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?

Dear Councillor Simon Wooton,

I hope you are well and a belated congratulations for being voted in leader of Rochford District Council last July.

I purposely write to you as a person of leadership for my area and with genuine interest of your views, given someone in your position will naturally do your very best to put resident interests (amongst other things) at the heart of everything.

I’m namely reaching out to you in relation to the identified or proposed plans for new housing development.

Before I go on, I feel for integrity I should briefly introduce myself and explain what has compelled me to write to you. I’m Jason McGinley, a 47 year old who moved to the Hawkwell area back in 2002/3, I am married, have 3 children (mostly grown up now) and have my Dad living close by. The reason I moved here was to find more space, tranquility, good schooling and the green space. The pace of life here back in 2002/3 was much slower and quieter than I was used to but was just what we looking for, and we integrated quickly and very much appreciated the qualities of local community life and living.

I’m not a man of erratic views or knee-jerk decisions and want for nothing in the main. However, I’ve found myself thinking over the last few years that perhaps it’s time to move on to somewhere which offers what we found here back in 2002/3. The area in ‘some’ ways has developed out of all recognition and has become an area with different dynamics, with seemingly many more people and car traffic and now feels quite claustrophobic and restrictive – feelings which my last area were reminiscent of.

So with introductions out the way, I understand plans seem to include over 6,200 houses across 6 sites with others involved in addition. I’m also mindful of the considerable amount of new housing already developed over last number of years and observe just from them along, a distinct lack of new supporting services / shops / road access - notwithstanding the impact to existing services in the surrounding areas. Specifically on the ‘past’ element effect, I’ve tried not to use the roads at all during weekends due to the traffic congestion stress it brings to me on a personal level.

Before I try to summarise business type reasons of concern, I’m conscious that this type of issue is 1 of many part of the bigger plan you’re responsible for. I also understand that for every past there’s also a present and a future, which requires a lot of balancing, thought and change, Having said all that, I do think there’s a lot of overlap across multiple touch-points, including decision making, and for that reason I’d like to really ‘pick-your-brains’ on the wider view and challenges or pressures you have to factor in to decisions.

For me it’s crucial to understand and differentiate between the directives you’re working to against viable options specific to our district – I’m sure this is something that most residents would have empathy on too?

On the ‘overlap’ I referred to, budget is a big one, as is climate and environment, younger generation, core services and local business. Being in business myself, naturally I can see benefit from creating efficiencies and making strategic decisions which embed and have sustainable impact. Personally I have lots of ideas around both, and am more than happy to impart these as part of resident feedback – should there be good reason to.

I genuinely am really interested to hear the challenges for our district and how you have to balance and manage these as part of a local and central Govt plan, including any personal thoughts presuming you’re a local resident too.

Back to the new housing point, the main aspects of concern or interest are:

1) Road traffic and lack of road infrastructure to deal with this – personally speaking, I can’t even see or understand how implementing new road space will even impact or help with this issue, for example the road in and out of Rayleigh through to Rochford and beyond just can’t cope anymore and neither would the main roads like A127 – we’re simply at ‘tipping point’.
Beyond the local access, those outside our district would find it near impossible to access what our area has to offer without extreme delay or difficulty.

2) Lack of new support services and shops / or impact to existing – such as supermarkets, doctors, hospitals, dentists, car parking, park space, exercise space, public transport and public houses. I often find which situations like this, you hear about conceptual ideas and promises without analysis of numbers before/future and real thought to how this will truly affect these things without having those who work or live on the ground in or near these things.

3) Population – whilst this relates to points 1) and 2) coming back to the qualities and dynamics the area offered back in 2002/3 versus what it’s like now, it just seems that there’s now too many people for what the area can deal with. I’m inclusive but this is something different to simply preferring it less busy.

4) Air pollution / Climate / Environment – for me this all overlaps and whilst more housing will bring more diversity, I just cannot see how for any of these points we will be in a better position ‘locally’, rather the opposite. Any statistical development analysis over last 5 or 10 years would be useful, against what locally and centrally we’re trying to achieve in this space and how more housing will align to the ambition.

5) Green Space / Flooding – again I think this overlaps. Much of the local beauty and attraction is the green space and all that it offers for wildlife and people alike, yet we keep taking it up more and more with concrete. Additionally, the flooding aspect as result and impact to utility service disruption i.e. blockage/flooding. To me this is alarming from both a future risk point of view and personal experiences namely from blocked drains causing both flooding and polluted flooding (from faeces) – which has become much more frequent. Ultimately I presume this is a shared risk for local Council services, budget and disruption too.

6) Youth – there seems to have been a lack of Council driven effort to generate new ideas or services which positively engage youth and the younger generation. This is an aspect I’ve spoken about for years too. There seems to be a whole range of opportunities but possibly a lack of budget, insight or plan to develop it. Additionally, it seems we now live in a world of such heavy compliance / regulation / and process, that bringing these types of things to life take extraordinary time and cost with incredible inefficiency – making them then quite un-attractive to take up. Also getting the right people involved is crucial to success.

7) Crime – I really don’t know the statistics here but do know on experience that it has become a much more frequent occurrence in recent years versus when we first move here. As result, I’m keen to hear what is planned in this regard if thousands of new residents arrive?


I recently saw a Rochford District Council report from 2018 on additional dwelling plans between 2010 – 2025, and attach a screen shot below. In reflection my immediate thoughts were:

• Planned 3,750 dwellings in a 15 year period (2010-2025) versus:

now in 2021 adjusted plans suggest ‘additional’ 6,236 dwellings across 6 sites alone, which seems a huge uplift in comparison?

• How policy can change from 1 year to another completely affecting previous plans
• What additional new dwellings have been developed in the interim period 2018 – 2021
• There were 33,600 dwellings in 2011, how many are there in 2021
• The 2021 Census doesn’t seem to be accessible yet?

I also found a Population chart (per below) which whilst has steadily grown from 2002 – 2018 by 7,656, it seems comparatively fair in relation to new dwellings, which using the above chart (from 2018) of 3,750 new dwellings there were 3,887 additional in population. One could suggest then, that this was driven mainly be ‘new housing’ more than anything else?

I remain interested in your response but for completeness and timing have also copied in the ‘SpatialOptions’ team. Please let me know if you prefer to arrange a face-to-face meeting as part of any response, or, feel free to call me too.

Firstly the Consultation Process. The volume and format of information contained in the consultation was difficult to access and view online. It was difficult to understand the context of the consultation and RDC are not reaching residents who have no internet. It is also very difficult to cross reference when trying to write a response.

In my opinion the most important factor is that Infrastructure needs to be addressed before more housing is added to the area - This is a key concern for residents exacerbated by the volume of recent and proposed development causing additional pressure on roads, education, social services, health facilities and local employment opportunities. In particular our roads and cycle paths are in a very pitiful state of repair and are only likely to worsen with significant further development. The main route, the B1013 is already at full capacity and we the residents have concerns with traffic volumes causing severe Jams, increase in road noise and pollution combined with the very poor state of the roads with potholes etc

The Infrastructure Funding Statement states all financial and non-financial developer contributions relating to Section 106 conditions should be completed but this has not always been the case and is not the case when larger sites are split up. This was evident at the Hall Road development that promised a school and and doctors both of which were promised but not delivered

Open Spaces - The value of our open spaces and the issues with climate change have become a priority. The use of empty buildings and Brownfield sites should be evaluated first and consideration should be given to identifying an area where a discrete garden village with appropriate infrastructure, separate from current settlements, could be created. Prime examples of such working developments include Chelmsford Beaulieu Park and the South Woodham Ferrers development. I believe that approach is much better that the “Pepper Pot” approach in that it does not give residents a clear picture of the local area erosion of space and general slow increases of population that lead to an adverse effect on local infrastructure.

Potential Developments in Hockley - The plan proposes around 1000 additional houses in Hockley with additional developments on land bordering the Parish. This density will have a major detrimental impact on the quality of life for residents. A particular concern is traffic. The volume of traffic on the B1013, into which most of the proposed new sites, including CFS045, CFS064, CFS160 & 161, CFS074, CFS194, CFS169, CFS150 and CFS020 will feed, is already at an unacceptable level. Many proposed sites are not within walking distance of services and bus and train services are limited. Current high levels of traffic mean that there is already a detrimental effect on the quality of life for residents as well as local commerce and potentially on individuals’ health, given levels of pollution. Additional traffic, potentially thousands of cars, will only worsen matters.

The proposal for development on land at Belchamps, CFS074, is particularly worrying due to the lack of open space for activities available to youngsters and community groups in the Rochford District. The site has been a very valuable well used resource and it is important this is retained for our future generations.

Whilst I understand the need to provide additional housing in Hockley, infrastructure requirements need to be considered and addressed alongside any consideration of potential development sites. Also proper consideration needs to be given to identifying development away from existing settlements. Whilst this may be unattractive due to upfront costs, such an approach could save money in the long term.

I consent. To my name and comments being added to the Councils consultation database and understand anonymous comments cannot be accepted.
I would like to be added to the council planning list and consent to my data being stored and processed for the purposes of receiving planning updates by email

The Mill is the biggest hall in Rayleigh and if you have done your homework you would know so many classes, events etc were held there. Every day, morning, afternoon & evening something was going on. With all the hundreds of houses being built in the area people will want somewhere to go, after all it’s getting more and more difficult to get out of Rayleigh which is becoming gridlocked.

Thank you for the chance to provide comments and initial observations to this vast and extremely complex subject. Emotions will run high on this sensitive initiative which will cloud some of the critical issues that need to be resolved.

Whilst I feel the over consumption of our open spaces and converting these into housing and/or commercial buildings is not in the best interest of the community as a whole, the reality is we need to provide affordable and appropriate housing for our ever increasing population. As such I’m not necessarily contesting the sites themselves but rather, sounding concerns and the clear basic needs that this major scale of building demands. I believe the key points have been trapped/identified in your various documents but what's absolutely vital is that we simply do not flag these points simply as a tick box exercise but rather, effect real actions that will address the major impacts.

1. Infrastructure – this is pretty obvious and it not only centres around the supporting roads for the new sites but equally, wider consideration to the roads that feed Hockley, Hawkwell, etc. As numerous people have already pointed out, the traffic congestion into and out of these places is pretty dire and adding more homes, businesses will only exacerbate this situation further. Just acknowledging this and failing to take mitigating action is no longer acceptable. As our leaders and management of local the communities your roles are to ensure you take sound and well considered decisions that properly measure the whole picture. Implementing further building programmes (through more housing, etc) whilst at the same time, tinkering around the edges of the supporting infrastructure is no longer acceptable nor truly viable. Infrastructure also extends to the drains and the ability to soak away the rainfall and occasional flooding that we sometimes experience. Equaly, it extends to proper maintenance and investment of services to support these additional solutions so that they continue to be fit for purpose.
2. Services – the ever increasing of new residential homes brings an increase in demands on Doctors, Dentists, Schools, nursery’s , sewage, broadband, and so forth. Some of these services are failing to provide the appropriate level of support to the community today, adding more residents into the mix will drive the levels of frustration even further when people are unable to access these services in a reasonable timeframe. Yes funding cuts make this a challenging issue but increasing demand on these basic services at the same time obviously makes the situation worse.
3. Floodplains –We all recognise climate change and the worsening impacts we are witnessing in our day to day lives, is it really sensible that we path over further parts of our green and open spaces within the areas we live. We need flood management solutions that can combat this increasing risk to our environment.


I fully appreciate the above are major factors that are not quick fixes, require significant investment and asks for strong leadership form those empowered. But reality is, we have been expanding our community by large scale housing developments (house building) for many many years now but failed to properly develop fundamental infrastructure plans along the way. We need investment in these areas to cope with the growing residents numbers. At some point, the demands on the infrastructure become overwhelming and it can no longer properly function. In many cases, we are beyond that tipping point already.

