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

If the development of new settlements were to take place, they would be ideal for the creation of new community infrastructure, and an ideal opportunity for the infrastructure to be a core part of the planning stage.

With strategy one we will do grow to quickly and can reclassify buildings for different uses such as schools, healthcare etc

Do not implement COL 7 or 20.
Keep our community structures in place if this is valuable to you as it is to the local communities.

there are plenty of brownfield sites that could be used for leisure centres and swimming facilities (such as current industrial units and run down areas). Clements hall needs radical improvement - it was a good centre many years ago which has now been overwhelmed by demand.

Give a true figure for the refurbishment of the mill hall and halt the demolition and desecration of our conservation area to spend hugh sums of money on new offices for themselves which will not benefit the residents of Rayleigh who are in the majority in the District and will probably prove to be a hugh white elephant given the new ways of working bought about by Coronavirus

I'm not sure that modern demands will require more facilities, more people will move to video interviews at the Drs and online delivery of prescriptions. Modern designs and smoke detectors probably lesson the need for fire stations and interactions with the police occur more online than ever.

Yes we need to ensure that our community are able to have suitable places to meet, however we need to be aware that we do have a number of facilities like this in the district.

I selected option2 with modifications.
The schools need to be in a co-operative trust allowing community control.
There is a need for vocational education 16-18 but also 11-16.
By choosing the site and controlling the curriculum provision there is the possibility of adding small businesses, community kitchens, senior citizen care, pre school and nursery.
This will not be cheap but developers via section 106 could provide. Additional funding could be possible. With care and forethought we could create a replacement community facility that would include a cinema/theatre

Q1.
Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
I would expect to see reference to:
• The Infrastructure Delivery and Funding Plan
• Level 2 Strategic Flood Risk Assessment
• Local Cycling and Walking Infrastructure Plan
These plans are needed to assess the long-term sustainability of any proposed sites. Without these I find it difficult to make any comments.
Evaluation of the impact of current development on Hullbridge
I cannot comment on the suitability of the sites in the plan without the Infrastructure Delivery and Funding Plan which I have been told is being undertaken at present. In my opinion it is premature to consult without these.
I would expect it to see reference to
i) the main Roads and the principal junctions and exit points to Hullbridge on Lower Road, Watery Lane and Hullbridge Road as well as the junction with Rawreth Lane.
ii) Consultation with the schools in Hullbridge, Hockley and Rayleigh to accurately asses capacity, too often there are no places in specific school.
iii) Consultation with Doctors and Pharmacies as well the local Healthcare Trust, currently the Riverside Medical Centre are not moving forward with expansion proposals due to high costs.
iv) Air Quality Management - too many parts of the District have poor CO2/CO readings
Any such Plan would need agreement with Rochford District Council, Essex County Council, and Southend Borough Council as they are all affected.
Q2.
Do you agree with our draft vision for Rochford District? Is there anything missing from the vision that you feel needs to be included? [Please state reasoning]
Mostly. Although you have not included enough information on how you might achieve housing for the hidden homeless (sofa surfers) or those on low incomes, schemes to allow the elderly in large houses to be able to downsize or how you plan to provide suitable commercial units of varying sizes, to allow businesses to up or downsize into a suitably sized premises without them needing to relocate into another area. No provision for emergency housing.
Q3.
Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making? [Please state reasoning]
Yes, as each settlement has its own characteristics and needs.
Q4.
Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included? [Please state reasoning]
No comments.
Q5.
Do you agree with the settlement hierarchy presented? If not, what changes do you think are required? [Please state reasoning]
Broadly yes. But it is important that the hierarchy is not changed through developments and cross boundary development must be carefully planned.
Q6.
Which of the identified strategy options do you consider should be taken forward in the Plan? [Please state reasoning]
Creating a new town would enable all the infrastructure to be put in place, allowing more scope for cycling routes and pedestrianised areas. This will stop the urban sprawl which is currently happening in the larger town (and proposed in option 1), creating traffic havoc and pollution. A single large urban development, possibly shared with Wickford could allow a more environmentally friendly development. A development that allows the infrastructure to be developed in advance of the housing.
Q7.
Are there any reasonable alternatives to these options that should be considered instead? [Please state reasoning]
Small development and windfall developments should be included in housing count.
Q8.
Are there any key spatial themes that you feel we have missed or that require greater emphasis? [Please state reasoning]
Yes: Cultural and Accessibility.
Q9.
Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change? [Please state reasoning]
Yes. You must ensure the district has a suitable plan to protect not only the towns and village communities, houses, and businesses but also natural areas as well. The district needs good defences to limit flooding in all areas, protecting people and wildlife. Maybe these could be incorporated in the “natural” landscape theming. New developments not only need to address their carbon footprint but also the design of the housing they build so that they limit flood damage; raised floors, bunded gardens etc. All building should be carbon neutral.
Q10.
Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character? [Please state reasoning]
Yes. All coastal areas and areas of special interest, especially where there is a risk of flooding and harm to the environment need careful consideration.
The Ancient woodlands such as Kingley Woods, Hockley Woods and Rayleigh Grove Woods and all natural parks, not just the actual woodlands but also the surrounding areas and the proposed Regional Park to the West of Hullbridge.
Q11.
Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the district to supply low-carbon or renewable energy?
Yes.
New developments should be able to produce all energy requirements from zero carbon sources.
Q12.
Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at? [Please state reasoning].
Yes. The World is suffering a climate crisis, without higher standards we will not be able to reduce carbon sufficiently to avoid the crisis.
Q13.
How do you feel the plan can help to support the local generation of low-carbon and renewable energy? Are there locations where you feel energy generation should be supported? [Please state reasoning]
Solar and heat pumps in all new development as standard.
Incentives to encourage existing developments to install solar onto their properties as well as any commercial buildings to be fitted with solar to their roofs; there are many flat roofed buildings all over the district that could accommodate solar panels without damaging the landscape. Explore tidal energy and seek out suitable locations in order to ascertain whether it is viable. Retrofitting existing housing and commercial buildings.
Q14.
Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the district, or should different principles apply to different areas? [Please state reasoning]
The district has some very distinct areas and a “one shoe fits all” would be detrimental to some smaller communities. The place-making charter should be bespoke, with each area being considered in its own right. The rules on building should be strict so as to enhance the areas of development and needs to consider the wider picture in respect of amenities, open spaces, retail, schools, services, pollution, character and accessibility (to name but a few). There should not be deviation of plans unless there are exceptional circumstances. Time and again, SPD2 documents are ignored and ugly extensions and dormers are built to the detriment of the area.
Q15.
Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included? [Please state reasoning]
Yes, but they must be kept to.
Q16.
a.
Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
Yes.
b.
If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas? [Please state reasoning]
You need different design guides as this district is both unique and diverse and the “one shoe fits all" would be detrimental to its character and charm.
c.
What do you think should be included in design guides/codes/masterplans at the scale you are suggesting? [Please state reasoning].
You need to ensure that the character and heritage of the settlements are adhered to whilst allowing for some growth, in order to rejuvenate the smaller settlements if needed.
Q17.
With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing? [Please state reasoning]
By working closely with planners and developers, as well as different charities and communities, residents and businesses. You will then get a better understanding as to what you need and what will be achievable.
Q18.
With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas? [Please state reasoning]
The district has a large number of houses, existing and approved that have four or five bedrooms. The number of homes available with two or three bedrooms is small, which increases their price and availability. The smaller properties are the ones that need to be affordable for families. You must ensure that the “affordable“ properties are not all flats and that minimum or higher standards are met for gardens and recreational space. There are sure to be single, elderly residents that would like to downsize from their large family homes, into a smaller, more manageable one but do not wish to go into an assisted living, residential or retirement homes. They may want a one or two bedroomed property, maybe one storey, or low-rise apartment that they own freehold.
We should safeguard the number of smaller bungalows available and make sure that the existing stock is preserved and a suitable number are provided in the housing mix. You need to consider that some residents may need residential care and you should be looking at ways to cope with the rising number of elderly and provide accommodation for them also.
Consideration should be given to the provision of house for life, bungalows and other potential buildings for downsizing families .
The plan makes no reference to social housing quotas.
The district desperately needs to meet the needs of the hidden homeless. People like the adult children on low wages who have no hope of starting a life of their own away from their parents. By living in these conditions, even if the family unit is tight and loving, it will cause mental health issues, stress and anxiety. You also need accessible properties for the disabled members of our community, where they are assisted in order to fulfil a normal as possible life. All these issues, and perhaps many more, need be addressed.
Q19.
Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing? [Please state reasoning]
Housing for the hidden homeless – those “sofa surfing”, or adult children living at home with parents as they are on low wages or wages that would not allow them to move out to rent or buy somewhere on their own. Adapted homes for the disabled. Smaller, freehold properties for the older generation to enable them to downsize from large family homes. Emergency housing.
Q20.
With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our permanent Gypsy and Traveller accommodation needs? [Please state reasoning]
You need to find a permanent site that has a little room to expand but not exponentially. The “Traveller” life has changed over the years and you should revisit the criteria for the traveller community to meet the legal requirements. Strong controls are needed to prevent illegal building work and to ensure the site populations do not exceed capacity.
Q21.
With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs? [Please state reasoning]
See answer to Q20
Q22.
What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites? [Please state reasoning]
See answer to Q20.
Q23.
With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan? [Please state reasoning]
The council should stop developing existing commercial land into housing. Too many sites have already been lost and many more are planned to go. Consider how the plan can help those businesses wanting to expand. Work with local schools and colleges, as well as businesses and the job centre, to see what sustainable employment is needed in the district. Incorporate ways to assist in schemes to train all ages get back into work or upskill. Developers should be encouraged to use local labour.
Q24.
With reference to Figure 30, do you consider the current employment site allocations to provide enough space to meet the District’s employment needs through to 2040? Should we seek to formally protect any informal employment sites for commercial uses, including those in the Green Belt? [Please state reasoning]
No. The current employment site allocations on Figure 30 do not provide enough space to meet the district’s employment needs through to 2040. There are eighty-seven thousand people in the district. There is no data on the form to suggest how many of these are in employment and how many are looking for work but the council need to reassess its future needs in order to future-proof our residents’ opportunities. The plan should only formally protect sites the that have a future and a potential to expand or continue effectively.
Q25.
With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?
Option 3 could deliver new opportunities for employment as it would be a new site completely. Industrial units of various sizes, with room for expansion plus retail, hospitality and other employment could be included in the criteria for the development.
Q26.
Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?
Environmental services - woodland conservation and management. Improve manufacturing base and revisit the JAAP to make the airport Business Park a technological park.
Q27.
Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g., skills or connectivity?
Other forms of sustainable transport (Tram), gigabit broadband and Wi-Fi. Apprenticeships or training for all ages with jobs at the end of training. No new roads.
Q28.
With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system? [Please state reasoning]
The airport brings little to the economy, It could be better used as an expanded technological park or for housing.
Q29.
Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
Yes. You should conform to and improve existing policies for protecting wildlife areas. Everyone should be doing all in their power to protect wildlife sites. All wildlife is important and has been neglected, sites have been slowly lost over the years. Wildlife now enters suburban areas as their own habitats have diminished and they can no longer fend for themselves adequately from nature. Badgers and hedgehogs as well as rabbits, frogs, newts, voles and shrews are declining and are seldom seen apart from dead at the roadside. Bat numbers are declining as their habitats are lost. Designating initial sites is a step in the right direction but more must be done. It is proven that mental health issues can be relieved by nature and keeping the sites sacred is more important now than it ever was.
Keeping a biodiverse environment, with wildlife and the environment in which it relies is paramount. You mention that Doggett Pond no longer meets the standard but are there no steps to improve its status instead of dismissing it? It is obviously an important site for the wildlife in that area. To lose it would be to our detriment. You should be looking at creating new sites with every large housing development, and protecting them to improve our district and our own wellbeing. Private households should not be allowed to take over grass areas and verges or worse, concreting the verges over for parking and cost savings.
These areas, although small are still areas for wildlife. Bees and butterflies are also in decline, as are the bugs which feed our birds. The plan should create new wildlife meadows to encourage the pollinators in order to future proof our own existence. You should be exploring smaller sites that could be enhanced, managed and protected to give future generations a legacy to be proud of.
Q30.
Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection? [Please state reasoning]
Yes. The plan must protect them for future generations and teach our children their history and importance so that they can continue to keep them safe.
Q31.
Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?
On site. You can then assess in real time and sort out any issues you would not have known about off site.
Q32.
With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan? [Please state reasoning]
You need to retain what we already have by ensuring the necessary links are in place to join as many as possible, and ensuring that public rights of way are not blocked by land owners and are kept free from debris. You also need to assess some paths to make them accessible to the disabled so that all is inclusive. There are some green areas that do not have public facilities and it would be advantageous to look into offering this in the larger spaces. For example, a small toilet block and hand washing facilities in the car park. Obtaining funding from new developments that can enhance existing areas as well as providing new spaces and facilities. The sites should be well-maintained.
Q33.
Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
They are a step in the right direction, but you need to assess periodically in order to be able to add further links to any new parkland that may be created in the future. The map is unclear as it does not show exact routes.
Q34.
With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure? [Please state reasoning]
Enhancing existing areas and ensuring developers include green space and recreational facilities within their developments. A new, separate development would be able to deliver this within their plan layout. Ensuring there are suitable links, access and footpaths. Making sure some of these footpaths are maintained and accessible for the disabled.
Q35.
With reference to the options above, or your own options, how can we address the need for sufficient and accessible community infrastructure through the plan? [Please state reasoning]
Assess the shortfall of facilities and networks before plans are approved so that adequate planning and funding can be secured before any building takes place.
Q36.
With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure? [Please state reasoning]
A new town would have this infrastructure built into its plans. Funding for improvements must otherwise come from developers if an area is already overpopulated.
Q37.
Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities? How can we best address these? [Please state reasoning]
Most of the District feels overcrowded; the road network is no longer fit for purpose, some schools are near to capacity, it is difficult to obtain a GP or dental appointment. There is little to no disabled play areas or play equipment. There are often issues with waste collections, drain and road cleaning and verge trimming. The District Council does not have the staff to deal with all these issues. The council should either build another waste recycling site, or develop a better waste collection program which allows extra waste to be collected next to the bin. The current recycling site at Castle Road is no longer capable of expanding to meet the needs of an ever-growing population. The plan should also identify a site to accommodate commercial waste facilities to stop fly tipping.
Q38.
With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan? [Please state reasoning]
Improve what we already have. The tennis courts on Fairview Park needs improvement. Safeguard our open spaces to protect wildlife and recreation. Develop different types of sporting facilities. We need to offer free recreation.
Q39.
Are the potential locations for 3G pitch investment the right ones? Are there other locations that we should be considering? [Please state reasoning]
All-weather facilities should be considered.
Q40.
Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering? [Please state reasoning]
They look suitable. They will probably need funding.
Q41.
With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
A new development would be able to deliver this in their plans or fund improvements for existing facilities in line with national strategy and requirements.
Q42.
Are there particular open spaces that we should be protecting or improving? [Please note, you will have an opportunity to make specific comments on open spaces and local green spaces in the settlement profiles set out later in this report]
The sites will be specific in each parish. You must protect all of these recreational spaces and improve them, if necessary. Once lost to development, they can never come back. There are too few areas of accessible open space.
Q43.
With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan? [Please state reasoning]
You should reassess the planning policies regarding alterations made to the buildings on the heritage list, especially those in conservation areas. There have been a few occasions where buildings of “interest” (or other) have been altered, and that places in conservation areas have been allowed canopies, shutters and internal illumination of signage without challenge. Any building work should be sympathetic to the area and you should require corrections to unauthorised changes, even if they have been in place for some time. Shop fronts are huge areas of uninteresting glass with garish colours. No objections are raised to signage and advertising that is out of character with a conservation area in a heritage town. Ensure statutory bodies are consulted and heeded.
You should take effective actions to manage the footways, ‘A’ boards and barriers are obstructions to those with impaired sight or mobility.
Q44.
Are there areas of the District we should be considering for conservation area status beyond those listed in this section? [Please state reasoning]
You should not take areas of precious woodland to make way for housing.
Q45.
Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets? [Please state reasoning]
Yes there are many sites of historic importance which should be included.
Q46.
With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant? [Please state reasoning]
You can only have a vibrant town centre if there are shops to go to. If these units are subsequently changed to residential then our town centres will be fractured and uninviting. The new Use Class E will mean it will be even more important for the council to protect our retail outlets. You need to work actively with premises owners in order to assist in the re-letting of any empty shops. Maybe offer a reduced rent to new businesses as a start-up scheme. You could contain this as a “local” business only – allowing the entrepreneurs in the Rochford District a chance to showcase their businesses. You also need to be able to negotiate with the owners of empty shops how they can best strive to fill these premises and if not, then have some visual displays in the windows, perhaps photos of the old towns or useful information, to make them more attractive. Explore business rates levies.
Any plan should be reviewed frequently; at least every 4 years
It is a well-documented fact that independent businesses have done better than large chains during Covid as they are able to diversify at short notice. RDC need to incentivise new small or micro businesses into our town centre, either through grant support or another mechanism. Occupied premises create employment, increase footfall and reduce vandalism. Landlords should be engaged with to ensure quick turn-arounds, or for more flexible lease agreements where for example a new business can take on a shorter lease to test the market.
Good public transport links are crucial for our villages, neighbourhoods and town centres.
Q47.
Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make? [Please state reasoning]
Yes.
Q48.
With reference to Figures 38-40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
Yes.
Q49.
Should we continue to restrict appropriate uses within town centres, including primary and secondary shopping frontages within those centres? If yes, what uses should be restricted? [Please state reasoning]
Yes. A mix of retailers is essential as a lack of variety will eventually kill off the high streets. We need to have a balance of outlets that keep the area viable as you would lose the vibrancy you are hoping to achieve.
Q50.
With reference to your preferred Strategy Option, are there opportunities for growth to deliver improved retail and leisure services in the District? [Please state reasoning]
Unfortunately, there has been a tendency to switch from commercial outlets to residential, where smaller retail areas have been sold off and housing development has been allowed. In a new development there would be scope to add a small, medium or large retail precinct, depending on the development size.
Retail parks, leisure areas and outlets are proving in many cases, the preferred option for consumers, normally as a result of having everything in one place, free on-site parking and maximum choice. We feel that some of the sites, whilst not suitable for large housing developments, may be suitable for something of this type. It would create much needed employment, opportunity and tourism for the area. Retail parks, leisure areas and outlets are proving in many cases the preferred option for consumers, normally as a result of having everything in one place, free on-site parking and maximum choice. I feel that some of the sites out forward in Rayleigh, whilst not suitable for large housing developments, may be suitable for something of this type. It would create much needed employment, opportunity and tourism for the area.
Q51.
With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan? [Please state reasoning]
The council needs to follow the rule “No development before infrastructure”. Houses are being built without adequate road, pedestrian and cycle networks in place. New developments should be planned with cycle paths and walkways that link up with existing paths. The existing paths need updating and attention.
Q52.
Are there areas where improvements to transport connections are needed? What could be done to help improve connectivity in these areas?
More work needs to be done on the A127 and The Carpenters Arms roundabout. The feeder lanes proposed some years ago to link the Fairglen interchange with The Rayleigh Weir in both directions is now essential as this is a bottleneck. Hockley needs another access. Connecting the cycle ways into a proper cycle network as part of the plan. A tram system. No new roads should be built.
Q53.
With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [Walking, cycling, rail, bus, road etc.]
Better links to the Chelmsford perhaps through a tram system, new roads must not be built. Designated cycling paths that are separated from existing roads and pavements, but adjacent to our road networks would help improve traffic flow. Ensure the cycle network links with public transport as part of a complete review of sustainable transport.
Q54.
Do you feel that the plan should identify rural exception sites? If so, where should these be located and what forms of housing or employment do you feel need to be provided? [Please note you may wish to comment on the use of specific areas of land in the next section]
This may be a suitable option for a retirement village that could be restricted to single storey dwellings only, and could include community facilities such as convenient store, community centre and so on.
Q55.
Are there any other ways that you feel the plan should be planning for the needs of rural communities? [Please stare reasoning]
Better public transport and sustainable transport links.
Q56.
a.
Do you agree with our vision for Rayleigh? Is there anything you feel is missing? [Please state reasoning]
No Comment
b.
With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
No Comment
c.
Are there areas in Rayleigh that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
No. Large scale residential development in Rayleigh should be resisted in the new Local Plan. So called windfall development should be incorporated in the overall development targets thereby reducing large scale development.
d.
Are there areas that require protecting from development? Why these areas? [Please state reasoning]
Conservation areas and green belt and sites subject to the exclusion criteria on the call for sites should be protected. Proposed sites within Rayleigh and on the Western side should not be considered for development. Only an infrastructure plan would provide evidence that the chosen sites are sustainable in the long term, and greenbelt and environmental policies should be adhered to in relation to open spaces on the edge or within the town.
e.
Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
All green spaces, no matter how small, hold some significance, especially to those who use them for recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets.
Q57.
a.
Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]
No Comment
b.
With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?
c.
Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
d.
Are there areas that require protecting from development? Why these areas? [Please state reasoning]
Hockley Woods
Rayleigh Town Council. Spatial Plan Response 17 V 2.0 Published 13th September 2021
Q60.
a.
Do you agree with our vision for Hullbridge? Is there anything you feel is missing? [Please state reasoning]
No. This has been written by someone with no awareness of Hullbridge. I support the Parish Council Vision.
b.
With reference to Figure 48 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Hullbridge?
The biggest issue with further development in Hullbridge is the distinct lack of infrastructure – whether that be roads, schools, transport and other general services – and so, without even mentioning the fact that many sites lay within the projected 2040 flood plains, the suggestion that further development can take place on any considerable scale is untenable. Any consideration of commercial or community infrastructure, such as youth services, care facilities, or local businesses would equally need to be subject to the same discussion and scrutiny.
Housing [market, affordable, specialist, traveller, other]
c.
Are there areas in Hullbridge that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
All of the areas lie within the green belt, and many will be within the projected 2040 flood plains, and so general appropriateness is not met with any; numerous promoted sites are outside walking distance of the majority of services and as such would increase residents using vehicles and increase reliance on our already stretched local infrastructure.
d.
Are there areas that require protecting from development? Why these areas? [Please state reasoning]
Significant portions of Hullbridge remain vital for local wildlife, its habitats, and the natural environment. As such, any and all developments along the River Crouch, the surrounding areas of Kendal Park and those that lie north of Lower Road should be protected from development.
e.
Do you agree that the local green spaces shown on Figure 48 hold local significance? Are there any other open spaces that hold particular local significance? [Please state reasoning]
All green spaces, no matter how small, hold some significance, especially to those who use them for recreation. They are of particular community value and should not be developed. They must be seen as the vital green area not the next place along the line to be built on. It is reasonable for RDC to encourage the development of a garden village away from existing communities to accommodate the Governments home building targets.

