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 regard to the Proposed Local Plan

The local area is already suffering from overcrowding without adding more houses.
The new builds at Rawreth Lane and Hullbridge have already shown that developments cause major disruptions to the traffic in the area.
The installation of the two new roundabouts caused delays in all directions for many days over several months. This was at the same time as ongoing work on other roads within the area.

The total grid lock in the area when an incident occurs only goes to show that the traffic levels are already at breaking point.
Understandably, when a water main bursts and the road collapses it becomes necessary to close the road. However, the ensuing queues and problems to move around the area again only demonstrate the already heavy density of traffic.

When new homes are built little consideration seems to be given to the needs of the proposed residents. Which schools are the children supposed to go to?
Where will they find doctors and dentists? How will they travel to and from work? Wolsey Park has just one bus which goes along Rawreth Lane only every two hours.

The existing open spaces are relatively small for the existing number of residents. If the proposed sites are to be built on this ratio will be even lower.

The future plans do not show any intention to increase open spaces, build schools or extra leisure facilities.

The road surfaces in the area are dreadful. Some repair work has been done but adjoining areas remain untouched. Increased traffic flow will not improve this situation.

Dear Sir / Madam
Rochford Local Plan Spatial Options (Regulation 18)
Thank you for the opportunity to comment on your Spatial Options Document. These representations are submitted on behalf of Rydon Homes which has land interests to the south of Wellington Road, Rayleigh (Call for Sites references CFS053 and CFS086). Rydon is promoting the land for the residential development of around 110 homes (including affordable housing.
By way of clarification, the Rydon representations comprise of the following documents :
- this letter which provides a strategic overview of the issues raised in the Regulation 18 document
- a schedule which provides responses to certain of the questions posed in the
Regulation 18 document
- a Green Belt assessment prepared by Liz Lake Associates
- a Landscape Assessment prepared by Liz Lake Associates
- Transport Strategy site prepared by Vectos
- Local Plan Evidence Base Appraisal Technical Note prepared by Vectos
- Surface Water Flood Risk Technical Note, prepared by Stuart Michael Associates
- Design Assessment prepared by Omega.

Overview of the Regulation 18 Document
The strategic direction of the Reg 18 Plan is strongly supported since it seeks to move towards a more sustainable pattern of development where new development can be low carbon and be located where a good range of facilities can be accessed by foot, cycle or
public transport. It is considered that these over-arching principles strongly point to a strategy which locates most development in the main towns. In this context, Rayleigh should be considered the primary focus for development in the District since
- it is the largest town, by a large degree
- it contains the widest range of facilities, services, jobs and public transport
- it is the only ‘Tier 1’ settlement in the District and is at the top of the District retail hierarchy
- this approach is also supported by the conclusions of your Integrated Impact Assessment.
Whilst it is accepted that major urban extensions can sometimes have the ‘critical mass’ to deliver infrastructure, many Local Plans have been found unsound because of a lack of range and choice of sites plus the delivery risks involved in a strategy based around a very limited number of large sites. A failure of one large site can prejudice the whole plan.
It is for these reasons that in addition to Rayleigh being the primary focus for development in the District, the new housing allocations should be in the form of a mix of sizes and locations around the town. This will allow scope for diversity, choice and the involvement of smaller
housebuilders. It is also a robust delivery strategy. For reasons explained below, it is considered that the land south of Wellington Road fulfils all the objectives of your emerging Local Plan and can assist in improving the ‘completeness’ score of Rayleigh.
The consultation document seeks views on the overall level of development in the District. Comments on the three options are :
- Option 1 ‘Current Trajectory’ (4,500 homes) : This would substantially undershoot the Government’s standard methodology and is a strategy which is likely
to fail at Examination
- Option 2 ‘Standard Methodology’ (7,200 homes) : This is the absolute minimum housing provision needed to avoid the plan being found unsound
- Option 3 ‘Standard Methodology + 50%’ : Whether the uplift is 50% or some other figure is not the real issue. Government policy states that the Local Authorities
should seek to meet the unmet needs of adjoining areas, where this is achievable. In view of this, the Local Plan evidence base should investigate the degree to which
Rochford can exceed 7,200 homes in the period to 2040 in order to meet unmet housing needs from adjoining areas and provide more affordable housing.
For these reasons, the Plan should adopt ‘Option 3’ and seek to provide housing in excess of 7,200 homes.
South of Wellington Road
As noted above, Rydon is promoting 6.31hectares of land south of Wellington Road as a housing allocation for around 100 homes.
In addition to complying with your emerging strategy of locating allocations is sustainable locations where facilities can be accessed by foot, cycle and public transport, the promotion of this site is supported by Rydon’s own evidence base. These documents are attached, but can be summarised below :
1. Green Belt Review by LLA : This report assess the Green Belt role of the site and places this in the context of the Council’s study undertaken by LUC. The main
problem with the LUC report is that its site assessment is insufficiently ‘fine grained’ to pick up smaller sub areas which have development potential within large parcels
which, overall, are not seen as having potential. The LLA report then provides a Green Belt assessment of a sub area made up of only sites CFS053 and 086. This
identifies how this site is effectively an indent in the eastern built-up edge of Rayleigh with development on three sides. It also has a strong tree / hedgerow boundary on its eastern side and its topography slopes inward towards the urban area of the town. In
combination, this means that the site could be developed without materially compromising the purposes of the wider Green Belt around Rayleigh.
2. Landscape Assessment by LLA : This ties in closely with the LLA Green Belt review and demonstrates that sites CFS053 and 086 have significantly different
landscape characteristics from the wider area of open countryside to the east. As such, it is capable (with mitigation) of being developed with limited impact on the
wider landscape.
3. Sustainable Transport Assessment by Vectos : Whilst the Local Plan concept of ‘completeness’ is supported, it is felt that the methodology used is flawed. As a
consequence, sites CFS053 and 086 are given much poorer ‘completeness’ scores than they actually merit. The Vectos report suggests some amendments to the
methodology to make it both more logical and accurate. As a consequence, the Rydon sites, with the existing public footpath / bridleway route to Napier Road and on
to the Town Centre can be seen as very sustainable location. It will also assist the achievement of ‘completeness’ in Rayleigh.
4. Drainage Report by SMA : In response to the drainage concern identified in the Site Assessment, Stuart Michael Associates (SMA) have been commissioned by Rydon
Homes Ltd to assess the impact of the risk of flooding from surface water on the Site.
Whilst the site is located within Flood Zone 1, the site is also identified as being low, medium and high risk of surface water flooding. SMA’s report confirms that any
surface water flooding is constrained to the peripheries and low lying areas of the site within and adjacent to the existing watercourses. Proposals can therefore be brought forward with no risk of flooding. It should be noted that the proposals could also include provision to mitigate risk of flooding to properties outside the site and
downstream of the site.
5. Design Assessment by Omega : The Design report seeks to synthesise all the evidence contained in the Rydon evidence base to produce an illustrative masterplan. This shows a development of between 92 and 110 homes arranged within generous levels of open space. The urban context analysis indicates certain design themes which could be adopted to ensure that a sense of place can be created, as well as somewhere which echoes the essential characteristics of the best of Rayleigh’s urban fabric.