I wish to raise specific objections to the potential house building around Little Wakering and Great Wakering, covered in the Rochford Spatial Options Consultation:

1. I am concerned at further building along Little Wakering Road because of the adverse impact on drainage and potential for greater flooding. The council will already be aware of drainage issues in Little Wakering and Barling and the measures taken to resolve them. Further housing in the area will add to this unresolved problem.
2. Any new housing must be matched by an appropriate increase in infrastructure - GP's, Schools, Policing, Care Services etc. This is true of even limited housing numbers. Failing to do so will deteriorate the existing services for the community. And the council need to carefully consider the increase in traffic and congestion in the area - along with associated pollution.
3. With Climate Change a very real threat, loss of Green Belt and habitat is a concern. We need to be protecting this land - not seeking to build on it. We need to concentrate any building on brownfield sites. And we need to look at re-purposing commercial sites - which is what is happening along Victoria Avenue in Southend, where offices are being converted into apartments. And with an increase in sea levels expected, why would we be considering building houses on lowland areas where flooding is more likely in the future?
4. We need to ensure the villages of Great Wakering, Little Wakering and Barling retain their identities and remain physically separate from other communities. This will not happen if building takes place which joins us to Rochford, Shoebury or Southend. Eventually we will simply become a part of the Southend municipal borough.
5. The South East is already overbuilt and densely populated - we simply cannot keep building here. Clearly housing needs to be built in areas of the country that are less populated - with incentives for businesses to develop in those areas. This would fit with the governments aims to even up the country and see more investment in the north. Whilst the government may have specified housing numbers for councils, for these reasons I think Rochford District Council must resist them.

We have read through the plan and have the following observations/comments.

Page 17 - Mentions working alongside Neighbourhood Planning groups. Who are they and how do we contact them as there is no other information or reference we could find in the plan that would help

Infrastructure

According to this plan, and whilst the planning process links the number of houses being built with social planning e.g. schools, healthcare facilities etc, road infrastructure planning is not aligned. Decisions should not be made to increase additional numbers to the area without a strategy and an agreed plan for roads. It is clear that road infrastructure is not strategically or planned to align with the proposed increase numbers of house/people/cars coming into the area.

Within the plan where is the attention to other land infrastructure such as sewage and waters supplies given that in the last few years Rayleigh has suffered more flooding due to more concrete, drier summers and little to no thought out plan to disperse the excess water?

Surely continued house building should not go ahead at pace unless the above can be aligned?.

Housing Developments

A lot of the housing developments with planned momentum which are being carried out, now always seem to reach an advanced stage before local objections can be made; almost always resulting in a fait a compli. Why? As our council, is there not a thought as to why these decisions anger people in the community and end up causing more grief because it is not transparent? An example is the now public proposed development around Albert Road and Grove Road and surrounding farmland in Rayleigh. What role did the Neighbourhood Planning Group have in this? Again, who are they and how are they contactable?

Crime and Policing

Where in the plan is the strategy to combat excess crime which naturally happens when more people come into the area whether we like this fact or not? In fact there is no mention of Police funding at all in the plan.

I am emailing my comments regarding the planned developments particularly as it affects Lower Road between Hullbridge and land to the west of Wadham Park Avenue.

The plan for more houses in this area, without substantial improvements to the existing road network, would continue to worsen what is already a saturated situation. As a pedestrian, it is somewhat dangerous to walk along the unpathed part of this road & the additional traffic would exacerbate the situation.

Notwithstanding this, there are virtually no public transport links along Lower Road eastward from Ferry Road. This matter would need to be sorted.

Due to what would seem to be a lack of a master plan from the Government, it would seem that a piecemeal approach is being taken with regard to some of the planned areas of development. Surely, it would be more appropriate to continue to expand the existing new development in Hullbridge to the west rather than to the east. This area is, at least, closer to existing transport links. Alternatively, perhaps it would be more appropriate to build the majority of the houses required at a purpose-built site where adequate facilities & utilities could be constructed.

It would appear that none of the planned growth is being matched or considered, at present, by any increase in local infrastructure (such as doctors, dentists, roads & public transport) and also that any developer contributions are almost minimal in this regard.

There would also be substantial damage environmentally as the vast majority of the proposals are on Green Belt/agricultural land which supports large amounts of wildlife, some of which are in danger. We must not allow this constant need to build on such sites with a total disregard of the damage caused.

I appreciate that no final decision has yet been made as to which sites will be developed but would request that due consideration be made to the impact each will have on its locality. We should endeavour to ensure that financial interests do not outweigh environmental interests.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

I am writing to object to the use of Site CFS064 (Land north and east of Folly Chase, Hockley) as part of the Spatial Options Consultation.

As stated on the Site Appraisal Paper, this site will impact on the ancient woodland of Betts Wood that adjoins this site. This is only a small ancient woodland and should be protected for future generations. Having lived next to the woods for many years, I have seen first-hand the wildlife and fauna that inhabits this small beautiful woodland. I have seen many animals including badgers, foxes, owls, deer, squirrels, bats and insects that live in the woodland and traverse across the field CFS064 to hunt. By building on the allocated site you will be turning the woodland into an isolated island which will have a detrimental impact on the wildlife and biodiversity that live there. Ancient woodlands account for only 2.5% of land cover in the UK. I understand that Paragraph 175C of The National Planning Policy Framework for England states that "when determining planning applications, local planning authorities should apply the following principles" - "development resulting in the loss of irreplaceable habitats (such as ancient woodland) should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists". Please can you confirm what your "exceptional reasons" are for choosing this site.

The site also adjoins an open space (behind the Community Centre) where children can play safely away from traffic. There are not many open spaces like this within Hockley and this should be left for the children of the village to enjoy where they can ride bikes away from vehicles and play ball games safely.

The Site Appraisal Paper states Primary Schools as a "4". I know there are three primary schools in Hockley but I also know that all the schools are at "bursting" point now. My daughter attends Hockley Primary and her classroom just barely accommodates the children within in her class. How do you propose fitting more children into the school if you build 214 homes on this site. The school will also be impacted by the noise and pollution that will occur from building on this site. The roads are already congested around the school during drop off/pick up and it is extremely dangerous for the children attending trying to negotiate the roads now. How do you propose alleviating the congestion to the roads around this area?

The Paper also states Health Care as a "4". With only two doctors' surgeries in the area, where it is almost impossible to get an appointment now, how do you propose accommodating the building of more houses not only on this site but in Hockley generally.

The same can be said in relation to the roads entering and leaving Hockley which are already congested - how will you alleviate the impact of more traffic due to building more houses in the vicinity. Hockley does not have the infrastructure in relation to roads, schools and health care at present to accommodate more home building.

This site has previously been flooded, can you confirm that this will not happen again in the future or have any impact on existing properties in the vicinity.

For the sake of building 214 homes there must be only marginal gains for the home owners with increased noise and pollution for everyone in the vicinity.

I hope you will take this email and my objections into consideration when deciding on the sites you wish to build upon.

[additional email via same address from daughter]

To Sir/Madam,

Please don't build on the field! Your actions will destroy a perfectly good habitat and effect everything around it. All wildlife will be destroyed or will move out which would be a very tricky situation as you have the school on one side the Community centre in the middle and the train tracks on the other side. However, they could move to the other little woods but it is almost full and it would be impossible to make it a home for other animals. It would also affect Betts woods which I have seen every single secret den and hiding place spending hours after school exploring with my best friends. I would hate to see what they would look like after you started to build near them. If you hadn't noticed there is a stream that gives me and my family water but it would be piloted and disgusting! There is a badger's den which I have seen myself and I am concerned that you could disturb it. There may also be a whole underground burrow underneath the field and if you began to build houses on it will collapse and you will not be able to build on it anyway ruining a habitat at the same time.

Consultation on the New Local Plan by Rochford District Council, Site CFS064
Land bounded by Folly Chase, Betts Farm Estate, Hockley Community Centre, the railway line and Hockley Primary School.
Please accept this as my comment on the proposed development above.
It is completely unreasonable to suggest any further development in the above area. There were already concerns at the last development at the time and to add any further properties would be totally unadvisable.
Greensward Academy and Hockley Primary School are both full and adding a further housing estate based on say, 2 children per household would mean that schooling would not be available for these children.
Despite my complete opposition to this development on the basis of lack of infrastructure and resources such as primary clinics, shops, and over-crowding of roads to Rayleigh and Rochford my most vehement concern is that of a lack of schooling for the incumbent population.
Where are these children going to be educated??. Do you have plans for a new school in the vicinity?? Both infant, primary, secondary and sixth form college.
I totally oppose the development of this land. As a long term resident and local teacher I totally refute any development at the above land.

Good morning ,
I give below my comments on the spatial plan.
We live on Ashingdon Road and have done since 1984 We are concerned about the plan fir the following reasons :- A Traffic on the roads are at bursting point . At 7.30 am the traffic going towards Rochford is at a standstill both ways due to king Edmunds school commencement and is back to past brays lane . A lot of traffic now bypasses this by taking brays land and through stambridge coming out by the fire station as I do myself.
B the clear way operates from 8am which needs to be made earlier . One a previous Monday there was a builders merchants lorry unloading by holt farm so traffic was at a standstill back to Anne Boleyn pub and the school children were late for king Edmunds on the school buses. Obviously it is a problem also till after 9 with holt farm school, st Teresa’s and Rochford primary schools.
C the larger heavy lorries coming from the wharf along brays lane and along Ashingdon road is of great concern as they are so close to the children and during the day to adults and to pass each other sometimes mount the pavements . No wonder Rochford roads are one of the worst in the county . Also to us is the high number of accidents on Ashingdon road and a lot of youngsters driving well in excess of the 30 mph speed limit . It is a high injury road which again is a burden on the emergency services . So we need more speed reduction measures especially from lascelles gardens up to the victory pub and down to Ashingdon school .
D infrastructure needs to be improved prior to any of these proposed developments such as doctors , hospitals , roads , councils services as already these are overwhelmed such as hospitals as I believe a lot of patients are diverted to Chelmsford as there’s no room in Southend or Basildon.
E planning needs to be stricter as developers are taking advantage and cramming in multiple properties where on or two were previously increasing the traffic and demands on services . The council seems to be an easy touch that if they break the planning laws the council cannot pursue them due to lack of money unfortunately .
F when we should be thinking if the environment multilingual trees are being destroyed by developers illegally and woodlands being taken over for development.
These are some of our comments that need to be considered with the plans for the future .
I must say if we were younger we would have considered moving outside the area regrettably .
I look forward to your comment

Consultation Process -The volume and format of information contained in the consultation was difficult to access and view online. It was difficult to understand the context of the consultation and RDC are not reaching residents who have no internet.

Infrastructure - This is a key concern for residents exacerbated by the volume of recent and proposed development causing additional pressure on roads, education, social services, health facilities and local employment opportunities. In particular our roads and cycle paths are in a very pitiful state of repair and are only likely to worsen with significant further development.
The Infrastructure Funding Statement states all financial and non-financial developer contributions relating to Section 106 conditions should be completed but this has not always been the case and is not the case when larger sites are split up.
Open Spaces - The value of our open spaces and the issues with climate change have 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 limited access in terms of roads into and out of the area. Open space is at a premium. Development of many of the proposed sites would mean a further reduction in air quality, increase in light pollution and the loss of trees and farming land at a time when food production and supply is becoming a cause for concern. Sites of Special Scientific Interest will also be affected. Essential green belt is being allowed to erode. The use of empty buildings and Brownfield sites should be evaluated first and consideration should be given to identifying an area where a discrete garden village with appropriate infrastructure, separate from current settlements, could be created.