Dear council,

Thank you for the opportunity to comment of the Spatial Options Consultation and I do hope you take time to consider my suggestions.

I absolutely understand the need for further housing in the District so that future generations have the option to reside in the area and to own their own home. However I urge you to please attempt to be as innovative and creative as possible in your delivery of these new homes and their location.

Put simply, I believe your local plan for housing and net carbon zero targets contradict each other and are incompatible in their current forms. Almost certainly meeting central government housing targets almost certainly prevent the District meeting net carbon zero due to increased road traffic and ever decreasing tree coverage.

The most considerable bone of contention among existing residents is to protect the current greenbelt from future development.

With these three factors in mind, please consider refraining from all development on greenbelt and instead optimise this land offered to plant new woodland, rewilding projects and leisure space, which will safeguard greenbelt, habitats and help meet the net zero carbon targets.

In terms of where to then build the urgently needed housing, please consider brownfield as much as possible, or even better, new settlements with its own infrastructure would be optimal. I personally see Ballards Gore (between Canewdon and Paglesham) as an ideal opportunity for a new settlement, or even the expansion of Paglesham as a settlement. Current development appears to be unfairly proportioned across Rayleigh, Hullbridge, Rochford and Great Wakering, with little to no development having taken place across Canewdon, Paglesham, Stonebridge, Barling Magna, and South Fambridge in the last 10-15 years.

Thank you again for the opportunity to feed suggestions into this consultation and I urge you to please proceed responsibly by not further destroying greenbelt and habitats, reducing tree coverage, and taking the character away from the lovely villages that make up Rochford District.

We would like to preface everything we are about to say with the following. Our district cannot take
any more housing. We do not have the infrastructure. Government targets, or no government targets,
what you are allowing to happen to our communities is permanently destroying what has made this
area such a beautiful place to live for many, many generations. Council officers and councillors need
to have much more integrity when carrying out these consultations and making planning decisions.
There needs to be more determination to stop this endless destruction. There are many stories from
around the country of councils and councillors that are being creative and taking a few more risks in
order to save and preserve their communities and their heritage. I expect to see more of this from
Rochford District council in the years ahead - be more tenacious - we are counting on you. The
residents in Ashingdon have shown us this can be done with their successful campaign against SER8
- now it's time for the Council to step up to the plate. It's time to start representing your residents and
the people that pay your wages!
We strongly object to any development on green belt land. We are in the middle of an environmental
crisis - the evidence of which is all around us. The council must immediately cease to approve any
further development on green belt sites and only brown belt sites must be considered. With this in
mind, all proposed green belt sites must be removed from the local plan in order to make green belt
development as difficult as possible.
Furthermore, we would add that the local infrastructure simply cannot cope. Medical facilities are all
vastly over-subscribed. There is a lack of doctors and NHS dental places, not enough school places
and already over-sized classes. The County Council have proved how utterly inept they are at even
attending to the most basic repairs on some of our most dangerously damaged roads. We simply
cannot allow more traffic to go through the district's roads until all outstanding repairs have been
addressed and a proper strategy has been drafted, presented, and agreed with the residents of our
district for how the roads will be managed and maintained proactively going forwards. The county
council have clearly demonstrated they cannot be trusted to get on with this and now need to be put
under pressure by district councils and their residents.
Road capacity is another serious issue. This can be evidenced if you try and travel anywhere by car
on a Monday to Friday during rush hour or on a Saturday (if, heaven forbid, you try and go anywhere
to possibly try and enjoy your spare time away from your home). This view is clearly widespread
among many residents and councillors based on the events surrounding the recent rejection of SER8.
Any further development that is approved (for example, on brown belt sites) must have ample
infrastructure included within the proposals. This must also factor-in the infrastructure deficit we are
already running due to existing developments having been allowed to go ahead without adequate
controls and safeguards being in place to ensure that supporting infrastructure is also delivered.
Therefore, any new developments must deliver not only their own infrastructure needs but also help
'pay down' some of the deficit that has been built up. The council must (we repeat - MUST) make sure
the infrastructure is secured and committed to. Furthermore, the infrastructure must (we repeat -
MUST) be delivered before any housing is allowed to be developed. This must be a prerequisite. The
council must not allow another Hall Road situation to materialise. It is actually beyond a joke that Hall
Road still does not have a school, with no sign of one appearing anytime soon. The word
incompetence just doesn't cut it.
In addition to the above, we would like to add the following specific objections to the following sites:
CFS074 - Land south of Mount Bovers Lane, Hockley
This land must be removed from the Local Plan. The house building would ruin the landscape and
views that are available from Hawkwell Chase, Hawkwell Common and from Main Road Hawkwell
(looking towards Gusted Hall). This land should be kept out of the local plan and (when the
opportunity allows) used to extend the natural areas around Cherry Orchard and Gusted Hall.
CFS045 - Belchamps Scout Site, Holyoak Lane, Hawkwell
CFS251 - Land at Peartree Cottage, Holyoak Lane, Hockley
CFS191 - Land at Mount Bovers Lane, Hawkwell
CFS074 - Land south of Mount Bovers Lane, Hockley
CFS160 - Northlands Farm, 65 High Road, Hockley
CFS161 - 57 High Road, Hockley, Essex, SS5 4SZ
CFS083 - Land south of Hall Road and west of Ark Lane, Rochford
CFS078 - Land west of Cherry Orchard Way and south of Cherry Orchard Lane, Rochford
CFS079 - Land west of Cherry Orchard Way and east of Cherry Orchard Lane, Rochford
CFS135 - Land at Flemings Farm Road, Eastwood
CFS059 - Land at Sandhill Road, Eastwood
CFS037 - The Ramblers & Dahlia Lodge, Eastwood Rise, Leigh
CFS134 - Land between Eastwood Rise and Rayleigh Avenue, Eastwood
CFS027 - Land north of Bull Lane, Rayleigh
CFS029 - Land at Turrett Farm, Napier Road, Rayleigh
CFS098 - Land north of Napier Road, Rayleigh
CFS053 - Land south of 38 and 39 Wellington Road, Rayleigh
We would like to request that this land is removed from the Local Plan. The location falls within, or
very close to, the Upper Roach Valley Special Landscape Area. This area has been afforded a
special status for good reason and therefore these sites must be removed from the Local Plan. We
would also request for the Special Landscape Area to be extended to encompass the land in the
above sites. Losing any land within, or close to, the Special Landscape Area would result in a
permanent loss or deterioration of very special green spaces - these must be protected for
environmental and wildlife reasons as well as to be enjoyed by future generations.
CFS064 - Land north and east of Folly Chase, Hockley
This land must be removed from the Local Plan. This field offers a unique home for wildlife and is one
of the few remaining rural landscapes and walks for residents living on Betts Farm. Hockley Primary
school would also not stand any chance of catering for the number of places a development of this
size would require. Even with a possible extension, the school, surrounding roads and facilities were
simply not built/designed to cater for the number of residents this would require. There are also
significant issues with road access from Folly Lane which is already an extremely hazardous road.
CFS264 - Land at Greenacres Nursery, Hockley
CFS040 - Eastview House and Haslemere, Church Road, Hockley
These sites must be removed from the local plan due to the damage to wildlife, the environment, and
the effect on the landscape within the area. There are also already significant road safety issues with
Church Road, Folly Lane, and Fountain Lane. All these roads are very dangerous to navigate based
on current traffic levels and this would be made significantly worse with any/all of these developments
taking place. There are also regular flooding issues on Church Road which would only get worse with
further building on surrounding land.
CFS082 - Land between Ironwell Lane and Hall Road, Hawkwell
CFS081 - Land at Stroud Green, north of Hall Road, Rochford
CFS002 - Land at Nursery Corner, between Rectory Road and Hall Road, Hawkwell
These sites must be removed from the local plan due to the total number of new dwellings that they
could represent (in particular CFS082 and CFS081). The area is already unable to cope with traffic
and infrastructure demand. The views from Ironwell Lane out onto these sites have been enjoyed for
hundreds of years. They have already been permanently compromised by the Hall Road development
and no further destruction of the area can be allowed to take place.
CFS132 - Ivanhoe Nursery, Ironwell Lane, Hawkwell
CFS219 - Ivanhoe, Ironwell Lane, Hockley, Essex, SS5 4JY
CFS240 - Old Parsonage, Ironwell Lane, Hawkwell, Essex, SS5
CFS118 - The Paddock by Clements Hall Way, Rectory Road, Hawkwell
CFS140 - Old Nursery, Ironwell Lane, Hawkwell
CFS018 - Land between The Grange and Red Roof in Ironwell Lane SS5 4JY
CFS036 - Land adjacent to Rectory Terrace off Rectory Road, Hawkwell
These sites must all be removed from the local plan due to the surrounding roads already being
significantly over-subscribed thanks for the Clements Gate development. They are nowhere near any
schools (resulting in yet more traffic) and will also detract from the otherwise beautiful countryside that
can be enjoyed when walking up Ironwell Lane.
CFS194 - Land North of Rectory Road, Hawkwell
CFS169 - Meadowlands, Victor Gardens, Hockley, SS5 4DY
CFS020 - Land rear of St Marys Church, Rectory Road, Hawkwell
These sites must be removed from the local plan due to their proximity to St Mary's church. The
surrounding landscape has always been farmers’ fields and countryside and it must stay this way.
The area is already unable to cope with traffic and infrastructure demand. The views from St Mary's
and the public footpaths out onto these sites have been enjoyed for hundreds of years. They must
continue to be left as green belt countryside.
CFS093 - Greenacres and adjacent land, Victor Gardens, Hawkwell
CFS017 - Greenacres, Victor Gardens, Hawkwell
CFS093 - Greenacres and adjacent land, Victor Gardens, Hawkwell
These sites must be removed from the local plan in order to protect the amount of green space
around a densely populated area. The surrounding landscape has always been farmers’ fields and
countryside and it must stay this way. The area is already unable to cope with today's traffic and
infrastructure demands. The views from Clements Hall and the public footpaths out onto these sites
have been enjoyed for hundreds of years. They must continue to be left as green belt countryside.
CFS216 - Land at Fambridge Road, Ashingdon
This site must be removed from the local plan due to the potential number of houses (which the
surrounding roads and local infrastructure cannot support) and the fact the land is within the Coastal
Protection Belt Special Landscape Area. The Coastal Protection Belt Special Landscape Area must
be protected and enlarged.
CFS121 - Land north of A127, Rayleigh
CFS261 - Land east of Oxford Road, Rochford
CFS222 - Land at Dollymans Farm, Doublegate Lane, Rawreth
CFS163 - Land at Lubards Lodge Farm, Hullbridge Road, Rayleigh, SS6 9QG
CFS164 - Land at Lubards Lodge Farm, Hullbridge Road, Rayleigh, SS6 9QG
CFS148 - Land north of Rawreth Lane, Rawreth
CFS171 - Land to the North of Rawreth Lane, Rawreth
CFS146 - Land at Rawreth Hall Farm, Rawreth Lane, Rawreth
CFS147 - Land north of London Road, Rayleigh
CFS099 - Land to the west of Hullbridge
CFS149 - Lane Field and Hullbridge Hill, Watery Lane, Hullbridge
CFS172 - Land At Cracknells Farm, Hullbridge
CFS265
CFS067 - Three Ashes, land to the south of Tinkers Lane, Rochford
These sites must be removed from the local plan due to the potential number of houses - which the
surrounding roads and local infrastructure cannot support.
COL27 - Freight House Car Park, Rochford
COL13 - The Freight House, Bradley Way, Rochford
These sites must be removed from the local plan and retained in their current form. They should
continue to be made available to the residents of the district as community facilities.
COL07 - The Mill, Bellingham Lane, Rayleigh
This site must be removed from the local plan and retained in its current form. It should continue to be
made available to the residents of the district as a community facility.
CFS063 - Land south of Watts Lane, Rochford
CFS067 - Three Ashes, land to the south of Tinkers Lane, Rochford
Sector D (All references)
These sites must be removed from the local plan due to the inadequate roads in the area. Even with
new or enlarged roads the existing roads already struggle with the volumes of traffic that they need to
cater for today.
We respectfully ask you to make sure our views and those of our family are fully represented in this
process and during the subsequent stages of the local plan being written and implemented.

