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

I do not think the local towns and villages can sustain any more housing,the area is totally gridlocked at present the roads cannot cope with the volume of cars at present let alone adding more housing to the area.
Southend hospital is overwhelmed as are the doctor surgerys and schools,infrastructure must be addressed before any more homes are built,and not just a couple of new roundabouts as we have seen done in Hullbridge.
I have lived in Hullbridge since 1962 and am using the same roads as of then to enter and exit the village the amount of cars on the narrow old roads cannot cope anymore,also the amount of gas and water leaks on these roads lately from high volumes of traffic and heavy lorries is ridiculous .
Hullbridge has endured nearly 4 years of traffic lights,dust,noise and disruption from all the new housing estates in the area it is not fair on the local residents in the area enough is enough !!!!
I appreciate the need for more housing but do not see affordable housing at present with houses being sold at £400,00 plus,the only winners at present are the large building firms such as Barretts etc.
A whole new town needs to be built such as we had before like Basildon and south Woodham,where shops ,doctors and services are put into place to service the expanding population,unlike as is happening at present where 500 plus homes attached to existing towns with nothing more than a new roundabout is put in to service the area.
Rochford council is appalling in their handling of the housing being allowed at present without sorting the bigger problems out that the area has,any car journey is taking twice as long nowadays and to get a hospital or doctors appointment is getting longer by the day.
The whole area has reached saturation point essex needs green space and less traffic if we are to combat, climate change and give our kids and grandkids a future,please look at one new big town to give the housing and AFFORDABLE housing the area needs rather than keep tagging new housing estates onto already over stretched areas as is happening at present.

You must be fully aware of the pressures existing with the fully stretched Hospital and Doctor Surgeries, Schools, Packed Highways and traffic jams, more so at peak times that affects travel and bus service delays,let alone the poor condition of the roads and streets throughout the district. There may also be loss to the current green belt.
All these provisions must be greatly improved and developed before any further approval to building, particularly housing, is granted.
In the past it seems that these points have been ignored or somehow skirted around by developers.
Your observations would be appreciated.
So let us see Action First, but possibly the status quo will remain.

Considering all of the doctors and schools in the area of Rayleigh are full to overflowing - adding all of the houses proposed is not sustainable if the current infrastructure is not upgraded.

I OBJECT unless:
A. A new Primary AND secondary school is built in the area to accommodate the hundreds of children that will be joining the area (adding to those joining the area on the Hullbridge estate) B. At least 1 new doctors surgery is built to accommodate residents as it is increasingly hard to get an appointment with doctors at the moment without all of these extra residents C. Suitable parking is provided with each property ie. space for at LEAST 2 cars per household as that is a minimum required for families at the moment D. Suitable green space is kept for local wildlife/mental health of residents/exercise E. Potentially a new road into Rayleigh from the A1245 or Beeches Road/Chelmsford Road to accommodate the new traffic that will be entering the area considering the build up of traffic currently.

On behalf of Thorpe Estate Limited (my client), please find our comments on the Rochford Local Plan Spatial
Options Consultation (SOC). My client is the owner of some 90 hectares of land to the north of Bournes
Green Chase and to the east of Wakering Road. It lies to the south west of Great Wakering. It is identified
on the plan attached.
The majority of the site falls within the administrative boundary of Southend on Sea Council (SoS) apart from
a small part of the site in the north east corner which falls within the administrative boundary of Rochford
District Council.
My client is in the process of producing an illustrative masterplan for their site, which will be supported
technical analysis on key topic areas, including transport, flood risk and ecology. This will be provided to the
Council in due course.
This masterplan for the site will be produced in conjunction with a wider masterplan and promotion of
neighbouring parcels of land by Cogent Land LLP. A collaborative approach is being taken with Cogent, which
includes co-ordination in respect of transport and other critical infrastructure.
These representations are made in the context of not having had the opportunity to engage with officers at
the Council and we would welcome a meeting at the earliest opportunity.
My client is the owner of the land, which should assure the Council that it is a site which is deliverable and
that there are no legal or ownership hurdles to overcome.
The legislative requirements for the production of Local Plans are set out in Part 2, Local Development, of
the Planning and Compulsory Purchase Act 2004 and in national guidance within the National Planning Policy
Framework 2021 (NPPF).
Paragraph 11 of the NPPF requires that ‘plans should promote a sustainable pattern of development that
seeks to meet the development needs of their area; align growth and infrastructure…..’.
It also requires that ‘strategic policies should, as a minimum, provide for objectively assessed needs for
housing and other uses, as well as any needs that cannot be met within neighbouring areas’.
Chapter 3 of the NPPF then goes onto set out the detailed requirements for plan making, including the
requirement set out in paragraph 24, that each authority is under a ‘duty to cooperate’ with each other on
strategic matters that cross administrative boundaries.
The objective of the plan making process is to be able to put forward a plan that is ‘sound’ and meeting the
requirements set out in paragraph 35 which are:
1. Positively prepared – to meet the area’s objectively assessed needs; and is informed by agreements
with other authorities, so that unmet need from neighbouring areas is accommodated;
2. Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on
proportionate evidence;
3. Effective – deliverable over the plan period, and based on effective joint working on cross-boundary
strategic matters that have been dealt with rather than deferred, as evidenced by the statement of
common ground; and
4. Consistent with national policy – enabling the delivery of sustainable development in accordance
with the policies in this Framework and other statements of national planning policy, where relevant.
Whilst we note that the plan is at a very early stage, we do not consider that the plan is heading in a direction
where it is likely to be considered to accord with the four requirements of soundness and therefore is not
likely to be found ‘sound’.
Our overarching concern is that the Council does not appear to be discharging its responsibilities under the
duty to co-operate in respect of strategic/ cross boundary matters and specifically in relation to my clients’
interests, with SoS Council in respect of housing and infrastructure.
At this stage we would note the number of plans that have been rejected by Inspectors at submission/
examination stage on this very issue, including Sevenoaks District Council, St Albans City and District Council
and Wealden District Council.
We would urge the Council to review its approach to ensure that the Local Plan that gets put forward for
examination accords with the requirements of paragraph 35 of the NPPF.
Our comments below focus on the high-level strategic issues, although, my client will wish to comment on
policies not addressed below at later stages in the plan making process.
The National Picture
The Council are bringing forward their Local Plan at a time of significant challenges facing the country,
particularly because of the Covid-19 pandemic which has exacerbated historic issues of under-delivery of
housing over the past few decades.
This lack of supply is causing substantial issues in the housing market, particularly in relation to affordability
and suitability. The government has estimated that housing need in England is 345,000 homes per year.
The government has therefore set its ambition to achieve 300,000 homes per year.
Whilst the supply of housing has been increasing year on year, only 244,000 homes were delivered in 2019-
20, according to a Government research briefing, ‘Tackling the under-supply of housing in England’.
Housing Need in the Region
At a regional level, there are six South Essex authorities, which are listed below, along with their performance
against the Governments Housing Delivery Test, which measures delivery against housing requirement over
the previous three monitoring years:
1. Basildon – 45%;
2. Brentwood – 69%;
3. Castle Point – 48%;
4. Rochford – 95%;
5. Southend – 36%; and
6. Thurrock – 59%.
Not one of the six authorities have met their target and these delivery rates are amongst the lowest in the
Country and, on average, are delivering only slightly more than half (59%) of the regions housing need.
Clearly this is an issue that needs addressing urgently to avoid disastrous social and economic consequences
for the region.
We note from the SOC that Rochford is likely to have sufficient available land to accommodate its OAN which,
for now, we take at face value, albeit that we are aware of a recent refusal of planning permission on an
allocated site. It may be the case that my client decides to challenge the Council’s supply against the tests
set out in Annex 2 of the NPPF.
It is very clear from the draft SoS Local Plan, that they do not have a supply of homes that gets anywhere
close to meeting their OAN without the release of Green Belt land within their own administrative boundary,
see further commentary below. For SoS’s OAN to be met in full, neighbouring authorities, would need to
accommodate the shortfall estimated to be in the region of 3,550 to 4,300. However, given the historic
undersupply within the neighbouring authorities, who have their own challenges, it is difficult to see how
this could realistically be accommodated.
Clearly radical steps are required to address this issue.
Strategic Plan Making
It is not clear what the latest position is with the South Essex Plan. It is disappointing that this doesn’t appear
to be moving forward to allow strategic policies and growth requirements across the six neighbouring
authorities to inform and lead Local Plan production.
We are also disappointed that the Joint Part 1 Local Plan between Rochford and SoS appears to have now
been abandoned. We do not believe that an update to the November 2019 Statement of Common Ground
(SoCG) with SoS has been prepared setting out what the approach is in relation to cross boundary strategic
matters and this clearly should have been agreed before publication of the SOC.
We would particularly note the statements made at 4.3 and 4.5 of the November 2019 SoCG, which stated:
Providing Sufficient Homes – housing need is high across the area and a large amount of land is being
promoted for development either side of the Rochford/Southend administrative boundary. There is a need to
ensure that preparation of a spatial strategy, site assessment and selection is consistent across both authority
areas;
Transport Infrastructure and connectivity - Developing appropriate integrated and sustainable transport
networks to support the efficient movement of people and goods, including strategic transport corridors
(including A127, A13 and A130) recognising the requirements of both Essex and Southend local transport
plans, including modal shift, sustainable travel, new technology, rail franchisee investment plans, footpath
and cycle networks, and any access mitigation to enable strategic scale development across administrative
boundaries, and future proofed internet access to all new development;
We consider these to be two fundamental parts of the plan making process which require cross boundary
co-operation and yet seem to have been abandoned.
In the absence of this plan moving forward to take an overarching view of growth requirements for the
region, we would strongly contend that the Council should re-engage with SoS to update the SoCG as
required in paragraph 27 of the NPPF. These statements will need to demonstrate how strategic policy
making is being addressed and what steps are being taken to accommodate the significant un-met housing
need, because it is not at all clear how this requirement is satisfied in the draft version of the plan.
These statements should be updated and made publicly available for review at each stage of the plan making
process.
Release of Green Belt Land
Paragraph 140 of the NPPF sets out the tests for the release of Green Belt land and confirms that it should
only be altered where ‘exceptional circumstances are fully evidences and justified, through the preparation
or updating of plans’.
Paragraph 141 goes onto set out the steps that need to be undertaken as part of the justification for
‘exceptional circumstances’. These are:
1. makes as much use as possible of suitable brownfield sites and underutilised land;
2. optimises the density of development in line with the policies in chapter 11 of this Framework,
including whether policies promote a significant uplift in minimum density standards in town and city
centres and other locations well served by public transport; and
c) has been informed by discussions with neighbouring authorities about whether they could accommodate
some of the identified need for development, as demonstrated through the statement of common ground.
Given the scale of housing need in the region, it must be the case that there are exceptional circumstances
that would justify the release of Green Belt land.
Within the context of the above, we have set out our comments on the SOC below.
Spatial Options Map
The Spatial Options Map put forward with the SOC shows my clients land, and neighbouring sites, designated
as Regional Park, which is an interpretation of a concept set out in the South Essex Green and Blue
Infrastructure Study.
Whilst, my client would be content for some of their land to be provided as parkland as part of a
comprehensive masterplanned approach to release their site from the Green Belt for housing led
development, they would not release it solely for the purpose of it being used as parkland.
Critically, the failure to allocate their site would seriously compromise the ability for SoS to deliver homes to
be able to meet their Objectively Assessed Need.
The Spatial Options Map therefore fails all the tests set out in paragraph 35 of the NPPF in relation to the
allocation for my client’s site at parkland as it would not be deliverable.
Rochford in 2050
We agree with the thrust of the Draft Strategic Priorities and Objectives, particularly:
1. Strategic Objective 1 – provision of sufficient homes to meet local community needs in partnership
with South Essex neighbours;
2. Strategic Objective 2- provision of a mix of homes to support current and future residents;
3. Strategic Objective 9 – provision of infrastructure; and
4. Strategic Objective 10 – working with neighbouring authorities and the County Council to deliver
infrastructure.
The objectives identified above are consistent with the requirements of the NPPF, particularly in its
requirements to work strategically with neighbouring authorities to meet housing need and provide
appropriate supporting infrastructure.
However, for the reason set out below, we do not consider the SOC provides the necessary framework to
deliver on these objectives. We consider the reverse is likely to be the case and, as drafted, it would prevent
the current and future need of the area being met.
Strategy Options
It is difficult to properly understand what is proposed within this chapter. The spatial plans (Figures 18-21)
lack clarity and in the absence of a key we cannot be certain what the Council are proposing.
We would ask that at the next stage, much improved plans with a meaningful key are provided to make it
clear what is proposed and where to avoid ambiguity.

Our overarching concern with this chapter is that none of the development options set out in this chapter
take account of the development options that are being put forward within SoS’s ‘Refining the Plan Options’
version, which includes the release of my client’s land, and neighbouring parcels, from the Green Belt for a
residential led development.
Indeed, it would appear that it will only be possible for SoS to meet its OAN through the development of my
client’s land along with neighbouring parcels promoted by Cogent Land LLP and a neighbouring authority
(potentially Rochford) accommodating any shortfall. However, there may be pressure from the other three
South Essex Council’s for housing shortfalls to be accommodated beyond their administrative boundaries.
In order for SoS OAN to be fully addressed, section 2.3i – Requirement for New Homes of the SoS draft Local
Plan identifies that between 3,550 to 4,300 new homes would need to be accommodated either in Rochford
or another neighbouring authority.
At the very least the SOC should include this within its options, including taking account of provision of
strategic infrastructure, particularly roads.
Strategy Option C of the SoS draft Local Plan shows the development of my client’s land, with neighbouring
sites and associated infrastructure.
Strategy Option D shows this growth extending into Rochford, which would allow SoS’s housing OAN to be
met in full.
At the very least, the Council ought to be fully engaging with SoS about its housing need and under its duty
to co-operate required by paragraph 35 a) of the NPPF and testing these options at consultation stage as
part of its SOC. Not to do so is a serious failure of proper planning in this region.
The options currently being promoted within the SOC would likely prevent SoS being able to deliver Options
C or D within its draft Local Plan and therefore prevent it from getting anywhere close to meeting its OAN.
Spatial Themes
My client is generally supportive of the thrust of this chapter and the principles to guide development coming
forward. In particular, the requirements for new development set out in ‘A Place-Making Charter for
Rochford’. We believe the 13 (or 14) points identified will enable the provision of good quality development
consistent with the NPPF.
We don’t have specific comments to make in respect of the questions raised, other than in respect of 16a to
16c. Whilst we feel that design codes will be helpful, these should be kept high level and not specific, unless
in relation to areas of very strong character or of heritage or landscape value. More specific design codes
could be readily formulated at outline permission stage.
Overly prescriptive codes at this stage in areas that are not constrained potentially stifle innovative design.
Housing for All
In relation to questions 17 to 19 It is important that the Council’s policies relating to housing units within
schemes are not overly prescriptive and take a flexible approach. We would expect a definitive policy is
likely to result in most developments being unable to meet that policy for a variety of reasons, such as site
constraints, viability, location, access to services/ public transport etc.
It is our experience that the unit mix that comes forward on each site, should be tailored to the individual
circumstances of that site, having regard to identified need.
We would therefore agree that a combination of Options 2 and 4 would be the most appropriate.
We agree that all homes should meet, or exceed, Nationally Described Space Standards, unless exceptional
circumstances prevent that from being possible, such as conversions or co-living schemes.
We agree that all homes should meet M4(2) of the Building Regulations, again, unless exceptional
circumstances prevent that from being possible.
Finally, we also agree that a ‘suitable’ proportion of new homes should be built to M4(3) of the Building
Regulations. However, we would strongly suggest that evidence ought to be produced to identify and justify
any prescriptive requirement set out in policy to ensure is is not overly onerous and proportionate to the
likely level of need.
Green and Blue Infrastructure
Our comments in relation to this chapter concern my clients’ landholdings which are shown in Figure 32 as
providing Regional Parkland. As the majority of this land is within the administrative area of SoS, we would
recommend that the Council’s immediately look to co-ordinate their approach. Not to do so, risks any
positive conclusions in respect of the duty to co-operate. The approach suggested within the SOC is at odds
with that shown within SoS’s draft plan, particularly in relation to the options that show my clients land being
released from the Green Belt for housing led development.
At no stage has my client put forward its land for regional parkland and, even if it is not released from the
Green Belt for development, it would remain in private ownership. This proposal is therefore not deliverable
and not consistent with paragraph 35 of the NPPF.
We would therefore strongly suggest that the Council review this chapter with the relevant landowners to
understand what is capable of being delivered.
My client would however be prepared to dedicate some of their site to parkland as part of a wider master
planned approach, but only as part of a residential led scheme.
Community Infrastructure, Questions 35 to 37
We agree with the Council’s approach, that it is critical that appropriate infrastructure if planned for to take
account of future growth. However, where we do not agree with the approach taken by the Council is in
relation to the concerning apparent lack of cross boundary discussions with neighbouring authorities about
their future growth and how infrastructure provision may need to be planned for to take account of those
requirements.
Consistent with comments made above, we would strongly urge the Council immediately engage with its
neighbouring authorities so that a cross boundary approach is taken to infrastructure provision that will
address future needs.
Infrastructure should be provided for as part of a cross boundary approach and as part of ‘walkable
neighbourhoods’ to ensure communities have facilities on their doorstep.
Transport and Connectivity
We enclose comments from Arup who are my clients transport and highways advisors in respect of this
chapter of the SOC.
The Wakerings and Barling, Questions 59a to 59e
We do not agree with the vision for The Wakerings and Barling shown in the SOC for reasons previously
explained. It would prejudice the ability for SoS to meet its housing need and the Council should be
discussing the potential release of surrounding Green Belt sites and other strategic cross boundary matters
to facilitate this.
Summary and Recommendations
Thank you for allowing us the opportunity to comment on your SOC. Whilst there are a great many aspects
of the plan that my client fully supports, for the reasons set out above, it does not meet the requirements
for plan making set out in national guidance. If it were to move forward on this basis, we do not believe it
would be capable of being found ‘sound’ in accordance with the tests set out in paragraph 35 of the NPPF.
Chiefly amongst our concerns is that the Council appear to have abandoned its engagement with SoS, and
taking a co-ordinated approach to strategic policy making to meet the need for the region, particularly in
relation to housing growth.

As identified above, the South Essex region is catastrophically failing to deliver homes to meet need and has
produced only slightly more than half of its requirement. It is difficult to see what further ‘exceptional
circumstances’ would be required to justify the release of Green Belt land and to use the plan making process
to take a co-ordinated approach to housing and infrastructure delivery.
We would strongly encourage the Council engage with its neighbours and key stakeholders, including my
client, to agree a strategic approach to accommodating housing need in the area and associated
infrastructure. This is a requirement confirmed in paragraph 25 (and elsewhere) of the NPPF. Ideally, the
Council should re-engage with SoS and produce a joint Part 1 plan to deal with cross boundary strategic
issues. Failing that, we would request that the Council provide an up-to-date Statement of Common Ground
prior to the publication of each plan making stage (in accordance with paragraph 27 of the NPPF) to clearly
set out how it is looking to work with its neighbour on cross boundary strategic issues moving forward.
We note that the Council plans to undertake a transport study that will look at, amongst other things, any
requirements for new road infrastructure. It is essential that this happens only once there is a better
understanding of cross boundary issues, particularly housing, so that this infrastructure can be planned in a
way that facilitates the growth required for the region.
We would very much welcome an opportunity to discuss my client’s land and the strategic growth in the
region with officers at a meeting in the near future. As currently formulated – this plan is seriously flawed
and requires amendment.