Conclusions
Rydon welcomes the publication of the Regulation 18 document and supports many of its aims and objectives which work towards a more sustainable and low carbon future. As part of this, your own evidence base and the Integrated Impact Assessment would suggest that the town of Raleigh should be the primary focus of new development. Rydon support this and consider that its own evidence base clearly makes the case for the allocation of around 110 homes south of Wellington Road.
Should you wish to discuss these representations in more detail, we would be pleased to arrange an early meeting.

Rochford Local Plan Regulation 18 Spatial Options Consultation
Representations on behalf of Rydon Homes
Responses to Questions
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?
A : The draft ‘Vision’ for Rochford contains many appropriate and supportable elements, but it should contain a commitment to delivering sufficient high quality homes to meet need.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
A : Yes, there should be separate ‘Visions’ for each of the main settlements. This will help capture their diversity and distinctiveness. It may be necessary to have a a generic ‘villages / hamlets’ Vision for the smallest communities.
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?
A : The strategic objectives are generally supported. However, the number should be expanded to cover cross-cutting themes. An example would be to make the link between the objective for zero carbon and the concentration of new development in sustainable locations (ie. the larger towns) explicit.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
A : Yes, the settlement hierarchy is sound. It correctly identifies Rayleigh as the Tier 1 primary settlement in the District.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
A : Dealing first with the level of Growth, Option 1 (Current Trajectory) would fail to meet the standard methodology figure. As a consequence, it is probable that the Plan would be found unsound and fail. Option 2 (Standard Methodology) is the minimum possible figure
that the Plan could pursue and could still be found unsound since it would not be attempting to meet the unmet needs of adjoining local authorities. Option 3 (Standard Methodology + 50%) has the greatest chance of being found sound since it would allow Rochford to meet some unmet needs from adjoining authorities and would allow a greater portion of affordable housing in the District to be met. The reference to 50% in Option 3 is misleading. Option 3 should just have the objective of exceeding the standard methodology figure by whatever the District can accommodate. This may be +15%, it may be +60%. The evidence needs to be produced to justify a specific figure.
With regard to the spatial strategy options, the most sustainable and deliverable option is 2A (Urban Extensions Focussed on Main Towns). However, in reality, this is likely to take the form of Option 4 (Balanced Contribution) since in order to meet the overall housing
provision, there will need to be both urban intensification and some strategic releases at the main towns.

Q7. Are there any reasonable alternatives to these options that should be considered instead?
A : A refined option would be a Balanced Contribution made up of
(i) Some urban intensification
(ii) Small / medium urban extensions at main towns
(iii) A limited number of strategic releases to ‘top up’ the yield from (i) and (ii) to meet the selected housing provision.

Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis?
A : Zero carbon should be added to the list of themes.

Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood
risk and coastal change?
A : A sequential approach to flood risk is both logical and in accordance with the guidance in the NPPF.

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?
A : The Coastal Protection Belt and Upper Roach Valley should have continued protection.

Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
A : Agree in principle, the difficult question is what is the appropriate percentage which is both viable and deliverable.

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?
A : This may not be necessary since the Government is already proposing to strengthen Building Regulations to deliver high energy efficient standards. If the Local Plan was to propose even higher standards, this would need to be rigorously tested in terms of the impacts on both viability and delivery.

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?
A : Yes, a high level ‘place making charter’ would be useful, in principle to provide guidance whilst not being inflexible.

Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
A : The principles are generally supportable. However, carbon negativity (as opposed to being carbon neutral) is unrealistic.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
A : Rydon supports this objective in principle. However, design guides, codes and masterplans should only be produced in full collaboration with landowners and developers. Any documents should be regarded as flexible and allow alternative approaches to come
forward, where these can be fully justified.

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?
A : A single Design Guide for the whole District would become too generic and fail to identify what makes each settlement unique. Settlement specific design guides would be most effective, as long as they do not stifle innovation and can allow alternatives approaches,
where fully justified.

Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?
A : It is important that any documents are not too prescriptive and allow a degree of flexibility. All documents should include a date by which they will be reviewed.
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?
A : The appropriate response is to negotiate a site specific mix which is appropriate to the settlement and the characteristics of the site itself (Option 2). National Space Standards are appropriate. The approach to Part M4 of the Building Regulations could reflect that adopted in the London Plan.

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?
A : Option 4A is the most appropriate solution to meeting open space needs if they can all be met on site. Any needs which cannot be met on site should be met by off site contributions.

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?
A : Option 2 (incorporating Town Centre policies in the Local Plan) is the most appropriate approach.

Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make?
A : Given the status of Rayleigh as the Tier 1 settlement in the Settlement Hierarchy and its wide range of shops and services, it should be defined as the only ‘Primary Town Centre’ at the top of the retail hierarchy.

Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
A : The Vision for Rayleigh is appropriate in that it captures the need for new allocations to be accessible by foot, cycle or public transport.

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other
A : Rydon is promoting the residential allocation of sites CFS053 and 086 south of Wellington Road, Rayleigh for around 110 homes. The justification for this allocation is set out in the attached Sellwood Planning covering letter plus
- The Green Belt Review by Liz lake Associates
- The Landscape Assessment by Liz Lake Associates
- The Sustainable Transport Assessment of the Promotion Site by Vectos
- Drainage report by SLR
- Design Assessment by Omega.
In summary, the land being promoted by Rydon accords with the emerging spatial strategy of the Local Plan in that it is located in Rayleigh which is the most sustainable settlement in the District with the greatest range of services, facilities, jobs and public transport. Within Rayleigh, the site is within easy walking / cycling distance of a wide range of facilities and can assist in the achievement of the ‘completeness’ objective of the Local Plan. The development of the site will cause no material harm to the wider Green Belt and countryside since it represents an indent in the built form on the eastern side of Rayleigh, with development on three sides. The eastern boundary of the site is strongly vegetated and when combined with the topography would represent a strong and defensible long term boundary to
the Green Belt in this location.

Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate? Why these areas?
A : Yes, sites CFS053 and 086 south of Wellington Road.
Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
A : The green spaces shown are of local significance and should be identified as such. No additional green spaces should be identified as having local significance.