We would like to preface everything we are about to say with the following. Our district cannot take
any more housing. We do not have the infrastructure. Government targets, or no government targets,
what you are allowing to happen to our communities is permanently destroying what has made this
area such a beautiful place to live for many, many generations. Council officers and councillors need
to have much more integrity when carrying out these consultations and making planning decisions.
There needs to be more determination to stop this endless destruction. There are many stories from
around the country of councils and councillors that are being creative and taking a few more risks in
order to save and preserve their communities and their heritage. I expect to see more of this from
Rochford District council in the years ahead - be more tenacious - we are counting on you. The
residents in Ashingdon have shown us this can be done with their successful campaign against SER8
- now it's time for the Council to step up to the plate. It's time to start representing your residents and
the people that pay your wages!
We strongly object to any development on green belt land. We are in the middle of an environmental
crisis - the evidence of which is all around us. The council must immediately cease to approve any
further development on green belt sites and only brown belt sites must be considered. With this in
mind, all proposed green belt sites must be removed from the local plan in order to make green belt
development as difficult as possible.
Furthermore, we would add that the local infrastructure simply cannot cope. Medical facilities are all
vastly over-subscribed. There is a lack of doctors and NHS dental places, not enough school places
and already over-sized classes. The County Council have proved how utterly inept they are at even
attending to the most basic repairs on some of our most dangerously damaged roads. We simply
cannot allow more traffic to go through the district's roads until all outstanding repairs have been
addressed and a proper strategy has been drafted, presented, and agreed with the residents of our
district for how the roads will be managed and maintained proactively going forwards. The county
council have clearly demonstrated they cannot be trusted to get on with this and now need to be put
under pressure by district councils and their residents.
Road capacity is another serious issue. This can be evidenced if you try and travel anywhere by car
on a Monday to Friday during rush hour or on a Saturday (if, heaven forbid, you try and go anywhere
to possibly try and enjoy your spare time away from your home). This view is clearly widespread
among many residents and councillors based on the events surrounding the recent rejection of SER8.
Any further development that is approved (for example, on brown belt sites) must have ample
infrastructure included within the proposals. This must also factor-in the infrastructure deficit we are
already running due to existing developments having been allowed to go ahead without adequate
controls and safeguards being in place to ensure that supporting infrastructure is also delivered.
Therefore, any new developments must deliver not only their own infrastructure needs but also help
'pay down' some of the deficit that has been built up. The council must (we repeat - MUST) make sure
the infrastructure is secured and committed to. Furthermore, the infrastructure must (we repeat -
MUST) be delivered before any housing is allowed to be developed. This must be a prerequisite. The
council must not allow another Hall Road situation to materialise. It is actually beyond a joke that Hall
Road still does not have a school, with no sign of one appearing anytime soon. The word
incompetence just doesn't cut it.
In addition to the above, we would like to add the following specific objections to the following sites:
CFS074 - Land south of Mount Bovers Lane, Hockley
This land must be removed from the Local Plan. The house building would ruin the landscape and
views that are available from Hawkwell Chase, Hawkwell Common and from Main Road Hawkwell
(looking towards Gusted Hall). This land should be kept out of the local plan and (when the
opportunity allows) used to extend the natural areas around Cherry Orchard and Gusted Hall.
CFS045 - Belchamps Scout Site, Holyoak Lane, Hawkwell
CFS251 - Land at Peartree Cottage, Holyoak Lane, Hockley
CFS191 - Land at Mount Bovers Lane, Hawkwell
CFS074 - Land south of Mount Bovers Lane, Hockley
CFS160 - Northlands Farm, 65 High Road, Hockley
CFS161 - 57 High Road, Hockley, Essex, SS5 4SZ
CFS083 - Land south of Hall Road and west of Ark Lane, Rochford
CFS078 - Land west of Cherry Orchard Way and south of Cherry Orchard Lane, Rochford
CFS079 - Land west of Cherry Orchard Way and east of Cherry Orchard Lane, Rochford
CFS135 - Land at Flemings Farm Road, Eastwood
CFS059 - Land at Sandhill Road, Eastwood
CFS037 - The Ramblers & Dahlia Lodge, Eastwood Rise, Leigh
CFS134 - Land between Eastwood Rise and Rayleigh Avenue, Eastwood
CFS027 - Land north of Bull Lane, Rayleigh
CFS029 - Land at Turrett Farm, Napier Road, Rayleigh
CFS098 - Land north of Napier Road, Rayleigh
CFS053 - Land south of 38 and 39 Wellington Road, Rayleigh
We would like to request that this land is removed from the Local Plan. The location falls within, or
very close to, the Upper Roach Valley Special Landscape Area. This area has been afforded a
special status for good reason and therefore these sites must be removed from the Local Plan. We
would also request for the Special Landscape Area to be extended to encompass the land in the
above sites. Losing any land within, or close to, the Special Landscape Area would result in a
permanent loss or deterioration of very special green spaces - these must be protected for
environmental and wildlife reasons as well as to be enjoyed by future generations.
CFS064 - Land north and east of Folly Chase, Hockley
This land must be removed from the Local Plan. This field offers a unique home for wildlife and is one
of the few remaining rural landscapes and walks for residents living on Betts Farm. Hockley Primary
school would also not stand any chance of catering for the number of places a development of this
size would require. Even with a possible extension, the school, surrounding roads and facilities were
simply not built/designed to cater for the number of residents this would require. There are also
significant issues with road access from Folly Lane which is already an extremely hazardous road.
CFS264 - Land at Greenacres Nursery, Hockley
CFS040 - Eastview House and Haslemere, Church Road, Hockley
These sites must be removed from the local plan due to the damage to wildlife, the environment, and
the effect on the landscape within the area. There are also already significant road safety issues with
Church Road, Folly Lane, and Fountain Lane. All these roads are very dangerous to navigate based
on current traffic levels and this would be made significantly worse with any/all of these developments
taking place. There are also regular flooding issues on Church Road which would only get worse with
further building on surrounding land.
CFS082 - Land between Ironwell Lane and Hall Road, Hawkwell
CFS081 - Land at Stroud Green, north of Hall Road, Rochford
CFS002 - Land at Nursery Corner, between Rectory Road and Hall Road, Hawkwell
These sites must be removed from the local plan due to the total number of new dwellings that they
could represent (in particular CFS082 and CFS081). The area is already unable to cope with traffic
and infrastructure demand. The views from Ironwell Lane out onto these sites have been enjoyed for
hundreds of years. They have already been permanently compromised by the Hall Road development
and no further destruction of the area can be allowed to take place.
CFS132 - Ivanhoe Nursery, Ironwell Lane, Hawkwell
CFS219 - Ivanhoe, Ironwell Lane, Hockley, Essex, SS5 4JY
CFS240 - Old Parsonage, Ironwell Lane, Hawkwell, Essex, SS5
CFS118 - The Paddock by Clements Hall Way, Rectory Road, Hawkwell
CFS140 - Old Nursery, Ironwell Lane, Hawkwell
CFS018 - Land between The Grange and Red Roof in Ironwell Lane SS5 4JY
CFS036 - Land adjacent to Rectory Terrace off Rectory Road, Hawkwell
These sites must all be removed from the local plan due to the surrounding roads already being
significantly over-subscribed thanks for the Clements Gate development. They are nowhere near any
schools (resulting in yet more traffic) and will also detract from the otherwise beautiful countryside that
can be enjoyed when walking up Ironwell Lane.
CFS194 - Land North of Rectory Road, Hawkwell
CFS169 - Meadowlands, Victor Gardens, Hockley, SS5 4DY
CFS020 - Land rear of St Marys Church, Rectory Road, Hawkwell
These sites must be removed from the local plan due to their proximity to St Mary's church. The
surrounding landscape has always been farmers’ fields and countryside and it must stay this way.
The area is already unable to cope with traffic and infrastructure demand. The views from St Mary's
and the public footpaths out onto these sites have been enjoyed for hundreds of years. They must
continue to be left as green belt countryside.
CFS093 - Greenacres and adjacent land, Victor Gardens, Hawkwell
CFS017 - Greenacres, Victor Gardens, Hawkwell
CFS093 - Greenacres and adjacent land, Victor Gardens, Hawkwell
These sites must be removed from the local plan in order to protect the amount of green space
around a densely populated area. The surrounding landscape has always been farmers’ fields and
countryside and it must stay this way. The area is already unable to cope with today's traffic and
infrastructure demands. The views from Clements Hall and the public footpaths out onto these sites
have been enjoyed for hundreds of years. They must continue to be left as green belt countryside.
CFS216 - Land at Fambridge Road, Ashingdon
This site must be removed from the local plan due to the potential number of houses (which the
surrounding roads and local infrastructure cannot support) and the fact the land is within the Coastal
Protection Belt Special Landscape Area. The Coastal Protection Belt Special Landscape Area must
be protected and enlarged.
CFS121 - Land north of A127, Rayleigh
CFS261 - Land east of Oxford Road, Rochford
CFS222 - Land at Dollymans Farm, Doublegate Lane, Rawreth
CFS163 - Land at Lubards Lodge Farm, Hullbridge Road, Rayleigh, SS6 9QG
CFS164 - Land at Lubards Lodge Farm, Hullbridge Road, Rayleigh, SS6 9QG
CFS148 - Land north of Rawreth Lane, Rawreth
CFS171 - Land to the North of Rawreth Lane, Rawreth
CFS146 - Land at Rawreth Hall Farm, Rawreth Lane, Rawreth
CFS147 - Land north of London Road, Rayleigh
CFS099 - Land to the west of Hullbridge
CFS149 - Lane Field and Hullbridge Hill, Watery Lane, Hullbridge
CFS172 - Land At Cracknells Farm, Hullbridge
CFS265
CFS067 - Three Ashes, land to the south of Tinkers Lane, Rochford
These sites must be removed from the local plan due to the potential number of houses - which the
surrounding roads and local infrastructure cannot support.
COL27 - Freight House Car Park, Rochford
COL13 - The Freight House, Bradley Way, Rochford
These sites must be removed from the local plan and retained in their current form. They should
continue to be made available to the residents of the district as community facilities.
COL07 - The Mill, Bellingham Lane, Rayleigh
This site must be removed from the local plan and retained in its current form. It should continue to be
made available to the residents of the district as a community facility.
CFS063 - Land south of Watts Lane, Rochford
CFS067 - Three Ashes, land to the south of Tinkers Lane, Rochford
Sector D (All references)
These sites must be removed from the local plan due to the inadequate roads in the area. Even with
new or enlarged roads the existing roads already struggle with the volumes of traffic that they need to
cater for today.
We respectfully ask you to make sure our views and those of our family (including our two sons –
Roland and Gordon Harwood) are fully represented in this process and during the subsequent stages
of the local plan being written and implemented.

Thank you for consulting Castle Point and Rochford Clinical Commissioning Group (the CCG) on the Rochford New Local Plan: Spatial Options Consultation paper 2021. The CCG and the Mid and South Essex Health and Care Partnership (HCP) welcome the
opportunity to provide comments on the consultation document. The focus of the comments is on the document’s approach to health and wellbeing and, the provision for healthcare facilities.
Draft vision
It is noted that the draft vision for Rochford in 2050 makes references to achieving a network of infrastructure including health as well social and green infrastructure, enabling residents to work locally and have many accessible and high quality open spaces including coastline that residents can enjoy. These ambitions will promote the health and wellbeing of our population and are supported.
Draft Strategic Priorities and Objectives
The strategic priorities to meet the need for homes and jobs in the area; to provide for retail, leisure and other commercial development, infrastructure and climate change mitigation and adaptation are supported. Amendments are suggested to strengthen the strategic objectives that support these priorities.
Strategic objective 2: The stated objective is to plan for a mix of homes needed to support current and future residents, in particular viably addressing affordability issues and supporting our ageing population. The objective is supported; access to quality housing is one of the wider determinants of health.
Reference could be drawn from the Lifetime Homes standard to ensure that homes make life as easy as possible for as long as possible, providing accessible and
adaptable accommodation for everyone, from young families to older people and individuals with a temporary or permanent physical impairment. This approach should,
over time, allow older people to stay in their own homes for longer and reduce the need for home adaptations.
It is also important to recognise the housing needs of younger members of the population and to address the challenges of entering the housing market. In addition,
the ability of health and social care workers to access the housing market should be considered when addressing the affordability of housing. A local health and care
workforce, as well as built and digital infrastructure, is needed to successfully deliver services for the benefit of our population.
Strategic objective 3: Economic wellbeing is a wider determinant of health and so objectives to deliver more local jobs such as strategic objective 3 are supported.
Strategic objective 4: In addition to allocating land for employment development, provision should be made to enable working from home, which has the benefits of
reducing travel. Houses should be of sufficient size and flexible designs to accommodate this option.
Strategic objective 7: The scope of this objective could be extended from the town centres in Rayleigh, Hockley and Rochford meeting local niche shopping and leisure
needs to include a broader range of activities. These could include shared workspaces for local businesses, community cafes and drop-in facilities for early intervention health services, which would support health and wellbeing of the population.
Strategic objective 8: This objective could include improvement of village and neighbourhood centres to enable the delivery of some health services such as
vaccination centres and drop-in facilities. This would benefit the health and wellbeing of residents and reduce the need to travel.
Strategic Objective 11: Encouraging walking and cycling and so levels of physical activity is supported. Ensuring that our population is well served by public transport is
important to achieving equal access to healthcare services and is important both in new developments and to link established and new developments.
Strategic objective 14: The CCG and HCP welcome the inclusion of strategic objective 14 and look forward to working with the Council and other partners to ensure that our population has access to good quality social and health and wellbeing services.
Strategic objective 15: The inclusion of a reference to older people in this objective is positive. However, it should be made clear that promoting healthy and active lifestyles, and improving physical and mental health and wellbeing, is important for people of all ages, including young people.
Strategic objective 23: Mitigating and adapting to climate change is supported. This objective should be amended to make it clear that those changes are current as well as
forecast and so require immediate action.
Figure 16 – Typical Levels of Growth required to Deliver Infrastructure
It is important to note that the level of growth required to deliver a primary healthcare centre given is, as the title indicates, only typical. There are circumstances where a new facility would be triggered by a development of less than 3,500 additional dwellings and others where 3,500 new dwellings would not result in the provision of a new healthcare facility.
Spatial Strategy Options
Additional healthcare capacity will be needed to provide primary care services to meet the needs of new residents in each of the spatial strategy options. How this additional capacity is achieved will need to be the subject of discussion
informed by more detail about the scale and location of development. New facilities are one option but may not be the most appropriate solution in all cases. Increased capacity through reconfiguration and/or extension of existing premises will also be considered.
It is requested that the wording in the ‘This strategy could deliver…’ text boxes on pages 30, 31 and 32 be amended from ‘…new medical facilities…’ to ‘additional medical facility capacity’. This is to clarify that new facilities will not necessarily be delivered in relation
to all growth whether through urban extensions, concentrated growth or a balanced combination of the options presented.
Further information about the scale and location of developments in the options presented would be needed to form any preference for a particular spatial strategy. The Health and Care Partnership would welcome discussions with the Council and further involvement in development of the local plan strategy to ensure that healthcare needs are properly addressed.
Question 9 – It is agreed that a sequential approach should be taken, and development should be located away from areas at risk of flooding. The HCP would not support the provision of healthcare premises in areas of high flood risk.
Question 10 – The Coastal Protection Belt and Upper Roach Valley should be safeguarded from development as they are a valuable resource to help residents
maintain good physical and mental health.
Question 11 – The principle of requiring developments to source energy from low-carbon and renewable sources in supported. Care should be taken to ensure other important resources, such as landscape are not compromised as a consequence.
Question 12 – Yes, developments should be striving for the highest energy efficiency standards. New NHS buildings are being designed to standards higher than the building regulations in the drive to achieve net-zero carbon developments.
Place-making and design
The inclusion of a place-making charter for Rochford in the Local Plan is supported. It should secure high quality buildings and built environments as well as green and blue spaces; encourage active travel; make provision for local/community food production; and require accessible and adaptable homes. It is also important that existing
communities and new developments, including for our travelling communities, are successfully integrated with easy active travel options and public transport between
them. This approach will help to ensure that development has positive impacts on the health and wellbeing of all of our residents
Healthcare facilities
The structure of healthcare bodies in Mid and South Essex changing. Separate clinical commissioning groups are coming together in an integrated care body which will be part of an integrated care system with other health and social care partners. It is therefore requested that the reference to the Castle Point and Rochford Clinical Commissioning Group is removed.
It is suggested that the ‘Healthcare Facilities’ text on page 57 of the consultation document is replaced by:
With a growing and ageing population, provision of health and community facilities and services within the district is going to become even more important. There is a need to
provide health care facilities that meet existing and future needs, including those arising from the population growth across the plan period. There are currently 10 GP practices in Rochford and the average list size is around 9,500 patients.
The shape of healthcare delivery in Mid and South Essex is also changing. As well as increasing capacity in all three hospitals in Mid and South Essex, the health and care partnership is aiming to invest in and support GP practices to work together to provide
joined up care, building activities in prevention, helping people at an earlier stage and
avoiding serious illness. These priorities will require healthcare hubs that can host a wider
range of healthcare services including diagnostics and early intervention services; support
a move to improved digital services and provide capacity for drop-in and wellbeing services. These will be established through a combination of refurbishment and/or extension of existing facilities; sharing of facilities; and new build projects. The Health and Care partnership is pleased to have to opportunity to respond to the Rochford Local Plan consultation and requests ongoing engagement in development of the plan.

1. Introduction
These representations are submitted by Wood Group UK Ltd (Wood) on behalf of Bloor Homes Ltd.
⚫ Section 2 provides a summary response to the Spatial Options consultation,
specifically in support the ‘Potential Cross-Boundary Opportunity’ east of Wickford,
explaining why the site should be part of whichever Strategy Option is taken forward
as it performs so well.
⚫ Section 3 sets out further detailed justification for a strategic land allocation to the
east of Wickford - centred on the release of sites CFS222 and CFS239 from the Green
Belt and improvements to remaining Green Belt in this area1
- in the context of
national Green Belt policy, sustainability, limited harm and the Council’s evidence base.
⚫ Section 4 explains the specific opportunities and benefits associated with a strategic
land allocation east of Wickford, supported by a concept masterplan and proposed
revision to the Green Belt boundary. This is intended to aid understanding of the
significant potential of this location.
⚫ Section 5 provides answers to the specific questions identified in the consultation
document.

2. Summary
A strategic site allocation to the east of Wickford has such significant credentials in sustainability
and Green Belt terms that it should be allocated as a strategic site whichever Strategy Option is
taken forward - the allocation could be central to Strategy Options 2, 3 or 4. Option 1 (urban
intensification) is unsound given that it does not meet the district’s housing needs and would not
constitute a positively prepared plan.
The size and status of Wickford as essentially a Tier 1 settlement equivalent to Rayleigh at the top
of Rochford’s settlement hierarchy means that this is where development should be focussed.
Wickford is a highly sustainable location for growth and development. It has a range of services,
two secondary schools, strategic employment, retail and a recently upgraded railway station
providing trains to London Liverpool Street. This is all within close proximity to land east of Wickford, which adjoins Wickford Business Park, lies on the A129 high frequency public transport
corridor and is just a 15-minute bus/cycle journey to the railway station and town centre.
In Green Belt terms the ‘exceptional circumstances’ for reviewing boundaries required by NPPF140
are evidenced and justified by the lack of available land outside the Green Belt to meet the district’s
needs through to 2040. When reviewing Green Belt boundaries, the promotion of sustainable
patterns of development and use of previously developed land or sites well-served by public
transport are policy requirements (NPPF142) which the site supports given the sustainability
credentials outlined above. The extent of land controlled by Bloor in this location also provides
the opportunity for compensatory improvements to the remaining Green Belt, through the
provision of new/enhanced sports pitches, biodiversity net-gain and improvements to
walking/cycle links (also NPPF142).
Land east of Wickford is well-related to the urban edge, is visually well-contained, already contains
urbanising influences and has the long term robust boundary of the A130. The presence of the
A130 as such a strong recognisable physical barrier - central to defining Green Belt boundaries
through plan-making under NPPF143(f) - is a particular advantage that other strategic Green Belt
locations in Rochford district do not have (for example, in contrast, there is no such significant and
defensible barrier for development sites centred on Strategy Option 3b, north of Southend).
Release of land east of Wickford will therefore not result in urban sprawl, nor lead to neighbouring
towns merging or encroachment into the countryside. In Green Belt terms land east of Wickford is
a unique opportunity and the best performing strategic location for Green Belt land release,
resulting in the least harm.
From a landscape and heritage perspective it also one of the best performing strategic locations
assessed as part of the Spatial Options consultation (again, in contrast, Strategy Option 3b is in
proximity to designated heritage assets and in an area with low landscape capacity to
accommodate new development). It also an area of lower landscape sensitivity when compared
with other options.
As illustrated on the accompanying plans (Appendix A), a strategic site allocation east of Wickford
can deliver around 1,500 new homes and employment at a scale which supports the delivery of
new community infrastructure, including a primary school and new local centre (convenience retail
and other community facilities). An allocation here would reduce the pressure on other
communities in Rochford district.
In terms of delivery, the land is all under the single control of Bloor Homes, a 5* housebuilder
committed to working with Rochford District Council, the local community and key stakeholders to
realise the opportunities presented by this important opportunity.

