural use.

Stonebridge and Sutton might possibly provide a substantial amount of new housing, judging only from the map, but provision of a new motorway (through where) seems doubtful.

Hockley and Hawkwell - housing availability and affordability "a key issue" - due to several problems.

Its services were adequate for its needs. But, as elsewhere in Rochford and UK, and as I wrote earlier, council houses designed for those of limited means were sold under Right to Buy (I believe this arrangement is now abolished). Also, as earlier, a new motorway would be needed, not possible.

Also, possibly attracted by convenience of rail line to London, this area has recently attracted wealthy residents from London and elsewhere. Modest homes/gardens have been demolished, replaces by mansions and blocks of flats. So, middle and low income families have been driven out to wherever they can afford, to be replaced by rich middle-aged. Elsewhere in the district large estates of expensive homes have been erected, presumably with the same results. Some driven out have been paid sums needing a mortgage in order to move. Developers don't expect to pay notable sums for "land" (including others' homes).

Mainly, only available land for building is Green Belt or "flood risk", not suitable.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43844

Received: 19/09/2021

Respondent: Mrs Barbara J Oliver

Representation Summary:

In Local Development Framework - Allocations DPD Reg.25, it was stated that there would be 'public park land providing a buffer between the built environment and A1245'. Proposed sites (CFS146 and CFS147) show proposals right up to the A1245, which if joined to the existing development would most likely add at least another 1000 dwelling to an already over populated and under infra-structured area.

With the number and size of the sites shown as Rayleigh and Rawreth proposed sites map, it is difficult to see how the natural and historic environment can be 'conserved or enhanced'.

Full text:

Draft Local Plan

I would like to make some observations about the above for consideration.

1. Judging by the map showing proposed sites for development, Rayleigh appears to be ringed on all sides, more building making it into a very large town which cannot cope with what is already happening, let along any more. The people of Rayleigh have strong ties with other towns and cities, including London, but we have no wish to become part of an area as large as a city, or to be joined to these other towns. As I'm sure they'll feel the same.

2. Before any further development is even considered the infrastructure must be looked at carefully. Any traffic or road survey must also be carried out at 'busy times' to reflect the enormity of the traffic problem already existing in the Rayleigh area.

3. This map shows far more development than was agreed in the previous plans. In Local Development Framework - Allocations DPD Reg.25, it was stated that there would be 'public park land providing a buffer between the built environment and A1245'. Proposed sites (CFS146 and CFS147) show proposals right up to the A1245, which if joined to the existing development would most likely add at least another 1000 dwelling to an already over populated and under infra-structured area.

4. With the number and size of the sites shown as Rayleigh and Rawreth proposed sites map, it is difficult to see how the natural and historic environment can be 'conserved or enhanced'.

5. Rayleigh is already a town that at times is gridlocked, it is often used as an extra road to Southend when the A127 is blocked by frequent hold ups, (Sunday 19th September is a one) adding more development will just increase the frequency of this happening.

6. Building dwellings in the middle of the town and reducing the facilities is not the answer to the need for housing. In fact how many of the recent proposal would be of a price to attract first or young buyers? Some of this land is very close to listed buildings and a scheduled ancient monument which would undoubtedly suffer if surrounded by dwellings. How long would it be before the residents became upset by noise from these facilities and then they are closed down? These are part of the heritage of Rayleigh and should be preserved along with the Mill Hall.

7. Having large conurbations of housing on the edge of any town does not mean that the business (money) will be brought into the town centre, in fact money will most likely go to large shopping malls and the town centre will die, as has been witnessed in a number of towns in the midlands. Does the local authority really wish the towns of this country to resemble the towns of the USA? We need to preserve our heritage.

8. I believe there is a place for a separate development, such as a garden village which could be built with its own infrastructure.

I do not think it is sensible to live in the past but it is important to look after this country and preserve its character, which after all also attracts visitors and brings in revenue.

I hope you will take these observations into consideration when making any decisions.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43845

Received: 19/09/2021

Respondent: Mrs Barbara J Oliver

Representation Summary:

In Local Development Framework - Allocations DPD Reg.25, it was stated that there would be 'public park land providing a buffer between the built environment and A1245'. Proposed sites (CFS146 and CFS147) show proposals right up to the A1245, which if joined to the existing development would most likely add at least another 1000 dwelling to an already over populated and under infra-structured area.

With the number and size of the sites shown as Rayleigh and Rawreth proposed sites map, it is difficult to see how the natural and historic environment can be 'conserved or enhanced'.

Full text:

Draft Local Plan

I would like to make some observations about the above for consideration.

1. Judging by the map showing proposed sites for development, Rayleigh appears to be ringed on all sides, more building making it into a very large town which cannot cope with what is already happening, let along any more. The people of Rayleigh have strong ties with other towns and cities, including London, but we have no wish to become part of an area as large as a city, or to be joined to these other towns. As I'm sure they'll feel the same.

2. Before any further development is even considered the infrastructure must be looked at carefully. Any traffic or road survey must also be carried out at 'busy times' to reflect the enormity of the traffic problem already existing in the Rayleigh area.

3. This map shows far more development than was agreed in the previous plans. In Local Development Framework - Allocations DPD Reg.25, it was stated that there would be 'public park land providing a buffer between the built environment and A1245'. Proposed sites (CFS146 and CFS147) show proposals right up to the A1245, which if joined to the existing development would most likely add at least another 1000 dwelling to an already over populated and under infra-structured area.

4. With the number and size of the sites shown as Rayleigh and Rawreth proposed sites map, it is difficult to see how the natural and historic environment can be 'conserved or enhanced'.