Firstly I should like to say that I think the presentation of this to the local people is far too complicated and I feel many people will just “give up” trying to respond However, I will attempt to put my views to the best of my ability.
I feel strongly that there should be no further major development in Hullbridge as this would damage the environment, compromise and have a detrimental impact on existing wildlife and result in more pollution and flooding. With the current UK emphasis on planting trees and hedgerows to help reduce pollution and benefit our natural wildlife, any further major development would go completely against this philosophy.
With the information given to me, I feel that the best option would be to build all housing in one location west of Rayleigh where there are already good transport links via A127, A130 and A13 These roads would serve as good links for work and business in Basildon, Southend, Wickford, Chelmsford, Thames Gateway and Tilbury2.
This option would enable a “tailor-made” approach to good housing and infrastructure, schools, GP surgeries, open spaces and community facilities. This option would not put extra strain on the current villages whose roads, facilities and amenities are already stretched to breaking point. An example of this is the current through traffic on Lower Road in Hullbridge where there has been a vast increase in the volume of traffic and consequential increase in air pollution (due to recent developments in Rochford and Ashingdon). Lower Road has become a rat run for traffic from Southend and en route areas through to to Chelmsford. The increased volume and speed of traffic along Lower Road makes getting in and out of residential driveways on to Lower Road extremely hazardous; it can take anything up to ten minutes to pull off our driveway safely. The increase in Lower Road traffic has resulted in numerous accidents in recent times, one of which was sadly a fatality. The keep left sign on Lower Road near the junction with Long Lane has been completely demolished by a car on one occasion. On another occasion a car hit the lamp-post bringing it completely down. Numerous animals have been run over. A car ran into a van that was trying to exit his own driveway on to Lower Road. A man was knocked off his motorbike in Lower Road. The air ambulance has had to attend incidents in Lower Road twice within five days recently. It is virtually impossible to cross Lower Road safely on foot and one lady recently told me she has become virtually housebound in Central Avenue as, because of continuous stream of traffic, she cannot get across Lower Road on her mobility scooter and there is no pavement for her to travel along to get to Hullbridge village shops and GP.
In addition, heavy goods vehicles are continually using Lower Road and these are putting excessive strain on the underground utilities. This means we are constantly experiencing the road being dug up for water main repairs, gas leaks, etc. Even a major sinkhole appeared in Hullbridge Road in the summer 2021.
Hullbridge has limited school facilities and I understand that only last year an infant school child was allocated a place in a Harlow school as there were no other local options available at that time.
The only GP surgery in the village is at capacity and getting through on the telephone is extremely problematic because so many people are trying to get appointments. In addition there is a shortage of doctors.
In Lower Road Hullbridge, there is no regular bus service, which means children at the south end of Hullbridge have a thirty minutes’ walk to the local infants and junior schools. This is tiring for five year olds and difficult in the winter months when it is dark and often wet. As there is no regular bus service along Lower Road, senior school children have a long walk along a busy main road to catch the bus at Coventry Corner (the nearest bus stop for number 20 bus). When the bus arrives, it is often full up with children and commuters who have previously boarded in the village along Ferry Road.
At the south end of Hullbridge there are no public recreational facilities. There is a local sports club but this is not open to the general public to allow children to just play and run around. In addition there are no general community facilities for the older people at the south end of Hullbridge.
We do have a number of valued and well used footpaths and bridle ways but these would be lost if there were to be further development in Hullbridge.
I understand that according to a recent report, much of the proposed development area in Hullbridge will be below sea level by 2050 - it makes no sense to consider further development on such vulnerable sites.
It is for these reasons that I feel further major development in Hullbridge should not be permitted.

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

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

Background

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Strategy Options

Q5: Do you agree with the settlement hierarchy presented?

No.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Spatial Themes

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

No.

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

Yes.

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

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

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

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


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

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

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

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

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

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

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

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

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

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

Please see our response to Q16 and Q59.

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

Please see our response to Q14.

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

Yes.

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

Please see our detailed response to Q16b. and Q16c.

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

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

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

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

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

Please see also our response to Q16b.

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

Housing For All

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

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

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

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

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

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

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

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

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

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

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

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

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

Q19. Are there any other forms of housing that you feel we should be planning for? How can we best
plan to meet the need for that form of housing?
No.

Biodiversity

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

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

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

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

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

Community Infrastructure

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

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

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

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

Yes.

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

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

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

Yes – see our response to Q.36.

Open Spaces and Recreation

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

BDW support Option 4.

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

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

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

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

Yes.

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

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

No.

Transport and Connectivity

Q51: With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
BDW support a combination of all Options identified by the Council in addressing the need for sufficient and
accessible community infrastructure through the plan.

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

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

Please also see our response to Q51.

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

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

Please see our response to Q52 / Q53.

Planning for Complete Communities

Wakerings and Barling

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

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

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

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

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

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

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

Next Steps

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

Yours faithfully
David Churchill
Partner

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

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

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

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

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

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

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

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

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

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

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

Strategy Options

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Spatial Themes
Q8: Are there any key spatial themes that you feel we have missed or that require greater emphasis?
No.
Q9: Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?
Yes.

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

Q10: Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from
development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape character?
BDW would expect these designations to be afforded the necessary weight in the emerging Local Plan and/or
at the planning application stage. Subject to the Council selecting either Option 2b or 4 as set out in the
response to Q.6 above, BDW also suggests that sites which are unconstrained from such designations should
be the focus of allocations in the emerging Local Plan.
Q11: Do you agree we should require development to source a percentage of their energy from low carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
Whilst BDW support the principle of requiring a percentage of energy in developments to be from low-carbon and renewable sources, this should be subject to consideration of viability.

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

Q12: Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?
Whilst BDW support the principle of requiring energy efficiency standards of developments to be higher than
the building regulations, this should not be a requirement for all developments. The ability to achieve this will be subject to the viability of a scheme.
Therefore, to be acceptable in planning terms, developments should meet the energy efficiency standard set out in the building regulations. If a scheme were to exceed building regulations, this should be recognised as a bespoke merit / positive of the scheme, that should weigh favourably in the planning balance.
Q14: Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas?
BDW support the inclusion of a place-making charter and the listed standards, in principle.
Whilst broad objectives (e.g. aiming for carbon-neutrality; tackling air quality; promoting active travel) may help
achieve a collective Vision for the area, sufficient account and flexibility must be given for settlement / site-specific circumstances.
Please see our response to Q16 and Q57.

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

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

Q16b: If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
BDW oppose the imposition of a single, broad design guide/code for the District. As the Council recognise,
this would fail to account for and preserve the mix of historic, natural, and urban environments that help to
create distinctive local vernacular and character. Conversely, BDW would also oppose the production of
specific, prescriptive design codes on a site-by-site basis which would not provide sufficient flexibility, restrict the use of innovative methods and technologies, and frustrate artistic interpretation – all of which may impact
a development’s viability and contribution to “beauty”.
BDW support the imposition of broad strategic objectives (as set out in the place-making charter, as well as
the National Design Guide and National Model Design Code) with sufficient flexibility for design to be responsive to circumstances of a site as they evolve. This might include more specific, but still broad objectives are settlement/area level.
Indeed, Paragraph 129 of the NPPF advises that developers may also choose to prepare design codes in
support of planning application for sites they wish to develop. This option would give the freedom to provide
interpretation and sufficient resourcing from the private sector to develop appropriate design codes, in
accordance with the National Design Guide and National Model Design Code.