Potential Developments in Hockley - The plan proposes around 1000 additional houses in Hockley with additional developments on land bordering the Parish. This density will have a major detrimental impact on the quality of life for residents. A particular concern is traffic. The volume of traffic on the B1013, into which most of the proposed new sites, including CFS045, CFS064, CFS160 & 161, CFS074, CFS194, CFS169, CFS150 and CFS020 will feed, is already at an unacceptable level. Many proposed sites are not within walking distance of services and bus services are limited. Current high levels of traffic mean that there is already a detrimental effect on the quality of life for residents as well as local commerce and potentially on individuals’ health, given levels of pollution. Additional traffic, potentially thousands of cars, will only worsen matters.

The proposal for development on land at Belchamps is particularly worrying due to the lack of open space for activities available to youngsters and community groups in the Rochford District. The site has been a very valuable well used resource and it is important this is retained for our future generations.

Whilst I understand the need to provide additional housing in Hockley, infrastructure requirements need to be considered and addressed alongside any consideration of potential development sites. Also proper consideration needs to be given to identifying development away from existing settlements. Whilst this may be unattractive due to upfront costs, such an approach could save money in the long term.

Objections to Spatial Options Paper
Areas in Hullbridge to the East and West of current Residential Streets.
To the East CF5099, CF5149, CF5006
To the West CF5003, CF5193, CF5190, CF5172, CF5265, CF5151, CF5128.
These plans are totally premature, as the impact on the infrastructure of the 4 developments within the district are mostly unfinished, therefore no accurate assessment can be made.
None of these sites comply with Government Guidelines N.P.P.F July 21.
Which include the following guidelines and statements.
Infrastructure first. Until all developments are completed, no new assessments can be made on Health, schools, public transport, road capacity. Therefore no accurate data can be reached. The A127 has clearly reached it’s capacity, taking 1 ½ Hrs to do a 30 min journey in rush hour. Many road users taking the alternative route via Hullbridge. Deliveries have been aborted due to traffic chaos affecting residents and businesses.
Green Belt/ Farmland. should only be used as a last resort.
Flooding. Land with the potential to flood now or in the future should not be considered unless mitigation measures can prevent flooding. This would prove impossible to secure all the riverbank and hold back the tide. Climate change has this area prone to flooding within 20 years. Additional building on this land would impact on current housing.
Many of the roads adjoining these sites are without surface water drainage.
Carbon emissions in the Rayleigh area are the highest in Essex, with the county having the most cars in the UK. This is a health risk. Builders have already removed trees and hedge rows which need to be replaced, to help address this. No further decline should be permitted.
Housing development should only be permitted to provide for the requirements of existing residents, and then should be within villages and towns avoiding expanding boundaries close to other parishes, villages and towns, to avoid urban sprawl.
These developments should be withdrawn immediately.

Comments on RDC Local Plan Consultation for Hockley Sept 2021
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.

Infrastructure - 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.

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. Many 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. Sites of Special Scientific Interest will also be affected.
The Merryfields Avenue proposal has been previously rejected by residents due to access issues as the land borders on the Nature Reserve. Consideration should be given to incorporating it into the Reserve rather than releasing it for development.

• 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;
• 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;
• Essential green belt is being allowed to erode further which will be impossible to replace;
• Enforcement on unauthorised development is not adequately managed.
• The volume of traffic has increased to an unacceptable level on the B1013 causing noise, smells and
disturbance; Is the traffic survey up to date;
• 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. 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. The site has been a very valuable well used resource and it is important this is retained for our future generations.
We have to consider some growth in Hockley and surrounding areas but a more measured approach must
be taken on the sites put forward by landowners. The views of our residents on the Consultation should be
acted upon by RDC and unsuitable and overdeveloped areas withdrawn from the Plan.

ROCHFORD DISTRICT COUNCIL SPATIAL OPTIONS CONSULTATION (REGULATION 18) - BARRATT DAVID WILSON HOMES RESPONSE: LAND EAST OF STAR LANE AND NORTH OF POYNTERS LANE, GREAT WAKERING

On behalf of our client, Barratt David Wilson Homes (‘BDW’), please find enclosed representations to the
Spatial Options consultation currently being undertaken by Rochford District Council (‘the Council’).

Background

BDW
BDW is the nation’s leading housebuilder, creating great new places to live throughout Britain. In 2019/20,
BDW delivered over 12,600 new homes.

BDW are experts in land acquisition, obtaining planning consents and building the highest quality homes in
places people aspire to live. This expertise has been shared with the Council in recent times through the
delivery of other schemes in the District – including the High Elms Park development in Hullbridge.

BDW is committed to being a sustainable housebuilder and continue to integrate sustainability into their
business practices, helping to create better homes and communities and a strong business for the longer term.

Land east of Star Lane and north of Poynters Lane, Great Wakering
BDW is currently promoting Land east of Star Lane and north of Poynters Lane, Great Wakering as an
allocation for housing in the emerging Local Plan. This land ownership covers two HELAA parcels: CFS057
and CFS070. These representations are supported by a Framework Plan which is appended to this letter,
alongside a site location plan.

BDW would like to make the following observations on the content of the Spatial Options consultation.

Vision, Priorities and Objectives
Q2: Do you agree with our draft vision for Rochford District?

Whilst BDW agree with the draft vision for Rochford District in principle, we would like to make the following
observations.

As currently drafted, no reflection of the purpose, aims and objectives of the emerging South Essex Joint Spatial Plan (JSP) is made. The Statement of Common Ground (SoCG) (2018) between the six constitutive Councils (plus Essex County Council) involves a commitment to work together on strategic planning matters, including meeting the housing needs of entire sub-region in full (our emphasis) (see Chapter 9). The relationship between Rochford and Southend-on-Sea is imperative to achieving this, as recognised by the current in-tandem production of new Local Plans in these areas – including the production of a joint evidence base (e.g. Green Belt, HELAA). The evidence base (see HELAA June 2020 Update) is clear that Southend will be unable to meet its objectively assessed housing need on deliverable sites within its administrative boundaries in both policy-on and policy-off scenarios (a shortfall of 6,671 dwellings from 2020-2040), whilst Rochford (in a policy-off scenario) contains deliverable sites to provide a surplus of 35,935 dwellings from 2020-2040 – including Land east of Star Lane and north of Poynters Lane, Great Wakering. Given the relationship between the two administrative areas, it is imperative that the Council works constructively with
Southend (and other Council’s within the South Essex JSP) to meet the commitment of the JSP to deliver
South Essex’s housing need in full. It is important that the commitment to working with the JSP Councils to meet the needs of the area in full is recognised in the development of a vision that looks further ahead than
just the Plan period (i.e. to at least 30 years) to ensure future generations have clarity on the growth of the
District in the context of the JSP area.

With regards to ‘Our Society’, the Council’s supporting text should be evolved to recognise that although
focussing on previously developed land may be the priority, the evidence base demonstrates there is
insufficient land within these categories to deliver its objectively assessed needs. The HELAA (June 2020
Update) demonstrates a total of 4,320 dwellings can be provided (including a 39dpa windfall) on previously
developed / currently approved sites – a shortfall of 2,880 dwellings. The Urban Capacity Study indicates that
this, at a maximum, can be increased to 5,000 dwellings, still leaving the Council with a shortfall. The Vision
needs to evolve to cover a longer period (as per Paragraph 22 of the NPPF) and recognise that growth on
greenfield sites (including Green Belt) must now take place under an appropriate strategy – which should allow
for a mix of sites and a range of homes to be delivered which can help combat affordability issues and support
Growth across the plan period (see our answer to Q6).

With regards to ‘Our Environment’, the Council’s pledge to retain an extensive Metropolitan Green Belt
designation is noted, but in light of the evidence regarding objectively assessed development needs it is
important that this is clearly defined to allow for future growth to be accommodated within the Green Belt
following Plan reviews.

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

BDW agree with this approach, in principle, insofar as it allows for both the correct quantum and type of
development to be delivered within each settlement to meet the Council’s identified needs.
Please also see our response to Q5, Q6, Q7 and Q59.

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

BDW broadly agree to the strategic priorities and objectives identified in principle.

However, as set out in our response to Q1, BDW consider the Council should amend Strategic Priority 1,
Objective 1 to reflect the need to deliver its objectively assessed needs – as a minimum – including
consideration of the contribution that could be made to solving housing numbers across the South Essex JSP
area.

Strategy Options

Q5: Do you agree with the settlement hierarchy presented?

No.

We have reviewed the Council’s Settlement Role and Hierarchy Study (SRH) (2020) (undertaken by Troy
Planning for both Southend-on-Sea and Rochford) and the supporting Topic Paper 4: ‘Complete Communities’
(produced by Rochford District Council and focussing solely on Rochford District) to inform this view.
We do not wholly oppose the Council’s decision to consider the ‘completeness’ of settlements as a means of
both formulating the position of settlements within the hierarchy, as well as the likely level of development
required within these settlements to instigate their completeness. The latter is particularly beneficial with
regards to promoting sustainable development in rural areas, as required by Paragraph 79 of the NPPF.
We also welcome the elements of the conclusions with regard to ‘capacity for growth’ (see Paragraph 11.17 –
Paragraph 11.36 of the SRH) which aptly reflects that ‘significant growth’ would be suitable in Rayleigh,
Rochford (with Ashingdon) and Hockley (with Hawkwell); ‘some growth’ at Great Wakering and Hullbridge; and
‘sustained limited growth’ at Rawreth, Great Stambridge, Stonebridge, Paglesham, South Fambridge and
Canewdon – with the latter comparatively more ‘complete’ then the others.

However, BDW consider there are elements to the approach taken to the SRH Study could be improved and
given greater weight.

Firstly, we feel it is the presence of day-to-day facilities that is the most important consideration on the
sustainability / completeness of a settlement. Based on Table 2 of the Topic Paper (pg. 10), the settlements
can be ranked accordingly:

Settlement - Rayleigh
Total Facilities - 17
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 3/5
Sport & Leisure - 2/2

Settlement - Rochford (including Ashingdon)
Total Facilities - 17
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 3/5
Sport & Leisure - 2/2

Settlement - Hockley (including Hawkwell)
Total Facilities - 16
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 2/5
Sport & Leisure - 2/2

Settlement - Wakerings and Barling
Total Facilities - 12
Green Infrastructure - 2/4
Education - 2/3
Civic - 3/5
Health - 2/3
Town Centre Uses - 1/5
Sport & Leisure - 2/2

Settlement - Hullbridge
Total Facilities - 12
Green Infrastructure - 2/4
Education - 1/3
Civic - 4/5
Health - 2/3
Town Centre Uses - 1/5
Sport & Leisure - 2/2

Settlement - Canewdon
Total Facilities - 7
Green Infrastructure - 2/4
Education - 1/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 1/5
Sport & Leisure - 1/2

Settlement - Rawreth
Total Facilities - 6
Green Infrastructure - 1/4
Education - 1/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 2/2

Settlement - Paglesham
Total Facilities - 3
Green Infrastructure - 1/4
Education - 0/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - Great Stambridge
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - South Fambridge
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - Stonebridge (including Sutton)
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

The table above shows a clear hierarchy across the settlements. Rayleigh, Rochford (including Ashingdon)
and Hockley (including Hawkwell) are all equally as sustainable and have high / the highest levels of
completeness. Thereafter, the Wakerings and Barling, and Hullbridge, are the next most “complete”
settlements – with moderate levels of completeness. The rural settlements are comparably lower, with the
exception of Canewdon and Rawreth which are relatively more complete.

Whilst it is recognised that walking and active travel should be promoted, the SRH’s approach of using the %
of each space within a defined walking catchment of the services within the settlement fails to account for three
key points:

The areas of settlements with the highest completeness scores across the Districts are the central areas
of Rayleigh, Hockley (including Hawkwell), and Rochford (including Ashingdon). However, as the Council’s evidence base shows, the ability to locate new housing in these central areas is restricted by both capacity and its requirement to deliver dwellinghouses (rather than flats) – notwithstanding the aims to seek to support development in rural areas. Accordingly, this would require locating development in areas where walking completeness is not as high in peripheral areas, which as the data demonstrates, is equally issue across all settlements.