3. Justification for a strategic land allocation /
cross boundary opportunity east of Wickford
3.1 Green Belt
NPPF Green Belt Policy
Exceptional circumstances (NPPF140)
The case for exceptional circumstances for Green Belt land release in Rochford – as required by
NPPF140 - is established under Strategy Options 2 and 3. As recognised on page 29 of the Spatial
Options, Strategy Option 1 (urban intensification), predicated on no Green Belt land release, will
not meet Rochford’s growth needs, and is therefore unlikely to be considered sound, being not
positively prepared. Green Belt land is needed. The question is where the best locations are to do
so whilst limiting the overall harm to the Green Belt and with respect to the requirements of
NPPF142 and NPPF143 in particular.
Promoting sustainable patterns of development and giving first consideration to land which has
been previously-developed ‘and/or’ is well-served by public transport (NPPF142)
Wickford is rightly recognised as equivalent to a Tier 1 settlement2
– i.e. the top of the settlement
hierarchy alongside Rayleigh. It has two secondary schools, strategic employment and retail, with
Wickford railway station - recently subject to a £4m package of improvements – providing trains
into London Liverpool Street.
Land east of Wickford is highly sustainable, as supported by the Council’s evidence base, including
the Complete Communities Topic Paper. As shown on Figure 4 of this topic paper the site adjoins
frequent public transport (more than 4 services per hour), with bus stops to the north west
(Southend Road roundabout3
), east (A129/Old London Road) and west (Hodgson Way). As part of
a strategic site allocation there is the potential to route a bus into the site and enhance
accessibility.
As supported by the Site Appraisal Paper all key facilities are nearby, including secondary school
(Beachamps High), local shops and Post Office (centred around the junction of Southend
Road/Fanton Walk/Bruce Grove), healthcare (Shotgate Surgery), jobs and employment (at
Dollymans Farm, Wickford Business Park & Fanton Hall Farm). Furthermore, the site is well-located
in proximity to extensive areas of open space, including sports pitches at The Warren, Rayleigh FC
Boys & Girls, Chichester Ground Football Pitches and Shotgate Park (with respect to the Site
Appraisal Paper, the site should at least score ‘4’ given proximity within 400-800 metres). Land
east of Wickford is just a 15-minute bus/cycle journey from the railway station and the town centre.

Promoting sustainable patterns of development in NPPF Green Belt terms therefore means
directing a significant share of new growth and development towards Wickford, whichever Strategy
Option of 2, 3 or 4 is pursued.
The site is already part brownfield and part developed with clear urbanising influences - as
acknowledged in the Site Appraisal Paper - encompassing one of the district’s twelve ‘informal
employment areas’ (Economy & Skills Topic Paper) as well as an existing dwelling and curtilage at
Dollymans Farm.
A particular benefit in terms of sustainable patterns of development is the ability to provide a scale
of development which supports additional infrastructure and investment, with the 1,500 homes at a
level which sustains provision of a new primary school, as well as supporting facilities including a
local centre, which alongside existing and enhanced public transport all helps to create a truly
‘walkable’ neighbourhood. The ability for strategic allocations to deliver infrastructure
improvements is identified in the Spatial Options Document, supporting Strategy Options Topic
Paper and the Interim Integrated Impact Assessment IIA4
. This will also be a sustainability benefit to
the existing area – including users of Wickford Business Park and neighbouring residential areas.
This would support the intentions of Strategy Options 2, 3 and 4 whereby the ability to fund and
deliver new infrastructure is identified as a clear opportunity.
Delivering compensatory improvements to the environmental quality and accessibility of the
remaining Green Belt land (NPPF142)
Compensatory improvements to the environmental quality and accessibility of the remaining Green
Belt - another key objective of NPPF142 - could also be secured given the extent of land within
Bloor Homes’ control (e.g. around CFS223, 226, 227, 230 & 238). Improvements could include a
combination of enhanced green infrastructure connectivity, new recreational routes for walking and
cycling and additional playing fields/sports provision. This would also align with NPPG002 (Green
Belt - Reference ID: 64-002-20190722) in terms of the range of compensatory improvements. By
tying such improvements in with the allocation and future planning permission, this would also be
deliverable in the context of NPPG003 (Reference ID: 64-003-20190722) and can be secured via the
S106 process.

Defining a clear Green Belt boundary (NPPF143(f))
The A130 is a significant clear physical feature and long term permanent boundary to the east of
Wickford which would form a logical defensible boundary which is capable of enduring beyond the
plan period. In this regard land east of Wickford is a unique opportunity – with no other strategic
locations having such a significant and robust Green Belt boundary, in combination with
accessibility, sustainability and suitability (being of lower environmental value).
The Council’s Green Belt Study (Assessment Area AA01 / Sites 222, 239, 238 & 223)
Against the fundamental purpose of the Green Belt – to prevent urban sprawl (NPPF137) – the
Green Belt Study rightly recognises that the area makes a weak contribution. Surprisingly it then
identifies a ‘High’ harm impact score which then follows through into the Site Appraisal Paper.

This appears predicated on the conclusion that the area makes a ‘strong contribution’ to
preventing encroachment on the countryside. However, the assessment is flawed because it fails to
reflect the existing urbanising influences in the area, incorrectly stating that the area is
undeveloped. The presence and extent of ‘urbanising land uses and features that could diminish
openness or compromise the rural character of the countryside’ are identified as key factors in the
Green Belt Study’s own methodology (2.46, 2.477, 2.50 and 2.53) but then disregarded in the
assessment of Parcel 1/AA01. Examples of the urbanising features on the site are illustrated on the
photographs presented at Figure 2. Urbanising influences include the employment areas at
Dollymans Farm (note: non-agricultural uses), and residential use at Dollymans Farm itself, as well
Fanton Hall employment area to the south east. The presence of the A129 and A130, pylons,
employment distribution infrastructure and railway line are also urbanising influences.
Furthermore, the assessment of encroachment and wider performance of the land in this area in
terms of Green Belt purposes then fails to reflect the role of strong physical boundaries, i.e. the
A130 in this case. The dictionary definition of encroachment concerns a gradual advance beyond
usual or ‘acceptable limits’ – the acceptable limit in this case being the A130. This should be a
fundamental consideration as part of the assessment and at present is a significant omission in the
study’s methodology and in the appraisal of Parcel 1/AA01. The assessment should be revised to
conclude a weak contribution to this Green Belt purpose.
In reality, and as explained earlier in this section this is a unique and strongly performing Green
Belt site because it is so well-related to the existing urban edge, already contains urbanising
influences, is visually well-contained and has such a strong boundary in the A130 that other
strategic development locations do not have. It is the best option with the least level of harm to
the Green Belt particularly with regard to the fundamental policy aim of the NPPF in preventing
urban sprawl.
Revised scoring for Parcel 01 (from the Stage 1 Assessment) and Parcel AA01 (from the Stage 2
Assessment) is therefore presented in Figure 3. It is concluded that the overall contribution to
Green Belt purposes is weak and the harm of release reduces to low-moderate. This should then
be coupled with the site’s sustainable development credentials.

Wider local plan evidence base: Site Appraisal Paper – Land East of Wickford
The Site Appraisal Paper identifies all land within Bloor Home’s control in this location as
deliverable within 5-years subject to policy, encompassing sites CFS222, CFS239, CFS238, CFS223
and CFS226. The Site Appraisal Paper shows how well-located the area is in landscape terms, lying
outside of the more sensitive landscapes in the district. Informed by the findings of the Landscape
Character, Sensitivity and Capacity Study identifies land east of Wickford as lying within a ‘LowMedium’ landscape sensitivity and ‘Medium-High’ landscape capacity to accommodate
development. The main development sites comprising CFS222 and CFS239 are also unaffected by
designated heritage assets, unlike other strategic development areas assessed in the District.
These sites all perform well in terms of accessibility given proximity to high frequency public transport on the A129 and access to facilities and services. However, there is an inaccuracy in the
scoring with respect to access to open spaces. This does not reflect the latest position on the ground, whereby the sites are very well-located in proximity to extensive areas of open space,
including sports pitches at The Warren, Rayleigh FC Boys & Girls, Chichester Ground Football
Pitches as well as Shotgate Park. The scoring for CFS222 and CFS239 should be increased from ‘1’
to ‘4’ given the extent of open space provision already within 400-800m.
In terms of access to public transport, whilst accessibility to high frequency bus routes is
recognised, the scoring for CFS222 does not yet reflect the ability to deliver
enhancements/improvements as a central part of any development scheme. In reality CFS239 –
which scores well with a ‘4’ given that it abuts the A129 and is within 400 metres of bus stops at
Southend Road roundabout – would form part of the single comprehensive allocation which aligns
with the masterplan enclosed at Appendix A. The masterplan reflects the ability for a bus to route
in and out of the scheme in order that new homes would be within 400m, so this could easily be dealt with as part of the allocation and consenting process, in which case CFS222 would also score
4.
Figure 4 presents the revised scoring for sites CFS222 and CFS239 under Bloor’s control on land east of Wickford which are to form the main area for Green Belt land release presented in section 4.
The land clearly outperforms other locations with respect to Green Belt, landscape, accessibility,
ecology and heritage.

4. Strategic land allocation - concept masterplan,
potential & opportunities
As summarised in section 2 and justified in section 3, land east of Wickford is the best location for a strategic land allocation, and should play an important role under Strategy Options 2, 3 and 4. In Green Belt terms, Wickford’s status akin to a Tier 1 settlement, accessibility to high frequency
public transport, services and facilities – and ability to deliver new community infrastructure – is
entirely consistent with promoting the sustainable patterns of development envisaged by NPPF142.
The A130 is a strong and longer term defensible Green Belt boundary unique to this location, helping limit sprawl and encroachment. Alongside the area’s relationship with the existing urban edge, visual containment and existing urbanising influences it is the best performing location for
Green Belt land release with the least harm to the overall role and function of the Green Belt in Rochford district.
In landscape and heritage terms this area would also result in the least harm when compared with other strategic options. It provides the opportunity for the Council to deliver growth in a location which minimises impacts on existing communities and environmental assets.
Appendix A provides a draft concept masterplan, with Appendix B providing a context plan and proposed revision to the Green Belt boundary in this location.
The draft concept masterplan is based on the following key features and benefits.
⚫ Around 1,500 homes, a mix of market and affordable in response to local needs, on a net residential area of around 40ha.
⚫ 2ha of land for a new 2FE primary school, supporting the Spatial Options opportunity to deliver growth at a scale which provides and sustains new infrastructure.
⚫ A new local centre, located next to the new school site, providing convenience retail
and other community uses.
⚫ A robust, long-term and defensible Green Belt boundary, capable of enduring beyond the plan period and supporting the sustainable patterns of development envisaged by NPPF142(f) Green Belt policy. The A130 and railway line provides a clear boundary using an existing physical feature that is readily recognisable and likely to be permanent, entirely consistent with NPPF132(f). Appendix B sets out the proposed Green Belt boundary revision.
⚫ New and enhanced playing pitches as a ‘hub’ for sports and recreation. The Council’s Playing Pitch Assessment and Action Plan identifies the opportunity to provide greater security of tenure for sports provision in this location – including at The Warren (CFS226) which is land under Bloor’s control. Further pitches could be provided west of the Warren/A130 or land to the east which is also within Bloor’s control. This would utilise existing bridleways all of which would link sports provision with the new homes, across the existing Pegasus crossing on the A129, with access off the A129.

Alongside the bridleways and existing crossing, the scheme would promote the use of public transport through the ability to route a bus into the site to secure a 400m walkable catchment and could provide ped/cycle links to the west through to Wickford.
⚫ Visual containment can be maximised by retaining key landscape features and enhancing structural planting alongside the site’s northern and eastern boundaries, complemented by the provision of sustainable drainage and wildlife habitats to deliver net biodiversity gain all on-site. 50% of the site would comprise green uses.
⚫ Access would be via a new roundabout on the A129, providing a tree-lined avenue
into the neighbourhood, with a potential secondary access located to the east (refer to
the masterplan in Appendix A for details).

5. Response to specific questions
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
For the reasons explained in section 2, the cross-boundary opportunity east of Wickford has such
significant and unique credentials in sustainability, Green Belt and deliverability terms that it has a
role to play in delivering all Strategy Options 2, 3 and 4.
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?
Standards for new developments relating to both energy supply and energy efficiency standards should be left to national building regulations (e.g. linked to the Future Homes Standard or similar
initiatives in the future).
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
Under Strategy Options 2, 3 or 4, a strategic land allocation east of Wickford could clearly support
the opportunity for new green infrastructure, including a new hub for sports provision in this
location (improving both the quality and quantity of sports pitches), improvements to GI
connectivity (e.g. upgrading existing bridleways), biodiversity net gains and further strategic
landscaping, particularly associated with the establishment of a robust and defensible Green Belt
boundary to the east of Wickford / west of the A130. This package of measures would also support
the environmental quality and accessibility of remaining Green Belt land, as set out in NPPF142.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to
deliver new or improved community infrastructure?
Under Strategy Options 2, 3 or 4, a strategic land allocation east of Wickford can deliver growth at
a scale – 1,500 homes plus employment - which provides and sustains new community facilities,
including land for a 2FE primary school, new local centre (which provides convenience retail and
other community provision), extensive green infrastructure as well as new and enhanced sports
provision. Further details are provided in sections 3 and 4 of these representations.
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?
Bringing forward a strategic land allocation east of Wickford – under Strategy Options 2, 3 or 4 –
would support improvements to open space and sports provision. There are opportunities to deliver additional pitches as well as greater security of tenure, for example, on retained Green Belt
land centred on sites CFS223 and CFS226, all on land which Bloor Homes controls and would tie in
with a new strategic land allocation. The opportunity to provide greater security of tenure at The
Warren in particular (CFS223) is identified in the Playing Pitch Assessment and Action Plan. Further
details are provided in sections 3 and 4 of these representations, with the opportunity to provided
new pitches identified on the concept masterplan presented in Appendix A (6-7ha of
new/enhanced pitch provision complemented by extensive green infrastructure and biodiversity
net gains).
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?
The potential for impacts on the significance of heritage assets and their setting is a key constraint
to consider through plan-making and subsequent decision-taking on planning applications. The
Council should look therefore towards options with no/limited heritage constraints, as is the case
for land east of Wickford, recognised in both the Site Appraisal Paper and IIA.
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?
Growth should be directed to the most sustainable locations already well-served by high frequency
public transport, services and facilities, and where there is the opportunity to deliver a scale of development to sustain new services and facilities to deliver truly walkable neighbourhoods.
Promoting sustainable patterns of development is central to the review and release of Green Belt land and where land east of Wickford performs particularly well. Wickford is equivalent to a Tier 1
settlement, has rail access into London Liverpool Street, with the opportunity that Bloor has identified just a 15-minute bus/cycle ride to the station and lying on a high frequency public transport corridor (recognised in the Connecting Communities Topic Paper). Land east of Wickford
is already identified as having a positive contribution to sustainable transport in the IIA. Further detail on transport and sustainability for the cross-boundary opportunity east of Wickford is provided in sections 2, 3 and 4 of these representations.

Having reviewed the Strategy Options presented, Option 3b appears less suitable in transport terms for the following reasons.
⚫ A review of the potential development sites outlined in Figure 17 associated with Option 3b of the Spatial Strategy Options shows there is a lack of suitable infrastructure to support a significant level of housing growth in this region when compared with other strategic options (e.g. land east of Wickford). Figure 2 of the Complete Communities Topic Paper shows that this area is also less well-served by public transport – highlighting non-frequent bus services and services less than 4 per hour when compared with the high frequency public transport provided on land east of Wickford (tested under Option 3a).
⚫ The land identified for Option 3b within the Spatial Strategy Options is sandwiched between the River Roach to the north, Potton and Foulness Islands to the east, the existing settlement of Southend-on-Sea, and the River Thames to the south and London Southend Airport to the west.
⚫ The only strategic route to and from this area is via the A127 which provides a route
west towards the A130 (north / south route) and the M25. All vehicle redistribution and growth associated with a new, large residential settlement in this area would therefore be required to utilise the A127 as the main route in and out of the area. This route also serves as the main route for London Southend Airport which is due to continue to expand.
The other option for movement into and out from the area is less strategic and comprises the A13 London Road though this would require traffic to travel through
the centre of Southend-on-Sea.
⚫ If a strategic scale of development is proposed then significant new transport
infrastructure may be required, whereby the location of Option 3b presents limitations. For example, the proximity of London Southend Airport to the A127 to the south, and River Roach to the north mean there is very little scope to enhance a connection east from lands north of the town centre.

Q63a. Do you agree with our vision for Rawreth? Is there anything you feel is missing? [Please state
reasoning]
Land east of Wickford sits within Rawreth parish but is fundamentally related to and links to
Wickford/Shotgate, lying east of the A130. Engagement with the parish council will be central to
our approach, including how the wider transport, green infrastructure, sports pitches, school and
local centre to benefit existing residents in this area.
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?
Linked with the response to Q63a, the cross-boundary opportunity east of Wickford should be
recognised and allocated as part of the new local plan under whichever strategy option is taken
forward. The opportunities associated with this land allocation are presented in sections 2, 3 and 4
of these representations, supported by the concept masterplan provided in Appendix A.
Essentially, it would comprise a new walkable neighbourhood of around 1,500 homes, employment
plus 2FE primary school and local centre, through removing sites CFS222 and CFS239 from the
Green Belt. A new defensible Green Belt boundary would be established to the west of the A130
and north of the railway line, as shown on the plan enclosed at Appendix B.
Retained Green Belt land under Bloor Homes control – comprising CFS238, CFS223, CFS226, CFS227 and CFS230 – could deliver compensatory improvements to the environmental quality and
accessibility of remaining Green Belt land, including new and improved sports pitches (e.g. CFS222 and CFS226/The Warren), biodiversity net gain, improved walking/cycle links and strategic landscaping.