Dear Sir / Madam,

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

Thank you in advance for your attention to this matter.

Kind Regards,
Jane

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

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

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

I have received messages and now a postcard regarding the RDC New Local Plan. We would like you to know that we feel any kind of action to the needed changes within the Rochford District will probably be ignored as many complaints and comments have been made over the many years we have lived here and very little has been done. Our roads in the area are in the most disgusting condition causing danger not only to motorists but cyclists, motor bike riders and pedestrians. The work that does get done is inadequate and has to be redone on frequent occasions. Drains are blocked and cause rain to flood roads. The housing estates are being built regardless of the lack of infastructure, the inability for some children to attend schools within their catchment areas, due to overcrowding, a lack of GP surgeries, parking facilities, which are overpriced and inadequate. The bus service regardless of the increased population is still poor, sites which are part of our heritage are either sold off or left to deteriorate as is the site where the old police station is in Rochford. The possibility of Mill Hall being pulled down, leaving no social centre for sport, entertaining etc. is also on the cards. Shops are closing due to high business rents and are left in poor condition making them undesirable to new business ventures. The gatehouse at the end of Hawkwell Park Drive is falling into disrepair beyond belief with overgrown garden etc. We thought this was a listed Grade 11 building. The cake shop next to it is a disgrace and would not tempt me or many people i know to have a cake made there particularly when you see the state of the waste ground outside. The parking at the end of Hawkwell Park Drive is appalling causing back ups of traffic into the road around which cars/vans turning off the main road are unable to progress. The overspill of cars from White Hart Lane Service Station, which are left in Hawkwell Park Drive and Park Gardens is also unacceptable. The cost of our Council tax is high enough to warrant all of these problems being resolved and I am afraid, as are many people I know, feeling that your request that we have an input into the future of our area is a complete waste of time.

SPATIAL OPTIONS CONSULTATION - NEW LOCAL PLAN
REF: CFS027, CFS098, CFS086, CFS029, CFS053
AND OTHER PROPOSED DEVELOPMENT SITES AROUND RAYLEIGH

Looking at the proposed development sites for Rayleigh, it is not difficult to conclude that we are quickly becoming engulfed as a borough within Greater London where Rayleigh’s identity will be erased. Rayleigh is a ‘Market Town’ and has an immense amount of history to preserve and protect.

Sunderland is one such place where surrounding villages have lost their identity with village backing onto village without any green space to separate identities. I have experienced the effect of suffocation this creates, which definitely has an effect on one’s mental health. Rayleigh and Hullbridge are within metres of realising this scenario!

The impact that the proposed plan will have on the area is immense – trying to cross Rayleigh by car from the Rayleigh/Hockley boundary to The Weir takes at least half an hour on a good day, where a journey to Duxford only takes an hour! The amount of traffic on our roads has increased twofold bringing with it an increase in pollution, which has already been reported as dangerously high at times in Rayleigh Town. Our health is at risk. Even trying to sit in your garden these days brings with it a ‘hum’ of constant traffic along the Hockley Road and trying to cross the Hockley Road on foot is like taking a risk with your life.

The effect that building to this scale will have on the A13 and A127 is incomprehensible. The A127 from 3pm onwards is already just a car park and the added traffic on the A13, although improvements are being made for Tilbury Docks traffic, will undoubtedly resemble the A127, especially with an unprecedented building plan around Linford and the proposed building of a New Thames Tunnel crossing. We are at crisis point without adding to this crisis.

Where is all the added traffic to go? We have no added infrastructure at all in Rayleigh. The most recent development in progress along Rawreth Lane was promised to include a new school and doctor’s surgery, but, yet again, developers appear to have pulled back on this promise and the Council fails to make sure such facilities are put in place. How are we, the public, to believe that these further proposed developments will cater for an increase in such essential needs? Without them our schools, doctors, and hospital (already at breaking point) will no longer be able to provide a decent level of service, if any. No wonder house sales have increased in the area with residents moving out.

The public’s mental health is seriously under attack. During Covid lockdowns it was literally a breath of fresh air to be able to walk in open spaces, especially where proposed sites between Wellington Road and Bull Lane are concerned, taking in the land behind Nelson Road, Albert Road and off the top of Bull Lane. As a community we need our open spaces for our sanity and to thrive. Nelson Road is already fast becoming a rat run and, as mention before, Hockley Road is becoming chocked with traffic. A new development on these sites will be extremely detrimental with a threat of losing Hockley Woods (another historic area connected to Henry VIII) to further development.

Rayleigh is a dumping ground for large estates of houses with even our children not being able to afford to live in the area. ‘Affordable homes’ are ‘not affordable’. It doesn’t help with people from the London area moving out of London to the suburbs adding to house price increases. My three children have had to leave the district, my youngest only being able to afford property from Manchester northwards! This also affects family dynamics, not only with children having to move to the other side of the country, but having to live at home into their thirties. Instead of all the massive executive homes being built, what is wrong with terraced houses to help our young buy at truly affordable prices and get on the housing ladder? It should also allow more land to be used more economically providing a greater number of homes. I’m not saying halt building entirely, but small pockets of building will be more acceptable than these such vast proposals.

Even if ‘locals’ wanted to buy, it appears London councils are buying up property in the area because it is cheaper than housing their residents in London, i.e. Hall Road development. What a blot on the landscape Hall Road is with houses packed in like slum buildings of old (on top of each other) and the height of properties being so overbearing. It appears this is what Rayleigh is to expect too by looking at the Rawreth Lane development and all that may follow.

There are very little facilities for the adolescent members of our community to engage in enjoyment, even when my children were young there was a huge lack of something for them to do and nothing appears to be available with the Council wanting to demolish the only community hall we have at Bellingham Lane. As a result of losing community spaces no doubt Rayleigh will be looking at an increase in crime (adding to a presently overstretched police force) and the influx of residents from London boroughs may well add to an increase in the already budding gang culture in the South East. These points have to be considered.

I strongly oppose to demolishing Rayleigh Mill Community Hall. To engulf the area in flats is unthinkable what with taking away visible access to The Mount and surrounding it in yet more concrete. Regal House will be so close to the proposed flats and reducing car parking spaces is also unbelievable. It isn’t easy to park in Rayleigh at the best of times and there is no park and ride scheme. I am aghast at a new community hall plan being so small, especially with the amount of increased housing that is being proposed in Rayleigh. It will no way be ‘fit for purpose’. As a resident, my family and I have/ utilise The Mill Hall on many occasions. Our community ‘needs’ this coming together space.

Surely sacrificing an area of green belt away from existing towns to provide a ‘New Town/Garden Village’ would be a better proposition to ease the impact that such a New Local Plan for the Rochford District would create. Fossetts Way requires serious consideration to ease the burden on Rayleigh.

Rayleigh is being suffocated and living within it is becoming suffocating too – it will no longer be the town it was. We have too much development already and to build at this level will kill Rayleigh’s energy and spirit.

For the above reasons, I am opposing such large schemes of development in and immediately surrounding Rayleigh.

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

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

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

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

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

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

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

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

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

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

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

• Hello, please see my comments on the Spatial Options Considerations with particular regard to the following sites CFS027, CFS029, CFS053, CFS086 and CFS098. I strongly object to the redevelopment of the the areas listed above and I have summarised my reasoning below.
Traffic congestion/pollution
The proposal amounts to some 350 new properties being build along with new/upgraded access points. This will amount to a significant increase in traffic in the area and the resulting traffic pollution, traffic noise and highway safety concerns.
There are many children who use Victoria Park and Fairview park for their recreation and consideration should be given to their safety and wellbeing which could be impacted by the increase in traffic.
The local road infrastructure is not sufficient to deal with this increase in traffic. For example, Nelson Road is a very narrow road and is already used as a rat run, the increase in traffic volumes will further exacerbate the problem,
The same can be said of Helena Road, Victoria Road and Bull Lane. The increase in traffic volumes resulting from the proposed redevelopment will obviously make the situation much worse.
Rayleigh is already extremely congested with traffic. Take for example the Hockley to Rayleigh Road (B1013). This is already very heavily used, as is Hambro Hill, which is used a main thoroughfare between North Rayleigh and Hullbridge. This of course will also have adverse implications for Ashingdon, Hawkwell, Rochford and other surrounding villages
Parking is already a problem in Rayleigh town centre, the addition of several hundred cars will increase the strain on the already overstretched local parking facilities
Another consideration is the high volumes of traffic in Rayleigh caused when there is an issue with traffic on the the A127, A13, Rayleigh weir. Rayleigh is used as the alternative route which often causes Rayleigh to be gridlocked. This also has a knock on affect for Hullbridge, Ashingdon, Hawkwell, Rochford, Hadleigh, Benfleet and other surrounding villages.
Other Considerations

The preservation of our green belt and open spaces is essential. This is especially relevant in todays climate where open spaces and places to exercise have been paramount in helping people with mental health issues.

The encroachment of our countryside through more development should be prevented to safeguard our natural habitat and the 'merging' of towns/villages should be avoided.

Take for example the redevelopment of Bullwood Hall and the proposal to establish further housing on the sites I mention earlier in this correspondence. Hockley and Rayleigh get ever closer, it's only a matter of time before they become one.

With regard to the proposed development of agricultural land. With the urgency in trying to rectify the issues surrounding climate change why take away a green space and build properties causing more pollution to add to the problem.

Now that we have left the European Union surely it is incumbent upon us as a nation to become more self sufficient in all aspects including food production, This means preserving our agriculture and agricultural land.

The destruction of our local wild life environment would also be catastrophic. There are deer, badgers, foxes, bats and many species of birds in the area behind Nelson Rd/Napier Rd which will be lost to the area.

There must also be careful consideration given to additional schools, GP surgeries, dentists and clinics required. As I'm sure you are aware, to get an appointment with a doctor or dentist now proves to be difficult. With more people moving to the area this will only aggravate the situation.

I would like to express concerns about the plans for development and housing on our beautiful and essential green spaces.

Living in the centre of Hockley I am acutely aware of the pressure on our local road system which has increased significantly in recent years. The mini roundabout at the Spa is already dangerous to use, far too small for the sheer number of cars, and difficult to use safely when turning out of and into Woodlands Road. I also feel that many of the local roads and infrastructure as a whole is inadequate for the current volume of traffic, let alone any additional development. With one road in and out of Hockely, and many dangerous potholes and burst water mains on Rochford and Hockley roads at all times of year, RDC need to focus ensuring the roads can cope with current housing, let alone additional.

There also needs to be adequate schools, doctors, public transport etc to cover the additional needs of new housing. The 3-4 local primary schools in Hockley are all oversubscribed as it is.

Trees and woodlands are absolutely essential for counteracting climate change, as well as providing homes for a wide range of wildlife, and providing the local children with invaluable education and experiences. The U.K. is already facing a critical shortage of trees. Green spaces are under threat when they should be cherished and protected. We are incredibly lucky to have the fields and woodlands, which are used daily by families, dog walkers, joggers and ramblers.

In particular the plan ref CFS064, which proposes a development on a well loved green space and ancient woodland behind Folly Chase, the Hockley Community Centre, and Hockley Primary school, is disturbing to the many families that use these areas on a regular basis for fresh air and outdoor activities.

If the last year and a half of a global pandemic has had any positive impact on us as a community it is that people have rediscovered a love for the local green space, woodlands and wildlife. Being locked down throughout a lot of 2020 and 2021 was extremely damaging to both the mental and physical health of children and adults. Being able to walk, run and play in the fields and woods as a form of exercise was a lifeline to some families, keeping little ones active and allowing parents to clear their minds. I can’t tell you how many times I heard people express how grateful they are to have this precious space and how crucial is has been, and will always continue to be, for the well-being of the community.

Stand in the field behind the community centre and watch a Jay hop along, spot a squirrel, listen to the crickets and birdsong. Imagine losing this resource to diggers and developers, knowing the damage it’ll cause the local area, traffic, air quality, pollution levels, wildlife, infrastructure, education and overall health of our community. I hope and trust that the council will choose to invest in and care for the community it already has, to help us thrive and protect our beautiful green spaces, fields, woodlands and homes.

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

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


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


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


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


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

Q5. Do you agree with the settlement hierarchy presented?


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


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

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

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

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

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

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


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

Spatial Themes

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


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


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


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


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


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


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


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


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

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


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

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

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


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

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

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


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

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

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

Housing for All

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


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

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

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

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


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

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


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

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


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

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

Employment and Jobs

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


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

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

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

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


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

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

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


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

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

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

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


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

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


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

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

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


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

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

Biodiversity

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


YES

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

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

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


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

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

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

Green and Blue Infrastructure

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


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

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


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


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

Community Infrastructure

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


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

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

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


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

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

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

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


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

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

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

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


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

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


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

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


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

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


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

Heritage

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


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

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


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


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

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


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

Town Centres and Retail

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


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

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

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


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

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

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

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


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

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


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

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

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


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

Transport and Connectivity

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


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

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


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

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

Green Belt and Rural Issues

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


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

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

Planning for Complete Communities

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


N/A


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


N/A


Q56d. Are there areas that require protecting from development?


N/A


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


N/A

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



N/A

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


N/A


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


N/A


Q57d. Are there areas that require protecting from development?


N/A



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

N/A

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

N/A

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

N/A

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


N/A

Q58d. Are there areas that require protecting from development?


N/A



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


N/A


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

N/A

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


N/A




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


N/A





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


N/A


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


N/A


Q60a. Do you agree with our vision for Hullbridge?


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

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

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


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

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


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

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


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

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


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

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


N/A


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


N/A


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


N/A


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

N/A

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

N/A



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


N/A


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


N/A


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

N/A



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

N/A



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


N/A





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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A

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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A






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


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

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


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

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


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

Create a Country Park to the west of Hullbridge.

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

Are there plans for a new hospital, doctors surgeries and schools in these new plans as they are essential before anymore building goes ahead. The roads also need to be fit for purpose.
Why is nobody planning the infrastructure to support such excessive building in the area?

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

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

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


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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

CRITICAL REVIEW: New Local Plan - Spatial Options Document 2021

Dear Sirs,
I am writing in response to the Councils call for responses to their, "Spatial Options Document 2021".

In summary, as a local resident of Rayleigh since 1964 and a local resident of Hockley since 1985 the Council's plan falls far short of expectations. There have been a number of similar planning documents since the turn of the century. And at each consultation the Council has failed to address the concerns of residents about infrastructure. In particular, the total absence from the Plan of any facts published by infrastructure providers for the provision of improvements. You will be all too familiar with Resident's frustration and anger with the Council and with Councillors that this continuing omission is causing.
The "Spatial Options Document 2021" is no different to its predecessors in this regard. In her reply to me dated 21 June 2021 regarding concerns I have with the apparent "creeping house building" in our district, Acting Managing Director, Angela Hutchings, says, "... that each of these infrastructure providers will have their own strategy for improving infrastructure provision in the area that, whilst informed by the Council's Local Plan, are functionally independent documents." This might well be the case, but it does not take a rocket scientist to draw from these documents and pull together a meaningful spatial options plan for sustainable house building in our district.

I challenge Ms Angela Hutchings to re-issue the Plan and to include a meaningful review that shows the provision of infrastructure improvements AND in addition, that said improvements are in "lock-step" with house building.

Furthermore, a re-issued Plan must include a clear Council policy on how they will control house builders from this moment forwards. Thus far the Council have failed to earn the trust of local residents in this regard. The Hall Road development being a case in point. Going forward the Council and Councillors must be totally transparent with Residents on how they will achieve this.

Mr Mark Francois, MP shares similar concerns. In February 2018, (at the time of the last Plan consultation,) my neighbour Mr Layzell wrote to him expressing concerns about the "New Local Plan." In reply, Mr Francois included a copy of his letter to the then Managing Director, Mr Scrutton, in which he agrees with local residents that a plan for 7,500 new homes was probably too much for the district to bear. And that among a number of well made points Mr Francois expressed the view that,

"... experience shows that house builders who develop in the district tend to do so at a considerable profit ... house builders need to be firmly held to account [on adequate contributions ... to the local community] and that the Council should be robust in ensuring that profitable house builders make sufficient and timely contributions to the extra infrastructure that will be required by the developments they create."

Another issue I have with the contents of the Plan document can be found under the Chapter called “Community Infrastructure”. The introduction contains a link to the Council’s “Infrastructure Position Statement.” Expecting to be taken to a paragraph outlining the Council's approach, one is instead taken to a 100 page document (issued in 2019.)

I persevered and dipped into the section about roads but was disappointed to read that it only talks about issues at a high level. But not about local pinch points such as the Spa round-a-bout, or how Essex Highways propose to improve it and our “B” roads that are already at full capacity during peak times each day!

A more general concern about the Plan document is simply the daunting size of it and therefore the Council's failure to provide guidance notes to residents. All we received was an e-mail and/or a card through the door inviting us to review the document at https:// Rochford.oc2.uk.

In addition, the e-mail and/or card does not highlight the importance of the Council's interactive map and what it contains. I was fortunate to receive a copy of "Item 8" of the Planning Policy Committee agenda for the 23 June 2021. The introduction to "Site Appraisals" was informative.

The whole issue of development is a very important one to the local residents and our quality of life. I look forward to receiving your response to the consultation exercise in due course.

Having reviewed the documentation In regards to the new local plan I have a few comments I would like to make.
In general I am not opposed to the building of new homes and all the blue areas put forward are not a surprise. This is a lovely place to live so I understand the appeal for new potential residents but also why so many like myself choose not to leave. I also feel it would create lots of opportunities for current business and the creation of new as time goes by.
Where I am confused is the lack of consultation or information in regards to infrastructure. It is pretty obvious that this area has now become quite saturated by new housing having to use our existing roads. Cherry Orchard was introduced in my primary school years to deal with the growing demand back then and I think it is fairly fair to say this has increased quite considerably 20 years later.
New roads are surely an absolute must (in addition to our current roads being improved). Given the traffic issues posed when developments are in construction new diversions need to be in place prior to commencement.
Surely there is a provision to introduce new routes like the one made in Cherry Orchard to create other means of getting from A-B.
Hockley alone has one way in and two ways out. That is just simply not viable considering the amount of homes being suggested.
Develop new housing if it is required but what’s the plan surrounding this? Where can that information be found? Who is responsible for this?
I feel that more residents would be supportive if it was made clear that things will be made better. More accessible green space will made available within developments, the provisions for flood plains. Rayleigh has experienced Wheatly woods flooding this year and it’s hard not to assume this is because of the new homes close by. Will there be a need for more ponds/reservoirs to deal with the loss of flood plains? If so where will these go? Education and the NHS are other areas which need to be explained. Our schools in Hockley are already at capacity. I find it quite disgusting that children are being taught in portacabins in playgrounds in 2021 and this is accepted to stuff more pupils in beyond the schools actual capacity.
People will naturally fear all the development because the infrastructure is not in place. Everything is running at capacity already so it is difficult not to see this plan in a negative light. There will never be support to meet housing quotas until all aspects of the infrastructure is openly discussed with residents and addressed.