Secondly, and related to the above, the aggregated scores mask the most suitable sites within individual
settlements. For example, in Wakerings and Barling, the inclusion of the peripheral areas of the cluster
contribute predominantly to the settlement’s poorer walkability. BDW’s site at Land east of Star Lane and
north of Poynters Lane, Great Wakering is well related to the centre of Great Wakering – and would have a far greater walkability score than more peripheral edges.

Finally, and related to the above, the completeness of settlements can only be improved where sufficient
development is provided to add additional infrastructure. For example, BDW’s site in Great Wakering would allow sufficient justification for the expansion of the adjacent school – with land reserved for this purpose.

In regard of the SRH’s assessment of public transport services, it has only looked at the quantitative aspects
via the frequency of services. Paragraph 105 recognises that maximising sustainable transport solutions will
vary between urban and rural areas. Indeed, predominantly, this will be recognised as the frequency of
services – and therefore the qualitative aspect of these services is equally, if not, more important. In the case
of Great Wakering, 91% of the settlement has access to a non-frequent bus service. However, a number of
the available services (e.g. 8, 14) allow access to Southend – which the SRH recognises as the Tier 1
Settlement for both areas combined. With the exception of the most complete settlements in Rochford, Great
Wakering is a sustainably located settlement with (relatively) good transport access to Southend.

In light of our thoughts above, we consider the Council should retain its existing hierarchy – as set out at
paragraph 4.9 of the Core Strategy:

Tier 1: Rayleigh; Rochford (and Ashingdon); Hockley (and Hawkwell)
Tier 2: Hullbridge and Great Wakering
Tier 3: Canewdon
Tier 4: All other settlements

In accordance with the ‘capacity for growth’ conclusions, Tier 1 should seek to receive ‘significant growth’, Tier
2 ‘some growth’, and Tier 3 and 4 ‘sustained limited growth’ – although with recognition that Canewdon is far
more sustainable than other rural settlements. The Council should seek to distribute growth accordingly,
informed by the relative constraints of each site.

As an additional observation, the Council will have to consider how any extension North / North East of
Southend would be considered within the settlement hierarchy if this option is to be carried forward.

Q6: Which of the identified strategy options do you consider should be taken forward in the Plan?
We support Spatial Option 2B primarily, but also Option 4.

We have reviewed the supporting Topic Paper 11: ‘Strategy Options’ (produced by Rochford District Council) to inform this view.

As recognised by the Council, Option 1 would fail to deliver its development needs. The HELAA (June 2020
Update) and Urban Capacity Study (2020) have concluded that insufficient space exists within the existing urban areas and on previously developed sites to meet the Council’s identified need. Paragraph 61 of the
NPPF is clear that local housing need defined by the standard method determines “the minimum number of
homes needed […] unless exceptional circumstances justify an alternative approach”. In the absence of
exceptional circumstances required to justify an alternative approach, Option 1 cannot be reasonably
progressed by the Council.

Accordingly, the Council will be required to release Green Belt Land.

Option 2a would fail to promote sustainable development in rural areas, in order to enhance or maintain their
vitality – as required by paragraph 78 of the NPPF. As our answers to this consultation have demonstrated,
there are capable sites – such as Land east of Star Lane and north of Poynters Lane, Great Wakering – which
have the potential to deliver such growth, as well as to fund the additional infrastructure these communities
need.

Whilst Option 3a, 3b and 3c could instigate the delivery of large numbers of dwellings (notwithstanding the
potential to deliver development that meets cross-boundary issues – see below) the Council should have due regard to the fact that large strategic sites often have longer build-out times, and the requirement of Paragraph
69 to identify at least 10% of housing requirement on small- and medium-sites. Furthermore, as noted above,
there are clear opportunities for this delivery to be directed to existing settlements.

In light of the above, we consider Option 2B would provide a more dispersed growth strategy that provides
opportunities to balance housing trajectory across the District – on both small and large sites, brownfield and
greenfield sites, and across different settlements.

We loosely also support Option 4, which recognises that a combination of all listed strategies to deliver the
broad range of requirements of national policy and the development Rochford needs. Option 4 will be heavily
influenced by any decision of the Council to deliver housing in excess of its minimum. The evidence currently
demonstrates that Southend will require cross-boundary delivery due to insufficient land, and Rochford should
continue to work constructively with Southend (and other surrounding authorities) to ensure that housing
delivery is satisfied across the South Essex Housing Market Area.

Q7: Are there are any reasonable alternatives to these options that should be considered further?
See our response to Q6.

Spatial Themes

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

No.

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.

Paragraph 162 of the NPPF confirms the aim of the sequential test is to steer new development to areas with
the lowest risk of flooding from any source, and that development should not be allocated or permitted if there
are reasonable available sites appropriate for the proposed development in areas at lowest risk of flooding.

The evidence provided by the South Essex Level 1 Strategic Flood Risk Assessment (April 2018) confirms
Land east of Star Lane and north of Poynters Lane, Great Wakering is predominantly located in Flood Zone 1
(including accounting for climate change). As illustrated on the Framework Plan, it is possible for development
to be concentrated in these areas, with those small areas of Flood Zones 2/3 being kept free from development.

In accordance with Paragraph 162, this site should be a preferred option for allocation.

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?


BDW would expect these designations to be afforded the necessary weight in the emerging Local Plan and/or
at the planning application stage. Subject to the Council selecting either Option 2b or 4 as set out in the response to Q.6 above, BDW also suggests that sites which are unconstrained from such designations should be the focus of allocations in the emerging Local Plan.

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?

Whilst BDW support the principle of requiring a percentage of energy in developments to be from low-carbon and renewable sources, this should be subject to consideration of viability.

BDW is committed to being a sustainable housebuilder and continue to integrate sustainability into their
business practices, helping to create better homes and communities and a stronger business for the longer term. BDW has a proven track record as a sustainable housebuilder, including achieving a 22% reduction in
carbon emissions since 2015 and aims to be the country’s leading sustainable national housebuilder by
achieving net zero greenhouse gas emissions by 2040 (the first major housebuilder to do so); in addition to 100% of their own electricity to be renewable by 2025; and new homes design to be net zero carbon from
2030.

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?

Whilst BDW support the principle of requiring energy efficiency standards of developments to be higher than
the building regulations, this should not be a requirement for all developments. The ability to achieve this will be subject to the viability of a scheme.

Therefore, to be acceptable in planning terms, developments should meet the energy efficiency standard set out by building regulations. If a scheme were to exceed building regulations, this should be recognised as a bespoke merit / positive of the scheme that should weigh favourably in the planning balance.

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?

BDW support the inclusion of a place-making charter and the listed standards, in principle.

Whilst broad objectives (e.g. aiming for carbon-neutrality; tackling air quality; promoting active travel) may help
achieve a collective Vision for the area, sufficient account and flexibility must be given for settlement / site-specific circumstances.

Please see our response to Q16 and Q59.

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

Please see our response to Q14.

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

Yes.

Following the recent update to the NPPF, paragraph 128 now requires all local planning authorities to prepare
design guides or codes consistent with the principles set out in the National Design Guide and National Model
Design Code.

Please see our detailed response to Q16b. and Q16c.

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?

BDW oppose the imposition of a single, broad design guide/code for the District. As the Council recognise,
this would fail to account for and preserve the mix of historic, natural, and urban environments that help to
create distinctive local vernacular and character. Conversely, BDW would also oppose the production of
specific, prescriptive design codes on a site-by-site basis which would not provide sufficient flexibility, restrict
the use of innovative methods and technologies, and frustrate artistic interpretation – all of which may impact
a development’s viability and contribution to “beauty”.

BDW support the imposition of broad strategic objectives (as set out in the place-making charter, as well as the National Design Guide and National Model Design Code) with sufficient flexibility for design to be responsive to circumstances of a site as they evolve. This might include more specific, but still broad objectives are settlement/area level.

Indeed, paragraph 129 of the NPPF advises that developers may also choose to prepare design codes in
support of planning application for sites they wish to develop. This option would give the freedom to provide
interpretation and sufficient resourcing from the private sector to develop appropriate design codes, in
accordance with the National Design Guide and National Model Design Code.

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

Please see also our response to Q16b.

BDW would expect the Council’s adopted design guides/codes to implement broad objectives (at District and Area level) that reflect the 10 characteristics of well-designed places, as set out in the National Model Design
Code. More site-specific design would be influenced by developer produced design codes at submission stage,
reflecting the broad aims.

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?

BDW support Option 4. This would involve taking a market-led approach to housing mix and not specifying
the types, tenures and sizes of houses that need to be delivered through a specific policy.

Option 4 would provide the flexibility required to address site-specific circumstances and respond to the types
of housing required as set out in the most up-to-date housing market assessments. This is the current approach to defining dwelling types, as set out in Policy H5 (Dwelling Types) of the adopted Core Strategy. Option 1 and 3 are too prescriptive and could lead to sites being unviable and not reflecting the needs of the local area. This in turn could delay allocated sites coming forward, leaving the Council facing problems with housing delivery.

If Option 4 was not preferred by the Council, and sufficient evidence was provided to justify such an Option, Option 2 would provide a suitable alternative, as it would factor in a level of negotiation on suitable housing mix (subject to market conditions and viability) – whilst seeking to take account of, and be responsive to, the type or location of development.

BDW support Option 5 in principle, requiring all new homes to meet the Nationally Described Space Standard
(NDSS). As recognised by the Council, the NDSS is currently an optional technical standard, and the Council
would be required to provide sufficient justification for implementing the standard – taking account of need and
viability.

With regard to Option 6 and 7, the requirement for new homes to meet Part M4(2) and Part M4(3) of the
Building Regulations is also an optional technical standard. PPG Paragraph 007 (Reference ID: 56-007-
20150327) confirms that, based on a housing needs assessment, it is for the local planning authority to set out
how it intends to approach demonstrating a need for this requirement, taking account of such information as
the likely future need for housing for older and disabled people (including wheelchair user dwellings), the
accessibility and adaptability of existing housing stock, and the overall impact on viability. In respect of Part
M4(3), Paragraph 009 (Reference ID: 56-009-20150327) is clear that where local plan policies requiring
wheelchair accessible homes are implemented, these should be applied only to dwellings where the local
planning authority is responsible for allocating or nominating a person to live within that dwelling. BDW would expect the appropriate evidence to be provided (within the updated SHMA or a Local Housing Needs
Assessment) to justify the inclusion of these bespoke policies.

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?

As set out in Figure 28 of the consultation document (taken from the South Essex SHMA) the overwhelming
need for dwellings in Rochford District are houses (85%), rather than flatted development (15%). BDW observe
the allocation of smaller, urban/previously developed sites will not satisfy the prevailing demand for
dwellinghouses, which typically require a greater extent of land.

In addition, whilst a strategy that focused development within and adjoining the main built-up areas with an
emphasis on the re-use of previously developed land would promote urban regeneration, it must be
emphasised that this strategy could result in the under delivery of affordable housing owing to viability issues.

It is well documented that the provision of affordable housing on brownfield land / urban sites is challenging
due to the expense associated with acquisition costs, remediation and/or higher than normal construction
costs. Given that market housing is required to subsidise the construction of the affordable housing, the
inevitable consequence is that Council’s targets for the delivery of affordable housing are seldom met when
such a growth strategy is adopted. This, in part, forms our reasoning for a more dispersed, mixed strategy
which includes the release of both underperforming areas of Green Belt which would allow the expansion of
existing towns and villages. Paragraph 73 of the NPPF states “the supply of large numbers of new homes can
often be best achieved through planning for larger scale development, such as new settlements or significant
extensions to existing villages and towns” should be supported.

Such a strategy will also ensure the required level of affordable housing is delivered as schemes on greenfield
sites can viably support delivery of affordable housing compared to brownfield land for the reasons referred to
above.