We have viewed the proposed Plan for the area surrounding our home in Blower Close and would like to record our objections to the proposal. Having lived here for 28 years we have enjoyed the Green Belt and the amenities it provides. If the Green Belt were to be developed it would devalue the whole area. The infrastructure would not meet the needs of your proposals. It is nearly impossible at the moment to get a Doctor’s appointment. There is so much traffic already that the Town is often gridlocked with queues of traffic trying to reach the main roads in and out of Rayleigh. It is often impossible to find empty spaces in the existing car parking areas and we know from experience that able-bodied drivers often use the Disabled Parking bays.

Under your Plan the development of the Green Belt would not enhance the whole area. We have seen the development alongside Hall Road, Rochford. Initially it was proposed that there would be a Doctors Surgery and a new school. The plans were passed before the developer sold off part of the area to another developer which allowed them not to build either a school or a surgery for the use of the residents. Indeed an area was sold to a London Borough to meet their housing needs. In Rawreth Lane we have yet another development reaching London Road and where traffic is reduced to a single lane. In Hullbridge they have built houses and had to build a new roundabout for the increased traffic from Watery Lane and Rayleigh. And there are always huge queues of traffic. Under your plans, fewer people would want to live in such congestion,

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

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

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

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

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

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

Dear Sir / Madam,

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

Thank you in advance for your attention to this matter.

Kind Regards,
Jane

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

EXECUTIVE SUMMARY
There is a compelling case for the allocation of the subject landholding at Tithe Park, Poynters Lane
in the emerging Rochford Local Plan. The proposal at Tithe Park will deliver up to 525 homes, facilitate the provision of a secondary school including scope for SEND and also contribute towards green and blue infrastructure by way of enhanced connections through the site, along with the extension of Friars Park.
The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive Contribution to housing delivery in the early years of the Local Plan.
The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. Furthermore, our client has undertaken a range of technical assessments in respect of the subject site which reinforce the Council’s evidence and
demonstrate that there are no impediments to this site in coming forward.
Crucially this area is assessed as being of medium to low landscape quality, value and sensitivity. It does not perform a strong Green Belt function. The development of this site will provide a logical planned extension which would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, to form a robust and consistent boundary to the redefined Green Belt.
The site is highly sustainable particularly given the high frequency local bus services which currently serve the site, with an average of 13 bus services per hour. Moreover, the provision of community infrastructure on this site would greatly enhance the sustainability credentials of the local area including Great Wakering.
The emerging Rochford Local Plan must meet their own housing needs, along with examining the potential to accommodate some of the unmet need arising from Southend-on-Sea Borough. Given the lack of undeveloped brownfield sites in RDC available for development, it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford. The Framework requires that in such instances first consideration needs to be given to land well served by public transport, such as the subject site.

There are currently no secondary schools in the south-eastern part of Rochford District to serve the site and settlements such as Barling, Great Wakering and Little Wakering, indicating that pupils from these areas need to travel some distance to facilities in other parts of Rochford or Southend/Shoeburyness. Moreover, the schools that are in the wider locality are poorly performing. There are currently no specific Special Educational Needs & Disability (SEND) facilities within
Rochford. While there are limited facilities in Southend, the school performance of these SEND schools is poor when compared to authority and national averages. The NPPF highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities. Paragraph 95 states that local planning authorities should take a proactive,
positive and collaborative approach to meeting this requirement, and to development that will widen
choice in education. Local planning authorities should give great weight to the need to create schools
through the preparation of plans. In light of the above, there is a compelling case for the delivery of a Secondary school and SEND provision in this area.
The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary
and SEND education facilities in this locality and also can contribute towards green and blue infrastructure delivery including the extension of Friars Park.
In summary the key benefits of allocating the subject site include -
• Delivery of up to 525 homes which will make a positive contribution towards the Council’s housing
needs in the short term;
• Ensure a diverse range of tenures (market and affordable) and range of house types;
• Provision of the land to deliver a Secondary School along with scope for a SEND facility;
• Enhance connections and green links through the site improving green and blue infrastructure and extending Friars Park;
• Deliver a robust landscaping strategy which achieves biodiversity net gain;
• Enhancement of Public Rights of Way through the site;
• Support local highway improvements from the site and encourage sustainable transport behaviours.

INTRODUCTION
1.1 These representations have been prepared by Iceni Projects Ltd (“Iceni”) on behalf of Stolkin and Clements (Southend) LLP in respect of the Tithe Park, Poynters Lane, Great Wakering. Our clients
are the freehold owners of this site and are committed to working with the Council and key
stakeholders to deliver a sustainable residential scheme and facilitate the provision of community
infrastructure in this location.
1.2 For reference, enclosed with these representations is a Design Document prepared by Turner Architects which sets out the vision, key features and development potential of the site.
1.3 The preparation of a new Local Plan for Rochford provides an important opportunity in which to deliver positive growth for Rochford and the existing community, along with delivering new homes and infrastructure. This proposal at Poynters Lane is complementary to the Vision for Great Wakering
as set out in the Consultation and will assist the Council in meeting their strategic objectives including the delivery of a Secondary School.
1.4 The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no Impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. The only considerations that the Local Plan evidence base raised in respect of this site relates to green belt; mineral safeguarding and agricultural land
classification and that the site is removed from a secondary school. These matters are considered in
further detail in these representations where it is demonstrated that there are no impediments to this
site in coming forward.
1.5 These representations in relation to Tithe Park are structured as follows:
• Section 2 provides an overview of the site location and context, along with the accessibility of the site to public transport and local services;
• Section 3 summarises the relevant national planning policy framework in so far as it relates to the subject site and proposals;
• Section 4 details housing and education needs in Rochford District;
• Section 5 sets out the evidence base prepared by the Council to date in relation to this site and also the technical reports prepared by our client which demonstrates the suitability of this site for development;
• Section 6 sets out the case for the allocation of the subject site at Tithe Park; &
• Section 7 contains the Conclusion and provides a response to the Questions contained in the Consultation.
SITE CONTEXT
Site Description
2.1 The site comprises a large, rectangular, open parcel of land to the south of Poynters Lane, with an area of 33 hectares, to the north-west of North Shoebury, within the administrative boundary of Rochford District Council. The site is located further south of Great Wakering High Street. The site wraps around a collection of farm buildings at Tithe Farm, and the properties at Tithe Cottages. The southern boundary of the site adjoins the borough of Southend-on-Sea.
2.2 The landholding is bound to the north by Poynters Lane and bordered to the west and south by postwar housing, and open space at Friars Park. To the east, lies an area of unmanaged scrub and grassland and a pocket of commercial development located at the junction of Poynters Lane and Wakering Road. North of this, on the opposite side of Poynters Lane is further residential and
commercial development at Crouchmans Cottages and Crouchmans Farm.
2.3 To the north of the site is an area of arable farmland, beyond which the settlement at Great Wakering
lies. The historic core of Great Wakering lies within the eastern part of the settlement. The village has grown in the latter part of the 20th Century, with housing estates extending the settlement to the north and south of the High Street. New development is currently ongoing at the southwestern edge of the village. Recent development has also occurred off Alexander Road, forming a cluster of housing, which extends someway south of the main part of the village.
2.4 The site is not covered by any statutory or non-statutory designations. The nearest listed building is
the Grade II North Shoebury House, which is located on Poynters Lane to the north-west of the Site. Foulness Ramsar site, Special Protection Area (‘SPA’) and Site of Special Scientific Interest (‘SSSI’) is situated to the east of the site.
2.5 There are a number of local services and amenities located within North Shoebury and Great Wakering including areas of open space, schools, shops, businesses and places of worship. A public footpath crosses the eastern part of the Site, linking Poynters Lane to Friars Park. A second public footpath follows the western boundary of the Site.
2.6 Views towards the site from the surrounding area are limited, due to its proximity to surrounding urban development. In terms of landscape character, the site is closely associated with the surrounding urban land uses, and it has an urban edge character. The site is assessed as being of medium to low landscape quality, value and sensitivity.
The site is exceptionally well located in terms of access to local bus services. The bus routes serving the subject site are detailed in the table below which illustrates that there are bus stops within 100 metres and 460 metres of the site providing a high frequency of services.
Table 2.1 Local Bus Services
Route Bus Stop Distance from Site boundary
Route 1 (The Renown to Rayleigh via Southend Bus
Station and Hadleigh (A13))
Shoebury
Renown
460m
Route 7 (Rayleigh to Great Wakering via Southend Bus
Station and Hawkwell)
Star Lane 100m
Route 8 ( (Rayleigh to Great Wakering via Southend
Bus Station and Ashingdon)
Star Lane 100m
Route 9 (Rayleigh to Shoeburyness East Beach via
Southend Bus Station and Eastwood).
Shoebury
Renown
460m
2.8 In addition, these services stop at Southend Central Bus Station which is a major public transport hub providing routes across Essex, including routes to Southend and Stansted Airports. An extract
of the local bus routes is shown in Figure 2.1.
[SEE DOCUMENT FOR IMAGE]

Both Routes 7 and 8 can be accessed from Poynters Lane, providing one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at the Renown on Constable Way with both routes each providing five buses per hour in the AM peak.
There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
2.10 The site is also well placed with a large number of local facilities with 1km of the site. These facilities include:
• Asda Superstore;
• Asda Pharmacy;
• Friars Park;
• Friars Primary School;
• St George’s Catholic School
• Convenience Store;
• North Shoeburyness Surgery;
• Eagle Way Surgery; and
• Parsons Barn Public House.
2.11 These local facilities, alongside the local bus services, highlight that the site is well located and
alternatives to car use are practical.

NATIONAL PLANNING POLICY FRAMEWORK
3.1 The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to the subject site.
Plan Led Approach
3.2 The National Planning Policy Framework (referred to herein as “the Framework”) states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
3.3 Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and
enhancement of the natural, built and historic environment. These policies should provide a clear
strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
Green Belt Release
3.4 Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
3.5 Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation and supporting evidence base recognises that RDC
are unlikely to have sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.
3.6 The Framework requires at Para 142 that “Where it has been concluded that it is necessary to release
Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” The subject site benefits from a high frequency bus service which connects this site to the key local centres, and also provides connections to major rail stations in the locality. In this respect the Framework requires that sites such as Tithe Park should be given first consideration for release from the Green Belt.
30 Year Vision
3.7 The Framework requires for large scale developments such as significant extensions to existing
villages and towns ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. The Framework does not define what constitutes a significant extension and thus it is not clear whether the development of the subject site would require a 30-year vision. Given the scale of the proposal and the timescales for delivery, it is
considered that this policy is not applicable in this instance, nonetheless further clarity is expected
from the Government on this policy in due course.
Planning for Education
3.8 The cornerstone of the Framework is the pursuit of sustainable development. The most recent
revision includes reference to UK’s commitment to pursuing the 17 Global Goals for Sustainable
Development in the period to 2030. Goal 4 relates to quality education and ensuring inclusive and
equitable quality education and promotion of lifelong learning opportunities for all.
3.9 In this vein, the Framework highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities in the promotion of healthy and safe
communities. Paragraph 95 states that Local planning authorities should take a proactive, positive
and collaborative approach to meeting this requirement, and to development that will widen choice in education. Local planning authorities should give great weight to the need to create schools through the preparation of plans
HOUSING & EDUCATION NEEDS ANALYSIS
Housing Needs
4.1 In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2 The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
4.3 Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in 10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4 The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. Southend-on-Sea Borough Council have published their Local Plan Consultation ‘Refining the Plan Options’ which confirms that they are unable to meet their full housing needs with an arising shortfall of 3,550 – 4,300 homes over the period to 2040. Given the close relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services
between the two authorities, RDC needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5 Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.
Set against this, the Council’s Housing and Employment Land Availability Assessment considers the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,5001 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short of the District’s
housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
4.7 The table below illustrates that RDC will have a shortfall in the range of 2,700 – 6,300 homes. The
Council is duty bound to test whether there can accommodate this level of development, particularly
in view of Southend-on-Sea’s ability to meet their housing needs.
[SEE DOCUMENT FOR TABLE]
Education Needs
4.8 Iceni Projects has undertaken an assessment of the educational needs provision in Rochford and
Southend-on-Sea.
4.9 Figure 4.2 provides an overview in terms of the geographical spread of the secondary school
provision across the two authorities. As it can be seen, the majority of schools are concentrated to the west and centre of the two authorities, with no schools within 2km of the site and one within 5km.
4.10 There are currently no secondary schools in the southeastern parts of Rochford District to directly
serve settlements in these areas such as Barling, Great Wakering and Little Wakering, indicating that children from these areas would need to travel to facilities in other parts of Rochford or Southend/Shoeburyness. The closest secondary establishment in the southeastern areas is the Shoeburyness High School.
[SEE DOCUMENT FOR IMAGE]

The spatial coverage of the various Rochford secondary establishments indicates that settlements located in the south east of the District (e.g. Great Wakering and Little Wakering), are currently situated on the edge of King Edmund School’s catchment area. This could lead to potential difficulties for residents of these areas and their children to access secondary school facilities. In addition, the site falls within the Shoeburyness High School catchment area.
4.2 The Department for Education provides the latest school performance tables through the Find and
compare Schools Tool.
In Rochford, the King Edmund School, which is closest to the Site has a rating of Well below average (-0.79). The performance of the school in terms of Grade 5 or above in English & maths GCSEs is lower than national averages. There is thus a qualitative issue regarding
the choice of good quality schools for residents living in the Rochford and the south-eastern part of Rochford District.
4.3 Moreover, in Southend-on-Sea the Shoeburyness High School ranks at below average; as does the
Southchurch High School. The school’s performance in terms of Grade 5 or above in English & Maths GCSEs is lower than Southend-on-Sea and national averages.
4.4 There are currently no specific Special Education Needs & Disability (SEND) facilities within
Rochford, with some of the mainstream schools in Rochford offering special education needs settings
for limited number of pupils. While there are limited facilities in Southend the school performance of
SEND schools is poor when compared to authority and national averages. There is thus a qualitative
issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District
EVIDENCE BASE & TECHNICAL ASSESSMENTS
5.1 The purpose of this section is to consider both the evidence prepared by RDC to date in so far as it
relates to the subject site and also to consider the technical reports prepared by our client in order to
inform the plan making process and assist the Council.
5.2 In this section we provide an overview of the Rochford Site Appraisals Paper, along with the Green
Belt and Landscape assessments undertaken by RDC.
5.3 Our client has undertaken the following technical reports in respect of the site –
• Green Belt & Landscape Assessment
• Flood Risk Assessment
• Agricultural Land Assessment
• Minerals Assessment
• Ecological Assessment
• Highways, Public Transport & Connectivity Analysis
• Community Infrastructure Audit
• Education Needs Assessment
5.4 In the interests of ensuring these representations are as concise as possible it is not intended to submit these technical reports with the submission, with the exception of the Green Belt and landscape assessment prepared by CSA, rather we will provide an overview of the key findings. We would be pleased to share these reports with the Planning Authority at the appropriate juncture.
RDC Site Appraisals Paper
5.5 The Site Appraisals Paper (SAP) forms an assessment of land being promoted for development in
the District, providing a technical understanding of the sustainability of different sites to inform future
decisions about development as part of the Council’s emerging Local Plan. The Council have stated that it is not the purpose of the SAP to arrive at a list of preferred sites, nor ‘select’ a list of final sites for allocation. The site selection process could logically follow as a next stage.
5.6 The assessment has not flagged any significant issues to hinder the development of Tithe Park (minus being a GB site). Using this assessment potential concerns from the Council regarding development on this site could include the site being Grade 1-3 agricultural land and a minerals safeguarding area. Our client has commissioned technical assessments in relation to these issues which are summarised further below.
5.7 A key issue that needs to be clarified is that the RDC analysis is incorrect in relation to bus frequency which states “The Site is between 400m and 800m from a bus stop however, no bus services received at stops within 400m”. This is an error and needs to be clarified to ensure the site benefits from the correct scoring when assessed against other sites. As detailed above at section 2, the site is within 100 metres of bus stops served by Routes 7 and 8 which provide one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at
The Renown on Constable Way, 460 metres from the site, with both routes each providing five buses per hour in the AM peak. There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
5.8 The sustainability of the locality is raised due to the lack of access to major facilities such as a secondary school. However, it is recognised the scale of the site is capable of delivering services such as a school which the subject site could facilitate.
5.9 No notable constraints in terms of site conditions have been identified, there is also a lack biodiversity
and ecology features on the site. Also, the sites close proximity to the strategic road network and suitable vehicular access being possible from a private road are considerations in favour of development on this site.
[SEE DOCUMENT FOR TABLE]

Green Belt & Landscape Assessment
5.10 The Council’s Green Belt assessment considered that release of the site from the Green Belt would result in a high level of harm to the Green Belt purposes. The study noted its potential role in maintaining separation between Great Wakering and Southend-on-Sea, and in preventing sprawl and countryside encroachment. The assessment did however acknowledge that the parcel was contained by development on two sides and that Poynters Lane would be a stronger Green Belt
boundary than the current one. Moreover, the Council’s evidence base identified that the majority of site falls within medium-high capacity area to accommodate development.
5.11 CSA Environmental have undertaken their own independent review of the site’s contribution to the
green belt, attached at Appendix 2 of these representations, and found that “development of the Site could provide a logical planned extension, which would effectively infill an area of land at the north eastern edge of Shoebury. It would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, which would form a robust
and consistent boundary to the redefined Green Belt. There would be some reduction in the
separation between Southend-on-Sea and the smaller settlement at Great Wakering, however a clear visual and physical break would remain”.
5.12 This area is assessed generally as being of medium to low landscape quality, value and sensitivity. The is consistent with the Council’s published Landscape Character, Sensitivity and Capacity Study.
5.13 Views towards the Site from the surrounding area are limited, due to its proximity to surrounding
urban development. There are filtered views from the rear of properties which lie adjacent to the Site, and from the open space at Friars Park. There are also views from Poynters Lane, and from the footpaths which cross the farmland at the edge of Great Wakering.
5.14 The site’s performance against the first four Green Belt purposes is summarised in the table below.
Table 5.2 Assessment of the Site against the four Green Belt purposes
[SEE DOCUMENT FOR TABLE]
In light of the above, it is considered that the Council should assess the green belt contribution of
this site independent of the wider area, and thus will reach similiar conclusions as the CSA Environmental analysis.