We wish to make the following comments on RDC New Local Plan.
1. It is well known that the Government has set targets for moving to zero carbon housing in this country by 2025. This was being realised in 3 steps firstly in 2010 a 25% improvement was made in the energy/carbon performance outlined in the Building Regulations then secondly in 2013 a 44% improvement was made and finally in 2025 we need to achieve zero carbon. This means that energy needed for heating lighting hot water and all electrical appliances in the house such as TVs and computers must be attained from renewable sources ie no burning of fossil fuels.
The main source of climate change is the human influence for emission of greenhouse gases. The UK produced more than 365 million tonnes of carbon dioxide in 2019. Almost half of these emissions were accounted for in energy use in buildings and more than a quarter came from the energy we use to heat light and run our homes and this does not include the massive amount of emissions produced by manufacturers in the production of most of the current building materials.
A draft Planning Policy Statement was published on climate change which expects Planning strategies to be examined in providing for new homes and it expects that all Local Planning Authorities should have an input in delivering the Governments climate change programme in facilitating any provision of new homes and infrastructure. Local Authorities therefore have a responsibility in leading their communities in dealing with climate change. Therefore the subject of housing supply needs to be looked at alongside the reduction of carbon emissions surely the best way of reducing these emissions is to limit the number of new homes being built and not by increasing the numbers year on year.
2. The NPPF states that developments should be directed away from areas of highest risk of flooding with developments not to be allocated if there are reasonably available sites appropriate for development in areas with a lower probability of flooding. Where development is necessary it should be safe without increasing levels of flood elsewhere.
South Essex Surface Water Management Plan statement includes consideration of flooding from sewers drains groundwater and runoff from land small watercourses /ditches that occurs from heavy rainfall. It appears that none of this was taken into account in the current development in Hullbridge the southern end of which is in the flood plain and should not have been built on. What was originally proposed on this site was the provision of underground attenuation tanks this was subsequently changed to attenuation basins together with an additional basin in the centre of the site which eventually discharges into an existing watercourse in Watery Lane. these basins will no doubt be full for the majority of time especially when calculated for a min of 1 in 1 year annual probability storm together with the amount of additional surface water runoff due to the extra impermeable surfaces from this development especially as DEFRA have now bottled out on introducing Sustainable Drainage Systems SUDS compulsory legislation. Baseline Review for Climate Change Adaption states that in addition to flood risk from tidal sources fluvial systems also pose a risk to parts of the district. The impermeable underlying geology and seasonable wet deep clay soils in the western parts of the district leads to rapid runoff of surface water into local watercourses which inevitably will only get worse with climate change.
3. In connection with Climate Change Mitigation it is stated that it has been demonstrated that Rochford District has a lower per capita transport emissions when compared to Essex as a whole yet BBC Look East recently reported that dangerous levels of nitrous oxide caused by diesel fumes are being found in and around the Rayleigh area. Also in a recent national news report it stated that record amounts of carbon dioxide have been recorded and is on the rise the highest in the past 4 years.
So why are we contemplating building more and more houses on Green Belt land creating more emissions and more traffic adding to this major problem.
4. Regarding Landscape and Historic Environment the NPPF states that Local Authorities planning system should recognise that heritage assets are an irreplaceable resource and preserve them in a manner appropriate to their significance. Again this was totally ignored for the current development striding Rawreth and Hullbridge. As stated in the Archaeological Assessment for this development the Local Authorities archaeological advisor at Essex County Council required archaeological mitigation measures in advance of any development impacts occurring and noted that the historical field boundaries within the site comprise undesignated heritage assets of local significance and recommended that the orientation and preservation of these historic boundaries should be encouraged within the detail of the development proposals. This has not been incorporated within this scheme especially the Ward Boundary between Rawreth and Hullbridge. It is also stated that any new development has potential to lead to incremental changes in landscape and townscape character and quality in and around the district. This includes through inappropriate design and layout.
But once again RDC granted planning Approval for the Hullbridge site which indicated the majority of the future dwellings being 2.5/3storey in an area consisting of mainly bungalows and chalet bungalows.
5. In connection with Population and Communities. Local Authorities should/must ensure that there is sufficient choice of school places which is of great importance. Yet recently at a local workshop meeting in Hullbridge it was pointed out that the local primary school had a few available spaces these children would eventually have to attend the surrounding secondary schools who have all confirmed that they are over subscribed. But according to RDC because these are not actually located in Hullbridge this is not an issue.
6. Regarding Safety Rochford is maintaining that it has a relatively low crime rate and is one of the lowest in Essex. At a recent meeting with the police at the Rochford Parish Rooms the majority of the large number of people who attended all had the same complaint which was that most crimes are not being reported due to the fact that there is hardly any or no response from the police who stated that this was mainly due to severe cutbacks. So the statement made by Rochford cannot be taken seriously.
7. In connection with the Green Belt the Government has stated that the fundamental aim of the Green Belt policy is to prevent urban sprawl by keeping land permanently open the essential characteristics of Green Belts are their openness and their permanence. The majority of this Districts land mass is designated as Green Belt and should only be released under exceptional circumstances. When we recently asked a RDC Planning Officer what is meant by exceptional circumstances he confirmed that this has not been defined. The Green Belt is supposed to serve five purposes 1. To check the unrestricted sprawl of large built up areas 2. To prevent neighbouring towns/villages merging into one 3. To assist in safeguarding the countryside from encroachment 4. To preserve the setting and special character of historic towns/villages 5. To assist in urban in urban regeneration by encouraging the recycling of derelict and
other urban land
RDC have already released large areas of Green Belt for development all over the district. With regard to the New Local Plan the submitted map for the local Hullbridge area shows the majority of the proposed larger sites are Green Belt with the exception of a portion of CFS 100 Brownfield Site being a lorry/heavy goods breakers yard which is obviously highly contaminated.
8. Regarding Health the NPPF states that health and well-being and health infrastructure should be considered in local plans and the NPPG states that Local Planning Authorities should ensure that health and well-being and health infrastructure are considered in local and neighbourhood plans and in planning decision making.
But once again this has been totally ignored by RDC on the western side of the current Hullbridge development site there are three existing Telecommunication Masts.
According to the Guide to Mobile Phone Masts. Independent scientists and doctors these are a major health hazard. Cancer clusters have been found around Mobile Phone Masts up to 400metres from a mast which in this case encompasses the majority of these new dwellings. People living near each other and close to a mast have ended up with rare cancers at the same time as each other. This has been the case in Devon Lincolnshire and Staffordshire. Many doctors are now so concerned that they have all signed petitions to demand that Governments take the health concerns over Mobile Phone Masts seriously.
Forecasts suggest that the number of people aged 85 and over in the District will increase in the future. An ageing population has the potential to increase pressures on healthcare services in the District. We do not agree that any future developments will not as stated will not result in increased pressure on existing primarary healthcare facilities. As stated by the NHS any future developments are likely to have an impact on the NHS funding program and these need to be fully addressed not by just making financial contributions only which in itself does not solve the shortage of doctors nurses dentists hospital beds and appointment times.

As stated above it is shown that RDC have not addressed previously any of the alternatives in terms of major impacts and sustainability especially with the current major development in Hullbridge and we therefore have no confidence that this will change in any future emerging New Local Plan for this District.
RDC need to take into account further carbon emissions overcrowding traffic congestion flooding and further drains on the existing infrastructure.

Listed below are some key issues that we feel need to be addressed in any New Local Plan A. Infrastructure is paramount to all Planning Applications including the provision of all services especially the condition of the existing road network being capable of accepting the increase in traffic numbers. Just providing a new roundabout to provide access to any new large development should not be taken as providing adequate infrastructure as this does not reduce the amount of traffic.
B. The density for outer suburbs should be as stated 20–40 dph with very few apartments and more bungalows. Local Authorities are currently using 30-60 dph which causes more overlooking/overcrowding more 3 storey dwellings and less amenity space. Density should be allocated for actual dwelling plots and should not include open space play areas access roads and space required for attenuation basins which should all be omitted from overall site areas.
C. Approval for development sites that merge with neighbouring villages/parishes especially striding across Ward Boundaries should not be allowed.
D. Brownfield sites are being totally ignored and Local Authorities should not be allowed to re -designate Green Belt without at least applying for a Change of Use in order to for local residents to submit their valid objections.
E. Developers should not be allowed to provide financial contributions for off site provision instead of providing the required numbers of affordable homes.
F. All Local Authorities should ensure that all Planning Applications take into account current Building Regulations for example the style of windows to comply with means of escape ventilation requirements and the use of certain types of external cladding materials G. A minimum number of Lifetime Homes with full wheelchair accessibility should be required to all new developments.
H. All developments should have all required energy generated by on-site renewable and low carbon sources.
I. Not enough amenity space is provided for apartment complexes. Drying areas and bin storage should not be included as part of the amenity space together with balcony areas. Balconies should not be allowed to provide for additional storage and clothes drying.
J. DEFRA should reintroduce Sustainable Drainage Systems SUDs as compulsory legislation to stop flooding.
K. Transport carbon emissions should be taken into account in and around the local areas.
L. Provision of youth facilities should not be by providing football pitches alone.
M. Developers should not be allowed to remove trees and hedgerows prior to the granting of Planning Consent.
N. All developments should be made to comply with their Local Design Guide especially car parking arrangements.
O. All developments should comply with Secure by Design with no back alleys.
P. No Planning Approvals should be granted for any housing development to be constructed near or adjacent to existing Telecommunication Masts.
Q. The awarding of the New Homes Bonus issued to Local Authorities by Government should not be a reason for granting Planning Permission.

I am writing to provide a response of behalf of East of England Ambulance Service NHS Trust (EEAST) in relation to the consultation on the Rochford Local Plan Spatial Strategy Options and to confirm our commitment to working in partnership with the Council and Mid and South-East Essex Sustainability and Transformation Partnership (MSE) (and any successor organization) to jointly plan the necessary infrastructure to help local community in Rochford prosper.
As part of joint health working, EEAST agree and support the points made by MSE in their separate response to the Strategic Objectives for Rochford.
As both a health partner and an emergency service, EEAST would hope to engage with the Council as the Integrated Development Plan is developed as a supporting document to the 2050 Rochford Local Plan. EEAST would request any developments adopt the jointly created emergency services Design Guide for Essex details can be found using the attached link: Engaging with the Emergency Services | Essex Design Guide (https://www.essexdesignguide.co.uk)
We welcome further discussions with the Council around how we collectively can mitigate the cumulative impact of housing and infrastructure developments across health services serving Rochford and where appropriate the surrounding area. Every effort is made to EEAST’s request for developer contribution is tailored to each individual development, or where less than 50 dwellings in each development, group of developments.

EEAST are in the process of developing an evidence-based formula to identify the impact of population growth for housing and infrastructure developments on ambulance services. This will include key projects to enable delivery of our services due to population growth on housing developments, nursing and care homes or over 55 developments. EEAST together with MSE would welcome further discussions around how the infrastructure impact of the Borough’s 2050 Local Plan can be collectively addressed and support net Carbon Zero, to deliver BREEAM Outstanding sustainability standards.

EEAST’s Estates Strategy (2020-2025) summary position is to provide cost effective and efficient premises of the right size, location, and condition to support the delivery of clinical care to the community served by the Trust. A range of national initiatives are underway aimed at improving performance and sustainability within the NHS across wider urgent and emergency system in all six counties along with Local Authorities and Councils, Universities, military establishments, and private providers of ambulance services. Addressing these changes requires the Trust to develop revised operating models and strategies for all aspects of its services, including operational support services such as the Estates Service. A key component of this process has been to establish the Trust’s future Operating Model and to commence planning for the resulting transformation of support services. Expansion to the existing Make Ready Hub and Spoke network will be required to meet the growing demographics.
Each Hub will have a network of Spokes termed Ambulance Station Response Posts (ASRP), tailored to meet service delivery and patient response specific to their local area. Other infrastructure developments such as road and rail also impact on EEAST as an emergency services provider, with requirements to meet nationally set response times.
The spoke network is determined by the changes to infrastructure and changes to local population health care needs through patient flow modelling and subsequently EEAST staffing requirements. The aim is to create demand-centric and agile spokes which are adapted to activity requirements (both permanent and temporary workforce requirements during significant infrastructure development construction periods) as these change over time.

Current East of England Ambulance Stations close to Rochford

Spokes can be made up of:
• Ambulance Station Reporting Base - 24/7 permanent reporting base for staff and primary response location for one or more vehicles
• Ambulance Station Response Post - primary response location which includes staff welfare facilities
• Standby Location - set in strategic locations where crews are placed to reach patients quickly. Facilities used by staff are provided by external organisations to EEAST.
The resulting estate configuration which consists of a network of up to 18 ambulance Hubs. Each Hub will incorporate:
• A make ready center from which the Make Ready Service is delivered
• Workshop facilities providing service, maintenance, and repair services for operations vehicles within the local spoke network, including Patient Transport Service (PTS) vehicles
• Consumable product stores, with stock-levels maintained on a just-in-time basis by direct supplier delivery
• Some Hubs will operate additionally as the bases for certain corporate, administrative and support services
• PTS facilities incorporated into the operational estate, primarily at the Hubs.
In addition, across the Trust’s region there are:
• Two Hazardous Area Response Team (HART) bases, located to best support the major airports within the Trust’s region
• A Trust HQ co-located within operational premises
• A regional training school providing staff professional training, co-located with driver training and supported by up to two satellite professional training locations plus general training facilities at each of the Hubs
• A fleet logistics center at one of the Hubs’, incorporating a 24-hour fleet logistics call-center
The Rochford area is covered by the Southend Hub which forms one of the 18 Make Ready Hubs across the region.
EEAST estates and development plans consider growth in demographics of population changes and therefore any increase in requirements to meet these changes will require modelling to account for the required increased workforce, equipment and vehicles. EEAST are currently participating in a service review to better understand what resources are needed to meet patient demand.

Acute, Mental Health, Social and Out of Hospital Services
As Integrated Care Systems deliver hospital services reconfiguration and transformation into new models of care, this means ambulance services will be impacted by:
• Ageing population and greater number of people living with long term conditions – creates greater demand on both emergency and commissioned patient transport services.
• An increased need for emergency ambulance services to deliver more out of hospital care, such as by expanding their “hear and treat” and “see and treat” services.
• Development of centralised care Hubs, such as vascular and stroke networks, may lead to increased conveyance times, but with improved outcomes for patients.
• Changes to discharge care models are likely to increase the number of patients discharged with more complex needs and are likely to require increased levels of care during transportation as well as effective and timely handover of care.
• Focusing on improvements to acute and ambulance service diagnostic and digital connectivity.
The provision of health and social care services out of hospital care into community and social care via diagnostic hubs and community locations will require changes to patient transport services.

Assessment of Rochford Local Plan 2050 Spatial Strategy Options

This section provides further assessment of the impact of each of the proposed options on EEAST Emergency Ambulance Services across the Spatial Options Consultation Paper 2021 and the likely mitigations to be considered as part of the Infrastructure Delivery Plan next year.

STRATEGY OPTION 1: Urban Intensification

Existing planned housing developments, including sites with planning permission, existing allocated sites and urban developments, involving around 4,200 new homes of which at least 800 will be affordable. Support utilisation of existing site and urban developments with provision of at least 800 affordable homes.

In relation to ambulance services providing support to this population growth, wherever possible this would be incorporated into existing ambulance Hubs or response posts, however this may not be possible and additional response or stand by posts may be required or relocated. This may be in larger primary care premises or jointly located with fire and police or other potential solutions.

EEAST would request any developments adopt the created principles in Essex: Engaging with the Emergency Services Essex Design Guide.

Potentially a further 1,500 homes by allowing higher density developments in urban areas and on existing allocations. As above
Existing planned employment developments, including sites with planning permission and existing allocated sites, involving a minimum of 120,000 m2 of permissioned employment space, including new high quality space at Airport Business Park and Michelin Farm As above
Capacity improvements to existing schools and healthcare centres, new onsite open spaces and sports facilities Any new health/medical premises would ideally provide the opportunity to explore an ambulance response post at this location including a suitable fast charging EV connection.

Potential requirement for financial contributions from developers.
Limited opportunities to deliver transformational new infrastructure as many of the developments would fall below the 50-home threshold to contribute to new infrastructure The combination of a number of small developments (<50 dwellings) affects ambulance service provision and consideration is requested to enable financial contributions from developers is assessed on a block basis to enable expansion or introduction of new response posts to retain the nationally mandated response times
Option 1 Urban Intensification EEAST does not have any particular preference for each sub-option, as any development option requires consideration of the suitable location of ambulance response and/or standby posts in order to meet the needs of the patient population growth which will impact on our ability to achieve national response times.

Our main consideration is the ability to access financial contributions from developers to support the expansion or relocation of ambulance stations/reporting/response and/or standby posts
Total 4,200 + 1,500 dwellings

STRATEGY OPTION 2: Urban Extensions
Option 2a: Focused on main towns
Option 2b: Dispersed to all settlements based on Settlement Hierarchy

An additional 3,000 – 5,000 homes relative to Option 1 of which at least 1,000-2,000 would be affordable Support utilisation of existing site and urban developments with provision of at least 1,000 – 2,000 affordable homes.

In relation to ambulance services providing support to this population growth, wherever possible this would be incorporated into existing ambulance Hubs or response posts, however this may not be possible and additional response or stand by posts may be required or relocated. This may be in larger primary care premises or jointly located with fire and police or other potential solutions.

EEAST would request any developments adopt the created principles in Essex: Engaging with the Emergency Services Essex Design Guide.

Up to 3 new primary schools, new medical facilities, open spaces, employment areas and transport connections Any new health/medical premises would ideally provide the opportunity to explore a response post at this location including a suitable fast charging EV connection.

Potential requirement for financial contributions from developers.

Opportunities to support rural services by directing some growth to villages with rural shops, schools or community facilities We support rural growth combined with regular appropriate public transport arrangements to support people getting to work/recreation/use of community facilities

The combination of a number of small developments (<50 dwellings) affects ambulance service provision and consideration is requested to enable financial contributions from developers is assessed on a block basis to enable expansion or introduction of new response posts to retain the nationally mandated response times.
Option 2a: Focused on main towns

Option 2b: Dispersed to all settlements based on Settlement Hierarchy
EEAST does not have any particular preference for each sub-option, as any development option requires consideration of the suitable location of ambulance response and/or standby posts in order to meet the needs of the patient population growth which will impact on our ability to achieve national response times.