Utilising this strategy will also disperse the effects of development, rather than focus this predominantly on a
single area – which could ultimately lead to negative impacts such as traffic congestion, noise and air pollution
and stretched community resources/infrastructure – for example. Dispersal will allow a greater range of
housing choice and provide the right type of homes in the right areas to meet the needs of all communities – one of the key parts of the Council’s vision.

A more dispersed growth strategy also provides opportunities to balance housing trajectory across the District and the wider South Essex HMA – as greenfield sites typically have quicker lead-in times / build out rates
compared to those often associated with complex brownfield sites.

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?
No.

Biodiversity

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

Whilst the Environmental Bill is still to receive Royal Assent, the intention of the policy to achieve biodiversity
net gains is clear and supported in principle by BDW.

This does not mean the Council should not seek to encourage developments to secure biodiversity net gain in
excess of the 10% set in the draft Environmental Bill – which of course will be a legal minimum. However, any
requirement to demonstrate a net gain in excess of 10% should be subject to a viability assessment and should
not be considered a requirement to make the development acceptable in planning terms (i.e. any provision in excess of the 10% figure should be considered an additional benefit of a proposed scheme).

PPG Paragraph 022 (Reference ID: 8-022-20190721) advises that biodiversity net gain can be achieved on-site, off-site or through a combination of both on-site and off-site measures. National guidance does not
explicitly state the percentage split between such provision, but Paragraph 023 (Reference ID: 8-023-
20190721) confirms such gain can be delivered entirely on-site or by using off-site gains where necessary.

Therefore, BDW would expect the Council to reflect the ambitions of the Environmental Bill and incorporate
the necessary level of flexibility in any allocation requirement and/or policy, providing opportunities to create networks to not just support biodiversity enhancement on-site, but also to encourage residents to have access to the natural environment on other sites (off-site) across the District. This would ensure improvements are both beneficial and viable.

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?

BDW support a combination of all Options identified by the Council in addressing the need for sufficient and
accessible community infrastructure through the plan.

Whilst the Council should seek to invest and protect existing community infrastructure, it should seek to first
locate development in areas with adequate proximity to existing infrastructure before seeking to promote sites
that are capable of facilitating the delivery of much needed community infrastructure in other areas. The latter
is evidence in the Land east of Star Lane and north of Poynters Lane, Great Wakering – which has reserved
land in order to deliver a new school in Great Wakering on the current Great Wakering Primary Academy site.

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

Yes.

The Council recognise a widespread lack of access to community facilities across the District. Where greater
access is more recognised in the major settlements, a concentration of development may put stress on these
existing facilities – whilst not delivering in more rural settlements.

Therefore, the implementation of Option 2b and/or Option 4 – both of which would permit urban extensions
across the settlement hierarchy – would permit the wider delivery of existing facilities whilst not creating
pressure spots.

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?

Yes – see our response to Q.36.

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?

BDW support Option 4.

Larger and strategic developments are capable of delivering areas for open space and recreation as part of a holistic development of a site. As evidenced in the Framework Plan, BDW consider a variety of public open
spaces, including strategic, local equipped areas of play (LEAPs) and a Multi-Use Games Areas (MUGAs) can
be incorporated into the proposals.

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

As set out in our response to Q38, BDW considers the Council should consider the potential for larger and
strategic-level development sites to deliver areas for open space and recreation as part of a holistic
development of a site.

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?

Yes.

Larger and strategic development sites are capable of delivering areas for open space and recreation as part
of a holistic development of a site.

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

No.

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?
BDW support a combination of all Options identified by the Council in addressing the need for sufficient and
accessible community infrastructure through the plan.

As set out in our response to Q5 and Q6, the Council should seek to incorporate a dispersed growth strategy.
A more dispersed growth strategy will provide a balance between utilising and optimising existing connections
in the more sustainable settlements, whilst providing improvements to less sustainable locations. A more
dispersed growth strategy will also work to avoid overuse and unnecessary congestion on more densely
populated areas, which bring with them problems of air quality and noise pollution.

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

Please also see our response to Q51.

As part of a more dispersed Growth Strategy, the Council should seek to ease congestion by locating
development in locations which can benefit from wider improvements – such as, as the Council recognise, bus
services to Great Wakering. This should be combined and recognised with the delivery of such infrastructure
through contribution and/or bespoke delivery in larger allocations.

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.]

Please see our response to Q52 / Q53.

Planning for Complete Communities

Wakerings and Barling

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

As per our response to Q4, through the lack of current alternative evidence, we consider the Wakerings and
Barling (in particular, Great Wakering) should remain a Tier 2 settlement.

BDW consider the restriction of Great Wakering to “development that […] is locally-responsive and aimed at
meeting the ongoing housing and employment needs of local residents” fails to account for the opportunity
provided by this comparatively sustainable settlement to provide a substantial contribution to the District’s
housing need with the proposed allocation at Land east of Star Lane and north of Poynters Lane, Great
Wakering.

The consultation document considers that the majority of Great Wakering has “reasonable walking access to
day-to-day services”, with BDW’s promoted site within the higher end of the walking completeness score (8-
10). In line with our Preferred Growth Strategy (Option 2b or 4), we consider this site has the potential to provide substantial growth at this settlement required to facilitate investment in infrastructure across the plan area, including the delivery of the school allocation and other infrastructure improvements – a key objective of the plan.

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

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

BDW consider Land east of Star Lane and north of Poynters Lane, Great Wakering (HELAA Refs: CS057 and CS070) as suitable, available, and deliverable sites for approximately 800 dwellings.

Next Steps

We trust the above is clear and look forward to being notified as to the next steps with the emerging Local
Plan, and if you can please confirm receipt, it would be much appreciated.

Yours faithfully
David Churchill
Partner

ROCHFORD DISTRICT COUNCIL SPATIAL OPTIONS CONSULTATION (REGULATION 18) - BARRATT DAVID WILSON HOMES RESPONSE: LAND EAST OF STAR LANE AND NORTH OF POYNTERS LANE, GREAT WAKERING

On behalf of our client, Barratt David Wilson Homes (‘BDW’), please find enclosed representations to the
Spatial Options consultation currently being undertaken by Rochford District Council (‘the Council’).
Background
BDW
BDW is the nation’s leading housebuilder, creating great new places to live throughout Britain. In 2019/20,
BDW delivered over 12,600 new homes.
BDW are experts in land acquisition, obtaining planning consents and building the highest quality homes in
places people aspire to live. This expertise has been shared with the Council in recent times through the
delivery of other schemes in the District – including the High Elms Park development in Hullbridge.
BDW is committed to being a sustainable housebuilder and continue to integrate sustainability into their
business practices, helping to create better homes and communities and a strong business for the longer term.

Land South of Hall Road, Rochford
BDW is currently promoting Land South of Hall Road, Rochford (HELAA Ref: CFS084) as an allocation for
housing in the emerging Local Plan for approximately 250 homes. These representations are supported by a
Vision Document which is appended to this letter, alongside a site location plan.
BDW would like to make the following observations on the content of the Spatial Options consultation.

Vision, Priorities and Objectives
Q2: Do you agree with our draft vision for Rochford District?

Whilst BDW agree with the draft vision for Rochford District in principle, we would like to make the following
observations.

As currently drafted, no reflection of the purpose, aims and objectives of the emerging South Essex Joint
Spatial Plan (JSP) is made. The Statement of Common Ground (SoCG) (2018) between the six constitutive
Council’s (plus Essex County Council) involves a commitment to work together on strategic planning matters,
including meeting the housing needs of entire sub-region in full (our emphasis) (see Chapter 9). The relationship between Rochford and Southend-on-Sea is imperative to achieving this, as recognised by the current in-tandem production of new Local Plans in these areas – including the production of a joint evidence base (e.g. Green Belt, HELAA). The evidence base (see HELAA June 2020) is clear that Southend will be unable to meet its objectively assessed housing need on deliverable sites within its administrative boundaries in both policy-on and policy-off scenarios (a shortfall of 6,671 dwellings from 2020-2040), whilst Rochford (in a policy-off scenario) contains deliverable sites to provide a surplus of 35,935 dwellings from 2020-2040 – including Land South of Hall Road, Rochford. Given the relationship between the two administrative areas, it is imperative that the Council works constructively with Southend (and other Council’s within the South Essex JSP) to meet the commitment of the JSP to deliver South Essex’s housing need in full. It is important that the commitment to working with the JSP Councils to meet the needs of the area in full is recognised in the development of a vision that looks further ahead than just the Plan period (i.e. to at least 30 years) to ensure future generations have clarity on the growth of the District in the context of the JSP area.

With regards to ‘Our Society’, the Council’s supporting text should be evolved to recognise that although
focussing on previously developed land may be the priority, the evidence base demonstrates there is
insufficient land within these categories to deliver its objectively assessed needs. The HELAA (June 2020
Update) demonstrates a total of 4,320 dwellings can be provided (including a 39dpa windfall) on previously
developed / currently approved sites – a shortfall of 2,880 dwellings. The Urban Capacity Study indicates that
this, at a maximum, can be increased to 5,000 dwellings, still leaving the Council with a shortfall. The Vision
needs to evolve to cover a longer period (as per Paragraph 22 of the NPPF) and recognise that growth on
greenfield sites (including Green Belt) must now take place under an appropriate strategy – which should allow
for a mix of sites and a range of homes to be delivered which can help combat affordability issues and support
Growth across the plan period (see our answer to Q6).

With regards to ‘Our Environment’, the Council’s pledge to retain an extensive Metropolitan Green Belt
designation is noted, but in light of the evidence regarding objectively assessed development needs it is
important that this is clearly defined to allow for future growth to be accommodated within the Green Belt
following Plan reviews.

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

BDW agree with this approach, in principle, insofar as it allows for both the correct quantum and type of
development to be delivered within each settlement to meet the Council’s identified needs.
Please see also our response to Q5, Q6, Q7 and Q56.

Q4: Do you agree with the strategic priorities and objectives we have identified?
BDW broadly agree to the strategic priorities and objectives identified in principle.
However, as set out in our response to Q1, BDW consider the Council should amend Strategic Priority 1,
Objective 1 to reflect the need to deliver its objectively assessed needs – as a minimum – including
consideration of the contribution that could be made to solving housing numbers across the South Essex JSP
area.

Strategy Options

Q5: Do you agree with the settlement hierarchy presented?
No.