Education Needs Assessment
5.16 An Education Need Assessment has been prepared by Iceni Projects with the key findings –
• The demographic analysis shows an expected notable increase in the population of secondary school age over the next 6 years to 2027;
• By 2027, the school age population is expected to increase by 2,200 – 2,600 pupils in Rochford and Southend;
• Estimated there is a residual shortfall of approximately 880 to 1,280 places for both Rochford
and Southend when considering school age population increase and planned provision;
• Moreover, the closest schools to these areas (in both Southend and Rochford) are currently
performing poorly, with below average performance when compared to local authority and national averages;
• Lack of good quality secondary school provision in the area for residents to easily access;
• Beyond 2027, the demographic analysis indicates that additional need could be generated as
family housing is delivered and attracts enhanced in-migration to Southend and Rochford. A total population of secondary school age children (relative to the 2020 baseline) of between 2,000 –
3,000. This implies an additional need of up to 400 pupils relative to that to 2027.
5.17 There is currently capacity deficit in the Special Education Needs and Disability (SEND) facilities
closest to the Site. Moreover, the school performance of SEND schools within both Southend-onSea and Essex is poor when compared to authority and national averages. There is thus a qualitative issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District.
Community Infrastructure Audit
5.18 A Community Infrastructure Audit was also prepared by Iceni Projects, which presents an overview of current community facilities and services in the area where the Site is located. This assessment came to the conclusion the Local Impact Area where the site is located is considered to have a good range of community facilities. There is capacity in most existing facilities including sport and openspace, health care facilities and community facilities. However, it is likely that local education facilities
to experience some deficits if additional population is introduced into the area. The Report also identifies there is a shortage of allotments and young people’s provision in the District, therefore development on this site could address this need.

Highways, Public Transport & Connectivity
5.19 Iceni Projects undertook an initial Transport Assessment on the Site. The Assessment investigated
a number of potential options for the Poynter Lane / Star Lane Priority Junction to ensure sufficient capacity at this junction when the site is developed. The transport study demonstrates that there are a range of options in order to enhance Poynter Lane / Star Lane Priority Junction which include a new roundabout or a signalised junction.
5.20 There are currently no pedestrian frontages along Poynters Lane, but there are number of other
Public Rights of Way (PRoW) in the vicinity of the Site, including a pedestrian link to Great Wakering.
Local roads are commonly used by recreational cyclists albeit there are no formal cycle routes in the vicinity of the Site. There may also be an opportunity to improve recreational footpaths along the site boundaries to provide purpose-built routes to nearby local amenities.
5.21 As detailed above, the Site is also located in proximity to a number of bus routes in the vicinity of the
Site, serving routes across Essex including Southend and Stansted Airport. The nearest bus stops are located on Poynters Lane and Constable Way and there are up to 13 buses per hour available to residents at the Site which provide access to local train stations and major employment hubs.
Given its proximity to a number of local amenities combined with good connectivity to the public transport network, sustainable transport modes are considered feasible in this location.
Agricultural Land Assessment
5.22 An Agricultural Land Classification and Soil Resources Assessment has been prepared by Reading
Agricultural Consultants. This report set out the findings from an assessment of the Agricultural Land
Classification (ALC) and soil resources by means of a detailed survey of site and soil characteristics.
5.23 15.7 hectares (46%) of the site was identified as Grade 2 soil quality ‘Grade 2 is very good quality
agricultural land, with minor limitations which affect crop yield, cultivations or harvesting. The level of yield is generally high but may be lower or more variable than Grade 1’.
5.24 18.5 hectares (54%) was identified as Grade 3a ‘land has moderate limitations which affect the choice of crops, timing and type of cultivation, harvesting or the level of yield, it is subdivided into Subgrade 3a, which is land is capable of consistently producing moderate to high yields of a narrow range of arable crops or moderate yields of a wide range of crops’.
5.25 The majority of the district comprises Best and Most Versatile Agricultural Land. It is clear that there will be a loss of BMV as part of RDC meeting their local housing needs. On this site, there is no Grade 1 and the majority of the land is Grade 3a. The benefits of the proposed development outweigh any minor harm as a result of the loss in this respect.

Ecological Assessment
5.26 An Extended Phase 1 Habitat Survey was undertaken by Derek Finnie Associates in July 2021. The
Site was found to comprise a single arable field under a bean crop. On the northern, eastern and southern boundaries, outgrown, semi-mature hedgerows are present. There are no ecological constraints to developing the Site, with ample potential in any future landscape design to provide a net biodiversity benefit.
Minerals Assessment
5.27 A Minerals Assessment of the site was undertaken by Tetra Tech Environment Planning Transport Limited, this assessment concluded the majority of the site has previously been worked for minerals.
5.28 The report identifies that a small proportion of the site, approximately 5 hectares, are potentially still
suitable for mineral extraction, however it is not possible to state with any great level of certainty that mineral extraction could take place. Having found that the majority of the site has already been worked it is not considered that, in the case that any underlying economically viable minerals are proven, that this should be of any detriment to the site’s ability to be developed.
5.29 The site is of such a size that it would be possible to phase the development to incorporate the recovery of any minerals, sand or gravel in a timely manner. It is considered that the recovery of any sand and gravel could have sustainability benefits for the site. Depending on the quality of any resource that was proven, the sand and gravel could be used within the site’s construction.
Flood Risk Assessment
5.30 A Flood Risk and Drainage Note was prepared by Waterman to appraise the flood risk and drainage
opportunities and constraints at the Site. The key conclusions from this assessment are set out as, the EA Flood Map for Planning shows that the majority of the Site is located within Flood Zone 1, indicating a low risk of flooding from tidal and fluvial sources (less than 1 in 1,000 annual probability of river or sea flooding). Based on the proximity to the sea, it is understood that any flood risk to the Site would originate from tidal sources. The Map also indicates the majority of the Site is at ‘very low’
risk from flooding from surface water. There have been no recorded groundwater flooding incidents at or within the vicinity of the Site. The risk of flooding from artificial sources and sewers has also been assessed and is considered to be low.

THE ALLOCATION OF TITHE PARK FOR HOUSING & COMMUNITY
INFRASTRUCTURE
Spatial Strategy
6.1 RDC propose to take a positive approach to growth locally, helping to create a more inclusive housing
market, avoiding the emergence of housing-related issues including homelessness and concealed
households. A number of strategy options have been identified in the Local Plan Consultation that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
6.2 These representations support growth in the Great Wakering area and more generally to the east of
Rochford. In terms of spatial options, Option 2 seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns or villages. The development of the subject site would accord with Option 2b: Urban extensions dispersed to settlements based on hierarchy. Essentially our client’s preference is Option 4: Balanced
Combination, which proposes growth in terms of urban intensification, urban extensions and concentrated growth. It is considered that this is the only way that the Council will be able to meet their housing needs in the future through a range of growth options which deliver homes and infrastructure in tandem.
6.3 The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive contribution to housing delivery in the early years of the Local Plan.
6.4 The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary and SEND education facilities in this locality and also can also perform a role in the delivery of green and blue infrastructure.
Delivery of Homes & Community Infrastructure
6.5 The Consultation states that new development can also deliver community infrastructure stating that “It is therefore important that new growth is not simply seen as creating additional demand for community infrastructure but also as one of the most effective tools at creating additional supply”. The proposal at Tithe Park will deliver up to 525 homes, and also facilitate the provision of a
secondary school including scope for SEND and enhance connections between Southend and the
River Roach.
6.6 The Rochford Consultation is clear that while the Wakerings and Barling has a good range of core
facilities, these only serve local residents and ‘most town-scale facilities, such as a secondary school and large-scale job opportunities, are absent’. The Consultation further notes that ‘The population of the Wakerings and Barling skews slightly younger than the District average which may generate additional demand for housing and jobs in coming years’.
6.7 The proposed development comprising of new homes, provision of land for the delivery of a
secondary school and scope for SEND and open space is designed to be locally-responsive and aimed at meeting the ongoing needs of local residents. The nature of the development and the site location will ensure that the development of this site does not impact on the character of the existing settlements.
Design Principles
6.8 The proposal provides for landscape lead scheme which seeks to strengthen and enhance the
character of the area. The key design principles include :
• Residential development to be focused on the western and central parts of the Site, in close proximity to existing residential land uses.
• New pedestrian / cycle connections to connect into the adjacent residential areas and to Friars Park to integrate the proposals with the existing urban area at Shoebury;
• New planting and open space alongside the northern boundary with Poynters Lane to soften views of the new homes from the north and to provide a robust edge to the redefined Green Belt;
• Potential secondary school and SEND site and associated playing fields to be located to the east; and
• Existing rights of way to be retained and enhanced within green routeways.

CONCLUSION & RESPONSE TO QUESTIONS
7.1 In conclusion, and to summarise the main issues pertaining to these representations, a response to
the relevant questions relating to this site are set out below -
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]
7.2 Our client fully supports the delivery of the South Essex Estuary Park, however the current location
and extent of the park needs to be reconsidered. At present, the entirety of the subject site is indicated as a Regional Park. If this position were to be maintained the site will not deliver any new homes or education facilities. It also would not provide publicly accessible open space as the site would remain in private ownership. Therefore, it is considered that to facilitate the delivery of the
parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach, this site should be allocated for housing and community infrastructure. Our client welcomes the opportunity to engage with the Council and their consultant team to ensure the design of the proposals maximises the potential of the Park and ensures it is deliverable.
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
7.3 As detailed in these representations, it is considered that the subject site should be allocated for
housing and community infrastructure comprising a secondary school. In addition the development
of this site will enhancement green and blue infrastructure including an extension to Friars Park.
7.4 The Consultation details a vision for the Wakerings and Barling which highlights that more services
need to be developed to reduce its reliance on neighbouring towns and ensure villages should have
become more self-sufficient when it comes to homes, jobs and community facilities, including education.
7.5 The Educational Needs Assessment clearly demonstrates that there is a serious shortfall in
Secondary School and SEND provision in the vicinity of Great Wakering and the local area.
Furthermore, the limited provision that does exist in the area is poor performing. This proposal will enable the delivery of a new school which will meet existing and future needs of the locality. This would be of major benefit to the local community. The allocation of this site will also facilitate the delivery of the parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach.
Conclusion
7.6 Our client fully supports the Council in the preparation of a new Local Plan for Rochford in order to meet local needs and address current deficiencies in the District. The allocation of this site in a highly sustainable location, on land which has a limited contribution in landscape and Green Belt terms will assist the Council in meeting their strategic priorities. This site has the potential to deliver up to 525 homes, facilitate the provision of a Secondary School including scope for SEND provision and
contribute towards the delivery of blue and green infrastructure.
7.7 We welcome the opportunity to discuss the emerging Local Plan preparation and the Council’s proposals for this site in further detail.

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

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


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


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


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


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

Q5. Do you agree with the settlement hierarchy presented?


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


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

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

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

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

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

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


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

Spatial Themes

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


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


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


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


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


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


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


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


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

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


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

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

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


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

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

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


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

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

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

Housing for All

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


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

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

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

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


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

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


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

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


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

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

Employment and Jobs

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


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

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

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

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


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

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

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


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

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

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

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


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

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


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

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

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


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

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

Biodiversity

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


YES

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

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

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


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

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

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

Green and Blue Infrastructure

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


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

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


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


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

Community Infrastructure

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


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

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

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


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

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

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

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


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

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

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

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


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

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


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

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


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

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


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

Heritage

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


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

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


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


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

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


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

Town Centres and Retail

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


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

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

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


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

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

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

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


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

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


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

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

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


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

Transport and Connectivity

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


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

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


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

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

Green Belt and Rural Issues

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


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

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

Planning for Complete Communities

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


N/A


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


N/A


Q56d. Are there areas that require protecting from development?


N/A


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


N/A

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



N/A

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


N/A


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


N/A


Q57d. Are there areas that require protecting from development?


N/A



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

N/A

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

N/A

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

N/A

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


N/A

Q58d. Are there areas that require protecting from development?


N/A



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


N/A


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

N/A

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


N/A




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


N/A





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


N/A


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


N/A


Q60a. Do you agree with our vision for Hullbridge?


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

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

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


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

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


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

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


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

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


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

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


N/A


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


N/A


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


N/A


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

N/A

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

N/A



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


N/A


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


N/A


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

N/A



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

N/A



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


N/A





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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A

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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A






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


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

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


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

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


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

Create a Country Park to the west of Hullbridge.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Current East of England Ambulance Stations close to Rochford

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

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

Assessment of Rochford Local Plan 2050 Spatial Strategy Options

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

STRATEGY OPTION 1: Urban Intensification

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

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

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

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

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

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

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

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

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

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

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

Potential requirement for financial contributions from developers.

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

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

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

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

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

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

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

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

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

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

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

Option 3b: Focused north of Southend

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

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

Option 4: Balanced Combination
No sub-options

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

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

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

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

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

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

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

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

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

1. INTRODUCTION
1.1 These representations have been prepared by Pegasus Group on behalf of Penland Estates Limited in respect of their land interests in Rochford District Council (RDC).
1.2 These representations are submitted in response to the current Rochford Local Plan Regulation 18 ‘Spatial Options' consultation, which sets out the different growth
strategy options that could be pursued by the Council in the emerging Local Plan. The evidence base accompanying the Spatial Options document includes a Site Appraisal Paper which identifies the suitability of potential sites for allocation, including Penland Estate Limited's interests at:
• Site Reference CFS190: Land South of Pooles Lane, Hullbridge
1.3 The purpose of these representations is primarily to respond to the questions raised by the consultation to ensure there is a sound basis for emerging policies, as well as to support the most sustainable growth options of those set out in the consultation. These representations also confirm the deliverability of the above site and the exceptional circumstances in support of a minor revision to the Green Belt alongside the provision of a site-specific policy that allocates Land South of Pooles Lane, Hullbridge, for residential development in the emerging Local Plan. The representations are supported by high-level technical assessments and an indicative Framework Plan.
1.4 These representations should be read in conjunction with the enclosed high-level technical assessments and an Illustrative Framework Plan, which explain further
the opportunities available to create a high-quality and sustainable residential development with the ability to contribute positively towards the District’s significant housing needs.