Our main consideration is the ability to access financial contributions from developers to support the expansion or relocation of ambulance stations/reporting/response and/or standby posts
Total between 3,000-5,000 dwelling with 1,000 – 2,000 affordable

Option 3: Concentrated growth
Option 3a: Focused west of Rayleigh
Option 3b: Focused north of Southend
Option 3c: Focused east of Rochford

An additional 3,000 – 5,000 homes relative to Option 1 of which at least 1,000-2,000 would be affordable Support utilisation of existing site and urban developments with provision of at least 1,000 – 2,000 affordable homes.

In relation to ambulance services providing support to this population growth, wherever possible this would be incorporated into existing ambulance Hubs or response posts, however this may not be possible and additional response or stand by posts may be required or relocated. This may be in larger primary care premises or jointly located with fire and police or other potential solutions.

EEAST would request any developments adopt the created principles in Essex: Engaging with the Emergency Services Essex Design Guide.

Up to 1 new secondary school, 3 new primary schools, new medical facilities, open spaces, employment areas and new link roads Any new health/medical premises would ideally provide the opportunity to explore a response post at this location including a suitable fast charging EV connection.

Potential requirement for financial contributions from developers.
Greater opportunities to attract Government investment into existing and new infrastructure as part of the Thames Estuary Growth Area. Support growth opportunities
Greater opportunities to work with Basildon, Castle Point, Essex and Southend Councils to co-ordinate funding towards transformational transport infrastructure projects such as a new inter-urban rapid transit system or new link roads EEAST as an emergency service needs to be aware of and involved in transformational infrastructure projects as during the construction phase this may impact on our ability to achieve national response times.

Infrastructure changes also impact on any commissioned Patient Transport Services to ensure timely delivery and collection of patients for their appointments to acute hospitals/diagnostic hubs or other out of hospital services
Opportunities to deliver the eastern extent of the South Essex Estuary Park forming a new coastal country park in the east of the District Support opportunities to improve health and well -being of residents and visitors to the area
Option 3a: Focused west of Rayleigh

Option 3b: Focused north of Southend

Option 3c: Focused east of Rochford
EEAST does not have any particular preference for each sub-option, as any development option requires consideration of the suitable location of ambulance response and/or standby posts in order to meet the needs of the patient population growth which will impact on our ability to achieve national response times.

Our main consideration is the ability to access financial contributions from developers to support the expansion or relocation of ambulance stations/reporting/response and/or standby posts
Total between 3,000-5,000 dwellings with 1,000 – 2,000 affordable

Option 4: Balanced Combination
No sub-options

An additional 3,000 – 5,000 homes relative to Option 1 of which at least 1,000-2,000 would be affordable. Support utilisation of existing site and urban developments with provision of at least 1,000 – 2,000 affordable homes.

In relation to ambulance services providing support to this population growth, wherever possible this would be incorporated into existing ambulance Hubs or response posts, however this may not be possible and additional response or stand by posts may be required or relocated. This may be in larger primary care premises or jointly located with fire and police or other potential solutions.

EEAST would request any developments adopt the created principles in Essex: Engaging with the Emergency Services Essex Design Guide.

Up to 1 new secondary school, 3 new primary schools, new medical facilities, open spaces, employment areas and new link roads. Any new health/medical premises would ideally provide the opportunity to explore a response post at this location including a suitable fast charging EV connection.

Potential requirement for financial contributions from developers.
Greater opportunities to attract Government investment into existing and new infrastructure as part of the Thames Estuary Growth Area Support growth opportunities
Greater opportunities to work with Basildon, Castle Point Essex and Southend Councils to co-ordinate funding towards transformational transport infrastructure projects such as a new inter-urban rapid transit system or new link roads EEAST as an emergency service needs to be aware of and involved in transformational infrastructure projects as during the construction phase this may impact on our ability to achieve national response times.

Infrastructure changes also impact on any commissioned Patient Transport Services to ensure timely delivery and collection of patients for their appointments to acute hospitals/diagnostic hubs or other out of hospital services
Opportunities to support rural services by directing some growth to villages with rural shops, schools or community facilities. We support rural growth combined with regular appropriate public transport arrangements to support people getting to work/use of community facilities

The combination of a number of small developments (<50 dwellings) affects ambulance service provision and consideration is requested to enable financial contributions from developers is assessed on a block basis to enable expansion or introduction of new response posts to retain the nationally mandated response times
Opportunities to deliver the eastern extent of the South Essex Estuary Park forming a new country park in the east of the District Support opportunities to improve health and well-being of residents and visitors to the area
Option 4 Balanced Combination EEAST does not have any particular preference for each sub-option, as any development option requires consideration of the suitable location of ambulance response and/or standby posts in order to meet the needs of the patient population growth which will impact on our ability to achieve national response times.

Our main consideration is the ability to access financial contributions from developers to support the expansion or relocation of ambulance stations/reporting/response and/or standby posts
Total between 3,000-5,000 dwellings with 1,000 – 2,000 affordable

We hope this information provides a useful indication of the expected impact on health services for East of England Ambulance Services on the proposed Spatial Strategy Options set out in the Local Plan 2050 consultation document. We look forward to working with the Council, Mid Essex STP, police and fire colleagues throughout the development of the Local Plan 2050 and associated Infrastructure Delivery Plan.

Local Plan Spatial Options Consultation
Please find below the comments from Hockley parish Council regarding the Spatial Options consultation.
The need for housing is understood but many of the proposals in the Local Plan Consultation and the impact of over-development in Hockley are a major cause for concern, especially without evidence of supporting infrastructure. This initial consultation informs residents of landowners who have put forward sites for future development so there is a personal gain aspect here. Rochford District Council has a duty to actively support residents needs in all communities and influence
Government policies.
Consultation Process -The volume of information contained in the consultation was difficult to access and view online. Some links did not work properly. RDC are not reaching residents who have no internet.
Spatial Themes not included - Cultural and Accessibility.
Vibrant Town Centres: Work actively with premises owners to assist in the re-letting of any empty shops. Maybe offer a reduced rent to new businesses as a start-up scheme for “local” business only – allowing the entrepreneurs in the Rochford District a chance to showcase their businesses. Discuss with owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows, perhaps photos of the old towns or useful information, to make them more attractive.
Employment – District is lacking in Environmental services - woodland conservation and management. Work with local schools and colleges, as well as businesses and the job centre, to see what sustainable employment is needed in the district. Incorporate ways to assist in schemes/apprenticeships to train all ages get back into work or upskill (with jobs at the end of training.) Developers should be encouraged to use local labour. The current employment site allocations on Figure 30 do not provide enough space to meet the district’s employment needs through to 2040. There are eighty-seven thousand people in the district. There is no data on the form to suggest how many of these are in employment and how many are looking for work, but the
council need to reassess its future needs to future-proof our residents’ opportunities Improve Long-term Economic growth - Better road networks, gigabit broadband and Wi-Fi. The council should stop developing existing commercial land into housing.
Planned Forms of Housing: Young people/couples do indeed find it difficult to purchase property in Hockley. It is hoped that the new developments proposed will cater for their needs with more semi-detached properties than is now the case. The growing elderly population requiring
specialist/suitable accommodation need assistance. Many elderly single people are living in familysized homes when they would prefer more suitable accommodation such as bungalows or purpose-built flats. Mix of housing for “affordable“ properties with higher standards for gardens and recreational space. Consideration should be given to the provision of house for life, Adapted homes for the disabled, bungalows and other potential buildings for downsizing families. Housing
for the hidden homeless – those “sofa surfing” & Emergency housing. The plan makes no reference
to social housing quotas which should be included in all new developments. By working closely with planners and developers, as well as different charities and communities, residents, and businesses. You will then get a better understanding as to what you need and what will be achievable.
From 1st August it was announced that empty buildings and brownfield sites should be converted rather than build new. This alternative should be evaluated first.
Many development proposals would also mean a further reduction in air quality, light pollution and the loss of trees, farming, and arable land at a time when food production and supply is becoming a cause for concern.
Care needs to be taken to maintain the integrity of the existing settlements with respect to green boundary between Hockley and its neighbours. Essential green belt is being allowed to erode further (suggested land at north of Merryfields Avenue, Turret Farm, Church Road, land north east of Folly Lane, a number of sites on Greensward Lane, Lower Road and High Road) which will be impossible to replace.
Enforcement on unauthorised development is not adequately managed.
Local generation of low-carbon and renewable energy – It is encouraging to learn of Rochford
District Council’s intention to provide housing to meet the needs of both young and old that are
carbon neutral and energy efficient. New developments should be able to source some or all their energy from renewable sources. Solar in all new development as standard. Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs; there are many flat roofed buildings all over the district
that could accommodate solar panels without damaging the landscape. Explore tidal energy and seek out suitable locations to ascertain whether it is viable. Retrofitting existing housing and commercial buildings.
Infrastructure - The Council cannot comment on the suitability of sites in the plan without completion of Infrastructure Delivery & Funding Plan, Level 2 Strategic Flood Risk Assessment and Local Cycling & Walking Infrastructure Plan. This is a continuing concern to residents due to the volume of recent and proposed development causing additional pressure on roads, education, social services, health facilities and local
employment opportunities all of which gives a sustainable balance for our communities. The Infrastructure Funding Statement states all financial and non-financial developer contributions relating to Section 106 conditions should be completed but this is not the case when larger sites
are split up. If developers do not honour the conditions the money reverts to ECC and RDC who should use this to improve our existing facilities, especially on our roads and cycle paths which are in a pitiful state of repair and will only worsen with further development if funding is not used where was intended. The volume of traffic has increased to an unacceptable level on the B1013
causing noise, air pollution and disturbance; Is the traffic survey up to date?. The main access to Hockley and on to Southend is via the B1013; one of the busiest ‘B’ roads in the country. It is difficult to understand how this already congested road could cope with the vehicles from another 1,000 houses in Hockley, let alone those from adjacent villages and towns. Rochford District is on
a peninsular: traffic can go no further than Southend especially with limited access to the north of the county via Battlesbridge. It is suggested the Council undertake a road traffic survey before continuing with the District Plan.
Good public transport links are crucial for our villages, neighbourhoods, and town centres. Hockley
benefits from being on the main Southend Victoria/Liverpool Street train line. Unfortunately its bus
service is not so efficient with the nos 7 and 8 services passing through the village from Southend to Rayleigh and vice versa twice an hour. Services to other parts of the district/county have to be accessed from these two termini. The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian, and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a complete review of sustainable transport. Cycling infrastructure and other sustainable transport methods should be prioritised over a car-centric highway use.
Balancing access against increased congestion will be the issue for a lot of the promoted sites in Hockley. If RDC keep adding small developments to the boundaries of the town, it will overcrowd existing houses and add to urban sprawl.
Ensuring that public rights of way are not blocked by landowners and are kept free from debris. Assess paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look at offering this in the larger spaces. For example, a small toilet block and hand washing facilities in a car park.
Community infrastructure - Community infrastructure should be preserved and extended.
Access to town centres and secondary shopping by bicycle and foot should be made easier and safer. Hockley has a road network no longer fit for purpose, some schools are near to capacity, it is difficult to obtain a GP or dental appointment. Hockley is served by two GP practices, as has been the case for 50 years or more. Hockley’s health clinic closed in the last few years and
young mothers and the elderly have to travel to Rayleigh for medical attention. What are the plans for additional health services in line with the vastly increased population should the plan be enforced?. There is little to no disabled play areas or play equipment. There are always issues with waste collections, drain and road cleaning and verge trimming. The District Council does not have the staff to deal with all these issues. The current recycling site at Castle Road, Rayleigh is
no longer capable of expanding to meet the needs of an ever-growing population. The plan should also identify a site to accommodate commercial waste facilities to stop fly tipping.
Open Spaces - The value of our open spaces and the issues with climate change has become a priority. People will continue to reduce travel and split time working from home. Our open spaces are essential for wellbeing, exercise and relaxation. We are on an overpopulated peninsular surrounded by water with one way in and one way out and there is a proven risk of flooding. Open
space is at a premium. Unfortunately for the youth of Hockley, there is no sports field they can use in the village. The District Plan does mention the use of the Greensward Playfield and it is to be hoped this will be progressed. The District Plan places great emphasis on health and wellbeing. Fortunately Hockley is well served with a network of footpaths. It is important that they
are maintained and not encroached upon by development All green spaces, no matter how small, hold some significance, especially to those who use them
for recreation. They are of community value and should not be developed. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets. RDC must protect all recreational spaces
and improve them, where necessary.
Conservation areas, Green Belt & sites subject to the exclusion criteria (i.e. Sites of Special Scientific Interest) on the call for sites must be protected from Development.
Local Wildlife Sites review: RDC policies for protecting wildlife areas need to be updated. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was. Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. The plan should create new wildlife meadows to encourage the pollinators to future proof our own existence.
RDC to focus on concerns and consideration to wildlife, birds, animals, and insects. Alongside plants and endangered species. Surrounded by Green Belt, Hockley is lucky in having access to a number of open spaces. It is noted that the Marylands Nature Reserve is included in The District Plan but not Plumberow Mount Open Space or St Peter’s Road Open Space – all maintained by the Parish Council. Marylands Woods, Plumberow Woods, Crabtree Woods, Hockley Hall Woods and nearby
Beckney Woods are all ancient woodland but in private hands. It would be of great benefit to the community if they were included in the Local Plan and protected for the future. Betts Wood and, of course, Hockley Woods are in the care of the RDC. With so much development, it is obvious that flora and fauna will suffer. Consideration should be given to identifying further green spaces (not just play areas) for public use. Efforts should be
made to ensure wild-life corridors are incorporated into developments near to woods and open countryside.
Heritage
The District Plan contains a list of conservation areas. It is disappointing to note that St Peter and Pauls’ Church, Church Road and adjacent buildings (the old school house, Hockley Hall, Mill House and the former rectory) does not appear. In the surrounding green belt, it is constantly under threat and it would be a tremendous loss to the community should this historic part of the
village be developed.
Plumberow Mount (a Romano/British tumulus) does not appear in the document as an ancient monument.
Promoted Sites (Hockley)
The plan proposes around 1000 additional houses in Hockley with other developments on land bordering the parish. This density will have a major detrimental impact on the quality of life for the settlements.
• CFS105 (Land North of Hambro Hill) would negatively impact the openness of the Green Belt between Rayleigh & Hockley. Rochford Green belt study states this parcel of greenbelt has a ‘Moderate’ rating for Purpose 1, and a ‘Strong’ rating for 2 & 3. It checks the unrestricted sprawl of large built-up areas, prevents Rayleigh & Hockley merging into one another, and assists in safeguarding the countryside from encroachment.
• The Merryfields Avenue (green belt) proposal has been previously rejected by residents due to access issues as the land borders on the Nature Reserve and footpath 13. Consideration should be given to incorporating it into the Reserve rather than releasing it for development. The owner of the tract of land has made a few unsuccessful planning applications in the past on account of the threat to local wildlife, impact on ancient woodland, lack of access, the danger of flooding from the nearby stream and run off from the road. The cost effectiveness of providing access and services could prove to be exorbitant along with any damage incurred on the nearby
Nature Reserve, better that the land become part of the Reserve.
• Proposals for Folly Chase and Church Road will increase density and give further traffic problems on a busy county access road which has light industry and equestrian centres but does not have footways for pedestrian safety; vehicles are also subject to dangerous line of sight restrictions. The Folly Chase proposal was previously rejected by residents and supposedly dismissed by RDC but still appears in the Local Plan for development. The land to the north east of Folly Chase is adjacent to ancient woodland with protected trees (Betts Wood).
To the west of the site there is a green lane bordered with ancient trees which should be protected if development takes place. There is no public access to the site and there is concern that the adjacent community centre could be sacrificed for this purpose. What are the plans for the Community Centre and public footpaths which must be retained?
• Sheltered accommodation is in danger of being lost at Lime Court and Poplar Court.
• The proposal for development on land at Belchamps is particularly contentious due to the lack of open space for activities available to youngsters and community groups in the Rochford District. Any considered development would be a detrimental impact to the Historical
woodlands. This site has been a very valuable well used resource and it is important this is retained for our future generations.
• As Hockley Woods is the largest remaining wild woodland in the country RDC should be doing EVERYTHING it can to save it from development, either adjacent to or close by. RDC should also actively be adding to it by planting more trees to future proof its existence and status. RDC must protect any thoroughfares that access Hockley Wood.
These comments will be publicised on the Parish Council website, I would be grateful if you could do the same on the Rochford District Council website.

My question to your spatial options survey is: What is in it for young people?

Are there sufficient open spaces for them? Are there sufficient drop-in centres, community halls etc.?

Is there any joined up thinking, linking schools, charities, local sports facilities and the private sector when it comes to young people?

What help/support is there for young people with special needs?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

References CFSO27, CFSO29, CFSO53, CFSO86, and CFSO98
We strongly object to yet another set of houses being built in Rayleigh under the above proposals

This is another 329 houses on top of the current developments behind M&S, near Asda, Hullbridge, near Swallows Aquatics, across from the little cemetery near Edward Francis School (shocking eyesore of set of cheap built houses) and the bottom of Hambro Hill with more development by knocking down the Church next to Mark One Hire and the new proposals for Rayleigh Mill.

Then there is temporary aborted plans for a Gypsy area next to Rayleigh Downs Road that tried to slip under the radar.

This latest proposal is on land that serves a purpose for wildlife (where are the Wildlife reports required under the Wildlife Act), housing of people's horses which they depend on which encourages exercise and well being. The land also is a lovely place to walk as a family or by yourself to get away from the daily grind of Rayleigh becoming a concrete jungle that now floods more times than it should as there is no grasslands to soak up the excess.

We can see nothing viable in your plans for improving the infrastructure to support all this. Equally by contradiction, Rayleigh needs to reduce the pollution levels which you reported pre COVID as being excessive in the town centre. Based on just one new dwelling having one car that's nearly 1000 extra vehicles on the road. Which also means continued parking on the actual walkways which blights Rayleigh and therefore causes issues to disabled people, prams and those who just want to walk without having to step into the road to do so.

Add to that potential for additional buses to get the additional commuters and the pollution levels and traffic jams will increase. Which then affects those with severe respiratory issues.

How will the council balance these increases in their Climate Change, Open Spaces and Bio Diversity plans when it is, effectively, digging it all up?

Rayleigh had 3 Senior Schools, now has two and they are at capacity. Is another school going to be built?

Where is the plan to find more GP surgeries to support even more housing?

None of these developments are or will be 'affordable' to the young that live here so they will move elsewhere rendering less income for Rayleigh.

The plans state wanting to improve the high streets. We now have no clothes shops and more food, drink and hairdressing establishments and nowhere for young people. The rates for shops does not encourage new business as they are too high. Adding more vehicles trying to get into Rayleigh does not add to footfall adding to Rayleigh's coffers if there is nowhere to park! So people will continue to use out of town facilities.

The proposed development for Rayleigh Mill is another debate but to touch slightly on it, by reducing the parking to add more flats, where are people going to park for shopping or attending a wedding or indeed the flats themselves as people have more than one car.