We have reviewed the Council’s Settlement Role and Hierarchy Study (SRH) (2020) (undertaken by Troy
Planning for both Southend-on-Sea and Rochford) and the supporting Topic Paper 4: ‘Complete Communities’
(produced by Rochford District Council and focussing solely on Rochford District) to inform this view.
We do not wholly oppose the Council’s decision to consider the ‘completeness’ of settlements as a means of
both formulating the position of settlements within the hierarchy, as well as the likely level of development
required within these settlements to instigate their completeness. The latter is particularly beneficial with
regards to promoting sustainable development in rural areas, as required by Paragraph 79 of the NPPF.
We also welcome the elements of the conclusions with regard to ‘capacity for growth’ (see Paragraph 11.17 –
Paragraph 11.36 of the SRH) which aptly reflects that ‘significant growth’ would be suitable in Rayleigh,
Rochford (with Ashingdon) and Hockley (with Hawkwell); ‘some growth’ at Great Wakering and Hullbridge; and
‘sustained limited growth’ at Rawreth, Great Stambridge, Stonebridge, Paglesham, South Fambridge and
Canewdon – with the latter comparatively more ‘complete’ then the others.
However, BDW consider there are elements to the approach taken to the SRH Study could be improved and
given greater weight.
Firstly, we feel it is the presence of day-to-day facilities that is the most important consideration on the
sustainability / completeness of a settlement. Based on Table 2 of the Topic Paper (pg. 10), the settlements can be ranked accordingly:

Settlement - Rayleigh
Total Facilities - 17
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 3/5
Sport & Leisure - 2/2

Settlement - Rochford (including Ashingdon)
Total Facilities - 17
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 3/5
Sport & Leisure - 2/2

Settlement - Hockley (including Hawkwell)
Total Facilities - 16
Green Infrastructure - 2/4
Education - 3/3
Civic - 5/5
Health - 3/3
Town Centre Uses - 2/5
Sport & Leisure - 2/2

Settlement - Wakerings and Barling
Total Facilities - 12
Green Infrastructure - 2/4
Education - 2/3
Civic - 3/5
Health - 2/3
Town Centre Uses - 1/5
Sport & Leisure - 2/2

Settlement - Hullbridge
Total Facilities - 12
Green Infrastructure - 2/4
Education - 1/3
Civic - 4/5
Health - 2/3
Town Centre Uses - 1/5
Sport & Leisure - 2/2

Settlement - Canewdon
Total Facilities - 7
Green Infrastructure - 2/4
Education - 1/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 1/5
Sport & Leisure - 1/2

Settlement - Rawreth
Total Facilities - 6
Green Infrastructure - 1/4
Education - 1/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 2/2

Settlement - Paglesham
Total Facilities - 3
Green Infrastructure - 1/4
Education - 0/3
Civic - 2/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - Great Stambridge
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - South Fambridge
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

Settlement - Stonebridge (including Sutton)
Total Facilities - 0
Green Infrastructure - 0/4
Education - 0/3
Civic - 0/5
Health - 0/5
Town Centre Uses - 0/5
Sport & Leisure - 0/2

The table above shows a clear hierarchy across the settlements. Rayleigh, Rochford (including Ashingdon)
and Hockley (including Hawkwell) are all equally as sustainable and have high / the highest levels of
completeness. Thereafter, the Wakerings and Barling, and Hullbridge, are the next most “complete”
settlements – with moderate levels of completeness. The rural settlements are comparably lower, with the exception of Canewdon and Rawreth which are relatively more complete.
Whilst, it is recognised that walking and active travel should be promoted, the SRH’s approach of using the %
of each space within a defined walking catchment of the services within the settlement fails to account for three
key points:

• The areas of settlements with the highest completeness scores across the Districts are the central areas of Rayleigh, Hockley (including Hawkwell), and Rochford (including Ashingdon). However, as the Council’s evidence base shows, the ability to locate new housing in these central areas is restricted by both capacity and its requirement to deliver dwellinghouses (rather than flats) – notwithstanding the aims to seek to support development in rural areas. Accordingly, this would require locating development inareas where walking completeness is not as high in peripheral areas, which as the data demonstrates, is equally issue across all settlements.
• Secondly, and related to the above, the aggregated scores mask the most suitable sites within individual
settlements. For example, in Wakerings and Barling, the inclusion of the peripheral areas of the cluster contribute predominantly to the settlement’s poorer walkability. BDW’s site at Land east of Star Lane and north of Poynters Lane, Great Wakering is well related to the centre of Great Wakering – and would have
a far greater walkability score than more peripheral edges.
• Finally, and related to the above, the completeness of settlements can only be improved where sufficient
development is provided to add additional resource. For example, BDW’s site in Great Wakering would allow sufficient justification for the expansion of the school – with land reserved for this purpose.

In regard of the SRH’s assessment of public transport services, it has only looked at the quantitative aspects
via the frequency of services. Paragraph 105 recognises that maximising sustainable transport solutions will
vary between urban and rural areas. Indeed, predominantly, this will be recognised as the frequency of
services – and therefore the qualitative aspect of these services is equally, if not, more important. In the case
of Great Wakering, 91% of the settlement has access to a non-frequent bus service. However, a number of
the available services (e.g. 8, 14) allow access to Southend – which the SRH recognises as the Tier 1
Settlement for both areas combined. With the exception of the most complete settlements in Rochford, Great
Wakering is a sustainably located settlement with (relatively) good transport access to Southend.

In light of our thoughts above, we consider the Council should retain its existing hierarchy – as set out at
paragraph 4.9 of the Core Strategy:
Tier 1: Rayleigh; Rochford (and Ashingdon); Hockley (and Hawkwell)
Tier 2: Hullbridge and Great Wakering
Tier 3: Canewdon
Tier 4: All other settlements

In accordance with the ‘capacity for growth’ conclusions, Tier 1 should seek to receive ‘significant growth’, Tier 2 ‘some growth’, and Tier 3 and 4 ‘sustained limited growth’ – although with recognition that Canewdon is far more sustainable than other rural settlements. The Council should seek to distribute growth accordingly, informed by the relative constraints of each site.
As an additional observation, the Council will have to consider how any extension North / North East of
Southend would be considered within the settlement hierarchy if this option is to be carried forward.

Q6: Which of the identified strategy options do you consider should be taken forward in the Plan?
We support Spatial Option 2B primarily, but also Option 4.
We have reviewed the supporting Topic Paper 11: ‘Strategy Options’ (produced by Rochford District Council) to inform this view.
As recognised by the Council, Option 1 would fail to deliver its development needs. The HELAA (June 2020
Update) and Urban Capacity Study (2020) have concluded that insufficient space exists within the existing urban areas and on previously developed sites to meet the Council’s identified need. Paragraph 61 of the
NPPF is clear that local housing need defined by the standard method determines “the minimum number of
homes needed […] unless exceptional circumstances justify an alternative approach”. In the absence of
exceptional circumstances required to justify an alternative approach, Option 1 cannot be reasonably
progressed by the Council.
Accordingly, the Council will be required to release Green Belt Land.
Option 2a would fail to promote sustainable development in rural areas, in order to enhance or maintain their
vitality – as required by paragraph 78 of the NPPF. As our answers to this consultation have demonstrated,
there are capable sites – such as Land east of Star Lane and north of Poynters Lane, Great Wakering – which
have the potential to deliver such growth, as well as to fund the additional infrastructure these communities
need.

Whilst Option 3a, 3b and 3c could instigate the delivery of large numbers of dwellings (notwithstanding the
potential to deliver development that meets cross-boundary issues – see below) the Council should have due regard to the fact that large strategic sites often have longer build-out times, and the requirement of Paragraph
69 to identify at least 10% of housing requirement on small- and medium-sites. Furthermore, as noted above,
there are clear opportunities for this delivery to be directed to existing settlements.
In light of the above, we consider Option 2B would provide a more dispersed growth strategy that provides
opportunities to balance housing trajectory across the District – on both small and large sites, brownfield and
greenfield sites, and across different settlements.
We loosely also support Option 4, which recognises that a combination of all listed strategies to deliver the broad range of requirements of national policy and the development Rochford needs. Option 4 will be heavily
influenced by any decision of the Council to deliver housing in excess of its minimum. The evidence currently
demonstrates that Southend will require cross-boundary delivery due to insufficient land, and Rochford should
continue to work constructively with Southend (and other surrounding authorities) to ensure that housing
delivery is satisfied across the South Essex Housing Market Area.

Q7: Are there are any reasonable alternatives to these options that should be considered further?
See our response to Q6.

Spatial Themes
Q8: Are there any key spatial themes that you feel we have missed or that require greater emphasis?
No.
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.

Paragraph 162 of the NPPF confirms the aim of the sequential test is to steer new development to areas with
the lowest risk of flooding from any source, and that development should not be allocated or permitted if there
are reasonable available sites appropriate for the proposed development in areas at lowest risk of flooding.
The evidence provided by the South Essex Level 1 Strategic Flood Risk Assessment (April 2018) confirms
Land South of Hall Road, Rochford is predominantly located in Flood Zone 1 (including accounting for climate
change). As set out in the Vision Document, it is possible for development to be concentrated in these areas, with minor parts located in Flood Zones 2/3 free from development. These areas would instead be used for
surface water attenuation and other sustainable urban drainage (SUDS) options to mitigate flood risk. There
is also the opportunity to create biodiversity enhancements in this area.
In accordance with Paragraph 162, this site should be a preferred option for allocation.

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?
BDW would expect these designations to be afforded the necessary weight in the emerging Local Plan and/or
at the planning application stage. Subject to the Council selecting either Option 2b or 4 as set out in the
response to Q.6 above, BDW also suggests that sites which are unconstrained from such designations should
be the focus of allocations in the emerging Local Plan.
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?
Whilst BDW support the principle of requiring a percentage of energy in developments to be from low-carbon and renewable sources, this should be subject to consideration of viability.

BDW is committed to being a sustainable housebuilder and continue to integrate sustainability into their
business practices, helping to create better homes and communities and a stronger business for the longer
term. BDW has a proven track record as a sustainable housebuilder, including achieving a 22% reduction in
carbon emissions since 2015 and aims to be the country’s leading sustainable national housebuilder by
achieving net zero greenhouse gas emissions by 2040 (the first major housebuilder to do so); in addition to 100% of their own electricity to be renewable by 2025; and new homes design to be net zero carbon from
2030.

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?
Whilst BDW support the principle of requiring energy efficiency standards of developments to be higher than
the building regulations, this should not be a requirement for all developments. The ability to achieve this will be subject to the viability of a scheme.
Therefore, to be acceptable in planning terms, developments should meet the energy efficiency standard set out in the building regulations. If a scheme were to exceed building regulations, this should be recognised as a bespoke merit / positive of the scheme, that should weigh favourably in the planning balance.
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?
BDW support the inclusion of a place-making charter and the listed standards, in principle.
Whilst broad objectives (e.g. aiming for carbon-neutrality; tackling air quality; promoting active travel) may help
achieve a collective Vision for the area, sufficient account and flexibility must be given for settlement / site-specific circumstances.
Please see our response to Q16 and Q57.

Q15: Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
Please see our response to Q14.
Q16a: Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
Yes.

Following the recent update to the NPPF, Paragraph 128 now requires all local planning authorities to prepare
design guides or codes consistent with the principles set out in the National Design Guide and National Model
Design Code.
Please see our detailed response to Q16b. and Q16c.

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?
BDW oppose the imposition of a single, broad design guide/code for the District. As the Council recognise,
this would fail to account for and preserve the mix of historic, natural, and urban environments that help to
create distinctive local vernacular and character. Conversely, BDW would also oppose the production of
specific, prescriptive design codes on a site-by-site basis which would not provide sufficient flexibility, restrict the use of innovative methods and technologies, and frustrate artistic interpretation – all of which may impact
a development’s viability and contribution to “beauty”.
BDW support the imposition of broad strategic objectives (as set out in the place-making charter, as well as
the National Design Guide and National Model Design Code) with sufficient flexibility for design to be responsive to circumstances of a site as they evolve. This might include more specific, but still broad objectives are settlement/area level.
Indeed, Paragraph 129 of the NPPF advises that developers may also choose to prepare design codes in
support of planning application for sites they wish to develop. This option would give the freedom to provide
interpretation and sufficient resourcing from the private sector to develop appropriate design codes, in
accordance with the National Design Guide and National Model Design Code.

Q16c: What do you think should be included in design guides/codes/masterplans at the scale you are
suggesting?
Please see also our response to Q16b.
BDW would expect Council’s adopted design guides/codes to implement broad objectives (at District and Area level) that reflect the 10 characteristics of well-designed places, as set out in the National Model Design Code.
More site-specific design would be influenced by developer produced design codes at submission stage,
reflecting the broad aims.

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?