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

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

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

Q18. With reference to your preferred Strategy Option, are there areas or sites in Rochford that you feel require a specific approach to housing types, size and tenure? What is required to meet housing needs in these areas?
As set out in Figure 28 of the consultation document (taken from the South Essex SHMA) the overwhelming
need for dwellings in Rochford District are houses (85%), rather than flatted development (15%). BDW observe
the allocation of smaller, urban/previously developed sites will not satisfy the prevailing demand for
dwellinghouses, which typically require a greater extent of land.

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

A more dispersed growth strategy also provides opportunities to balance housing trajectory across the District and the wider South Essex HMA – as greenfield sites typically have quicker lead-in times / build out rates
compared to those often associated with complex brownfield sites.
Q19. Are there any other forms of housing that you feel we should be planning for? How can we best plan to meet the need for that form of housing?
No

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

Community Infrastructure
Q35: With reference to the options above, or your own options, how can we address the need for
sufficient and accessible community infrastructure through the plan?
BDW support a combination of all listed Options identified by the Council in addressing the need for sufficient
and accessible community infrastructure through the plan.
Whilst the Council should seek to invest and protect existing community infrastructure, it should seek to first
locate development in areas with adequate proximity to existing infrastructure (such as Land South of Hall
Road, Rochford) before seeking to promote sites that are capable of facilitating the delivery of much needed
community infrastructure in other areas.

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

Q37: Are there areas in the District that you feel have particularly severe capacity or access issues relating to community infrastructure, including schools, healthcare facilities or community facilities?
How can we best address these?
Yes – see our response to Q.36

Open Spaces and Recreation
Q38: With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
BDW support Option 4.
Larger and strategic developments are capable of delivering areas for open space and recreation as part of a holistic redevelopment of a site. As set out in our Vision Document, Land South of Hall Road has incorporated
approximately 4.18 ha of public open space, including a local equipped area of play (LEAP) within the current
design.
Q40: Are the listed potential hub sites and key centres the right ones? Are there other locations that we should be considering?
Yes.
However, the Council should consider that larger and strategic development sites are capable of delivering
areas for open space and recreation as part of a holistic redevelopment of a site.

Q41: With reference to your preferred Strategy Option, are there opportunities for growth to help
deliver improvements to open space or sport facility accessibility or provision?
Yes.
Larger and strategic development sites are capable of delivering areas for open space and recreation as part
of a holistic redevelopment of a site.
Q42: Are there particular open spaces that we should be protecting or improving?
No.

Transport and Connectivity
Q51: With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
BDW support a combination of all Options identified by the Council in addressing the need for sufficient and
accessible community infrastructure through the plan.
As set out in our response to Q5 and Q6, the Council should seek to incorporate a dispersed growth strategy.
A more dispersed growth strategy will provide a balance between utilising and optimising existing connections in the more sustainable settlements, whilst providing improvements to less sustainable locations. A more
dispersed growth strategy will also work to avoid overuse and unnecessary congestion on more densely
populated areas, which bring with them problems of air quality and noise pollution.

Q52: Are there areas where improvements to transport connections are needed?
Please see also our response to Q51.
As part of a more dispersed Growth Strategy, the Council should seek to ease congestion by locating
development in locations which can benefit from wider improvements. This should be combined and recognised with the delivery of such infrastructure through contribution and/or bespoke delivery in larger allocations.
Q53: With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [walking, cycling, rail, bus, road etc.]
Please see also our response to Q52 / Q53.

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

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

Yours faithfully

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

District Council’s new local plan up to 2040, the plan having been written by yourselves without any consultation of our community.

I have strong objections to any more new housing in Hullbridge as we are now suffering already from the present construction of the 550 houses previously given permission for. People’s lives have been made a misery from the increase in traffic, noise, pollution and constantly being stranded from roads being closed for numerous reasons. Even when the 550th house is finished I cannot see life becoming any easier.

If this latest plan is supposed to be extended to 2040, I understand Hullbridge will have a considerable amount of land that will be below sea level by then anyway! This village is renowned for flooding particularly in the Watery Lane area and I seriously wonder how the latest development being built now will manage over time.

Public transport is becoming increasingly more difficult with buses cut out and the whole of the No. 20 bus route sometimes just ceasing for several days for all sorts of reasons – road flooded, road impassable from holes appearing etc. The No. 20 bus route has 4 buses an hour – not 4-7 buses an hour! Where did the council come up with that figure? We have two roads in and out of the village and Watery Lane which can be hit and miss. If anything goes wrong with either of these roads chaos occurs. People are so delayed when these problems happen they are frequently late for work or appointments. With an increase in the population right now and not even thinking about the future the buses will be unable to cope.

The infrastructure in and around Hullbridge is very poor right now so in the future it can only get worse. Poor road links, poor public transport, not enough school places or medical services. There are very few leisure facilities in the village, and this is particularly bad for the young.

Green spaces - will there be much left by 2040 if the plan goes ahead? I thought we were in a Green Revolution but it would appear not in this area. Most of the greenbelt in and around Hullbridge will be non-existent and the character of our lovely village will be lost. The people of Hullbridge enjoy the few public footpaths and bridleways we have and the lovely walks along the river but in the future, these could be non-existent with huge numbers of new houses and an increase in population. The wildlife in and around the village will be seriously affected as I believe has happened already.

The saddest part for me is the nature of our ‘village’ is being trampled over and we could become just another urban sprawl.

These are my views and I hope you will consider them seriously.

I write in response to the above.

Firstly, with regard to the Vision Statement for Hullbridge - There was no consultation with our community before this vision was prepared - why was this not done? The vision I have is for Hullbridge to remain a village with an improved public transport system keeping the coastline as it is for residents and visitors to walk along and enjoy the unspoilt views.

I believe the most appropriate option of the 4 options RDC have suggested for the new local plan is to build all housing in one location whereby the infrastructure can be built to meet the requirements needed for these new developments. Looking at the map it would seem North of Southend appears to have far more land. This would be far more sensible than to start adding bits onto existing towns/villages and then having to add appropriate infrastructure with all the disruption, noise and pollution this would cause.

The infrastructure in Hullbridge is not adequate now, let alone when the new development of, I believe, 500 properties are finally completed from the previous Local Plan! This has caused significant strain on public services, roads etc. Yet the Council have failed to complete transport and sustainable infrastructure assessments prior to this consultation.

Hullbridge is already noticing the effects that increased housing has caused and the development is not even complete! The strain to our primary school (we have no secondary school) and to our medical centre.

The road infrastructure in Hullbridge cannot be improved upon. We have one road that runs through Hullbridge from Rayleigh to Hockley and one road that leads from Lower Road to the river (Ferry Road). These roads cannot be improved upon. It doesn’t take much for the whole village to be gridlocked or cut off if there is a problem. The sinkhole in Hullbridge Road this year is a good example where you could only get out of the village via Hockley causing significant problems not only in Hullbridge but in Hockley and beyond. Similarly, only yesterday, a road accident on Lower Road caused the road to be blocked and when vehicles tried to go through back roads all those roads became totally gridlocked. When the current development is finished we will have a lot more traffic on our one road in and out of the village so more chance of this sort of thing happening more often. Let alone having even more developments in future Local Plans.