Growth in not needed in terms of more housing. Investment in Rayleigh to be more affordable in terms of existing housing/empty premises/rates/infrastructure and keep it green is what is needed if Rayleigh is to flourish. Incentives for people to improve their own dwellings.

It is not yet more unaffordable, cheaply built housing which only lines the pockets of private developers and drain our resources and deplete our wildlife.

Don't just listen to your residents, hear them. Please

The easiest way for me to comment on the Local Plan is to make a general observation rather than try to fit it in with your documents.
I do not agree with the draft vision for the reasons set out below:
• the Council has failed to recognise that the need for housing is grossly overstated.
The significant number of houses which have been built recently are not for local people but for large numbers of people coming into the area-many from London. Rochford District Council should not be trying to solve the housing problems of London Authorities and others.
• Design
The houses built are bland and badly designed with no regard for the historic setting within the Rochford Hundred area.
• Infrastructure
There has been no attention paid to the infrastructure issues-there were no new schools or doctors’ surgeries built, despite the Council naively thinking this would happen. The roads did not and still do not have the capacity and design needed to accommodate additional traffic.
The Local Plan talks about Green Space and Open Areas but in reality these are ignored when it comes to going along with what developers want rather than what the local residents want.
To meet my concerns, the Council will need to devise a Plan which is very specific in addressing the matters I have raised in order to ensure there is no further development of unsustainable numbers of unsuitable houses. Simply making generalised statements is not acceptable.

Dear Mr Stephenson,

Response to Rochford District Consultation on New Local Plan

I am writing to you regarding Rochford District Council (RDC) consultation on your emerging new Local Plan. Please regard this letter as my formal response to your consultation. I have set out my comments under what I hope are a number of relevant headings below. In the interests of transparency, I declare an interest as a local resident myself, having lived in Essex for half a century and now in Rayleigh for a little over twenty years.

General Points

We obviously need to build some new homes in Rochford District over the next two decades, as we cannot expect people to live at home with their parents into their 50's. Nevertheless, the whole thrust of this letter is that there should be no further major housebuilding in the Rochford District without significant infrastructure investment first. Any new Local Plan has to be both environmentally and economically sustainable and must safeguard the interests of existing residents, as well as new ones.

Background

RDC has initiated this consultation, as part of the process of updating its Local Plan, an overall process which is likely to take around a further two years to complete. Once the draft plan, which should then cover the period out to 2040 has been formulated, this process should then include an examination in public by an Inspector from the Planning Inspectorate, at which I would like to request an opportunity to give evidence as one of the local MPs, when the time comes.

However, in the meantime, before RDC begins to finalise its new plan, the Council has sought early feedback from local residents, and I hope that as many as possible will have taken the Council up on its suggestion and provided comments of their own.

In my response, I have sought to make some important general points about the need to ensure that any future housebuilding is accompanied by the necessary expansion of local infrastructure. If that cannot be guaranteed, then I believe that major house building in the District should be resisted until it can.

Geography

Much of the Rochford District is effectively contained in a peninsula, bounded by the Thames Estuary to the South (beyond the Borough of Castle Point); the North Sea to the East and the River Crouch to the North, which forms a border for much of its length with the neighbouring Maldon District.

As a result of this, there are only a limited number of major routes into and out of the District, which are a major consideration in formulating any new plan.

Transport Corridors and Constraints

Rochford District is connected to the capital via a direct rail route into London Liverpool Street. This has been upgraded in recent years, with major investment in new overhead wires, longer trains with increased capacity and the upgrade of some platforms, plus a new station at Southend airport.

Prior to the Covid-19 pandemic, trains in the morning and evening rush hour were bursting to capacity. Passenger numbers are now recovering as we finally emerge from Lockdown but the extent to which capacity problems on the line will re-emerge will partly be determined by how working patterns alter post-pandemic and the extent to which people are permitted/desire to work from home, as opposed to a return to regularly commuting into London, in the traditional manner.

Rail capacity should be expanded further, when the much-delayed Crossrail (now named the Elizabeth Line) eventually opens across London, hopefully now no later than 2023. The Public Accounts Committee (PAC) on which I now sit, recently took evidence on Crossrail and is now likely to publish its latest report on the project, within the next few weeks.

In terms of air travel, unfortunately due to the loss of traffic resulting from the pandemic, both EasyJet and Ryanair have recently withdrawn scheduled passenger services from Southend, leaving the airport largely dependent on freight traffic and aircraft maintenance work for its survival. Hopefully, regular passenger services, including to popular holiday destinations, might be resumed once the economy has fully recovered, although this is by no means guaranteed.

However, the major constraint in terms of transport links to and from the Rochford District is undoubtedly the road network, which in many cases is already seriously overstretched. The two main road arteries leading to/from Rochford District are the A127 and A13.

In spite of a number of junction improvements in recent years on the A13 and A127 and widening schemes on the A13, both of these major roads are already at or very close to full capacity at rush hour. An Essex County Council A127 Task Force meeting, held a little before the pandemic struck, examined the 'heat maps' for both roads (i.e. the busier the road, the darker the shade of red on the map). These showed that in both the morning and evening rush hour, both roads glowed very deep red, with both at between 98% to 100% capacity. As we have emerged from Lockdown (and indeed as many people have avoided public transport, because of the virus) traffic levels are now virtually back to pre-pandemic levels already.

Despite some limited opportunities for modal shift (both roads are highly sustainable for cycle lanes, which would be subject to heavy traffic pollution anyway) there is a strong culture of private car use in South Essex, which many residents see as part of living in a free society. This seems unlikely to be altered by entreaties to simply abandon private car use, however well-intentioned (especially as some of those making such calls use their own private cars frequently as well).

DEFRA has been concerned for some time about air quality issues, especially along the A127 and has effectively compelled neighbouring Basildon Borough Council to implement a number of air quality initiatives, in order to obviate the imposition of a formal air quality zone in the Basildon/Pitsea area, close to the RDC boundary. Over the lifetime of the proposed new plan, this problem may be partially alleviated by the increasing introduction of electric vehicles but, while this may well deliver environmental benefits, it still does not solve the issue of the sheer volume of traffic already using both roads in the early 2020s, let alone by the late 2030s.

Along with some others, I have been calling for several years for a straightening out of the old Fortune of War junction on the A127 at Laindon (which itself would be likely to deliver air quality benefits, not least by avoiding the need for literally thousands of vehicles to slow down and then accelerate, in both directions, every day). Nevertheless, bureaucratic indifference from Essex County Council has meant that this idea is unfortunately little further advanced, despite its obvious benefits, including speeding up traffic flows on what is already one of the busiest A roads in the country.

In short, it is an 'inconvenient truth' that these two major roads are already virtually maxed out at peak times and any further local house building plans clearly have to take this serious constraint very much into account.

Unless the Government is seriously prepared to finance a major upgrade of the A127, to a largely three-lane M127 standard, (which would likely require upwards of a billion pounds), then major house building in the Rochford District should be strongly constrained.

Our local roads are extremely busy too. The B1013, which runs from Rayleigh, through Hockley and down into Hawkwell, is already one of the busiest B roads in the country, especially during the morning and evening peak. Also, the Ashingdon Road, leading from Ashingdon down through parts of Hawkwell into Rochford, is also a very busy road, as anyone who has used it regularly during the rush hour can testify. This is one of the reasons why I spoke out so forcibly at Rochford District Council's Development Committee against the recent Bloor Homes application to build 662 properties just off the Ashingdon Road, which I am pleased to say that RDC resolved to oppose (and which may now go to appeal as a result).

In any future plans for more housing in the Rochford District, a vital question will be, where will the accompanying new roads be built/expanded - and, crucially, who will pay for them? For all the reasons outlined above, it is important to raise this absolutely key issue now, before any new Local Plan is formulated.

Pressure on NHS Services

I declare a potential interest in raising the topic of pressure on NHS services, as my partner works as a Radiographer at an NHS hospital. Indeed, she has worked for the NHS for nearly two decades now. Nevertheless, this has helped to provide me with some additional insight into the pressure our hospitals and the wider NHS has been under, especially as a result of the Covid-19 pandemic.

Essex has five major District General Hospitals, arranged roughly in a star pattern, with Chelmsford (Broomfield) in the centre and the others in Harlow (North West); Colchester (North East); Basildon (South West) and Southend (South East). In 2020, Basildon, Broomfield and Southend came together to form the Mid Essex Hospitals NHS Trust. Even prior to the Covid-19 pandemic, all five hospitals were already under pressure and the pandemic has obviously exacerbated these problems further.

As far as I am aware, none of the forty hospitals earmarked for new construction and/or major rebuilds are currently earmarked for Essex and despite the best efforts of dedicated NHS staff, pressure on our hospitals in Essex and, in the case of RDC on Southend Hospital in particular, is only likely to be exacerbated by further major house building in South East Essex. NHS planners and the senior management of the Mid Essex Trust clearly need to take these additional pressures into account and a solution must be found or any major house building should be delayed until it is.

Access to primary care and GP appointments in particular is an increasing issue across the Rochford District as, again, the NHS seeks to rebalance in emerging from the pandemic. The reorganisation of Clinical Commissioning Groups (CCGs), which seek to co-ordinate primary care services and commission hospital care as well, from five CCGs to one across South Essex, is now being superseded by the creation of larger Integrated Care Systems (ICSs) which seek to more closely co-ordinate NHS and social care services.

A new Mid and South Essex ICS (which should mirror the area covered by Basildon, Broomfield and Southend Hospitals) is now scheduled to begin operating from April 2022 onwards. As well as these senior level organisations within our local NHS, any further expansion in the local population will need to be accompanied by a commensurate addition in the availability of primary care services, especially GPs. With the trend in recent years towards fewer but larger practices, there is a need to consider expanding the physical size of a number of practices (as, for instance, was achieved with the new extension to the Audley Mills practice in Rayleigh, several years ago). Similarly, just across the boundary in the Basildon Borough Council area, a major new surgery building was opened in Wickford town centre (also part of my Rayleigh and Wickford Constituency) just a few years ago.

However, the Riverside Surgery at Hullbridge secured planning permission several years ago to expand its first floor, to include extra consulting tooms and administration space, to cope with the expansion in the local population, including from the new Barratt David Wilson development of some 500 homes at nearby Malyons Farm. Nevertheless, several years on, mainly due to internal NHS bureaucracy, the work has still not commenced, despite the fact that houses on the new development are already being occupied in some numbers.

This complicated and highly bureaucratic process of 'passporting' developer contributions (which themselves often take years to come through), via local councils, to NHS organisations and then finally onto GP surgeries that need to expand to cater for more patients, clearly needs to be radically speeded up, a point which I intend to pursue with Government Ministers.

As well as physical buildings, an additional challenge is finding new GPs and other medical professionals to work in them. The establishment several years ago of a new Medical School at the Chelmsford campus of Anglia Ruskin University (ARU), an initiative which I strongly supported, may help in this respect. Within a couple of years, the first medical students should begin to graduate as Doctors from ARU (with around 100 or so then expected to do so each year). A number of these students are already working in Essex hospitals and GP practices and some of them will hopefully remain in Essex when they qualify. Via this route, we will hopefully be able to replenish or, over time. even increase the number of GPs working in Essex, as any increasing population will clearly require.

In fairness to the Government, it had already committed record amounts of additional spending to the NHS, even prior to the pandemic, with an increase of some £34 billion per year already programmed in by the end of this Parliament, under the NHS Long Term Plan. This significant extra investment will hopefully help boost NHS services in Essex, including in other vital areas, such as mental health too. However, it is also very important that extra resources being put into the NHS are focused on patient care and genuinely expanding NHS capacity, rather than merely multiplying NHS bureaucracy.

Nonetheless, in addition to additional Government resources, paid for out of general taxation, I believe that property developers, who are already making very comfortable profit margins from large scale housing developments, should be able to contribute considerably greater resources towards expansion of local NHS facilities than they do now, either via revised Section 101 agreements, the Community Infrastructure Levy (CIL), or similar instruments. This should be an important component of any Local Plan.

Pressure on Education and school places

Educational standards across the Rochford District are generally high and across Essex as a whole, some 90% of schools are now rated as Good or Outstanding by OFSTED. Perhaps unsurprisingly, therefore, there is continued pressure on school places ,especially at the most popular schools.

The four secondary schools in the Rochford District, which are all now Academies, have either all benefited (or are now due to benefit) from upgrades and an expansion in capacity in recent years. In Rayleigh, both FitzWimarc and Sweyne Park schools now have their own sixth forms (I campaigned for and subsequently opened both of them) and FitzWimarc has recently opened a new block, paid for largely by a grant from the Department for Education (DfE). Sweyne Park has just completed construction of a new block of several additional classrooms, financed mainly in this instance by Section 106 contributions from major housing developments in the area.

Greensward Academy in Hockley also has a sixth form and benefited from a major £14 million rebuild several years ago, paid for by the DfE following it becoming one of the first Academies to be established outside of the inner cities.

King Edmund School (KES) in Ashingdon, which also has a sixth form, is also now due for a major rebuild, following the discovery of serious building defects in some parts of the school buildings last year. Having recently been awarded a multi-million pound grant from the DfE to help finance these new facilities, including a large new block of classrooms, it is now hoped that the new block will be open for KES pupils by the commencement of the 2023/24 academic year.

The sixth forms at all for schools have proved popular and have now begun to provide many pupils and their parents with a very viable alternative to the four grammar schools in nearby Southend. However, despite their significant expansions, it will still be important to ensure that any availability of places at these four major schools can keep pace with any increases in demand from additional house building, over the lifetime of the plan.

At primary school level, there has not been the same across the board expansion in capacity as at secondary level within the Rochford District. Essex County Council, as the Local Education Authority (LEA) uses a highly formulaic method of calculating the need for new school places at primary level, based largely on birth rate data from NHS Trusts, extrapolated forward to calculate the demand for school places several years on.

However, this method, which is updated on an annual basis, is not good at capturing additional demand created 'in year' by families moving into the District and rapidly requiring school places, before the commencement of the new academic year each September.

In fairness, Essex County Council has sometimes been willing to temporarily expand capacity at some primary schools (as for instance at Riverside Academy in Hullbridge, prior to the pandemic) but as an LEA, Essex is often slower to react to the need to expand places at primary rather than secondary level and popular schools, even when they have become Academies, are still often discouraged from further expansion by excessive, 'Soviet style' bureaucracy at County Hall.

As one example of this, the new Countryside development in Rayleigh has set aside a plot for a new primary school, or alternatively ECC could expand capacity 'offsite' at nearby primary schools instead - with the developer paying for either option, via already agreed Section 106 contributions. However, despite some four years of being asked to make a choice, of one or the other, ECC has still refused to take a decision. In my view, ECC's highly dirigiste system for expanding school capacity at primary level, should be completely reviewed, from top to bottom, in order to allow successful schools to expand and to cater for any additional school places which may be required over the lifetime of RDC's new Local Plan.

Flood Risk

The issue of flooding and building in areas liable to flooding has long been an emotive issue in Essex, reach back as far as the Great Flood of 1953, in which a number of Essex residents unfortunately lost their lives, including nearby on Canvey Island.

As well as the North Sea immediately to the East, there are a number of rivers in the Rochford District, including the Crouch and Roach, plus a number of smaller tributaries and streams/brooks which permeate parts of the District, as far across as Rayleigh and Rawreth.

Given the pressure to release land for house building, there may be a temptation to recommend building in areas at potential risk of flooding, be it tidal or as a result of surface water run-off and/or local drainage systems being overwhelmed, during period of exceptionally heavy rainfall (such as unfortunately happened in Rayleigh and some other parts of the District in 2014). Building major housing estates only increases these risks and adds to pressure on the already pressurised local drainage network.

Even allowing for more modern flood management technology, such as Sustainable Drainage Systems (SUDS) on modern housing developments, it seems sensible, not least from both an environmental and safety standpoint, to strictly constrain house building ambitions in any areas which may be liable to flooding, for whatever reason. Again, given the specific geography and topography pf the Rochford District, this is an important consideration in formulating any new Local Plan.

Summary

Clearly, there has to be some limited future house building in the Rochford District, as young people cannot be expected to live at home with their parents into their 50's. Nevertheless, any such development has to be sustainable, both environmentally and economically.

Given the physical geography of the Rochford District and the constraints on its existing infrastructure, especially its road infrastructure, there should be strict limits on any major house building without major new investment in supporting infrastructure, whether financial by central Government; regional bodies such as the South East Local Enterprise Partnership (SELEP), Essex County Council or property developers hoping to profit from future developments in the Rochford District, or a combination of all four.

In this response to RDC's consultation I have sought to flag up a number of key infrastructure issues, including transport constraints, growing pressures on local NHS services, competition for school places and the dangers of building in areas of potential flood risk, all of which will require significant investment, if future house building is to be achieved, without a detrimental effect on my constituents. I trust that these comments will be taken into account as RDC evolves its new Local Plan over the next two years or so.

In view of the repeated references to the need for infrastructure investment contained in this letter, I am copying this response to a number of potentially interested parties, in both central and local Government. These include the Rt Hon Michael Gove MP, the Secretary of State at the Ministry of Housing, Communities and Local Government (MHCLG) and his Housing and Planning Minister, Christopher Pincher MP. I have also sent it to the Rt Hon Sajid Javid MP, the Secretary of State for Health and Social Care; the Rt Hon Nadim Zahawi MP, the Secretary of State for Education and to the Rt Hon Grant Shapps, the Transport Secretary, as well as to Christian Brodie, the Chairman of the South East Local Enterprise Partnership (SELEP), which includes Essex within its remit.

I have also copied it to County Councillor Kevin Bentley, the Leader of Essex County Council; County Councillor Lee Scott, Cabinet Member for Highways and Sustainable Transport at County Hall and also to County Councillor Tony Ball, ECC's Cabinet Member for Education and Lifelong Learning.

Dear Mr Stephenson,

Response to Rochford District Consultation on New Local Plan

I am writing to you regarding Rochford District Council (RDC) consultation on your emerging new Local Plan. Please regard this letter as my formal response to your consultation. I have set out my comments under what I hope are a number of relevant headings below. In the interests of transparency, I declare an interest as a local resident myself, having lived in Essex for half a century and now in Rayleigh for a little over twenty years.

General Points

We obviously need to build some new homes in Rochford District over the next two decades, as we cannot expect people to live at home with their parents into their 50's. Nevertheless, the whole thrust of this letter is that there should be no further major housebuilding in the Rochford District without significant infrastructure investment first. Any new Local Plan has to be both environmentally and economically sustainable and must safeguard the interests of existing residents, as well as new ones.

Background

RDC has initiated this consultation, as part of the process of updating its Local Plan, an overall process which is likely to take around a further two years to complete. Once the draft plan, which should then cover the period out to 2040 has been formulated, this process should then include an examination in public by an Inspector from the Planning Inspectorate, at which I would like to request an opportunity to give evidence as one of the local MPs, when the time comes.