BDW support Option 4. This would involve taking a market-led approach to housing mix and not specifying the types, tenures and sizes of houses that need to be delivered through a specific policy.
Option 4 would provide the flexibility required to address site-specific circumstances and respond to the types
of housing required as set out in the most up-to-date housing market assessments. This is the current approach to defining dwelling types, as set out in Policy H5 (Dwelling Types) of the adopted Core Strategy. Option 1 and 3 are too prescriptive and could lead to sites being unviable and not reflecting the needs of the local area. This in turn could delay allocated sites coming forward, leaving the Council facing problems with housing delivery.
If Option 4 was not preferred by the Council, and sufficient evidence was provided to justify such an Option, Option 2 would provide a suitable alternative, as it would factor in a level of negotiation on suitable housing mix (subject to market conditions and viability) – whilst seeking to take account of, and be responsive to, the type or location of development.
BDW support Option 5 in principle, requiring all new homes to meet the Nationally Described Space Standard
(NDSS). As recognised by the Council, the NDSS is currently an optional technical standard, and the Council
would be required to provide sufficient justification for implementing the standard – taking account of need and
viability.
With regard to Option 6 and 7, the requirement for new homes to meet Part M4(2) and Part M4(3) of the
Building Regulations is also an optional technical standard. PPG Paragraph 007 (Reference ID: 56-007-
20150327) confirms that, based on a housing needs assessment, it is for the local planning authority to set out how it intends to approach demonstrating a need for this requirement, taking account of such information as
the likely future need for housing for older and disabled people (including wheelchair user dwellings), the
accessibility and adaptability of existing housing stock, and the overall impact on viability. In respect of Part
M4(3), Paragraph 009 (Reference ID: 56-009-20150327) is clear that where local plan policies requiring
wheelchair accessible homes are implemented, these should be applied only to dwellings where the local
planning authority is responsible for allocating or nominating a person to live within that dwelling. BDW would expect the appropriate evidence to be provided (within the updated SHMA or a Local Housing Needs
Assessment) to justify the inclusion of these bespoke policies.

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?
As set out in Figure 28 of the consultation document (taken from the South Essex SHMA) the overwhelming
need for dwellings in Rochford District are houses (85%), rather than flatted development (15%). BDW observe
the allocation of smaller, urban/previously developed sites will not satisfy the prevailing demand for
dwellinghouses, which typically require a greater extent of land.

In addition, whilst a strategy that focused development within and adjoining the main built-up areas with an
emphasis on the re-use of previously developed land would promote urban regeneration, it must be
emphasised that this strategy could result in the under delivery of affordable housing owing to viability issues.
It is well documented that the provision of affordable housing on brownfield land / urban sites is challenging
due to the expense associated with acquisition costs, remediation and/or higher than normal construction
costs. Given that market housing is required to subsidise the construction of the affordable housing, the inevitable consequence is that Council’s targets for the delivery of affordable housing are seldom met when such a growth strategy is adopted. This, in part, forms our reasoning for a more dispersed, mixed strategy which includes the release of both underperforming areas of Green Belt which would allow the expansion of existing towns and villages. Paragraph 73 of the NPPF states “the supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns” should be supported.
Such a strategy will also ensure the required level of affordable housing is delivered as schemes on greenfield
sites can viably support delivery of affordable housing compared to brownfield land for the reasons referred to
above.
Utilising this strategy will also disperse the effects of development, rather than focus this predominantly on a
single area – which could ultimately lead to negative impacts such as traffic congestion, noise and air pollution
and stretched community resources – for example. Dispersal will allow a greater range of housing choice and provide the right type of homes in the right areas to meet the needs of all communities – one of the key parts
of the Council’s vision.

A more dispersed growth strategy also provides opportunities to balance housing trajectory across the District and the wider South Essex HMA – as greenfield sites typically have quicker lead-in times / build out rates
compared to those often associated with complex brownfield sites.
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?
No

Biodiversity
Q31: Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?
Whilst the Environmental Bill is still to receive Royal Assent, the intention of the policy to achieve biodiversity
net gains is clear and supported in principle by BDW.
This does not mean the Council should not seek to encourage developments to secure biodiversity net gain in excess of the 10% set in the draft Environmental Bill – which of course is a legal minimum. However, any
requirement to demonstrate a net gain in excess of 10% should be subject to a viability assessment and should
not be considered a requirement to make the development acceptable in planning terms (i.e. any provision in excess of the 10% figure should be considered an additional benefit of a proposed scheme).
PPG Paragraph 022 (Reference ID: 8-022-20190721) advises that biodiversity net gain can be achieved on-site, off-site or through a combination of both on-site and off-site measures. National guidance does not explicitly state the percentage split between such provision, but Paragraph 023 (Reference ID: 8-023-20190721) confirms such gain can be delivered entirely on-site or by using off-site gains where necessary.
Therefore, BDW would expect the Council to reflect the ambitions of the Environmental Bill and incorporate
the necessary level of flexibility in any allocation requirement and/or policy, providing opportunities to create networks to not just support biodiversity enhancement on-site, but also to encourage residents to have access to the natural environment on other sites (off-site) across the District. This would ensure improvements are both beneficial and viable.
BDWs site at Hall Road, Rochford is located on the River Roach and therefore offer substantial opportunities to improve the biodiversity of the site and deliver BNG.

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?
BDW support a combination of all listed Options identified by the Council in addressing the need for sufficient
and accessible community infrastructure through the plan.
Whilst the Council should seek to invest and protect existing community infrastructure, it should seek to first
locate development in areas with adequate proximity to existing infrastructure (such as Land South of Hall
Road, Rochford) before seeking to promote sites that are capable of facilitating the delivery of much needed
community infrastructure in other areas.

Q36: With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?
Yes.
The Council recognise a widespread lack of access to community facilities across the District. Where greater
access is more recognised in the major settlements, a concentration of development may put stress on these
existing facilities – whilst not delivering in more rural settlements.
Therefore, the implementation of Option 2b and/or Option 4 – both of which would permit urban extensions
across the settlement hierarchy – would permit the wider delivery of existing facilities whilst spreading the
existing pressures.

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?
Yes – see our response to Q.36

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?
BDW support Option 4.
Larger and strategic developments are capable of delivering areas for open space and recreation as part of a holistic redevelopment of a site. As set out in our Vision Document, Land South of Hall Road has incorporated
approximately 4.18 ha of public open space, including a local equipped area of play (LEAP) within the current
design.
Q40: Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering?
Yes.
However, the Council should consider that larger and strategic development sites are capable of delivering
areas for open space and recreation as part of a holistic redevelopment of a site.

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?
Yes.
Larger and strategic development sites are capable of delivering areas for open space and recreation as part
of a holistic redevelopment of a site.
Q42: Are there particular open spaces that we should be protecting or improving?
No.

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?
BDW support a combination of all Options identified by the Council in addressing the need for sufficient and
accessible community infrastructure through the plan.
As set out in our response to Q5 and Q6, the Council should seek to incorporate a dispersed growth strategy.
A more dispersed growth strategy will provide a balance between utilising and optimising existing connections in the more sustainable settlements, whilst providing improvements to less sustainable locations. A more
dispersed growth strategy will also work to avoid overuse and unnecessary congestion on more densely
populated areas, which bring with them problems of air quality and noise pollution.

Q52: Are there areas where improvements to transport connections are needed?
Please see also our response to Q51.
As part of a more dispersed Growth Strategy, the Council should seek to ease congestion by locating
development in locations which can benefit from wider improvements. This should be combined and recognised with the delivery of such infrastructure through contribution and/or bespoke delivery in larger allocations.
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.]
Please see also our response to Q52 / Q53.

Planning for Complete Communities
Rochford and Ashingdon
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing?
As per our response to Q4, in lack of current alternative evidence, we consider Rochford and Ashingdon should
remain a Tier 1 Settlement.
However, BDW consider the vision for Rochford and Ashingdon as ‘the gateway to our rural countryside’
undermines the designation of these areas as a Tier 1 settlement.
Q57b. With reference to Figure 45 and your preferred Strategy Option, do you think any of the land edge blue should be made available for any of the following uses:
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other
BDW consider Land South of Hall Road, Rochford (Ref: CFS084) provides a suitable, available, and deliverable site for approximately 250 dwellings.
The Vision Document supporting this submission provides detailed analysis of its suitability and deliverability, including how opportunities and constraints have been overcome.

Next Steps
We trust the above is clear and look forward to being notified as to the next steps with the emerging Local
Plan, and if you can please confirm receipt, it would be much appreciated.

Yours faithfully

David Churchill
Partner
E: david.churchill@carterjonas.co.u

Objection to the Spatial Options Consultation Proposals.
In Particular around Hockley Hullbridge and Rochford, All of which will add to the problematic traffic issues, with limited road access, also to the limited Healthcare and Schooling provisions.
I am deeply disappointed by the swathes of countryside/Greenbelt that has been highlighted as suitable for conversion to Housing land, from the report you commissioned with Southend by Lichfields in 2020.
I appreciate that East of England designated you in 2005 with the responsibility to enable the provision of 4750 new builds by 2025, which was added to the 20yr Local Strategic Plan, and that you have fallen behind meeting those targets.
I also appreciate all of the reports you have had drawn up and the various calls for land, which have encouraged many greedy land owners, and developers to offer their land for proposed change of use, hoping for the subsequent windfalls they will benefit from.
However, as a property and business owner within RDC over the past 35 years, I am extremely concerned and as I said before, disappointed that, although the area has grown significantly in population, the infrastructure has not grown to meet the existing demands, let alone cope with the increase of some approx. 15000 + people to inhabit these new proposed properties.
The residents of Rochford District have not seen Section 106 enable the provision of new Schools, GP Clinics, Social or Healthcare services. Prior to meeting you today at Hawkwell Baptist Church, it did seem that it was acceptable for RDC to allow the developers to divide the development sites between companies to ensure they reduce their responsibility of Section 106 obligations. However after it was explained that the funds for this provision has been made over to the council, and you pointed out that you have ‘advised‘ the NHS and Education that it is there awaiting them. But they have neglected to utilise these finds nor provide additional support. You told me at your open event today that you ‘consult with’ other parties regarding development proposals. This is not agreement to provide though is it. How can you possibly prepare for the future if the various stakeholders are not working with joined up thinking/synergy. The affected service partners need to be in full agreement prior to passing such huge permissions, otherwise the additional demands fall squarely onto the shoulders of the already overloaded services of Health and Education. The effect of which leaves the general community burdened with additional constraints.
(It’s hard enough as it is to find an NHS dentist or get a doctors appointment currently, classrooms are already overstretched and local schools bursting at the seams).
Local Police services are reducing, and the demands upon them increasing.
Road and access infrastructure has not been enhanced in any way to accommodate such a huge increase of up to 10,000 more vehicles on the roads (2.2 cars per house hold), travelling around the district now takes twice the time it used to 25 yrs ago, with journeys between Rochford and Rayleigh taking up to, and sometimes over, 40 mins during rush hours.
This increased congestion creates pollution, is not environmentally friendly, and will see a sharp increase to RDC’s carbon footprint.
The water gas and sewerage supplies are greatly affected, which will again affect the roadways as new services are provided.
Water run-off from additional ill planned bolt on sites, will also create localised flooding
Previously, Highways discussed the provision of an extension to the A130, another promise that is yet to be fulfilled. Had it have done so, you might have been better placed to have created a new village along its course, with schools GP and transport infrastructure incorporated.
Interestingly, Chelmsford have done just this with Beaulieu Park. The A130 has been improved and enabled a development which incorporates all of the infrastructure requirements to service the new population. This way shops services healthcare outdoor spaces and schooling have been incorporated, and a new village has been born.
They have met their Thames Gateway requirements, and not suffocated the existing population, but enhanced their District, providing both short- and long-term employment in the process. All of which has been accomplished, without disturbance or displacement of the existing local population.
To earmark so much of our territory is heinous, and will destroy the quality of life for tens of thousands of your existing residents.
The creation of a conurbation between Rochford / Hockley /Rayleigh to Wickford would be devastating to the local wildlife, and countryside and to the mental health of your current community as a whole.
In conclusion
Limited infrastructure has been provided or is planned to support the building of significant thousands of properties in the area, and without such regional fundamental investment, (providing enhanced and increased services and roads for all of the designated locations upon your interactive map), I consider this Spatial exercise to be not only premature, but irresponsible to your existing residents and taxpayers.
You would be better placed to enable the majority of the increased housing provision west of Rayleigh where access to the A130 and A127 would enable easy access, and such a large development would ensure that the full support structure is incorporated at the time of the build, in a seamless joined up integrated planned development with all the service providers, that adds benefits for all .