A lot of Hullbridge is Green Belt and Coastal Protection Belt. Any further developments would harm these areas and impact on natural habitats.

With regard Critical Flood and drainage risks - Hullbridge will have a significant proportion of the village below sea level by 2040.

Public transport in Hullbridge is not adequate. There is no public transport whatsoever that runs down Lower Road towards Hockley. There is now no school bus that runs in Hullbridge.

On the South side of the village there are no recreation areas and a lack of pavement and crossings, which with the increase in vehicles due to the current development and lack of speed restrictions has made it more dangerous for pedestrians than it was before.

So you can see that Hullbridge hasn’t got adequate infrastructure now so will certainly not be able to cope with any more development and serious consideration must be made to look at alternative options.

RDC/Spatial Consultation 2021 Questions

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

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

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

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

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

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

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

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

This mail is in response to your vision statement for Hullbridge, in particular my objections to the proposed housing development sites around Hullbridge.

All land around Hullbridge is Green Belt, this land should be vigorously protected rather than being given up and lost to housing developers. Some land also forms part of the Coastal protection Belt and should be protected at all costs.

There is also an abundance of wildlife in the fields and hedgerows surrounding Hullbridge it is important to conserve their habitats rather than destroy them.

When we moved to Hullbridge our property survey confirmed that Hullbridge was in a critical flood risk area, we live backing onto Cracknell's farm ( one of your proposed development sites ) where over 800 houses are planned, take away open fields and replacing them with houses and roads will drastically reduce the lands ability to absorb surface water increasing the risk of flooding.

There would be a loss of public footpaths and bridleways, these routes are very well used for horse riders, dog walkers and for exercise, by residents and visitors alike. Would you rather take your exercise walking the footpaths through open countryside or pounding the pavements of a new housing development , I know what option I would choose.

Transport links to Hullbridge are poor, access is along small B roads or even smaller and narrower unclassified roads, congested at the best of times, the extra traffic any new developments would bring would only make our already congested roads worse. Our one school and medical centre would struggle to cope with the amount of people these proposed developments would bring.

Hullbridge is a unique rural coastal village made up of traditional housing, mobile home sites, council maintained roads and private roads and should be preserved as such.

I understand that new housing is needed just not at the expense of a unique village like Hullbridge, I would therefore suggest any new housing be built in your strategy option 3 ( west of Rayleigh, north of Southend or east of Rochford ).

I write in response to the above.

Firstly, with regard to the Vision Statement for Hullbridge - There was no consultation with our community before this vision was prepared - why was this not done? The vision I have is for Hullbridge to remain a village with an improved public transport system keeping the coastline as it is for residents and visitors to walk along and enjoy the unspoilt views.

I believe the most appropriate option of the 4 options RDC have suggested for the new local plan is to build all housing in one location whereby the infrastructure can be built to meet the requirements needed for these new developments. Looking at the map it would seem North of Southend appears to have far more land. This would be far more sensible than to start adding bits onto existing towns/villages and then having to add appropriate infrastructure with all the disruption, noise and pollution this would cause.

The infrastructure in Hullbridge is not adequate now, let alone when the new development of, I believe, 500 properties are finally completed from the previous Local Plan! This has caused significant strain on public services, roads etc. Yet the Council have failed to complete transport and sustainable infrastructure assessments prior to this consultation.

Hullbridge is already noticing the effects that increased housing has caused and the development is not even complete! The strain to our primary school (we have no secondary school) and to our medical centre.

The road infrastructure in Hullbridge cannot be improved upon. We have one road that runs through Hullbridge from Rayleigh to Hockley and one road that leads from Lower Road to the river (Ferry Road). These roads cannot be improved upon. It doesn’t take much for the whole village to be gridlocked or cut off if there is a problem. The sinkhole in Hullbridge Road this year is a good example where you could only get out of the village via Hockley causing significant problems not only in Hullbridge but in Hockley and beyond. Similarly, only yesterday, a road accident on Lower Road caused the road to be blocked and when vehicles tried to go through back roads all those roads became totally gridlocked. When the current development is finished we will have a lot more traffic on our one road in and out of the village so more chance of this sort of thing happening more often. Let alone having even more developments in future Local Plans.

A lot of Hullbridge is Green Belt and Coastal Protection Belt. Any further developments would harm these areas and impact on natural habitats.

With regard Critical Flood and drainage risks - Hullbridge will have a significant proportion of the village below sea level by 2040.

Public transport in Hullbridge is not adequate. There is no public transport whatsoever that runs down Lower Road towards Hockley. There is now no school bus that runs in Hullbridge.

On the South side of the village there are no recreation areas and a lack of pavement and crossings, which with the increase in vehicles due to the current development and lack of speed restrictions has made it more dangerous for pedestrians than it was before.

So you can see that Hullbridge hasn’t got adequate infrastructure now so will certainly not be able to cope with any more development and serious consideration must be made to look at alternative options.

>> I write in response to the above.
>>
>> Firstly, with regard to the Vision Statement for Hullbridge - There was no consultation with our community before this vision was prepared - why was this not done? The vision I have is for Hullbridge to remain a village with an improved public transport system keeping the coastline as it is for residents and visitors to walk along and enjoy the unspoilt views.
>>
>> I believe the most appropriate option of the 4 options RDC have suggested for the new local plan is to build all housing in one location whereby the infrastructure can be built to meet the requirements needed for these new developments. Looking at the map it would seem North of Southend appears to have far more land. This would be far more sensible than to start adding bits onto existing towns/villages and then having to add appropriate infrastructure with all the disruption, noise and pollution this would cause.
>>
>> The infrastructure in Hullbridge is not adequate now, let alone when the new development of, I believe, 500 properties are finally completed from the previous Local Plan! This has caused significant strain on public services, roads etc. Yet the Council have failed to complete transport and sustainable infrastructure assessments prior to this consultation.
>>
>> Hullbridge is already noticing the effects that increased housing has caused and the development is not even complete! The strain to our primary school (we have no secondary school) and to our medical centre.
>>
>> The road infrastructure in Hullbridge cannot be improved upon. We have one road that runs through Hullbridge from Rayleigh to Hockley and one road that leads from Lower Road to the river (Ferry Road). These roads cannot be improved upon. It doesn’t take much for the whole village to be gridlocked or cut off if there is a problem. The sinkhole in Hullbridge Road this year is a good example where you could only get out of the village via Hockley causing significant problems not only in Hullbridge but in Hockley and beyond. Similarly, only yesterday, a road accident on Lower Road caused the road to be blocked and when vehicles tried to go through back roads all those roads became totally gridlocked. When the current development is finished we will have a lot more traffic on our one road in and out of the village so more chance of this sort of thing happening more often. Let alone having even more developments in future Local Plans.
>>
>> A lot of Hullbridge is Green Belt and Coastal Protection Belt. Any further developments would harm these areas and impact on natural habitats.
>>
>> With regard Critical Flood and drainage risks - Hullbridge will have a significant proportion of the village below sea level by 2040.
>>
>> Public transport in Hullbridge is not adequate. There is no public transport whatsoever that runs down Lower Road towards Hockley. There is now no school bus that runs in Hullbridge.
>>
>> On the South side of the village there are no recreation areas and a lack of pavement and crossings, which with the increase in vehicles due to the current development and lack of speed restrictions has made it more dangerous for pedestrians than it was before.
>>
>> So you can see that Hullbridge hasn’t got adequate infrastructure now so will certainly not be able to cope with any more development and serious consideration must be made to look at alternative options.
>>