However, in the meantime, before RDC begins to finalise its new plan, the Council has sought early feedback from local residents, and I hope that as many as possible will have taken the Council up on its suggestion and provided comments of their own.

In my response, I have sought to make some important general points about the need to ensure that any future housebuilding is accompanied by the necessary expansion of local infrastructure. If that cannot be guaranteed, then I believe that major house building in the District should be resisted until it can.

Geography

Much of the Rochford District is effectively contained in a peninsula, bounded by the Thames Estuary to the South (beyond the Borough of Castle Point); the North Sea to the East and the River Crouch to the North, which forms a border for much of its length with the neighbouring Maldon District.

As a result of this, there are only a limited number of major routes into and out of the District, which are a major consideration in formulating any new plan.

Transport Corridors and Constraints

Rochford District is connected to the capital via a direct rail route into London Liverpool Street. This has been upgraded in recent years, with major investment in new overhead wires, longer trains with increased capacity and the upgrade of some platforms, plus a new station at Southend airport.

Prior to the Covid-19 pandemic, trains in the morning and evening rush hour were bursting to capacity. Passenger numbers are now recovering as we finally emerge from Lockdown but the extent to which capacity problems on the line will re-emerge will partly be determined by how working patterns alter post-pandemic and the extent to which people are permitted/desire to work from home, as opposed to a return to regularly commuting into London, in the traditional manner.

Rail capacity should be expanded further, when the much-delayed Crossrail (now named the Elizabeth Line) eventually opens across London, hopefully now no later than 2023. The Public Accounts Committee (PAC) on which I now sit, recently took evidence on Crossrail and is now likely to publish its latest report on the project, within the next few weeks.

In terms of air travel, unfortunately due to the loss of traffic resulting from the pandemic, both EasyJet and Ryanair have recently withdrawn scheduled passenger services from Southend, leaving the airport largely dependent on freight traffic and aircraft maintenance work for its survival. Hopefully, regular passenger services, including to popular holiday destinations, might be resumed once the economy has fully recovered, although this is by no means guaranteed.

However, the major constraint in terms of transport links to and from the Rochford District is undoubtedly the road network, which in many cases is already seriously overstretched. The two main road arteries leading to/from Rochford District are the A127 and A13.

In spite of a number of junction improvements in recent years on the A13 and A127 and widening schemes on the A13, both of these major roads are already at or very close to full capacity at rush hour. An Essex County Council A127 Task Force meeting, held a little before the pandemic struck, examined the 'heat maps' for both roads (i.e. the busier the road, the darker the shade of red on the map). These showed that in both the morning and evening rush hour, both roads glowed very deep red, with both at between 98% to 100% capacity. As we have emerged from Lockdown (and indeed as many people have avoided public transport, because of the virus) traffic levels are now virtually back to pre-pandemic levels already.

Despite some limited opportunities for modal shift (both roads are highly sustainable for cycle lanes, which would be subject to heavy traffic pollution anyway) there is a strong culture of private car use in South Essex, which many residents see as part of living in a free society. This seems unlikely to be altered by entreaties to simply abandon private car use, however well-intentioned (especially as some of those making such calls use their own private cars frequently as well).

DEFRA has been concerned for some time about air quality issues, especially along the A127 and has effectively compelled neighbouring Basildon Borough Council to implement a number of air quality initiatives, in order to obviate the imposition of a formal air quality zone in the Basildon/Pitsea area, close to the RDC boundary. Over the lifetime of the proposed new plan, this problem may be partially alleviated by the increasing introduction of electric vehicles but, while this may well deliver environmental benefits, it still does not solve the issue of the sheer volume of traffic already using both roads in the early 2020s, let alone by the late 2030s.

Along with some others, I have been calling for several years for a straightening out of the old Fortune of War junction on the A127 at Laindon (which itself would be likely to deliver air quality benefits, not least by avoiding the need for literally thousands of vehicles to slow down and then accelerate, in both directions, every day). Nevertheless, bureaucratic indifference from Essex County Council has meant that this idea is unfortunately little further advanced, despite its obvious benefits, including speeding up traffic flows on what is already one of the busiest A roads in the country.

In short, it is an 'inconvenient truth' that these two major roads are already virtually maxed out at peak times and any further local house building plans clearly have to take this serious constraint very much into account.

Unless the Government is seriously prepared to finance a major upgrade of the A127, to a largely three-lane M127 standard, (which would likely require upwards of a billion pounds), then major house building in the Rochford District should be strongly constrained.

Our local roads are extremely busy too. The B1013, which runs from Rayleigh, through Hockley and down into Hawkwell, is already one of the busiest B roads in the country, especially during the morning and evening peak. Also, the Ashingdon Road, leading from Ashingdon down through parts of Hawkwell into Rochford, is also a very busy road, as anyone who has used it regularly during the rush hour can testify. This is one of the reasons why I spoke out so forcibly at Rochford District Council's Development Committee against the recent Bloor Homes application to build 662 properties just off the Ashingdon Road, which I am pleased to say that RDC resolved to oppose (and which may now go to appeal as a result).

In any future plans for more housing in the Rochford District, a vital question will be, where will the accompanying new roads be built/expanded - and, crucially, who will pay for them? For all the reasons outlined above, it is important to raise this absolutely key issue now, before any new Local Plan is formulated.

Pressure on NHS Services

I declare a potential interest in raising the topic of pressure on NHS services, as my partner works as a Radiographer at an NHS hospital. Indeed, she has worked for the NHS for nearly two decades now. Nevertheless, this has helped to provide me with some additional insight into the pressure our hospitals and the wider NHS has been under, especially as a result of the Covid-19 pandemic.

Essex has five major District General Hospitals, arranged roughly in a star pattern, with Chelmsford (Broomfield) in the centre and the others in Harlow (North West); Colchester (North East); Basildon (South West) and Southend (South East). In 2020, Basildon, Broomfield and Southend came together to form the Mid Essex Hospitals NHS Trust. Even prior to the Covid-19 pandemic, all five hospitals were already under pressure and the pandemic has obviously exacerbated these problems further.

As far as I am aware, none of the forty hospitals earmarked for new construction and/or major rebuilds are currently earmarked for Essex and despite the best efforts of dedicated NHS staff, pressure on our hospitals in Essex and, in the case of RDC on Southend Hospital in particular, is only likely to be exacerbated by further major house building in South East Essex. NHS planners and the senior management of the Mid Essex Trust clearly need to take these additional pressures into account and a solution must be found or any major house building should be delayed until it is.

Access to primary care and GP appointments in particular is an increasing issue across the Rochford District as, again, the NHS seeks to rebalance in emerging from the pandemic. The reorganisation of Clinical Commissioning Groups (CCGs), which seek to co-ordinate primary care services and commission hospital care as well, from five CCGs to one across South Essex, is now being superseded by the creation of larger Integrated Care Systems (ICSs) which seek to more closely co-ordinate NHS and social care services.

A new Mid and South Essex ICS (which should mirror the area covered by Basildon, Broomfield and Southend Hospitals) is now scheduled to begin operating from April 2022 onwards. As well as these senior level organisations within our local NHS, any further expansion in the local population will need to be accompanied by a commensurate addition in the availability of primary care services, especially GPs. With the trend in recent years towards fewer but larger practices, there is a need to consider expanding the physical size of a number of practices (as, for instance, was achieved with the new extension to the Audley Mills practice in Rayleigh, several years ago). Similarly, just across the boundary in the Basildon Borough Council area, a major new surgery building was opened in Wickford town centre (also part of my Rayleigh and Wickford Constituency) just a few years ago.

However, the Riverside Surgery at Hullbridge secured planning permission several years ago to expand its first floor, to include extra consulting tooms and administration space, to cope with the expansion in the local population, including from the new Barratt David Wilson development of some 500 homes at nearby Malyons Farm. Nevertheless, several years on, mainly due to internal NHS bureaucracy, the work has still not commenced, despite the fact that houses on the new development are already being occupied in some numbers.

This complicated and highly bureaucratic process of 'passporting' developer contributions (which themselves often take years to come through), via local councils, to NHS organisations and then finally onto GP surgeries that need to expand to cater for more patients, clearly needs to be radically speeded up, a point which I intend to pursue with Government Ministers.

As well as physical buildings, an additional challenge is finding new GPs and other medical professionals to work in them. The establishment several years ago of a new Medical School at the Chelmsford campus of Anglia Ruskin University (ARU), an initiative which I strongly supported, may help in this respect. Within a couple of years, the first medical students should begin to graduate as Doctors from ARU (with around 100 or so then expected to do so each year). A number of these students are already working in Essex hospitals and GP practices and some of them will hopefully remain in Essex when they qualify. Via this route, we will hopefully be able to replenish or, over time. even increase the number of GPs working in Essex, as any increasing population will clearly require.

In fairness to the Government, it had already committed record amounts of additional spending to the NHS, even prior to the pandemic, with an increase of some £34 billion per year already programmed in by the end of this Parliament, under the NHS Long Term Plan. This significant extra investment will hopefully help boost NHS services in Essex, including in other vital areas, such as mental health too. However, it is also very important that extra resources being put into the NHS are focused on patient care and genuinely expanding NHS capacity, rather than merely multiplying NHS bureaucracy.

Nonetheless, in addition to additional Government resources, paid for out of general taxation, I believe that property developers, who are already making very comfortable profit margins from large scale housing developments, should be able to contribute considerably greater resources towards expansion of local NHS facilities than they do now, either via revised Section 101 agreements, the Community Infrastructure Levy (CIL), or similar instruments. This should be an important component of any Local Plan.

Pressure on Education and school places

Educational standards across the Rochford District are generally high and across Essex as a whole, some 90% of schools are now rated as Good or Outstanding by OFSTED. Perhaps unsurprisingly, therefore, there is continued pressure on school places ,especially at the most popular schools.

The four secondary schools in the Rochford District, which are all now Academies, have either all benefited (or are now due to benefit) from upgrades and an expansion in capacity in recent years. In Rayleigh, both FitzWimarc and Sweyne Park schools now have their own sixth forms (I campaigned for and subsequently opened both of them) and FitzWimarc has recently opened a new block, paid for largely by a grant from the Department for Education (DfE). Sweyne Park has just completed construction of a new block of several additional classrooms, financed mainly in this instance by Section 106 contributions from major housing developments in the area.

Greensward Academy in Hockley also has a sixth form and benefited from a major £14 million rebuild several years ago, paid for by the DfE following it becoming one of the first Academies to be established outside of the inner cities.

King Edmund School (KES) in Ashingdon, which also has a sixth form, is also now due for a major rebuild, following the discovery of serious building defects in some parts of the school buildings last year. Having recently been awarded a multi-million pound grant from the DfE to help finance these new facilities, including a large new block of classrooms, it is now hoped that the new block will be open for KES pupils by the commencement of the 2023/24 academic year.

The sixth forms at all for schools have proved popular and have now begun to provide many pupils and their parents with a very viable alternative to the four grammar schools in nearby Southend. However, despite their significant expansions, it will still be important to ensure that any availability of places at these four major schools can keep pace with any increases in demand from additional house building, over the lifetime of the plan.

At primary school level, there has not been the same across the board expansion in capacity as at secondary level within the Rochford District. Essex County Council, as the Local Education Authority (LEA) uses a highly formulaic method of calculating the need for new school places at primary level, based largely on birth rate data from NHS Trusts, extrapolated forward to calculate the demand for school places several years on.

However, this method, which is updated on an annual basis, is not good at capturing additional demand created 'in year' by families moving into the District and rapidly requiring school places, before the commencement of the new academic year each September.

In fairness, Essex County Council has sometimes been willing to temporarily expand capacity at some primary schools (as for instance at Riverside Academy in Hullbridge, prior to the pandemic) but as an LEA, Essex is often slower to react to the need to expand places at primary rather than secondary level and popular schools, even when they have become Academies, are still often discouraged from further expansion by excessive, 'Soviet style' bureaucracy at County Hall.

As one example of this, the new Countryside development in Rayleigh has set aside a plot for a new primary school, or alternatively ECC could expand capacity 'offsite' at nearby primary schools instead - with the developer paying for either option, via already agreed Section 106 contributions. However, despite some four years of being asked to make a choice, of one or the other, ECC has still refused to take a decision. In my view, ECC's highly dirigiste system for expanding school capacity at primary level, should be completely reviewed, from top to bottom, in order to allow successful schools to expand and to cater for any additional school places which may be required over the lifetime of RDC's new Local Plan.

Flood Risk

The issue of flooding and building in areas liable to flooding has long been an emotive issue in Essex, reach back as far as the Great Flood of 1953, in which a number of Essex residents unfortunately lost their lives, including nearby on Canvey Island.

As well as the North Sea immediately to the East, there are a number of rivers in the Rochford District, including the Crouch and Roach, plus a number of smaller tributaries and streams/brooks which permeate parts of the District, as far across as Rayleigh and Rawreth.

Given the pressure to release land for house building, there may be a temptation to recommend building in areas at potential risk of flooding, be it tidal or as a result of surface water run-off and/or local drainage systems being overwhelmed, during period of exceptionally heavy rainfall (such as unfortunately happened in Rayleigh and some other parts of the District in 2014). Building major housing estates only increases these risks and adds to pressure on the already pressurised local drainage network.

Even allowing for more modern flood management technology, such as Sustainable Drainage Systems (SUDS) on modern housing developments, it seems sensible, not least from both an environmental and safety standpoint, to strictly constrain house building ambitions in any areas which may be liable to flooding, for whatever reason. Again, given the specific geography and topography pf the Rochford District, this is an important consideration in formulating any new Local Plan.

Summary

Clearly, there has to be some limited future house building in the Rochford District, as young people cannot be expected to live at home with their parents into their 50's. Nevertheless, any such development has to be sustainable, both environmentally and economically.

Given the physical geography of the Rochford District and the constraints on its existing infrastructure, especially its road infrastructure, there should be strict limits on any major house building without major new investment in supporting infrastructure, whether financial by central Government; regional bodies such as the South East Local Enterprise Partnership (SELEP), Essex County Council or property developers hoping to profit from future developments in the Rochford District, or a combination of all four.

In this response to RDC's consultation I have sought to flag up a number of key infrastructure issues, including transport constraints, growing pressures on local NHS services, competition for school places and the dangers of building in areas of potential flood risk, all of which will require significant investment, if future house building is to be achieved, without a detrimental effect on my constituents. I trust that these comments will be taken into account as RDC evolves its new Local Plan over the next two years or so.

In view of the repeated references to the need for infrastructure investment contained in this letter, I am copying this response to a number of potentially interested parties, in both central and local Government. These include the Rt Hon Michael Gove MP, the Secretary of State at the Ministry of Housing, Communities and Local Government (MHCLG) and his Housing and Planning Minister, Christopher Pincher MP. I have also sent it to the Rt Hon Sajid Javid MP, the Secretary of State for Health and Social Care; the Rt Hon Nadim Zahawi MP, the Secretary of State for Education and to the Rt Hon Grant Shapps, the Transport Secretary, as well as to Christian Brodie, the Chairman of the South East Local Enterprise Partnership (SELEP), which includes Essex within its remit.

I have also copied it to County Councillor Kevin Bentley, the Leader of Essex County Council; County Councillor Lee Scott, Cabinet Member for Highways and Sustainable Transport at County Hall and also to County Councillor Tony Ball, ECC's Cabinet Member for Education and Lifelong Learning.

Assuming emails will be accepted and previous near impossible navigation if the whole document is not required then I provide the following comments; observations and objections on the spatial options using CFS064 as an example and objecting to.that and development of Bull Lane; Napier Road and Wellington Road as well.

1) the whole process is flawed. Even at the "tail" of the pandemic some residents are unable or unwilling to contribute because of issues in attending events and/or lack of internet access preventing them viewing the proposals.

2) the central Government building requirements are based upon ideas originally drawn up by John Prescott in a Labour government. They do not take account of fundamental changes in working environment brought about by factors such as technology; COVID; and the demise of the High St. This may well see more town and city space particularly in London becoming available for accommodation. I am aware of a number of London companies "hotdesking" workers and essentially having only 50% attending on any one day. Couple this with the ability to store and use data electronically it is clear lots of office space will become available and the knock on effect may be other city shops close as there are less people using them. This relieves pressure on surrounding areas for building of more homes

3) the local plans take little account of the need to maintain open spaces. As seen in the Pandemic these were crucial for wellbeing. Plans involving building on Hockley Woods and fields around Betts Wood are not credible.

4) plans to build on areas around Bull Lane Nelson; Napier; and Wellington Roads put in jeopardy RDC's pledge to maintain gaps between the various towns and villages in the area. Here in particular the Hockley and Rayleigh buffer is already eroded by Bullwood Hall developments and new properties added to Turret Farm ( were these approved)

5) proposals to release agricultural land. Anyone who walked around the area in the pandemic will be well aware many of these plots are apparently used for growing food. Given current supply problems and the growing need to feed people this element seems to be fundamentally flawed.

6) it is clear from your own Q&A councils are out of their depth. Several correspondents have already raised the issue of the lack of infrastructure and the response has been GP surgeries; schools etc only need to be provided for large developments (approx 1000 houses). Clearly house builders know how to play the game and avoid such commitments (and provision of sufficient affordable housing).

7) in relation to several of the points above why all the councils (predominantly tory) in the Thames Gateway do not group together to lobby Tory central government for more power to determine their plans and to reach a better outcome for developments than seeing inner London borough's rent or buy large swathes of housing stock.

8) as with 3 above will Southend Airport remain open? Believe this is leased by RDC to Southend BC but, given the lack of passenger flights and income; one wonders if it will last. Is lease income being maintained? Is airport being subsidised? Would make ideal building plot

9)There is also a need to maintain historic and scientific areas as well as minimising impact on wildlife using green belt impacts all these

10) the roads are gridlocked at peak times and delivery times. Especially B1013. This is already the busiest B road in the county and adding any development in the vicinity is going to make this worse. Impacting health and particularly that of children in schools along the route RDC will be aware of the Coroner's findings in respect of the death of Ella Kissi-Debrah where air pollution was given as the cause. Perhaps RDC can confirm they have addressed all current air pollution problems and fully and correctly assessed all risks of this nature were further developments to take place

Land identified for potential Housing Development
Having read through proposals for potential development sites I am shocked at the number and location of some of the sites and the impact they will surely have on the local environment, the people, squeeze on existing services including hospitals, schools and shops, bus routes, railways and not forgetting roads.

This corner of South East Essex is already fit to burst as evidenced by the traffic volumes exiting the Southend area on a daily basis by whatever route possible with the consequent impact on pollution and noise in areas like Rochford, Hawkwell, Ashingdon and Hockley in particular. There is little or nothing that can be done on any of the major (and minor) routes serving this part of Essex.

The A127 could not be widened before it leaves Eastwood being developed on both sides; the A13 could not be touched before Sadler’s Farm roundabout due to being developed on both sides from Shoebury through to Benfleet; The Eastwood Road is residential all the way from Kent Elms corner to Rayleigh; the Hockley Road (including Hall Road, Alderman’s Hill, etc) from Rochford Station to Rayleigh is almost entirely residential on both sides other than in Rochford & Hawkwell and if the sites located on this route are developed that will only serve to clog the roads downstream to the west even more; Lower Road from Ashingdon through to Battlesbridge might prove the only logical route other than the impact on green belt and farm land, or finally something running along the estuary from Southend linking to the A13 way out west.