RDC/Spatial Consultation 2021 Questions

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Q5. Do you agree with the settlement hierarchy presented?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Q60a. Do you agree with our vision for Hullbridge?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

STRATEGY OPTIONS

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

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

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

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

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

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

SPATIAL THEMES

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

HOUSING FOR ALL


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

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

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

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

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

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

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

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

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

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

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

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

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

EMPLOYMENT & JOBS

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

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

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

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

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

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

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

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

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

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

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

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

BIODIVERSITY

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

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

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

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

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

On-site.

GREEN AND BLUE INFRASTRUCTURE

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

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

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

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

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

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

COMMUNITY INFRASTRUCTURE

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

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

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

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

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

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

OPEN SPACES & RECREATION

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

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

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

All-weather facilities should be considered where
appropriate.

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

The potential sites seem acceptable.

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

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

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

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

HERITAGE

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

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

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

Areas of precious woodland should not be taken for
housing.

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

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

TOWN CENTRES AND RETAIL


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

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

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

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

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

N/A

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

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

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

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

TRANSPORT & CONNECTIVITY

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

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

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

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

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

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

GREEN BELT AND RURAL ISSUES

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

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

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

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

PLANNING FOR COMPLETE COMMUNITIES

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

N/A

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

N/A

How could that improve the completeness of Rayleigh?

N/A

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

N/A

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

N/A

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

N/A

iv. Other

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

N/A

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

N/A

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

N/A

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

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

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

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

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

N/A

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

N/A

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

N/A

iv. Other

N/A

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

N/A

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

N/A

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

N/A

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

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

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

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

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

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

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

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

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

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

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

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

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

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

Dear Sirs

Objection - Spatial Options Consultation Proposals. CFS045/CFS251/CFS074/CFS002/CFS081/CFS082

Any further building in the area is obviously a ridiculous idea.

The roads are just about able to cope with current traffic. There are not enough schools to take on any more children. Our wildlife would be in danger... they already are.

Doctors surgerys are already having trouble coping with the influx of patients.

Dentists...see above.

Hospitals...see above... police...it goes on.

Rochford Council should represent those that pay the Council Tax and speak out for us and not be responsible for the destruction of the area.

Options 3a & 3b would definitely be more sensible.

The roads in Rayleigh are already congested with queues on side roads and main roads, such as London Road. How will we cope with more houses, cars, commercial transport etc? Has any provision been made for public transport to alleviate traffic jams?

Getting a doctor's appointment is already very difficult. How many doctor's surgeries are planned for and where are the doctors coming from? New roads, clinics, schools and shops will also be necessary.

We prefer options 3a & 3b.

If the housing is going to be around Rayleigh - where are the new roads, schools, doctors, clinics, shops?

The roads through Rayleigh are at present all congested and new housing will only make it worse! And roads local to and including Station Crescent are becoming like main roads. Has provision of public transport been planned for?

COL7 & COL20

I strongly object to the planned change of use of the Mill Hall and Civic Suite. The hall provides a valuable communal area for many functions e.g. keep fit classes, fairs for charities and many others.

The traffic conditions would be unbearable with even more housing. The planned housing would also stretch the schools and GP practices which are already under pressure.

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

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

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

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

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

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

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


Stakeholder Ref: CP15678E Community Representative Ref: 29007

Page 1. Clause 1.2

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

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

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

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

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

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


Stakeholder Ref: CP15678E Community Representative Ref: 29007


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

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

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

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

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

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

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


Stakeholder Ref: CP15678E Community Representative Ref: 29007

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


Stakeholder Ref: CP15678E Community Representative Ref: 29007

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

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

Brownfield and Greenfield land.

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

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

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

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

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


Stakeholder Ref: CP15678E Community Representative Ref: 29007

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


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

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

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

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

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



Stakeholder Ref: CP15678E Community Representative Ref: 29007


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

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

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

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

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


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

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

Stakeholder Ref: CP15678E Community Representative Ref: 29007


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

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

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

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

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

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

Stakeholder Ref: CP15678E Community Representative Ref: 29007

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

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

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

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

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


End of Appeal For Withdrawal.

I am a resident of Great Wakering and have lived in the village for all of my life (40 years) and I completely object to any additional developments in or surrounding the village.

The developments over the past 20 years have added additional stresses on our existing infrastructures where children whom live in the village cannot even get into the local school and I feel more houses will make the situation even worse. The answer is not in my opinion to build more properties and possibly a larger school but to prevent additional stresses placed upon the resources we currently have.

The surrounding fields not only provide vital habitats for wildlife but also for the residents and visitors to our village to enjoy. Losing this will not only affect the wildlife but our own health and well-being. During the Covid pandemic these open spaces and wildlife were critical to me, my family and fellow villagers and the loss of these would be horrendous.

The Village has seen many developments in my lifetime and although the redevelopment of sites such as the Old Brick works have made use of the old works that has now encroached onto the fields with people once having views to open farmland this is now a view onto someone’s home. As mentioned not only does this impact someone mentally but also financially as the loss of the open space view and not being overlooked has gone.

I am not alone in my views and hope you take my and my fellow villagers objections and prevent any such schemes to take place.

I wish to object to using sites CFS160,CFS161, CFS074, CSF194, CFS169, CFS150 & CSF020 for further housing.

My comments , whilst are intentionally brief but I trust succinct in the message I am trying to convey:

1. Road traffic. Pushing more traffic onto the already overcrowded roads is a nightmare prospect. The current condition of the roads is hazardous with numerous potholes which have not been repaired. The impact additional traffic will present will only further damage the roads we have through the neighbourhood.
2. Public transport is not good so people will use their cars. We have limited bus services and following the impact of the pandemic the train service into Liverpool Street is not at the same level as it was prior to March 2020. It is unlikely that the existing service provided by Great Abellio will improve.
3. Air pollution is a real concern and more traffic will only make things worse. Whilst the Government is seeking to reduce carbon emissions the proposed additional housing, at the potential loss of valuable woodland and rural areas will only reduce the local air quality and place greater pressure on the NHS. Furthermore, how will you meet air pollution targets with more traffic if we don't start to address the issues more seriously at a local community level?
4. What about local infrastructure? We do not have the schools, doctors or dentists to cope with that many more people. Surely, we need to see extensive investment in providing the services needed to support the community based upon our current requirements.
5. I am also worried about the impact on our fragile countryside and our vanishing wildlife. Hockley Woods is a valuable area for many uncommon species of butterflies and is the home for many woodland species of fauna and flora. We are also seeing more red kites and other birds of prey in the area, birds which in the 1970s were almost eradicated owing to the use of poisonous insecticides. The proposed plans will turn back the clock on all the conservation work carried out by the RSPB, EWT and other charities who are devoted to supporting wildlife but educating us about the value of the creatures we live alongside. Extra housing will put more pressure on what is left of our wildlife.

Essex is one of the most densely populated counties in England and over the past 30 years there has been a considerable number of housing developments, most recently Rawreth Lane, Hullbridge, Hall Road, Hawkwell plus the building of small developments two to five houses on plots which were originally occupied by a single house, for example there such developments in White Hart Lane, Hockley alone. This area should not be pressured into building that many new houses. It is for the reasons set out above unsustainable. Our existing roads and infrastructure cannot currently cope, any additional houses will only be detrimental to the area and the existing population.

I am writing to you to STRONGLY oppose the planning options for the houses across the green land (specifically, green space and farmland) around Rayleigh.

I am aware of the government agreement to build houses across a number of councils in England, however there ARE more options available to you than those outlined in your Spatial Options Plan.

Rayleigh is a very very busy town, with a small high street, one main car park and small roads with off street parking. Traffic is awful. There are two drs surgery’s, both of which are extremely over subscribed. The town is NOT big enough to hold more housing and infrastructure. Even if more shops or surgery’s were built, how do the roads cope?

There is a better option, by building housing developments on outskirts of town, where the roads are larger and less travelled and there is much more space to develop housing.

In addition to this, your proposed options are amongst densely inhabited wildlife areas, close to Hockley Woods. Many birds and other animals have made home here and you would be destroying their habitat. Many of these habitat thrive on the outskirts of woodland, where do you expect them to go when you build of their land!?

Building as proposed on the outskirts of town, means that you are far less likely to be billing on their habitat. There is little to no woodland between Southend and Rayleigh and that around Rawreth too.

Please Reconsider your plans to build
On your proposed sites and consider larger, more sustainable new villages instead.

I live at number [redacted] Spring Gardens, Rayleigh, SS6 7DQ and would like to comment upon the plan. I understand that I am a few hours late and apologise for this; I had wanted to provide my comments but got stuck in traffic for most of the afternoon in both the Southend and Rayleigh area. I hope you will accept my comments.

The plot that I wish to comment upon in particular is CFS077, Land to the north of Great Wheatley Road, Rayleigh. Number 47 Spring Gardens is situated on the corner of Spring Gardens and Poyntens which would be the access road for the plot.

1. (a) The first point I raise relates to the traffic, parked cars and narrow road access in this area. I attach photos showing 2 cars trying to drive in opposite directions just a few weeks ago, taken when I was out walking. This was actually a good day for parked cars when there weren’t that many around. The burgundy Fiesta in the picture had to reverse all the way back up the road to allow the other through. When there are many cars parked and also many cars trying to drive up and down the road (such as a school morning) this creates havoc. On some days it is almost impossible to leave my home in the car in any event, without adding (a) a construction site where articulated lorries will be driving up and down and needing access via Poyntens and then (b) a housing estate with potentially 263 houses where the majority of people will have at least 2 cars meaning an additional 526 cars to get in and out of Poyntens.

(b) This is also extremely dangerous as emergency vehicles would not stand a chance of being able to access anyone down our road in an emergency, potentially costing lives.

(c) Again very recently, there have been works being carried out at the top end of Spring Gardens where our part of the road meets the other part of Spring Gardens leading onto Love Lane. The road was closed but many cars chose to drive on the pavement to get through quicker. Works like this would create chaos with articulated lorries and the eventual additional 526 cars having to go down Love Lane instead and then up via Highmead.

(d) Further on the same point, when other works were carried out in the same place, the road was not shut but was so narrow that every car had to drive on the pavement to get round the corner. This would make a complete mess of the road and pavement if lorries are doing this.

(e) The pot holes in this area are terrible as it is and further works vehicles would render the road virtually undriveable given months of work and then the additional cars.

2. The second point I wish to address is in relation to wildlife. I attach photos of buzzards flying above our house and a woodpecker in our garden. We regularly have several slow worms and gold finches in our garden too and can provide photos if you’d like. Destroying their habitat to make room for houses will mean losing much of our wildlife in this area and is not something to be condoned.

3. There is then the general issue of lack of schools , doctors etc for a further 263 households of, likely, 4 people. It is virtually impossible to make an appointment at Audley Mills surgery which is where most people would register. To see a doctor one must walk up to the surgery at 6.30am to queue for opening at 7am when you can hope to get lucky and make an appointment. This leaves the poor unfortunate people with a sick child at home who are unable to get out to make the appointment with the worst chance of being able to secure that appointment. An already farcical situation would be made much worse unless more facilities are built immediately to cope with the influx of people.

4. A final point to make is the regular flooding of Poyntens. I do not know whether this is due to poor drainage or burst water mains (such as this week on Spring Gardens) but the prospect of flooding, works vehicles for the construction site, works vehicles to fix the flooding issue and a good deal of extra people and cars on a school morning is ridiculous.

I received a leaflet through our door from the Liberal Democrats on the issue of a garden village. I do not know a great deal about their plan but, on the face of it, this seems that it should be a consideration.

I could elaborate on all of these points but I am aware that I am already late in submitting my points and sincerely hope you will accept them.