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Q5. Do you agree with the settlement hierarchy presented?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Q60a. Do you agree with our vision for Hullbridge?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

STRATEGY OPTIONS

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

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

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

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

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

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

SPATIAL THEMES

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

HOUSING FOR ALL


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

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

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

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

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

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

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

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

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

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

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

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

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

EMPLOYMENT & JOBS

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

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

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

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

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

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

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

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

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

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

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

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

BIODIVERSITY

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

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

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

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

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

On-site.

GREEN AND BLUE INFRASTRUCTURE

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

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

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

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

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

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

COMMUNITY INFRASTRUCTURE

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

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

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

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

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

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

OPEN SPACES & RECREATION

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

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

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

All-weather facilities should be considered where
appropriate.

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

The potential sites seem acceptable.

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

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

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

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

HERITAGE

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

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

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

Areas of precious woodland should not be taken for
housing.

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

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

TOWN CENTRES AND RETAIL


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

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

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

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

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

N/A

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

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

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

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

TRANSPORT & CONNECTIVITY

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

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

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

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

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

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

GREEN BELT AND RURAL ISSUES

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

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

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

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

PLANNING FOR COMPLETE COMMUNITIES

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

N/A

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

N/A

How could that improve the completeness of Rayleigh?

N/A

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

N/A

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

N/A

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

N/A

iv. Other

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

N/A

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

N/A

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

N/A

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

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

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

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

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

N/A

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

N/A

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

N/A

iv. Other

N/A

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

N/A

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

N/A

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

N/A

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

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

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

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

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

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

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

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

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

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

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

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

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

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

Dear Sirs

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

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

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

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

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

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

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

Hambro Hill & Close Residents

RE CFS105

Reasons why this land CANNOT be included in the Local Plan.

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

2. Metropolitan Green Belt
- Developments must not negatively impact on the environmental quality of the local area, openness of the Green Belt or the character of the countryside.
- Rochford study: 'moderate' rating for Purpose 1 & 'strong' rating for 2 & 3:
- Checks the unrestricted sprawl of built-up areas
- Prevents Rayleigh & Hockley merging into one another
- Assists in safeguarding the countryside from encroachment.

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

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

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

INTRODUCTION
1.1 These representations have been prepared by Pegasus Group on behalf of Taylor Wimpey Strategic Land 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 Taylor Wimpey’s interests at:
• Site Reference CFS074: Land South of Mount Bovers Lane, Hawkwell

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 and reaffirm the deliverability (suitability, availability and viability) 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 Mount Bovers Lane, Hawkwell, for residential development in the emerging Local Plan.

1.4 These representations build upon and should be read in conjunction with Taylor Wimpey’s previous representations to the Rochford Local Plan-making process, which included high-level technical assessments and an Illustrative Framework Plan. These early representations explained the opportunities available at the above site to deliver 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 in respect of Taylor Wimpey's interests in Rochford.

Question 1: 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 agreed as being required to inform the preparation of a sound Local Plan
capable of effectively addressing local housing need. It is important to ensure the evidence is prepared under a robust and appropriate methodology and is subject
to scrutiny.

2.3 It is noted that the list of evidence includes a Settlement Role and Hierarchy Study (2021); this document is also referenced elsewhere within the Spatial Options document. However, this document is not available on either the consultation webpage or on the full evidence base webpage. This document should be made available for public review and Taylor Wimpey reserves the right to comment further once this document has been made available.

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?

2.4 The strategic objectives identified by the Council are agreed as being broadly logical and suitable for guiding the formulation of strategic policies within the emerging
Local Plan. As will be explored later in these representations, Taylor Wimpey will be able to contribute towards achieving the objectives relevant to residential
development. In particular, Strategic Objective 1 (to deliver sufficient, high quality and sustainable homes to meet local community needs) and Strategic Objective 2
(to plan for the mix of homes needed to support RDC’s current and future residents) will be met through the delivery of a wide range of new open market and affordable homes. It is agreed that the delivery of new homes should be assigned great importance, as the new housing will help to meet existing housing need, improve
housing affordability for all and aid in meeting the economic objectives of achieving new business growth.

2.5 Taylor Wimpey support the reference in Strategic Objective 1 to the need to prioritise the development of previously developed land. However, it should also be
acknowledged that sufficient brownfield sites are not available to meet the District's minimum housing needs in full, as stated in the Spatial Options document and
supported by the RDC Urban Capacity Study (2020). It should be referenced that the National Planning Policy Framework (NPPF, 2021) allows for changes to Green
Belt boundaries through the Local Plan-making process where exceptional circumstances exist (paragraph 140) and where this promotes sustainable patterns of development (paragraph 142). In a district where approximately 70% of the land is Green Belt, some release of Green Belt land may be necessary in appropriate locations to achieve sustainable patterns of development in line with the NPPF.

Question 5: Do you agree with the settlement hierarchy
presented? If not, what changes do you think are required?

2.6 As mentioned in answer to Question 1, the Settlement Role and Hierarchy Study (2021) does not appear to have been made available on the Council's website at the time of writing. Our answer to Question 5 is therefore given without a review of this document, which forms an important part of the evidence base in relation to the specific matter of the settlement hierarchy. The adopted Core Strategy categorises Hockley (including Hawkwell) as a Tier 1 settlement, alongside
Rochford and Rayleigh. The proposed separation of Rayleigh into Tier 1 by itself does not necessarily mean Hockley (including Hawkwell) is not as sustainable. It
cannot be stated at this time whether the settlement hierarchy has been derived using a robust and objective process until the Settlement Role and Hierarchy Study
has been reviewed.

2.7 Notwithstanding the above, Taylor Wimpey considers the settlement hierarchy presented within the consultation document should identify the settlement of
Hockley (including Hawkwell) at or near the top of the settlement hierarchy (i.e. Tier 1 or 2) as per the adopted Core Strategy (2011). This would be commensurate
with the sustainability of this settlement in terms of the important services and facilities required to meet day-to-day needs that are available within accessible
distance for residents of this settlement. Hockley (including Hawkwell) is able to sustainably support additional growth, and its position within the settlement
hierarchy is agreed in that sense. However, the Local Plan process going forward should take care to appreciate that the sustainability of a settlement is not fixed; it can be bolstered as a result of new and additional development, which can help to support the provision of new services or support the vitality of existing services through an increase in use and custom.