Add to the last paragraph the simple issue of road safety where schools are currently situated along or close to the routes, a growing elderly population who still have a right to safe walking or wheelchair routes, and the likely huge increase in pollution affecting the quality of all our lives who abide in this area.

It can not have escaped your notice that job opportunities for anyone moving into the area are limited since there are no major employers setting up here and so one must assume anyone moving here and already having a career will either commute by train or road towards the west including London. Looking specifically at trains, the services in the morning and evening peaks are already at capacity from Rayleigh onwards and that ignores the train travel along the Fenchurch St line from Leigh on Sea equally at capacity. The railway safety case will not support more train movements at peak along the two lines servicing S. E. Essex and lengthening the trains to increase capacity would prove an issue where existing station platforms could not cater for longer trains.

Has anyone checked the home locations of those holding title to the land where proposals for inclusion on the list of potential sites? If anyone doesn’t live locally surely they are after "make a fast buck” and not having a care for the environment or local residents?

I’m sure many of these issues have been discussed and dismissed due to blind obedience to government dictate. Nevertheless I feel sure allowing any of these developments to proceed without first making significant change to local infrastructure to cope in future, so that local residents will not be adversely impacted by heavy goods vehicles thundering through our towns villages adding to the problems mentioned above.

I wish to object to the proposed sites that have been put forward in the spatial options - NO MORE houses or accommodation should be built.

The local infrastructure is totally lacking and simply cannot cope with any more traffic - Essex are incapable of any basic highway maintenance let alone with coming up with a new plan to ease the traffic. The roads between Rayleigh, Hockley and Southend are gridlocked during both morning and afternoon rush hours. Our local hospitals/GPs/schools are all full to capacity so any increase in numbers will be a disaster for the local communities.

Our greenbelt needs to be protected - mental health is on the increase and if we build upon our greenbelt and therefore take away our natural nature where people can walk and connect then there will be even more mental health problems.

Infrastructure and transport needs should be a consideration NOW for what is already a congested / over subscribed area BEFORE any more development. The online Spatial Plan is extremely difficult to interpret due to when enlarging an area names / writing disappears and also switching back and forth to map / legends is confusing.

The money that Essex County Council has in a pot set aside for the Hall Rd development should be released in order that the school etc should be put forward for development. I understand this money can be released back to the originating developers if it is not utilised within a certain period of time. Is this true?

When will Essex Highways get their act together and spend some money on sorting our roads??

Persimmon Homes is a FTSE 100 housebuilder with a national presence. In 2020 the Group delivered 13,575 new homes, down from 15,855 in 2019 (largely in part due to the impact from Covid-19 on operations), although the selling price increased by about seven per cent.
Persimmon Homes has a strong presence in Rochford, having an option to deliver site CFS087: Land between Western Road and Weir Farm Road Rayleigh, and are actively seeking additional sites in Rochford to deliver much needed housing and regeneration in the Borough. Persimmon Homes welcomes the opportunity to comment on the New Local Plan Spatial Options Consultation Paper 2021.

In the short term, Persimmon Homes is aware that Rochford’s existing Local Plan is now out of date, as per the tests of the NPPF. Ensuring that an adequate supply of housing is provided is a key policy requirement of the NPPF. The Rochford District Core Strategy, which was adopted in December 2011, fails to meet the requirements of the NPPF. Therefore, it is imperative that the draft Local Plan continue to be progressed to allow it to be adopted as soon as possible so that the District can continue to plan effectively to meet the District’s ongoing needs.

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

The technical evidence that Rochford is preparing is comprehensive, though we would suggest the following additional evidence (which may be included within the evidence base documents listed) will also be required to inform the new Local Plan:

Heritage

An ‘initial Heritage Assessment’ is listed, which is vague, which is not sufficiently detailed or robust to properly consider the relationship of heritage assets and emerging site allocations. Persimmon Homes is, in particular, concerned that it identifies site CFS087 as having a ‘moderate-adverse’ impact on the Grade II listed Weir Farmhouse, despite this asset being located some distance from site CFS087 and screened from view (as would have been evidence if Place Services had undertaken site visits) by existing mature vegetation and twentieth century housing developments. The heritage asset listed within Place Services report therefore has no relationship with our allocated site, and cannot be seen from the site.

It is recommended therefore that the Council’s Heritage Evidence Base will need to be properly updated to include, at a minimum, some or all of the following:

• A Heritage Asset Review, to assess the significance of heritage assets and the contribution they make to their environment;
• Lists of Buildings of Local Architectural or Historic Interest;
• Conservation Area Character Appraisals Programme – noting that these were last reviewed in 2008 and therefore these need updating so that the Council have up to date evidence and therefore able to properly consider applications affecting these assets;
• Historic Environment Characterisation Studies; and
• Heritage Impact Assessments, and Archaeological Evaluation Reports, where relevant, on each allocated site. We would strongly recommend that these are prepared in accordance with each site developer and will need to involve site visits, rather than relying on a simple mapping exercise.

Highways

An ‘initial Transport Assessment’ is listed as being provided, which is a vague description and does not specify the required level of detail to support the Plan. It is recommended that this will need to include, at a minimum, some or all of the following:

• Transport evidence for the new Local Plan;
• Transport evidence mitigation;
• Sustainable Modes of Travel Strategy;
• Cycling Action Plan/Local Walking and Cycling Infrastructure Plan/Cycling Delivery Plan;
• Transport modelling of key strategic routes/junctions – the Spatial Options Document goes on to highlight the congestion affecting the road network, and identifies the improvements already planned for the A127 and Fairglen Interchange; and
• Infrastructure Delivery Plan.

Housing

Alongside the HELAA and SHMA, we would recommend the following:

• Self-Build Custom Build Housebuilding Register;
• Housing Implementation Strategy;
• Settlement Capacity Studies;
• Brownfield Land Registers;
• Schedule of Brownfield Sites and Extant Permissions; and
• Housing Trajectories.

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?

The draft vision at present appears to be too vague and lacks a real vision. It is clear that the two big challenges facing the country in the next 20-30 years are a lack of homes, particularly for both young and elderly, along with the impending threat of climate change and its attendant impacts. Therefore, both of these need to be reflected in the vision. Rochford should strive, in its local plan, to not only meet its housing supply but to plan beyond, as well as to meet the threat of climate change by encouraging
all developments to be ‘green’, to exceed climate change targets and to seek alternatives to the private car to transform how Rochford residents travel.
For example, the ‘Our Society’ vision needs to have a greater vision for the delivery of new housing and
supporting infrastructure. Rochford should welcome the challenge of building at least 360 homes per year, by choosing to focus on high quality developments and the attendant benefits of planning for the delivery of these homes.
Similarly, the ‘Our Environment’ vision does not refer to climate change, which is a missed opportunity, given the pressing need facing the Country in addressing Climate Change impacts and its repeated messages within the NPPF, particularly as detailed within Chapter 14, and at paragraph 153 which states that, “Plans should take a proactive approach to mitigating and adapting to climate change…”.
Alongside this, the Covid-19 pandemic has transformed how people work, with more people now choosing to work from home, more often. This needs to be reflected in the ‘Our Economy’ vision – can Rochford provide the employment hubs and flexible working conditions to meet the new ‘normal’ for example.

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

Persimmon Homes would agree that separate visions for each settlement would help guide decision making and notes, for example, the wide character as detailed within the settlement profiles from page 71 onwards of the Spatial Options paper. This confirms that Rochford ranges from Tier 1 Settlements such as Rayleigh with 34,000 residents, to isolated hamlets such as Paglesham and Stonebridge of only 250 residents. Clearly, the type and level of development is going to differ and a set of visions for each settlement would provide clarity to developers on the type, and level, of development that would be appropriate. Such vision statements could usefully be informed by the following:
 Historic Environment Characterisation Studies;
 Heritage Impact Assessments;
 Settlement Capacity Studies;
 Transport Studies and Strategies;
 Green Belt Studies;
 Strategic Land Availability Assessment;
 Flood Risk Assessments;
 Design and Development Briefs; and
 Masterplanning Studies

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?

The Spatial Options Paper lists 23 Strategic Options and Persimmon Homes broadly agrees with these, though we would have the following observations to make:
 Strategic Objective 1 – Persimmon Homes understands the Council’s reasons for looking to prioritise previously developed land first. However, the Paper goes onto confirm at page 29 that previously developed land will not be able to meet the Council’s housing targets in full; therefore there is no justification in prioritising previously developed land first. In many cases, greenfield sites are able to be brought forward quicker than previously developed land, particularly in the case of previously developed land having existing uses that need to be relocated first, or contaminated land that requires remediation. Accordingly, this objective could be reworded as follows:
“To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs, through working with our neighbours in South Essex and encouraging the redevelopment of previously developed land alongside suitably located greenfield sites to ensure the plan requirements are met in full.”
 Strategic Objectives 4 and 5 – these objectives could usefully reference the change in remote working patterns and confirm that Rochford will promote the use of flexible working practices to meet the needs of the ‘new normal’ arising from Covid-19, as well as offering flexible work
spaces to meet the needs of the 21st Century Office;
 Strategic Objective 6 – we would disagree with the phrasing ‘highest attainable quality’ as this is vague and imprecise; design is, to a large degree, subjective (particularly moreso where Local Authorities lack design codes and guides to guide the design of built form). We would therefore recommend the following revised wording:
“To ensure that all new homes and commercial premises are built to a high quality design and sustainability standard with a good level of access to green space and the countryside.”
 Strategic Objective 13 – this objective could usefully highlight Governments’ requirement to direct development to Flood Zone 1 (i.e. areas at the lowest risk of flooding);
 Strategic Objective 23 – the sole objective relating to climate change could usefully reflect Governments’ Future Homes’ requirement (being introduced in 2025).

Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think
are required?
Persimmon Homes would agree with the settlement hierarchy presented, which demonstrates that growth should be predominantly located at Rayleigh, Hockley and Rochford. As Rayleigh is the sole ‘Tier 1’ settlement, it is logical that as the Plan progresses, that Rayleigh takes a larger proportion of development than other settlements.

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

The NPPF makes it clear at para 61 that Local Planning Authorities should be looking to use the Standard Method to determine how many homes are required, stating, “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance…”.
Accordingly, it is confusing at Figure 15 that it includes a ‘current trajectory’ scenario of only 4,500 homes when this scenario will not deliver the Standard Method requirement of a minimum of 7,200 homes. The Council could, therefore, be clearer in this regard and confirm that this Scenario cannot be taken forward in isolation.
The Plan presents four options; Persimmon Homes would support a combination of Options 1 and 2.
Our comments of which are as follows:
 Strategic Option 1 – The Paper itself acknowledges that this Option will not be able to fully meet the Standard Method requirement, as well as acknowledging that it will not be able to deliver the brand new infrastructure that is required alongside new homes.
It is also identified within the Integrated Impact Assessment that the lower growth options will not deliver the required levels of growth, stating on page 25 that:
“The lower growth option will not meet the needs of all people in the district during the plan period. The medium and higher growth options will meet the needs of all people in the district and improve accessibility to housing, employment, training, health, and leisure opportunities.
The higher growth option is more likely to meet the needs of not only people in the district but beyond, as well and encourage the integration and interaction of cross-boundary communities through the delivery of large-scale developments. The medium and higher growth options are also considered for their overall potential to deliver a wider range of housing types, tenures and
sizes, particularly catering for the needs of groups with protected characteristics, such as specialist housing for the elderly and disabled.”
Furthermore, the Integrated Impact Assessment states that: “…smaller scale development proposals bring less opportunity for strategic infrastructure improvements, and may place increased pressure on local road networks.”
The Paper also identifies that said option to increase densities in urban areas are unlikely to be compatible with historic centres and local character, as confirmed within the Integrated Impact Assessment, which states:
“…it is recognised that the lower growth option will focus development in existing urban areas, with a higher potential in this respect to impact on historic centres.”
It also goes on to confirm
"Option 1 would not deliver sufficient housing to meet local needs over the Plan period, in this respect it is also likely to deliver less affordable housing and long-term negative effects can be anticipated.”
Again, we would request that the Council undertake updated Conservation Area Appraisals and Settlement Surveys so that the Council has the required evidence base to consider if increased densities, taller buildings etc. would be appropriate in the historic centres and urban areas, as this would help inform the actual number of dwellings available under this option.
We would also question that this Option uses sites that have retained site allocations from the 2011 Core Strategy, and would question why these sites have not been developed by now – are these sites developable and deliverable as per the tests of the NPPF. This is something that the District Council should review.
Accordingly, this option cannot be taken forward within the next stage of the Local Plan on its own, though it is acknowledged that some level of urban intensification on appropriate sites may be suitable to help meet the Standard Method.
 Strategic Option 2 – Option 2a proposes Urban Extensions focused in the main towns; as Rayleigh is the Districts sole Tier 1 settlement, it is logical and sensible that urban extensions should be focused in Rayleigh. Furthermore, it benefits from not being restricted by any flood zones, being sequentially preferable to many other settlements in the District.
The Spatial Options document identifies that this option would be able to deliver new infrastructure; meet local housing needs; and deliver quickly; all of which Persimmon Homes endorses.
This Option would also deliver the required level of growth required for employment needs, as confirmed within the Integrated Impact Assessment:
“The medium and higher growth options are more likely to have a significant positive effect on this IIA theme through the delivery of new employment land and retail floorspace. These options are also likely to deliver more new infrastructure upgrades and sustainable transport routes to attract further inward investment. Further to this, the higher growth options could contribute to the delivery of sub-regional improvements to green and blue infrastructure, which could have a positive effect on the tourism economy. Whilst positive effects are considered likely under all options, the lower growth option is considered less likely to lead to positive effects of
significance.”
It goes on to state:
“Urban extensions under Options 2a and 2b provide large scale development opportunities that can deliver new infrastructure provisions to support both existing (particularly those in edge of settlement locations) and future residents.”

It concludes:
“Significant positive effects are considered likely under Options 2a, 2b and 4.”
The delivery of sites under the medium and higher levels of growth would also allow for the delivery of climate change measures that are required and discussed later in the Spatial Options Document. The delivery of these measures may not be possible through reusing
existing buildings (Strategic Option 1) as confirmed within the Integrated Impact Assessment:
“…the delivery of large-scale growth that is more likely to come forward under the medium and high growth options present more opportunities for the delivery of low carbon infrastructure through economies of scale compared to the lower growth option.”
On the same theme, the medium and higher levels of growth options are much more likely to be able to deliver the biodiversity and green infrastructure improvements and contributions required, than on existing brownfield sites, as also confirmed within the Integrated Impact
Assessment:
“The medium and higher growth options are also noted for their potential to support the delivery of strategic green infrastructure provisions and associated biodiversity net gain. This includes improvements being explored in the green infrastructure network across the sub-region through the South Essex Green and Blue Infrastructure Study (2020), such as the Regional Parkland.
The Regional Parkland has the potential to act as alternative greenspace targeted at reducing recreational pressures at designated biodiversity sites. These options thus provide a greater contribution to the principles of the Essex Coast Recreational disturbance Avoidance &
Mitigation Strategy (RAMS).
The lower level of growth will mainly result in the delivery of new homes on urban and brownfield sites so has greater potential to avoid designated sites and support urban greening to some extent. The urban focus however is less likely to bring forward strategic mitigation, such as the Regional Parkland to mitigate the recreational pressures on designated biodiversity resulting from a growing population. As a result, the medium and higher growth options are considered more likely to perform better overall in relation to this IIA theme; however, the potential for a significant effect is uncertain as will be dependent on the location of growth.”
It continues:
“…the potential for larger-scale development under Options 2a and 2b is recognised for the potential for greater net gains in biodiversity.”
The site that Persimmon Homes is promoting – site CFS087 – would be capable of being delivered under this Option.
 Strategic Option 3 – The Spatial Options document identifies a number of significant ‘Cons’ which would impact upon the delivery of this option (and thus threaten the delivery of the plan as a whole), all of which we would agree with and would therefore recommend that this option is not progresses as:
o The plan identifies that this option involves complex land ownership issues which is likely to be difficult to resolve and address;
o Significant redrawing of the Green Belt boundaries, including proposing development in more sensitive Green Belt locations than other strategic options;
o Focussing development in a single location/settlement would deprive other settlements of being able to accommodate development, and thus potential infrastructure improvements.
On Environmental impacts, the Integrated Impact Assessment identifies that harm that this option would have on Environmental Quality, stating that:
“…extensive countryside development proposed through the concentrated growth options (Options 3a, 3b and 3c); which is considered highly likely to lead to negative effects of significance in this respect. Options 3a and 3b are also likely to intersect the flood plains of the Crouch and Roach tributaries, and development will need to ensure appropriate mitigation to avoid impacts on water quality…Negative effects of significance are considered more likely under Options 3a, 3b, 3c and 4 given the extent of concentrated growth development locations
in the countryside.”
 Strategic Option 4 – This option proposes a ‘balanced combination’ of all three; we would recommend a balanced combination of Options 1 and 2 represents the most suitable Spatial Strategy going forwards for the reasons given above and indeed as detailed within the Spatial Options document, and the Integrated Impact Assessment, which concludes:
“Option 4 is noted for its potential to perform better against a wider range of the IIA themes than the remaining options. This predominantly relates to the flexibility provided in a tailored approach, essentially combining the best performing aspects of each individual approach (urban intensification, urban extensions and concentrated growth).”

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

Southend are currently consulting on its ‘Local Plan - Refining the Plan Options’, with the Consultation running through until 26 October 2021. The NPPF is clear that Local Authorities should also plan to meet housing needs that cannot be met within neighbouring authority areas (para.61), stating that, “In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for”.
In this regard, it is noted that within their Plan proposes a ‘Development Opportunity D’ of c.10,000 homes, of which 4,900 homes lies within Rochford.
It is imperative, therefore, that Rochford works alongside Southend to understand if it needs to plan for these 4,900 new homes alongside its own minimum of 7,200 homes, which would need to be reflected within the next stage of the Rochford District Local Plan.

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

Persimmon Homes would request that further spatial themes topic papers are required, or updated, for:
 Place Making and Urban Design – further questions within the Spatial Options paper deal with design (Q14 – Q16), but as yet a corresponding topic paper has not been published to consider this issue. The NPPF places an increasingly strong emphasis on design, with the recent 2021 revision further emphasising the Governments’ commitment to building ‘beautiful’ homes and places, to be underpinned by Design Codes and guidance. Understanding how Rochford District Council intends to interpret this requirement will be key for Developers as the plan progresses and beyond.
 Flood Risk and Drainage – Briefly discussed within the Climate Change topic paper, but this issue needs to be sufficiently evidenced as the plan progresses.
 Landscape and Visual Impacts – As above.
 Heritage – The Heritage Topic Paper confirms that existing Conservation Area Appraisals date back to 2007 (if they exist at all) and that these, along with the ‘Local List’ may be updated as the Local Plan progresses. Persimmon Homes would strongly support this evidence being undertaken as understanding heritage impacts is often key, which cannot be understood without up to date evidence.
 Duty to Co-Operate and Strategy Options – As identified at Q7, these topic papers do not address the potential for Rochford needing to meet Southend’s housing needs, as is currently presented as a potential option within their new Local Plan ‘Refining the Plan Options’ 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?