2. SPATIAL OPTIONS DOCUMENT
2.1 This section responds to questions posed by the Spatial Options consultation that are relevant to Penland Estate Limited's interests in Rochford.
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?
2.2 The technical evidence that has been prepared and is yet to be prepared by the Council is supported as being required to inform the production of a sound Local
Plan in accordance with the provisions of the National Planning Policy Framework (NPPF 2021).
Q2. Do you agree with our draft vision for Rochford District?
2.3 Penland Estates Limited considers that the Draft Vision for Rochford District Council provides a sound basis for preparing a spatial strategy. Land to South of Pooles Lane, Hullbridge, will deliver upon the draft vision of Rochford District by providing a high-quality, well-designed development in a sustainable location with good
access to services and facilities which will foster vibrant and healthy communities.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
2.4 Penland Estates Limited broadly agree with the importance of adopting a range of separate visions for each of the District's settlements to help apply the district-wide vision and objectives at more localised settings. Nevertheless, there is likely to be considerable cross-over between the specific visions for individual settlement, and
as such, the benefits of this approach might not be fully realised.
2.5 Furthermore, this is likely to be quite a time-consuming exercise for the Council's Planning Policy Team to create separate visions for each of the District's
settlements. The Draft Local Development Scheme (2021-23) anticipates that the Local Plan could be submitted to the Secretary of State for independent
examination by Spring 2023, thus providing a short timescale to prepare and submit the emerging Local Plan. Therefore, it is considered that the resource of the
Planning Policy team is likely to be better deployed in other more pressing aspects of the emerging Local Plan process.
Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?
2.6 The Spatial Options document identifies five ‘Strategic Priorities.' Strategic Priorities one (meeting the need for homes and jobs in the area) and five (making suitable and sufficient provision for climate change mitigation and adaptation, conservation, and enhancement of the natural and historic environment, including landscape) are of particular interest to our client's site.
2.7 Our client is promoting Land South of Pooles Lane, Hullbridge, for the allocation of residential development through the emerging Rochford District Council Local Plan (RDCLP). It is estimated that the site is capable of delivering up to 226 new homes towards meeting the housing need target for the RDCLP. In addition to delivering much-needed market and affordable housing, the site will deliver upon the draft strategic priorities of the RDCLP as follows:
2.8 Meeting the need for homes (Strategic Priority 1 and 2) – Penland Estates Limited prides itself on working with developers that deliver well-designed, highquality, and sustainable homes for all to enjoy. Any scheme delivered on the site would provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include affordable housing provision which would be tenure blind in terms of design and well-integrated into the scheme to enhance social cohesion and generate community spirit. It is agreed that the
delivery of new homes sufficient to meet local housing need should be assigned great importance.
2.9 Climate change (Strategic Priority 5) – Any scheme would provide modern high-quality living with housing that meets the latest Building Regulation requirements in respect of energy and water consumption. In addition, the site is located in a highly sustainable settlement, within walking distance of a range of shops, services and pre and primary schools. The site’s location and proximity to
the local service provision in Hullbridge would assist in reducing travel by car and thus assist in reducing carbon emissions.
2.10 Natural environment (Strategic Priority 5) – Any scheme brought forward would aim to achieve a net gain in biodiversity through the retention, protection and enhancement of any on-site habitats, provision of extensive new public open space and high-quality landscaped areas. Existing vegetation at the site would be retained and enhanced through new planting to enhance the potential for habitat creation. In addition, drainage attenuation basins, required as part of the surface water drainage strategy, offer further potential to boost on-site biodiversity.
2.11 Furthermore, whilst the site is currently located in the Green Belt, the evidence provided in our representations and accompanying Green Belt Appraisal demonstrate that the site performs poorly against the five purposes of Green Belt as set out in the NPPF and is capable of coming forward for development without unduly damaging the integrity of the Green Belt. The evidence gathered by the Council clearly illustrates that the District's housing need cannot be sufficiently met
through urban and previously developed land only. Some release of Green Belt land in appropriate locations should be recognised as being necessary where 70% of the
District is designated as Green Belt. The release of Green Belt sites such as Land South of Pooles Lane, Hullbridge, will allow the continued sustainable growth of existing settlements, and would be consistent with the NPPF.
2.12 Historic environment (Strategic Priority 5) – The evidence provided in our representations, the accompanying Heritage Appraisal (see attached at Appendix A) and the Council's Initial Heritage Assessment of Submitted Sites (October 2020)
demonstrates that the site does not adversely impact any nearby heritage assets either directly or indirectly.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
2.13 The Options Spatial Paper includes a draft settlement hierarchy based on the 2021'Settlement Role and Hierarchy Study,' which uses various factors (including population size, availability and range of services and transport accessibility) to assess the relative sustainability of the District's multiple settlements.
2.14 The Adopted Core Strategy (2011) categorises Hullbridge (and Great Wakering) as a second-tier (out of four) settlement, where there is considered to be a more
limited range of services and access to public transport is judged to be relatively poor. The Spatial Options paper shifts Hullbridge into tier three (out of four) of its
draft settlement hierarchy. This appears to be due to the sub-division of Tier 1 of the Adopted Core Strategy into Tier 1 and 2 of the draft settlement hierarchy, with
Rayleigh remaining in Tier 1 and Rochford (including Ashingdon) and Hockley (including Hawkwell) shifting down into Tier 2 2.15 In addition to Hullbridge, the new proposed Tier 3 includes Great Wakering and
Canewdon. Penland Estates Limited, as outlined below, considers that Hullbridge is better related to the Tier 2 settlement of Hockley in terms of access to services,
population, geographical size, and transport accessibility, compared to the Tier 3 village Canewdon:
2.16 Population – according to the Parish Council website, Hullbridge's population is approximately 7,300, which is markedly greater than that of Canewdon (Tier 3) at circa 1,100. The other Tier 3 settlement of Great Wakering (including Little Wakering and Barling) has a similar population to Hullbridge at circa 7,200.
However, it is recognised that Hullbridge has a growing population, particularly through strategic allocations, such as the 500 unit Lower Road development in southwest Hullbridge (adopted Policy SER6 – South West Hullbridge). It is also anticipated that Hullbridge's population will continue to grow through strategic
allocations in the emerging Local Plan, given the sustainability of the settlement and its ability to support continued growth. This means that the population of
Hullbridge is anticipated to move closer to the suggested Tier 2 population threshold of 10,000.
2.17 Access to public transport – Hullbridge is serviced by the frequent no. 20 bus route operated by Frist Group (every 30 minutes between 7.00 to 21.00 Monday
to Saturday) to Southend via Rayleigh, where wider connectivity into London via the Greater Anglia train service is available. Great Wakering is similarly wellconnected as Hullbridge to public transport links; however, Canewdon is only serviced every two hours by the 60 bus route to Southend via Rochford. It is
recognised that neither Hullbridge nor Great Wakering includes rail links, as available in the Tier 2 settlements. Nevertheless, the frequent bus journeys to these rail station destinations from Hullbridge (and Great Wakering) provide accessible sustainable transport options for residents of these settlements.
2.18 Range of services and facilities – the village of Hullbridge has a good range of services and community facilities capable of meeting the everyday needs of
residents. These include three convenience stores, a dentist, GP surgery, library, pharmacy, a pre-school and primary school and public houses, fast food outlets
and restaurants. In comparison, Canewdon does not possess any such range of services facilities, with only a primary school, a convenience store, and a public
house. Great Wakering has a few more facilities, including a primary school, medical centre, and pharmacy and two public houses, albeit not to the extent found
in Hullbridge.
2.19 It is recognised that Hullbridge does not include a secondary school. Nevertheless, the no. 20 bus route provides a regular service (every 30 minutes) to the
settlements of Rayleigh and Hockley, which contain secondary schools as well as higher order retail services.
2.20 Access to jobs – several small-scale businesses are positioned around Hullbridge and at the various facilities and services mentioned above, which could
accommodate some local employment opportunities. It is considered that such employment opportunities would not be available at the Tier 3 settlement of Canewdon.
2.21 On the above basis, it is considered that the range of existing services and facilities available in Hullbridge mean that the village is better related to Tier 2 of the
settlement hierarchy than Tier 3. It is important that the Council has due consideration of the sustainability of Hullbridge when determining what level of growth is appropriate. The designation of Hullbridge as a Tier 3 settlement should not in itself be taken as a reason for allocating a certain level of growth. This is especially important as the Spatial Options document recognises that Hullbridge (and Great Wakering) are larger settlements than Canewdon; the scale of new
growth that would be appropriate for the settlements would therefore differ.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
2.22 Penland Estates Limited strongly agree with the identification of a housing requirement of 7,200 homes based on the standard method, which is in accordance
with paragraph 61 of the NPPF. The acknowledgement that this housing requirement forms the minimum housing needs for the District is also strongly agreed with; the Council must explore all opportunities available to accommodate additional growth above the minimum requirement and take on unmet need from neighbouring authorities that are constrained in the level of housing growth they are able to deliver.
2.23 The Spatial Options Document recognises that there is potential for Rochford District to accommodate unmet need from neighbouring authorities. The District's
neighbours are burdened with constraints to identifying sufficient land for housing, such as significant areas of Green Belt land which envelops existing urban areas
and areas of high flood risk. The authorities located within the same housing market area as Rochford have also struggled with maintaining sufficient levels of housing
delivery, further highlighting the importance of this matter. We therefore consider it to be highly likely that there will be unmet need arising from neighbouring authorities. In particular, early evidence issued for the Southend-on-Sea Local Plan preparation has indicated that Southend will require some of their housing requirement to be delivered in Rochford District (Issues and Options consultation,
April 2019). It is therefore vitally important that Rochford District pursues a growth strategy that includes a buffer in excess of the minimum housing required to meet local needs.
2.24 On the basis of the above, Growth Option 1 should be discounted as the strategy would not secure the level of housing required to meet the identified minimum
housing requirement. A sound Local Plan could not therefore be produced following this strategy.
2.25 Of the remaining options which would deliver sufficient housing growth, Penland Estates Limited is strongly supportive of Option 2 (Urban Extensions), particularly Option 2b 'Urban extensions dispersed to settlements based on hierarchy.'
2.26 Firstly, it is recognised that Rochford District Council have had a historic record of housing under-delivery, which in 2020 resulted in the Council having to publish a
Housing Delivery Test Action Plan as their 2019 Housing Delivery Test (HDT) was calculated at 77%. The 2020 Action Plan noted that the delayed delivery of several
strategic sites was a key factor. In particular, this was due to prolonged landowner and developer negotiations, delays at the planning application stage, and the time
taken to discharge pre-commencement conditions. The growth strategy for the Local Plan should therefore limit any over-reliance on large-scale strategic urban
extensions for delivering the required amount of housing.
2.27 Consequently, our client considers that the Council should identify available and deliverable small and medium-sized sites (10 and 1,500 homes) dispersed to
settlements based on hierarchy. This approach would be consistent with Paragraph 69 of the NPPF (2021), which states that "small and medium sized sites can make
an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly." The delivery of sites at this scale also helps to
ensure sustainable growth can take place across the District in a dispersed manner that allows all settlements to grow organically. 2.28 The NPPF allows for revisions to be made to the Green Belt boundary through the
Local Plan process where there are exceptional circumstances. As explained earlier, release of Green Belt land is required if the Local Plan is to deliver sufficient housing to meet the local housing needs for the District. This forms the exceptional circumstances required for the release of land from the Green Belt in appropriate locations. The delivery of small and medium-scale sites released from the Green Belt, such as Land South of Pooles Lane, will also play an important role in the Council meeting their five-year housing land supply as required by paragraph 68 of the NPPF.
2.29 Land South of Pooles Lane, Hullbridge, is available and deliverable within the Local
Plan period and should be considered further by the Council. Secondly, Option 2b will support existing services by directing further growth to villages like Hullbridge to support the vitality of local services. This approach is consistent with NPPF 79 of the NPPF (2021), which outlines that "planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services."
Consequently, sites in sustainable locations with good access to a range of services and facilities (generally Tier 2 and 3 settlements) should be selected to ensure the
sustainable and effective growth of settlements across the District.
2.30 The Council's Settlement Role and Hierarchy Study assesses the relative sustainability of individual settlements by considering its 'completeness'. The
theory is that the more services a place has, and the easier to access those services are, the more complete that place is. The 'completeness' assessment is shown in
the form of a heatmap, and for Hullbridge, this is shown on Page 82 of the Spatial Options Paper. Land to the South of Pooles Lane adjoins the north-eastern
settlement boundary of Hullbridge, which benefits from a 'walking completeness score' of between 11 and 13, which is the highest score in Hullbridge and is in the
second-highest category overall.
2.31 This is because the north-eastern section of Hullbridge includes Hullbridge preschool and Riverside Primary School, Hullbridge Community Centre, and a bus stop providing a frequent bus service to Southend and Rayleigh (one bus every 30 minutes). These services and facilities are less than a five-minute walk from Land
to the South of Pooles Lane. Additional services and facilities, including convenience stores, a dentist, GP surgery, library, pharmacy, and other fast food outlets and
restaurants, are within a 10-minute walk from the site. By affording sustainable levels of growth to sites such as these, it will assist in safeguarding existing services, public transport links and infrastructure which local people currently rely upon and support vibrant rural communities.
2.32 For the reasons set out above, Penland Estates Limited strongly supports the pursuance of Growth Option 2b, with concentrated growth dispersed to settlements based on hierarchy. This includes allocating growth in high performing and sustainable Tier 3 settlements, such as Hullbridge.
Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
2.33 Penland Estates Limited supports the Council's ambition of ensuring future growth takes place in a manner that is aligned with the national objective of transitioning towards a zero-carbon economy. Penland Estates Limited intends to work with developers that will create high-quality, energy-efficient buildings, which could
incorporate energy generation and conservation technologies, in line with the Council's strategy to reduce carbon emissions.
2.34 Notwithstanding this, there needs to be a balancing act in order to meet this target against the need to deliver a viable scheme. It is clear that further consideration is
required regarding the expected capital uplifts in the emerging Local Plan to ensure that energy efficiency is considered alongside viability. In doing so, the guidance
should consider the Government's figures in their Draft Future Homes Standard which will be in place by the time homes allocated by the new Local Plan are likely to be built. Any policy brought forward on this matter should therefore be supported by appropriate evidence that has investigated potential impacts on viability. The policy itself should include wording to reflect the importance of considering the overall viability of a scheme when determining the application of energy efficiency
initiatives over and above that required by Building Regulations
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?
2.35 The Council should be consistent with the Government's Draft Future Homes Standard that proposes to remove the ability of local planning authorities to set higher energy efficiency standards than those in the Building Regulations. This is because the Government considers the situation confusing, particularly as the application of energy efficiency standards across local authority boundary lines often means that homes need to be built to different technical specifications. This inconsistency creates inefficiencies in supply chains, labour and potentially the quality of outcomes.
2.36 Nevertheless, Future Homes Standard outlines that changes to the Building Regulations are expected to mean that between 75- 80% fewer carbon emissions
are released into the atmosphere from new development compared to ones built to the 2013 Part L requirement. Requiring new developments to achieve energy
standards higher than the proposed changes to the Building Regulations would need robust evidence identifying the need for such a requirement.
13. How do you feel the plan can help to support the local generation of lowcarbon and renewable energy? Are there locations where you feel energy generation should be supported?
2.37 The Council should promote the idea of the Local Plan supporting renewable energy developments by designating appropriate locations within the District for lowcarbon and renewable energy generation projects. The Council could consider a
'call for sites' process for potential low carbon and renewable sites submitted by landowners, site promoters or developers. The Council could then assess the suitability of submitted sites using relevant criteria.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
2.38 Penland Estates Limited broadly supports the principles contained in the draft place-making charter, which sets out a number of key principles for how new
development is expected to be delivered in a way that contributes positively to their setting and wider environment. In taking this charter forward however, it should be made clear what weight will apply to the principles contained in the charter at the development management stage, as well as how the charter will interface with development management policies.
2.39 Penland Estates Limited prides itself on working with developers that deliver welldesigned, high-quality and liveable schemes for all to enjoy. Place-making and
creating a sense of identity is at the heart of the scheme design shown on the enclosed Development Framework Plan (see attached at Appendix B), with a
consideration of the opportunities and constraints of the site (see plan attached at Appendix C). New dwellings would be modern but sensitively designed to complement the character of the local area, and public open space would be delivered to a high standard to stimulate on-site recreation and interaction between residents. The development would be a positive and environmentally friendly place to live, work and play.
Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
2.40 The production of new design guides, codes or masterplans alongside the new Local Plan could provide applicants with clarity about design expectations at an early stage. However, there are two important considerations to take into account.
Firstly, site-specific design guidance is likely to be useful only in cases where the development proposed is at a strategic scale or there are unique constraints which
design guidance would help to overcome. For the majority of small and mediumscale development, development management policies relevant to urban design and placemaking are sufficient in securing a high-quality design.
2.41 Additionally, the production of design guidance requires time and staffing resources. The Council should consider the level of detail required in a design code
and the possible impacts of delays due to detailed discussions and negotiations between applicants regarding a scheme's compliance with a design code. Given the Council's historic under-delivery of strategic housing sites, which has in part been attributed to delays at the planning application stage, it is considered that with the preparation of design guides and masterplans is likely to slow housing delivery rates further if required for all sites.
2.42 The suggestion that design guidance is produced alongside the Local Plan preparation would also potentially delay the Local Plan process; which would mean further delaying the delivery of much-needed homes, given the delays experienced in the Local Plan process thus far. It would also require developers to invest in upfront work with no certainty that their particular site would be allocated in due course.
2.43 As such, Penland Estates Limited considers the preparation of design codes, guides or masterplans should be limited to large-scale strategic sites or sites with particularly complex delivery strategies only. All other developments can be brought forward appropriately without specific design guidance, as development
management policies related to design will ensure the correct design principles are followed.
4 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?
2.45 Penland Estates Limited recognises the importance of providing a mix of homes to meet the identified local housing needs. Option 2 is supported as providing a logical and flexible approach to ensuring that each new development provides a mix of housing that is appropriate to its location, taking into account all relevant sitespecific factors. This would ensure schemes can provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include an element of affordable housing provision which would be tenure blind in terms of design and be well integrated into the scheme to enhance social cohesion and generate community spirit.
Q31. Do you consider net gains for biodiversity are best delivered on-site or offsite? Are there specific locations or projects where net gain projects could be delivered?
2.46 National guidance outlines that biodiversity net gain can be achieved on-site, offsite or through a combination of on-site and off-site measures. Schemes should come forward with the aim of achieving a net gain in biodiversity through the retention, protection and enhancement of any on-site habitats, provision of extensive new public open space and high-quality landscaped areas wherever
possible. However, the option of achieving net gain through off-site contributions or habitat creation should not be discounted, as there may be site constraints such
as viability which limit a site's ability to provide net gain on-site.
2.47 Existing vegetation at Land South of Pooles Lane site would be retained and enhanced through woodland belt planting to enhance the potential for habitat creation, as shown on the illustrative Development Framework Plan (Appendix B). In addition, surface water detention basins, required as part of the surface water drainage strategy, offer further potential to boost on-site biodiversity. All opportunities will therefore be taken to enhance the biodiversity of the 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?
2.48 National policy outlines that strategic plans should take a strategic approach to green and blue infrastructure to help promote active and healthy lifestyles, combat climate change and alleviate air quality issues. Well-designed green infrastructure can provide a sustainable alternative to car use through a connected network of
public rights of way and greenways. Proposed option 3 is supported, as the delivery of new and enhanced green infrastructure on new development sites will assist in
creating an improved network of green infrastructure throughout the District.
2.49 In reference to Option 2b ('Urban extensions dispersed to settlements based on hierarchy'), the Council should select sites that are in close proximity to the existing and proposed green and blue infrastructure networks to ensure that future residents have a sustainable alternative to car use. Land to the South of Pooles Lane is located within the Option 2b strategic area, and there is an existing 'secondary greenway' (ref PROW 287_6) approximately 300m to the east of the
site, running in a north-south direction as indicated on Figure 32 of the Spatial Options Document. To the north, this greenway connects to a network of existing and proposed coast paths along the River Crouch, which is less than a 5-minute walk from the site. To the south, this 'secondary greenway' connects to a network of primary greenways circulating Hockley.
2.50 The Land South of Pooles Lane, Hullbridge, promoted by our client Penland Estates Limited, is well placed to encourage a shift away from the private car. As shown by the submitted Framework Plan, any development at the Pooles Lane site will integrate into the existing highway network by providing vehicular, pedestrian and cycle access points. The Council's Site Appraisal (2021) recognises the accessibility of the site to existing walking and cycling infrastructure, as Land South of Pooles Lane (ref CFS03) is scored at level 5 (highest category), as the site is within 400m of an existing cycle or footway.
2.51 In contrast however, the Site Appraisal (2021) scores the site at level 2 for accessibility to public rights of way (the second-lowest category), as there are
adjudged to be no PROWs with 400m. However, a PRoW (ref 287_12) does indeed run along part of the site's eastern boundary, as indicated on the submitted Framework Plan and connects to the 'secondary greenway' (ref PROW 287_6), further to the south. Future residents of the site will significantly benefit from the existing and proposed green and blue infrastructure, which is directly connectable from the site. This inaccuracy within the Council's site assessment should be rectified to correctly reflect the sites accessibility in all ways, including to the PRoW network.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?
2.52 There is the potential for new development to contribute towards the upgrade and maintenance of existing facilities. Penland Estates Limited would welcome the opportunity to engage with the Council and local stakeholders in Hullbridge to understand local community needs.
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?
2.53 In reference to Strategy Option 2b ('Urban extensions dispersed to settlements based on hierarchy'), the Council should support sites that can help improve open space or sports facility accessibility or provision. This would be in line with proposed option 4 for meeting open space needs through the Local Plan, which proposes requiring new developments to provide on-site open space or contribute towards improving existing recreational facilities.
2.54 Land South of Pooles Lane is located in the Option 2b settlement of Hullbridge. As identified in the 2009 Rochford District Council Open Space Study, Hullbridge has deficits against the local minimum standards of natural and semi-natural greenspaces (-2.05ha), amenity green space (-0.11ha) and children's play space (-0.01ha). Incidentally, Hullbridge has the second-highest deficit in the District for the provision of natural and semi-natural greenspaces. The provision of sports facilities is 0.53ha above the local minimum standards. It is recognised that the Open Space Study informing the evidence base is slightly dated. Nevertheless, it is
expected that the settlement's deficits (or low provision levels) of semi-natural greenspace and amenity green space, and children's play space are likely to still
exist in the village.
2.55 Taking this information into account, Land South of Pooles Lane has the potential to provide around 3ha of open space throughout the site, serving a range of
different purposes. Open space will be landscaped with a variety of natural and semi-natural areas, such as new woodland belt planting and mixed grassland areas
to promote biodiversity. Circular walking routes are provided, integrated into the wider network of public rights of way in the area. A centrally located locally equipped area for play (LEAPS) can also be provided. The open space would be delivered to a high standard to stimulate on-site recreation and interaction between residents. The development would be a positive and environmentally friendly place to live, work and play.
2.56 Land South of Pooles Lane achieves the highest score for access to public open space in the Council's Site Appraisal (2021) paper, given that Hullbridge Playing
Field is located directly opposite the site. Hullbridge Playing Field contains various existing sports facilities, including a BMX track, skate park, basketball court, sports pitch, as well as play equipment. Furthermore, Hullbridge Yacht Club, located on the River Crouch, is less than a five-minute walk, providing future residents with a wider range of sports and leisure facilities. The Council should consider allocating sites, such as Land South of Pooles Lane, in the emerging Local Plan that are well placed to provide accessible open space and sports facilities, either on-site or within
close walking distances.
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?
2.57 Paragraph 104 of the National Planning Policy Framework (NPPF) identifies that transport issues should be considered from the earliest stages of plan-making,
which includes opportunities to promote walking, cycling and public transport. The importance of encouraging a shift towards more sustainable modes of transport is
recognised as this will assist in reducing climate change and congestion levels on roads.
2.58 The four options set out in the Spatial Option document are considered to be logical approaches to take in addressing transport and connectivity issues. The Rochford Local Plan should also promote sustainable forms of transport by allocating housing sites in sustainable locations in established settlements which possesses good quality public transport links, including; bus services, footways and cycleways. The preparation of an Infrastructure Delivery Plan or Cycling Delivery Plan would provide clear evidence of the infrastructure improvements that may be required to further support and achieve sustainable development.
2.59 The Land South of Pooles Lane, Hullbridge, is exceptionally well placed to encourage the shift away from the private car. As shown by the submitted
Framework Plan (Appendix B), any development at the Land South of Pooles Lane site will integrate into the existing highway and pedestrian infrastructure by
providing vehicular, pedestrian and cycle access points in appropriate locations. 2.60 By utilising the proposed access points, residents of the scheme will have
convenient and sustainable access (via walking or cycling) to education, a range of shops, and services capable of serving their day-to-day needs. The public transport links available to residents of a scheme at Land South of Pooles Lane are summarised in the schedule below. Access to these services could be further
improved through new development resulting in an increased level of users.
Public Transport Links
Bus stops outside Riverside School, Ferry Road:
No 20 bus service from Hullbridge to Southendon-Sea via Rayleigh:
Monday to Saturday- every 30 minutes
between 7.00 to 21.00, and hourly between
22.15 and 23.15
Sundays- every 30 minutes between 9.00 to
21.30
(0.3km – to bus stop, 3-10 minute walk)
Hockley train station,
Station Approach Hockley SS5 4BG
(6.2 km, 19 minute cycle, 10 minute car)
Rayleigh train station, 1 Castle Dr, Rayleigh, SS6 7HT
5.1 km
(18 minute cycle, 9 minute car,15 minute bus)
Q60a. Do you agree with our vision for Hullbridge?
2.61 Penland Estates Limited broadly support the draft vision of Hullbridge becoming self-sufficient and accessible by sustainable means and to make the most of its location by opening up its coastline as a more attractive and usable space for both residents and visitors. Any development should respond to meeting the housing needs of local residents, and it should be acknowledged that the aims of meeting housing needs and Hullbridge becoming self-sufficient are interlinked. The growth of service provision would be supported by new housing and new customers, which would encourage new businesses as well as support the vitality of existing
businesses.
2.62 The vision currently references the need to provide suitable housing for the elderly, which our client supports. However, the vision should be expanded to incorporate
the needs of young families and parishioners seeking local and affordable housing to ensure a diverse and sustainable settlement can be maintained.
2.63 Land South of Pooles Lane would seek to provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include
a provision of affordable housing which would be tenure blind in terms of design and be well integrated into the scheme to enhance social cohesion and generate
community spirit.
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?
Housing [market, affordable, specialist, traveller, other]
Commercial [offices, industrial, retail, other]
Community infrastructure [open space, education, healthcare, allotments, other]
Other
2.64 As mentioned in answer to question 6 above, Penland Estates Limited supports Growth Strategy Option 2b. This strategy would provide new development in
sustainable locations across the settlement hierarchy, of a scale that is suitable to the services provision in the relevant settlement. Land South of Pooles Lane (ref
CFS190), promoted by Penland Estates Limited to provide a medium-sized housing scheme, is exceptionally well placed in this regard. It would adjoin the north-western boundary of Hullbridge and lead to the natural extension of this sustainable settlement. The site is incredibly well related to existing services as illustrated on
the walking completeness score replicated below. Development of the site offers the potential to increase permeability within this part of the village, improving
access for existing residents located north of Pooles Lane. 2.65 This accessibility has been reflected in the Council's Site Appraisal Paper (2021), which aims to provide an indication of the relative sustainability and suitability of potential housing sites. For example, the site scores in the highest accessibility (category five) for access to a primary school (less than 400m), a bus (more than 10 bus services provided per hour within 400m), and walking and cycling infrastructure (less than 400m from existing footway and cycle paths). This assessment is strongly supported as reflecting the location of the site in relation to services and facilities, as illustrated in the summary table below.
[see document for table]
2.66 However, the site scores poorly in the following categories: green belt impact (level two), agricultural land classification (level one), access to a train station (level one), access to a secondary school (level one), town centre (level one) and employment site (level one). Additional information is outlined below to provide a more robust assessment of the site's credentials against its poorly performing categories from the Site Appraisal Paper and demonstrate the deliverability of the site.
Green Belt
2.67 Given the extent of the Green Belt across the District and drawn tightly around sustainable settlements such as Hullbridge, it is vital that specific parcels of Green
Belt land adjacent to settlement boundaries are subject to a detailed Green Belt review process. Notwithstanding its Green Belt designation, this land will often provide a sustainable location for growth by virtue of its proximity to the local service provision and public transport links. We consider that this is the case of Hullbridge, where our client is promoting Land South of Pooles Lane, Hullbridge.
Indeed, this is recognised in the Rochford District and Southend-on-Sea Borough Joint Green Belt Study (February 2020) undertaken by the Council, which at paragraph 3.9 states that the most sustainable sites for allocation may be located in areas that make a strong contribution to Green Belt purposes.
2.68 As explained earlier in these representations, the exceptional circumstances required to justify the release of land from the Green Belt are considered to exist
by virtue of the evidence base demonstrating there is insufficient non-Green Belt land available to accommodate the growth required during the Local Plan period. Paragraph 130 of the NPPF readily acknowledges that the plan making process can incorporate the review of existing Green Belt boundaries in exceptional
circumstances. Penland Estates Limited believe that exceptional circumstances exist to warrant such a review and consider that a modification is required in order
to deliver economic and housing growth which is recognised by the Government to be of national and potentially international importance.
2.69 Central to this review should be an assessment of specific parcels of land with development potential against the five purposes of Green Belt as set out in the
NPPF. Sustainable sites for housing growth which are found to not contribute to the five purposes of the Green Belt should be released and subsequently allocated for
development. It is strongly contested that this is the case for the Land South of Pooles Lane. The evidenced and justified release of this land from the Green Belt will allow development to come forward which will meet the objectives of achieving sustainable development as set out in paragraph 8 of the NPPF and assist in
delivering growth of regional and national importance.
2.70 In respect of Land South of Pooles Lane, an independent Green Belt Assessment of the site has been commissioned. The Assessment, produced by Pegasus Group, is appended to these representations (Appendix D). The Green Belt Assessment draws on the recently published Green Belt Study (February 2020) but applies a
finer-grain assessment in order to provide a comprehensive and robust, yet concise
assessment. The conclusions in respect of Land South of Pooles Lane contribution to the Green Belt purposes, is outlined below:
• Purpose 1: To check the unrestricted sprawl of large built-up areas. Site Contribution is assessed as Low/weak.
• Purpose 2: To prevent neighbouring towns merging into one another. Site Contribution is assessed as Low/Weak.
• Purpose 3: To assist in safeguarding the countryside from encroachment. Site Contribution is assessed as Moderate.
• Purpose 4: To preserve the setting and special character of historic towns. Site Contribution is assessed as Low/Weak.
• Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Site Contribution is assessed as n/a.
2.71 The detail underpinning the above listed conclusions is evidenced in the Pegasus Group report. In light of the specific assessment against each Green Belt purpose,
the Green Belt Appraisal provides an overarching conclusion which confirms that Land South of Pooles Lane provides a low contribution to the NPPF Green Belt
purposes. In respect of bringing forward development at the site, the Appraisal concludes that:
2.72 “the Council agree that there are exceptional circumstances to justify the release of land from the Green Belt to accommodate development needs, then the Green Belt land immediately around Hullbridge – the site, would be suitable for such release.”
2.73 It is strongly recommended that the Council review the Green Belt Assessment alongside the other submitted evidence from their Site Appraisal Paper and Green
Belt Review study. The results of the Green Belt Assessment have strongly influenced the formulation
of the Framework Plan, in particular with regard to the incorporation of landscape mitigation measures. These take the form of a substantial landscape buffer along
the length of the eastern boundary, which will comprise new woodland planting and will integrate with and enhance existing vegetation. The landscaping strategy for
the site will aid in creating a strong defensible Green Belt boundary, as well as create a scheme that responds sensitively to the countryside character, with a soft
transition from built development to rural countryside.
Agricultural Land Classification
2.74 The Site Appraisal Paper (2021) scores Land South of Pooles Lane (ref CFS190) level one (the lowest category), as the majority of the site is adjudged to contain Grade 1-3 agricultural land (best most versatile or BMV). The other sites in Hullbridge also mostly score level 1, with a few scoring level 2 (i.e. any part of the site contains Grade 1-3 agricultural land). The assessment is based on Natural England Agricultural Land Classification mapping. However, the Natural England maps' scale is intended for strategic use and is not sufficiently accurate for the assessment of individual fields. Given that the site is currently used for arable grazing, it is unlikely that the land will be classified as BMV agricultural land.
Nevertheless, it is clear that the loss of some agricultural land will be necessary if Hullbridge is to continue growing in a sustainable manner. The sites available for
development in this area are of a similar agricultural value, and it is considered the benefits of sustainable development would be sufficient to outweigh the loss of
agricultural land.
Drainage
2.75 The site is located within Flood Zone 1 (lowest risk) as defined by the Environment Agency. The site is therefore considered sequentially preferable for residential development in flood risk terms.
2.76 The score of level two for 'critical drainage risk' appears to have been informed by a high-level review of the surface water flood risk for the site. Mapping on the
Environment Agency long term flood risk website illustrates that the majority of the site is in an area of low or very low surface water flood risk. There are small,
localised areas of medium and high surface water flood risk, associated with low spots within the site or near watercourses. 2.77 This is a matter that can be suitably addressed through any future planning application, which would be supported by a surface water drainage strategy
incorporating Sustainable Urban Drainage Systems (SuDS). The Framework Plan which has been produced has been informed by a high-level Flood Risk and
Drainage Constraints Plan (Appendix E) which illustrates how surface water flood risk can be appropriately mitigated through the inclusion of detention basins in
appropriate locations. The location and design of the basins will be subject to further detailed drainage assessment, however it is considered that a scheme can
be designed that effectively mitigates the risk of surface water flooding.
Access to a train station
2.78 The nearest train station to Land South of Pooles Lane (ref CFS190) is located in Rayleigh approximately 5.2km, which is just over the 5km threshold for a level one score. However, the assessment should take into account where opportunities exist for linked trips via other sustainable modes of transport such as by cycle or public
bus. Land South of Pooles Lane is located less than two minutes' walk from the nearest bus stop, where there is a frequent bus service (every 30 minutes) to Rayleigh railway station, with the journey taking approximately 15 minutes (including walking to the bus stop). This provides a very sustainable option for future residents of this site, and the Council should consider this factor when
assessing the site's sustainability.
Access to secondary school
2.79 It is recognised that Hullbridge does not include a secondary school, and as a result, the site scores level one in the Site Appraisal Paper. However, as mentioned above, the frequent no. 20 bus route (every 30 minutes between 7.00 to 21.00 Monday to Saturday) between Hullbridge and FitzWimarc School, in Rayleigh takes
approximately 15-20 minutes. This is considered to be an acceptable distance for secondary-aged pupils who often travel by bus, bike or even train to get to school.
The Council should therefore consider the accessibility of secondary schools by modes of public transport when assessing the relative sustainability of a site.
Access to a town centre
2.80 The nearest town centre of Rayleigh is around 6.2km from Land South of Pooles
Lane (ref CFS190), which is therefore within level one threshold, as the site is more than 2.3km from the town centre. However, it should be recognised that Hullbridge
contains a range of services, which could be found on a high street, with three convenience stores, medical centre, a pharmacy and other facilities. These services
are therefore capable of supporting the day-to-day needs of residents within Hullbridge, limiting the need to travel beyond the village on a frequent basis.
2.81 The site is also less than two minutes' walk from the nearest bus stop, where there are frequent bus services (every 30 minutes) to Rayleigh town centre, with the
journey taking approximately 15 minutes. This provides a very sustainable option for future residents of this site. Furthermore, due to the impacts of the COVID-19
pandemic, there has been a greater focus on online retail shopping; thus, it is considered that the 2.3km threshold is unjustified adopted by the Site Appraisal Paper, particularly where residents of Land South of Pooles Lane could either access retail facilities by public transport or online.
Employment site
2.82 The nearest designated employment (Imperial Park) area is 4km from Land South of Pooles Lane in Rayleigh, which is just over the level one threshold of 2.3km.
However, this employment site can be accessed by frequent bus service (every 30 minutes), with the journey taking approximately 20 minutes, providing a
sustainable option for future residents of this site. The Council should also consider the impact of the COVID-19 pandemic with increased levels of working from home
practices when considering the relevant proximity of employment sites.
Conclusion
2.83 Penland Estates Limited consider that Land South of Pooles Lane, is suitable, available and achievable for development, taking into account the evidence that it
has prepared to support the site’s promotion so far. The site should be allocated in order to achieve a sustainable and deliverable development strategy for Hullbridge,
consistent with the Local Plan strategy as a whole.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Dear Rochford District Council members,