Question 6: Which of the identified strategy options do you consider should be taken forward in the Plan?

2.8 Taylor Wimpey supports the aim of the Council to ensure sufficient growth takes place over the local plan period to meet local housing need requirements as based on the use of the standard method to calculate the minimum housing needs for the District in line with paragraph 61 of the NPPF (2021). The Spatial Options document identifies a housing requirement of 7,200 homes (between 2020 – 2040) based on the standard method (i.e. 360 dwellings per annum).

2.9 Moreover, the consultation identifies a potential growth option of up to 10,800 new homes (2020 – 2040), representing the Standard Methodology + 50% which could help drive local economic growth or address unmet needs from elsewhere.

2.10 Taylor Wimpey strongly supports the Council's ambition to explore the opportunity to accommodate additional growth above that required by the standard method, to take on unmet need from neighbouring authorities in accordance with the NPPF requirement for Local Plans to be positively prepared. The neighbouring authorities are highly constrained both geographically and spatially, such as through large areas of Green Belt and areas of high flood risk. In general, the neighbouring
authorities have faced significant challenges in delivering sufficient levels of housing to meet identified housing needs. Southend-on-Sea to the south of Rochford District is particularly constrained with tight boundaries leaving limited available space for new development. Southend has a minimum housing requirement using the Standard Methodology of 1,180 new homes per annum and highlighted within their recent Local Plan Reg 18 consultation (2019) that even with Green Belt release, Southend will only be able to deliver around 20,000 new homes and that to meet their full requirements, neighbouring authorities such as Rochford will need to assist in the delivery of the additional 3,620 dwellings in the period 2020-2040. Rochford District will therefore need to make all possible efforts to accommodate housing above the levels required by the standard method to encourage economic growth and/or meet unmet needs arising from neighbouring authorities, acknowledging that this is a minimum requirement in light of the national priority to significantly boost the supply of housing in line with paragraph 60 of the NPPF. This will ensure the Local Plan is capable of meeting both Rochford District's needs as well as unmet need arising from Southend-on-Sea.

2.11 Taking the identified strategy options in turn. Option 1 (Urban Intensification) would not deliver a sufficient level of housing to meet identified needs, and it is
agreed that following this strategy would not result in a Local Plan being put forward that is sound in accordance with national policy. The strategy also relies too heavily
on committed developments and there is a risk that these developments will not deliver the expected levels of housing during the Plan period, with significant adverse social and economic impacts on the District as a result.

2.12 Option 3 (Concentrated Growth) is also not supported. It is considered that pursuing a growth option that focuses solely on the three towns Rayleigh, Southend and Rochford, would not lead to a sustainable level of growth. The Plan should seek to meet the needs of residents across the entire District; existing residents are likely to want to buy a home close to their existing ties to the local community and family. New growth should therefore be sensibly dispersed across the District to all settlements. Furthermore, Option 3 would lead to a high reliance on a few key strategic sites. Such large scale sites are likely to have slow rates of delivery; this
would make it difficult to meet the local housing requirement and maintain the rolling 5-year supply of housing required by paragraph 68 of the NPPF. Strategic
sites may also be subject to other risks to delivery, such as viability if the sites are also required to fund pieces of strategic infrastructure. In addition to delivery, this may also affect the level of affordable housing such strategic sites are able to deliver.

2.13 Option 2 (Urban Extensions) is strongly supported as it presents a strategy that would allow for sustainable growth to take place across the District, including the
organic growth of smaller settlements. This would allow the delivery of the Districts local housing needs as required by national policy for a sound Local Plan to be
adopted. The delivery of housing to meet local need would ensure the exceptional circumstances required for the release of land from the Green Belt could be met. It
is considered reasonable to disperse growth to all settlements as guided by the settlement hierarchy. This would ensure growth takes place in the towns and large
settlements that have the services and facilities needed to sustainably support a higher level of growth, while also ensuring smaller rural settlements can organically
grow in the manner required to sustain the vitality of the villages and meet the housing needs of local residents.

2.14 Taylor Wimpey is also in broad support of Option 4 (Balanced Combination) which combines elements of the above three options. A balanced combination of all
options would negate the negative outcomes of Option 1 not delivering sufficient levels of housing growth, as well as the risks associated with Option 3's reliance on a few key strategic sites. It would still allow for sustainable growth to take place in a dispersed manner across the District. It would however be key to get the balance
between the different options correct. It may be that under option 4, there is a need to ensure sufficient smaller urban extensions are allocated so they can be
brought forward early in the plan period to ensure there is no heavy reliance on the delivery of large strategic sites – as there are still risks associated with under-
delivery on large sites. A balanced approach to allocating a variety of sites both in terms of size and location will also have far greater potential to deliver a wide mix
of housing types and styles.

Question 9: Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?

2.15 In answer to the first part of question 9, Taylor Wimpey agrees that a sequential approach needs to be applied in allocating sites, as required paragraph 161 of the NPPF. This should be recognised as placing a further constraint on potential suitable land available for development and further necessitating the release of suitable Green Belt to ensure sustainable development can take place.

Question 11: 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?

2.16 Taylor Wimpey fully supports the transition towards a zero carbon economy and for new development to be as sustainable as possible, which includes new homes
that are energy efficient and minimise carbon emissions. Taylor Wimpey is committed to being a sustainable housebuilder and continues to incorporate sustainability into their business practices, helping to create better homes and communities and a stronger business for the longer term.

2.17 It should be recognised in the emerging Local Plan that before thinking about how 'green' the energy used is, it should first be considered how energy use itself can
be minimised. This includes ensuring the construction of homes is undertaken in a manner that allows the effective retention/insultation of heat in the winter and
natural cooling in the summer, ensuring less energy is required to heat the home and take a fabric first approach in the design of houses to further improve energy efficiency. All of these measures are secured under the relevant Building Regulations, an uplift to which will be secured through the implementation of the
forthcoming Future Buildings Standards.

2.18 The need to require development to source a percentage of their energy requirement from low-carbon and renewable sources should be assessed against
the above energy efficiency requirements. The actual percentage should also be calculated with regard to potential impacts on the viability of future developments,
and the financial costs for implementation will need to be considered in the Local Plan Viability studies.

Question 12: Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?

2.19 As explained above, the forthcoming new Building Regulations, which all development will be required to comply with, will ensure that all new homes that are built in the future will be built to a high energy efficiency standard. There is considered to be no beneficial need to require energy efficiency standards above those required by the new Building Regulations which will be in place upon adoption of the Local Plan. If the Council is to consider applying higher energy efficiency standards, robust evidence will be required supporting such a requirement. The evidence should include an assessment demonstrating no adverse impact on the
viability of future proposed developments.

Question 14. 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?