5. Rayleigh is already a town that at times is gridlocked, it is often used as an extra road to Southend when the A127 is blocked by frequent hold ups, (Sunday 19th September is a one) adding more development will just increase the frequency of this happening.

6. Building dwellings in the middle of the town and reducing the facilities is not the answer to the need for housing. In fact how many of the recent proposal would be of a price to attract first or young buyers? Some of this land is very close to listed buildings and a scheduled ancient monument which would undoubtedly suffer if surrounded by dwellings. How long would it be before the residents became upset by noise from these facilities and then they are closed down? These are part of the heritage of Rayleigh and should be preserved along with the Mill Hall.

7. Having large conurbations of housing on the edge of any town does not mean that the business (money) will be brought into the town centre, in fact money will most likely go to large shopping malls and the town centre will die, as has been witnessed in a number of towns in the midlands. Does the local authority really wish the towns of this country to resemble the towns of the USA? We need to preserve our heritage.

8. I believe there is a place for a separate development, such as a garden village which could be built with its own infrastructure.

I do not think it is sensible to live in the past but it is important to look after this country and preserve its character, which after all also attracts visitors and brings in revenue.

I hope you will take these observations into consideration when making any decisions.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43846

Received: 19/09/2021

Respondent: Mrs Barbara J Oliver

Representation Summary:

In Local Development Framework - Allocations DPD Reg.25, it was stated that there would be 'public park land providing a buffer between the built environment and A1245'. Proposed sites (CFS146 and CFS147) show proposals right up to the A1245, which if joined to the existing development would most likely add at least another 1000 dwelling to an already over populated and under infra-structured area.

With the number and size of the sites shown as Rayleigh and Rawreth proposed sites map, it is difficult to see how the natural and historic environment can be 'conserved or enhanced'.

Full text:

Draft Local Plan

I would like to make some observations about the above for consideration.

1. Judging by the map showing proposed sites for development, Rayleigh appears to be ringed on all sides, more building making it into a very large town which cannot cope with what is already happening, let along any more. The people of Rayleigh have strong ties with other towns and cities, including London, but we have no wish to become part of an area as large as a city, or to be joined to these other towns. As I'm sure they'll feel the same.

2. Before any further development is even considered the infrastructure must be looked at carefully. Any traffic or road survey must also be carried out at 'busy times' to reflect the enormity of the traffic problem already existing in the Rayleigh area.

3. This map shows far more development than was agreed in the previous plans. In Local Development Framework - Allocations DPD Reg.25, it was stated that there would be 'public park land providing a buffer between the built environment and A1245'. Proposed sites (CFS146 and CFS147) show proposals right up to the A1245, which if joined to the existing development would most likely add at least another 1000 dwelling to an already over populated and under infra-structured area.

4. With the number and size of the sites shown as Rayleigh and Rawreth proposed sites map, it is difficult to see how the natural and historic environment can be 'conserved or enhanced'.

5. Rayleigh is already a town that at times is gridlocked, it is often used as an extra road to Southend when the A127 is blocked by frequent hold ups, (Sunday 19th September is a one) adding more development will just increase the frequency of this happening.

6. Building dwellings in the middle of the town and reducing the facilities is not the answer to the need for housing. In fact how many of the recent proposal would be of a price to attract first or young buyers? Some of this land is very close to listed buildings and a scheduled ancient monument which would undoubtedly suffer if surrounded by dwellings. How long would it be before the residents became upset by noise from these facilities and then they are closed down? These are part of the heritage of Rayleigh and should be preserved along with the Mill Hall.

7. Having large conurbations of housing on the edge of any town does not mean that the business (money) will be brought into the town centre, in fact money will most likely go to large shopping malls and the town centre will die, as has been witnessed in a number of towns in the midlands. Does the local authority really wish the towns of this country to resemble the towns of the USA? We need to preserve our heritage.

8. I believe there is a place for a separate development, such as a garden village which could be built with its own infrastructure.

I do not think it is sensible to live in the past but it is important to look after this country and preserve its character, which after all also attracts visitors and brings in revenue.

I hope you will take these observations into consideration when making any decisions.

Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 43952

Received: 20/09/2021

Respondent: Kay Chesterfield

Representation Summary:

nvironmentally it's a disaster, this is a hunting ground for bats and owls. The hedgerows and fields provide food and shelter for birds, bees and other wildlife which are all essential for our survival.

Already we see hedgehogs killed on the road by speeding vehicles without a care for wildlife or people's lives. Pollution is already at too high a level.

We are supposed to be trying to halt climate change by planting trees. You intend ripping them up and destroying rural vegetation which absorbs CO2 and H2O, so preventing flooding too.

Full text:

I object to future planning for the reasons given below:

This is Wakering village not the London Borough of Wakering. Already there is too much development which the local shops, school, doctors cannot support and the volume of traffic is already excessive.


Environmentally it's a disaster, this is a hunting ground for bats and owls. The hedgerows and fields provide food and shelter for birds, bees and other wildlife which are all essential for our survival.

Already we see hedgehogs killed on the road by speeding vehicles without a care for wildlife or people's lives. Pollution is already at too high a level.

We are supposed to be trying to halt climate change by planting trees. You intend ripping them up and destroying rural vegetation which absorbs CO2 and H2O, so preventing flooding too.

There will not be enough food in the future we are told, so stop building on farmland. Build on brownfield sites, make more use of existing buildings.

Where am I supposed to live when I value a rural life - I am being pushed out by housing the hordes of people who care not of others or their environment.