My husband and I are writing in response to your New Local Plan and, in particular, to the Spatial Options Document 2021.

We have lived in the Ashingdon Road, near to the Golden Cross, for 51 years and have seen many changes in that time, mostly to the number of houses that have been built, either as new estates or squeezed into unused spaces between existing homes, and how the traffic from these all feeds into the Ashingdon Road.

We understand that growth must happen, that the area is and will continue to grow as it has been doing and that RDC has an obligation to provide a certain number of homes every year. However, it seems to us, that the Rochford Eco Village proposed by the owners of Doggetts Farm is an excellent way forward and we would highly recommend it.

It aims to meet everything that the local residents are most concerned about – firstly, affordable houses that can quickly be constructed, are carbon negative and have zero utility bills. Secondly, leisure facilities, these are recognised much more now than they were 50 years ago as being vital to our health and wellbeing as are woods, beauty spots and walks away from traffic pollution. Thirdly, the inclusion of doctors’ and dentists’ surgeries together with a Special Needs School and sensory play facilities for the further development of children and adults. None of this has been included in the housing estates that have been built since we lived here, and would have all the benefits of providing growth, homes and employment while protecting the environment.

Doggetts Farm lies between Rochford and Ashingdon and could well become a flagship of a carbon neutral, affordable development in this area that will not impinge further onto the Ashingdon Road. This is an opportunity that has not been available in the last 50 years but my husband and I firmly believe that you, as a Council, now has the responsibility to make it happen for the sake of everyone’s children and grandchildren in the next 50.

New housing in Ashingdon, Hawkwell and Hockley
My husband and I strongly oppose all new housing in the above mentioned areas.

There is a new housing estates being built in Rayleigh, Rettendon Road, which is already causing congestion on the roads.

We moved to Hockley over 10 years ago and traffic in these areas have gotten considerably worse over the years. The main roads feeding these areas are all single lane roads.

For example, coming back from visiting my mother ( Romford area) yesterday, the B1013 was conjested from the Spa, Hockley, because a lorry was trying to unload at Costcutter. Traffic was all the way back to Hambro Hill. It took me 20 minutes to pass the lorry. This happens on almost a daily bases with either bin-lorries, road works or delivery vans.

Bus services in these areas are inadequate at present and would no doubt get worse if these housing developments were approved.

MORE CARS will cause more traffic, especially as today there are usually more than 1 car per household.

There are not enough schools in these areas, not enough doctor surgeries. Southend Hospital cannot cope with the growing population at present, it cannot cope with a larger population in this area.

Our Green Belt areas should NOT be built on.

To Rochford council
We would like to raise our objections to the proposed sites identified in the Hockley Local Action Plan and in particular the sites listed above currently in the consultation process for future development. We live at the above property and moved to Hockley to live in a semi-rural village and to enjoy open spaces, wild life and all that county living offers, away from heavy traffic and poor air pollution. We understand the need for more housing in the southeast and would support housing projects which included their own infrastructure and facilities ie roads, schools, Doctors etc in an area that does not impact on existing towns and village which are already over- developed for the services and infrastructure in place.
The proposed development of the above sites would have a direct impact on our property and lifestyle and we oppose the development of those sites for the following reasons:
Housing built on CFS242 and CFS150 is likely to overlook our garden and the trees surrounding our property would need to be removed to enable building, spoiling our outlook and tranquillity and could result in property prices being affected as the desirability of the area would be compromised. Our property is located at the bottom of victor gardens which is on an incline and already suffers with water drainage problems and during the winter months the garden becomes water logged. Further development on CFS242 & CFS150 would impact further on water drainage in the area.
The Nature reserve is very close to the proposed sites and building on these areas would impact on the wildlife significantly.
We oppose the building on any green belt land to protect the countryside, Footpaths and bridleways which would be lost.
Parking in Victor gardens is likely to be impacted with further development. Many of the houses in the road have already been extended and some single plots purchased by builders and then replaced by two large properties which has increased the traffic and parking in the road.
We also oppose the over development of Hockley/Hawkwell to protect it as a village.
The roads are already very congested and presenting problems in the area and further development would cause major problems getting in and out of the village without new road structures being put in place.
Many of the local schools are already full or close to full capacity and more housing would result in a lack of school places and choice for local children. If more educational facilities are not provided with further development then our children’s education will be compromised at the expense of development and housing.
The health facilities in the area are already overstretched and more housing in the area will definitely impact on our heath services.
Having lived and worked in this area for over 25years we feel that Hockley/Hawkwell is already overdeveloped for the infrastructure and facilities in place and therefore oppose further major development/ housing of this area.