Persimmon Homes strongly recommends that Rochford take the sequential approach to Flood Risk as required by paragraphs 161-162, confirming that new development should be directed to areas with the
lowest risk of flooding from any source.
The flood map at Climate Change and Resilient Environments Topic Paper identifies that the four
settlements least impacted by Flood Zones are Rayleigh, Hullbridge, Hockley and Ashingdon, and therefore these settlements are sequentially preferable for residential development to meet the Local Plan needs than those settlements that lie within Flood Zones 2 or 3 (such as Great Wakering).
We would also take this opportunity to identify to the Council that the site that Persimmon Homes is
promoting (Site CFS087: Land between Western Road and Weir Farm Road, Rayleigh) lies within Flood Zone 1 and is therefore sequentially more preferable than those sites being promoted that lie within Flood Zones 2 and 3.

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

Climate change is a principal risk for Persimmon Homes and a significant issue, with more extreme weather events such as heatwaves, rising sea levels and flooding being experienced and resulting in impacts of both global and local significance. Society is more environmentally conscious with the international community and Government taking a leading role to reduce greenhouse gas emissions by setting and legislating ambitious targets for all to achieve.
As one of the UK’s leading house builders we acknowledge our role in supporting these common aims.
We understand the risks and challenges that climate change presents to our business and the wider industry. We are proactively working with all stakeholders to more effectively integrate climate change issues within our operations and ensure that sustainable improvements are managed in a pragmatic and robust manner.
We recognise that we have a key role to play in minimising our contribution to climate change, through
our own operations, our supply chain and by striving to ensure that the homes and communities we build are sustainable, inherently energy efficient and encourage our customers to live in a way that minimises any impact to climate change. We are committed to working alongside all stakeholders to achieve this.
Working with the Carbon Trust, a global climate change and sustainability consultancy providing specialist support to assist businesses to reduce their greenhouse gas emissions, Persimmon has set ambitious targets to be net zero carbon in our homes in use by 2030 and in our operations by 2040.These targets are supported by interim science based carbon reduction targets to reduce greenhouse gas emissions from our own operations by 46.2% (2019 baseline) and our indirect operations (i.e. those from our homes in use and our supply chain) by at least 22% per m2 completed floor area by 2030 (2019 baseline).
Referring back to the Spatial Strategy Options, the delivery of sites under the medium and higher levels
(Strategy Options 2 & 3) of growth would allow for the delivery of climate change measures that are required. The delivery of these measures may not be possible through reusing existing buildings (Strategic Option 1) as confirmed within the Integrated Impact Assessment:
“…the delivery of large-scale growth that is more likely to come forward under the medium and high growth options present more opportunities for the delivery of low carbon infrastructure through economies of scale compared to the lower growth option.”

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?

Persimmon Homes would support new homes being built to meet the new Future Homes Standard (being introduced from 2025), which proposes an ambitious uplift in the energy efficiency of new homes through changes to Part L (Conservation of fuel and power) of the Building Regulations. This will ensure that new homes produce 75-80% less carbon emissions than homes delivered under current regulations.

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?

As the Spatial Options document identifies, Rayleigh is diverse area with a mix of character and vernacular. Accordingly, a ‘Place-Making Charter’ would be welcomed as an overarching theme to guide all new development in the area during the plan period. Persimmon Homes welcomes the Government’s increasingly strong emphasis on design and place making, noting and agreeing with the Government’s statement at paragraph 126 of the NPPF that, “high quality, beautiful and sustainable buildings and places is fundamental to what the planning and development process should achieve.”
Accordingly, the more guidance on this that Rochford can produce (noting that design is often, subjective and without suitable guidance, decisions can be delayed), would only assist developers in understanding the Council’s aspirations in this regard. This would be supported by paragraph 126 of the NPPF, which states that, “being clear about design expectations, and how these will be tested, is essential for achieving this.”
It would also assist decision making in local residents and members are involving in the creation of
place-making charters and other design guidance; to ensure that design is properly considered by members and local residents at an early stage in the process and to ensure their views on design and place making are heard early; rather than such views being made during the application process (such as at Committee) which will delay decision making.
This would also identify if the same principles should apply throughout the District, or if certain settlements have specific principles and design, requirements that only apply to their settlement for example. Such an approach would be supported by paragraph 127 of the NPPF (“Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics.”)
As above, the more guidance that can be produced, and the more involvement and agreement with local residents/members, can only guide and aid the decision making process.
Of the principles identified within Spatial Options paper, the majority of these would apply everywhere in the District, albeit on some sites certain principles may not apply (impacts on the historic environment for example).
On Design Codes, the NPPF confirms at paragraph 128 that, “all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences. Design guides and codes provide a local framework for creating beautiful and distinctive places with a consistent and high quality standard of design. Their geographic coverage, level of detail and degree of prescription should be tailored to the circumstances and scale of change in each place, and should allow a suitable degree of variety.” Persimmon Homes would support Rochford District Council in the preparation of
Design Codes in the District.

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

Persimmon Homes would broadly support the draft Place-Making Principles, as they would provide a
broad framework for future Design guidance and policy produced by the Local Authority. We note however that there is not a principle relating to Biodiversity; given the Government’s commitment to ensure that development pursue opportunity for net gains to Biodiversity, it may be appropriate to reflect this within the place-making charter.

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

Persimmon would welcome the use of design guides, codes or masterplans, which would be supported by the NPPF:
“Being clear about design expectations, and how these will be tested, is essential…” (para. 126)
“Plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable.” (para. 127)
“To provide maximum clarity about design expectations at an early stage, all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code, and which reflect local character and design preferences.” (para.128)

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?

Persimmon Homes would refer to paragraph 129 of the NPPF:
“Design guides and codes can be prepared at an area-wide, neighbourhood or site-specific scale, and to carry weight in decision-making should be produced either as part of a plan or as supplementary planning documents. Landowners and developers may contribute to these exercises, but may also choose to prepare design codes in support of a planning application for sites they wish to develop.
Whoever prepares them, all guides and codes should be based on effective community engagement and reflect local aspirations for the development of their area, taking into account the guidance contained in the National Design Guide and the National Model Design Code. These national documents should be used to guide decisions on applications in the absence of locally produced design guides or design codes.”
However, given the variety of settlements and styles within Rochford, we would suggest that separate
Design Codes be created for each settlement.

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

The National Model Design Code, published July 2021, confirms that the preparation of a Local Design Code should follow seven steps:
1. Analysis.
1A - Scoping: Agreeing on the geographical area to be covered by the code and the policy areas that it will address.
1B – Baseline: Bringing together the analysis that will underpin the code and inform its contents.
2. Vision.
2A – Design Vision: Dividing the area covered by the code into a set of typical ‘area types’ and deciding on a vision for each of these area types.
2B – Coding Plan: Preparing a plan that maps out each of the area types and also identifies large development sites from allocations in the local plan.
2C – Masterplanning: On larger sites working with land owners and developers to agree a masterplan for each of the development sites establishing the key parameters and area types.
3. Code.
3A – Guidance for Area Types: Developing guidance for each area type by adjusting a set of design parameters.
3B – Code Wide Guidance: Agree on a set of policies that will apply equally across all area types.
We would advise the District Council to use the Model Design Guide as the basis for the production of
all Design Codes in the District.

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?

Of the options listed, Persimmon Homes would support:
 Option 2 – requiring a suitable or negotiable mix of housing that is response to the type or location of development;
 Option 5 – all homes to meet NDSS;
 Option 6 – all homes to meet M4(2); and
 Option 7 – a proportion of homes to meet M4 (3).
Option 1 listed proposes a non-negotiable mix to be provided on all housing developments. Clearly, this
option is unworkable in practice as certain sites are unable to deliver certain types of housing. For example, Brownfield sites in the urban areas are unlikely to be able to deliver suitable proportions of larger dwellings; likewise, heritage constraints in certain areas may influence the size of dwellings that a site could deliver to satisfy historic environment consultees. It is therefore more appropriate to require housing mix to be agreed during pre-application discussions, having regard to site and location characteristics, with the latest SHMA evidence used as a broad guide to inform those pre-application discussions.

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

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?

Guidance confirms that net gains should normally be delivered on site. However, where achieving biodiversity net gain is not possible on site whilst still delivering a viable project; developers have the option to contribute at a local or regional scale to off-site Offsetting or Compensation. This approach can often successfully result in greater gains for biodiversity than could be provided within a constrained development site. It supports delivery of Local Nature Recovery Strategies and is consistent with the central conclusion of the 2010 report ‘Making space for nature’, that we need more, bigger, better and joined up habitats.
Referring back to the Spatial Strategy Options, the medium and higher levels of growth options are much more likely to be able to deliver the biodiversity and green infrastructure improvements and contributions required, than on existing brownfield sites, as confirmed within the Integrated Impact Assessment:
“The medium and higher growth options are also noted for their potential to support the delivery of strategic green infrastructure provisions and associated biodiversity net gain. This includes improvements being explored in the green infrastructure network across the sub-region through the South Essex Green and Blue Infrastructure Study (2020), such as the Regional Parkland. The Regional Parkland has the potential to act as alternative greenspace targeted at reducing recreational pressures at designated biodiversity sites. These options thus provide a greater contribution to the principles of the Essex Coast Recreational disturbance Avoidance & Mitigation Strategy (RAMS).
The lower level of growth will mainly result in the delivery of new homes on urban and brownfield sites so has greater potential to avoid designated sites and support urban greening to some extent. The urban focus however is less likely to bring forward strategic mitigation, such as the Regional Parkland to mitigate the recreational pressures on designated biodiversity resulting from a growing population.
As a result, the medium and higher growth options are considered more likely to perform better overall in relation to this IIA theme; however, the potential for a significant effect is uncertain as will be dependent on the location of growth.”
It continues:
“…the potential for larger-scale development under Options 2a and 2b is recognised for the potential
for greater net gains in biodiversity.”

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?

Persimmon Homes would support a combination of option 1 and 3 listed on page 55 of the Spatial Options document to address green and blue infrastructure through the Local Plan:
 Option 1 – Allocating specific areas of land for strategic infrastructure appears a sensible and logical strategic objective to deliver tangible green and blue infrastructure through the course of the Local Plan. Strategic policies to the enhancement and protection of these areas would
be required to provide a policy framework for these specific areas (the coastal path project and South Essex Estuary Park for example), and contributions towards funding these projects could be secured, where required/relevant etc., through S106 contributions or CIL;
 Option 3 – Development sites of a certain scale (particularly edge of settlement, greenfield sites) are typically capable of being able to deliver on-site green and blue infrastructure; of providing connections to green and blue infrastructure through their site; or of securing financial contributions to improving green and blue infrastructure in the local area. With reference to our
site at Western Road, Rayleigh, the site benefits from an existing public right of way running through the centre of the site, and informal footpaths running along the southern boundary along the woodland edge. These informal paths have to be managed yearly in order to maintain these paths for the use of existing residents; without this regular maintenance these footpaths
would not be usable. The development of the site therefore look to retain these links and provide permanent, sustainable connections and to enhance these where possible, providing improved footpaths and links to the surrounding area, including to Kingley Woods to the west of the site. Access to the wider countryside can also be promoted through the development as
existing footpaths can be improved and maintained. There is scope to enhance the Green Infrastructure Network in the locality by providing more formalised and accessible links through the green spaces.

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?

With reference to the four options, we would comment as follows:
 Option 1 – support the protection of existing school and healthcare facilities through specific allocations.
 Option two – support the allocation of specific sites for the creation of new community infrastructure (providing that site is being allocated for that use or would not conflict with other site promotions).
 Option 3 – Broadly support requiring new developments to deliver new community infrastructure on site, though would caution that this would only apply to sites of a certain scale.
For example, the Essex County Council Developers’ Guide to Infrastructure Contributions highlights that developments with an individual or cumulative size of 1,400 homes are likely to be required to deliver a new two-form entry primary school, whilst developments with an individual or cumulative size of 4,500 homes or more will need to provide a new two-form entry secondary school. It would be simpler for the LPA to identify new sites for community infrastructure (new schools/extensions to existing schools, new surgeries/extension to existing surgeries etc.), and require developments to contribute towards those new facilities (with reference to para.34 of the NPPF requiring that Local Plans should clarify the level of contributions expected from new developments).
With reference to the Spatial Strategy Options, the Integrated Impact Assessment states:
“The medium and higher growth options are more likely to have a significant positive effect on this IIA theme through the delivery of new employment land and retail floorspace. These options are also likely to deliver more new infrastructure upgrades and sustainable transport routes to attract further inward investment. Further to this, the higher growth options could contribute to the delivery of sub-regional improvements to green and blue infrastructure, which could have a positive effect on the tourism economy. Whilst positive effects are considered likely under all options, the lower growth option is
considered less likely to lead to positive effects of significance.
We would also question whether the Council intends to progress with a Community Infrastructure Levy, to fund the development of new infrastructure in Rochford, as no reference is currently found on the Council’s website (and no reference is made to CiL within the Spatial Options Document). CIL is seen by many as creating a more transparent contributions system, whereby developer contributions can be calculated upfront (which assists developers with viability calculations, as well providing clarity to local residents/interests groups on the level of funding provided by new development and where that funding is directed towards).
Persimmon Homes would support Rochford District Council in the development of a Community Infrastructure Levy.

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?

Persimmon Homes would request that the Conservation Area Appraisals be updated as part of the emerging Local Plan process; these were last produced in 2007 so by the time the plan is adopted, these will be over 15 years old. The Local Authority are aware that settlements and areas change over time, and as such, it would assist greatly for these documents to be regularly reviewed.
Persimmon Homes are also concerned that our site at Western Road, Rayleigh (ref. CFS087) is marked poorly in the accompanying Site Appraisal Paper due to impacts on Built Heritage. This appears to have been assessed purely on the basis that there is a listed building – the Grade II listed Weir Farmhouse (List UID: 1322351) – but that this assessment has seemed to be have been undertaken purely as a mapping exercise and without any consideration to the sites relationship to this asset on the ground. The listed building is located a considerable distance from our site, and is screened from view not only by existing twentieth century development but also by considerable mature trees (which would be retained as part of any development proposals); therefore development of our site (ref. CFS087) would have no impacts on the setting of this listed building, as is fully confirmed within the Heritage Statement that accompanies these representations.
With reference to the Spatial Strategy Options, the Spatial Options Paper identifies that said option to
increase densities in urban areas are unlikely to be compatible with historic centres and local character,
as confirmed within the Integrated Impact Assessment, which states:
“…it is recognised that the lower growth option will focus development in existing urban areas, with a higher potential in this respect to impact on historic centres.”
We would therefore recommend that all assessments of built heritage impacts be fully assessed by up to date evidence, noting that the Council’s Conservation Area Appraisals haven’t been updated since 2007 and therefore may not accurately reflect existing site conditions.

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?
Persimmon Homes would support the four options listed to address transport and connectivity through the plan.

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

With reference to, our site at Western Road, Rayleigh (ref. CFS087), and the site is within a very sustainable location being walking distance to local amenities including schools (0.6 miles) and a train station (1.1 miles). A main bus route also runs in very close proximity to the site. The wider main road network is also easily accessible.
The development will provide betterment to existing footpaths, creating enhanced foot and cycle links to services and employment areas for new and existing residents. The existing PROW could be upgraded into a cycle link and a formal path that can connect to an east/west foot/cycle link that runs from Western Road to Weir Farm Road. This will allow a good connection to High Road and therefore services/employment/further transport networks. As previously stated, existing footpaths running through the site are informal and could be upgraded as part of the redevelopment proposals for the site to provide permanent, sustainable connections for existing and new residents.
Access to the wider countryside can also be promoted through the development as existing footpaths can be improved and maintained.

Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
Persimmon Homes agrees with the vision for Rayleigh. As the District’s only Tier 1 settlement, it is correct that it should take large proportion of the District’s Plan Requirements during the Plan Period.

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

Persimmon Homes is promoting site CFS087 for residential development. This 10-acre site is located
north of the A127 by Rayleigh Weir. The site is contained between the current residential area defined by the southernmost extent of Western Road and Eastern Road with the A127.
The majority of the site comprises rough grassland, which has no beneficial use. There is a Public Right
of Way (No25) running south from Eastern Road. The development offers the opportunity to formalise footpath links from Western Road. It would also offer the opportunity to create recreational routes through to Weir Farm Road. The allocation has the potential to enhance the Green Infrastructure Network in the local area.
The site benefits from being closely related to the existing built up area of Rayleigh, its town centre, train station, bus routes and key services. The Vision is that the site will add to the growth of Rayleigh, providing homes in a sustainable location close to existing services, transport links and accessible green space.
The site is located immediately south of the Main Settlement of Rayleigh and north of the A127.
Rayleigh Town Centre is within a 10-minute walking distance and the Train Station, with a direct link into London, is only 1.1 miles walking distance. A main bus route linking the town centre/train station, Southend, Basildon and Canvey Island runs through High Road. This is in close proximity of the site. The site has good access to the wider main road network.
The site is within walking distance to the nearest Primary and Secondary School (0.6 miles and 1.1 miles respectively).
The development of the site would provide beneficial enhancements to the public open space provisions
and improved walking/cycling links across the site to encourage new and existing residents to use
sustainable modes of transport.
The site does not serve the five purposes of Green Belt (as confirmed within the Council’s evidence base) and would benefit from housing development to allow for improved biodiversity creation and management. Development of the site would also provide an enhanced settlement boundary to the A127 and provide an improved setting for Ancient Woodland and Local Wildlife Site.
Development of the site will allow for delivery of required housing in a sustainable location.
Persimmon Homes are currently preparing an updated Promotional Document to support the allocation of the site for residential development, which will be submitted shortly.

Conclusion
The adoption of the new Local Plan (2023) remains, optimistically, 2 years away. The Council does not
have a published strategy for bolstering housing land supply in the period up to the adoption of the new Local Plan. The Council need to identify a strategy to boost significantly the supply of housing in the period up to the adoption of the development plan, such measures should include the early identification of suitable new sites and seeking to pro-actively work with landowners and developers to bring such sites forward.
The Council must ensure that a new development plan is taken forward without further delay. The continued lack of an up to date development plan is significantly hampering delivery and the regeneration imperative.
Persimmon Homes have an interest in site CFS087: Land between Western Road and Weir Farm Road
Rayleigh, which the Site Appraisal Paper confirms suitable, deliverable and available for residential
development, and are actively seeking additional sites in Rochford to deliver much needed housing and
regeneration in the Borough. Further details of this site, along with plans, are submitted as part of this submission to support its allocation within the Local Plan for development.