Question 15: Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?

2.20 In answer to question 14, Taylor Wimpey has no objections with a District-wide place-making charter that can form the basis for site-specific decision making. The
importance of good design in creating attractive and liveable places is wellunderstood. The place-making charter should clearly appreciate that each site is
unique, with different contexts, constraints and opportunities that will need to be taken into account.

2.21 However, it is not entirely clear what policy position such a charter would hold in the Local Plan and the level of consideration the decision maker will need to give
to the character. Thus, in answer to Question 15, it should be made clear how the charter should be read in relation to specific policies. Then it would be relevant to
consider what principles are appropriate to contain in a charter. At this stage, it is considered that any charter included as guidance should be high-level and
overarching, with specific detail to be provided in the accompanying development management policies. This will avoid the duplication of local planning policies, as
encouraged by paragraph 15 of the NPPF. The local plan policies themselves will need to consistent with the relevant provisions of the NPPF and national guidance.

Question 16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
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?
Question 16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?

2.22 The need to produce design guides, codes or masterplans alongside the new Local Plan is questioned. The production of such documents is likely to take considerable time, particularly if the Council intends to seek to adopt or endorse a design document for each proposed allocation. This would inevitably delay the Local Plan process and delivery of new homes as the Council's resources are drawn away.

2.23 Instead, Taylor Wimpey suggests that design codes or masterplans should only be encouraged at such an early stage for large strategic urban extensions that are of a scale and mix of land uses where a design code document would be helpful in regularising design principles across the entire site and/or ensuring a coordinated approach to the delivery of strategic allocations where multiple landownerships/interests are present.

2.24 For smaller scale extensions and developments (i.e. single ownership developments of <500 dwellings), it is considered that the masterplans and other design material that is submitted at the planning application stage, which may include Design Codes prepared by the Applicant in consultation with RDC and the local community at the Planning Application stage, would be sufficient for allowing the Council to provide input and ensure the correct design principles are being delivered.

Question 17. 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?

2.25 Taylor Wimpey considers that proposed Option 2 would provide a suitable approach to address the District’s housing need. This option would allow an element of certainty that overall housing needs will be met, while also allowing flexibility for local site-specific factors to influence the housing mix a development provides at the application stage. These factors could range from site-specific environmental or technical constraints and opportunities to local market intelligence and demographics indicating a need for certain types and tenures of housing. Option 2 would align with the NPPFs objective of creating strong, vibrant and healthy
communities (paragraph 8) that are mixed and well-balanced (paragraph 63).

2.26 However, it is considered that Option 3 would also operate well in conjunction with Option 2. Allocating specific sites for specialist housing for older people and selfbuild and custom-build housing in particular would allow the housing need to be addressed where it is most needed, which is in line with the recommendations of
the Planning Practice Guidance.

2.27 Taylor Wimpey further support Option 5 which requires all homes to be built to Nationally Described Space Standards, Option 6 requiring all homes to meet Part M4(2) (accessible and adaptable homes), and Option 7 requiring a suitable proportion of new homes to meet Part M4(3) (wheelchair user dwellings). However,
as is required by the NPPF (footnote 49) and supporting national guidance, these options will require sufficient evidence to be gathered and provided by the Council
to support the need for these requirements, and whether it is appropriate for all homes to meet these requirements rather than a proportion of new homes. As footnote 49 states, the Council will need to demonstrate through robust evidence that there is an identified need that would be met through the application of the Part M4(2) and Part M4(3) optional standards. The need to apply the internal space standards must also be justified. The Planning Practice Guidance expands on this to explain that the evidence produced must also take into consideration viability and site-specific factors in addition to need, ensuring that the application of these additional standards does not risk the delivery of new homes.

Question 31. 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?

2.28 Taylor Wimpey considers it is for the Council to undertake research and identify a suitable pipeline of sites towards which off-site biodiversity net gain contributions could be made. Biodiversity net gain should be delivered on-site wherever possible; however the possibility of off-site net gains should not be discounted for developments that are constrained geographically or by viability or other factors. Taylor Wimpey is committed to protecting and enhancing the biodiversity of its sites wherever possible.

2.29 Taylor Wimpey recognises that climate change, declining nature and other environmental problems are increasingly becoming a threat to the wellbeing of
people today and future generations. In respect of Land south of Mount Bovers Lane, Hawkwell (CFS074), Taylor Wimpey has commissioned an initial Phase 1 ecology survey and assessment (Appendix A) which demonstrates the potential for a measurable biodiversity net-gain to be delivered on the site through habitat
creation and restoration. Developments which can demonstrate Biodiversity Net Gain should be looked upon favourably by RDC both when allocating sites within
the emerging Local Plan and when determining schemes at Planning Application stage.

Question 34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?

2.30 In respect of Option 3 which requires new developments to provide on-site green and blue infrastructure, and/or contribute towards off-site green and blue infrastructure. Taylor Wimpey supports the provision of such local infrastructure, which can help to mitigate the impacts of flooding and contribute towards creating and improving wildlife habitats and enhancing the character and appearance of newdevelopment.

2.31 Land south of Mount Bovers Lane, Hawkwell (CFS074), is capable of contributingtowards the objective of creating enhanced local green infrastructure. As indicated on the Illustrative Landscape and Ecological Masterplan (Figure 9, Appendix B) the site has the potential to enhance the existing vegetation on the site through new planting such as shrubs, wildflower grassland and hedgerow. The landscape proposals also provide a new community orchard, new woodland planting and tree lined streets. These improvements to green infrastructure would help deliver the objectives of the South Essex Green and Blue Infrastructure Strategy, in particular the creation of the Central Woodlands Arc Regional Parkland and enhancements to the Upper Roach Valley to create a successful ‘green lung’ through the District.

Figure 1: Illustrative Landscape and Ecological Masterplan
[see document for image]

2.32 This local green infrastructure would enhance existing biodiversity, create an attractive landscaped setting for the new homes and enhance the leisure
opportunities available for both new and existing residents in Hawkwell, thereby delivering wider health and well-being benefits also. The site provides opportunities for links to be provided to the existing Public Rights of Way network located on the site boundaries, which will improve permeability and ease with which access can be gained to the wider countryside.

2.33 In terms of blue infrastructure, the submitted information further indicatively shows that the scheme has the potential to provide a network of ponds or swales that could create a new 'blue' corridor within the open space to the west. These ponds would complement the SuDS basins that will be provided within the developable,
eastern part of the site to deliver additional benefits. The blue infrastructure would help to mitigate the risk of flooding by assisting with the flow of water away from
homes, as well as provide ecological enhancements and assist in creating a naturalistic open space area to be enjoyed by residents.

2.34 It is noted that Option 3 states 'certain new developments' will be required to provide or contribute towards local green and blue infrastructure projects. As this objective is developed into a policy, it will be important to ensure that the threshold where Option 3 will apply to developments is made clear.

Question 35. 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?
Question 36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?

2.35 Taylor Wimpey supports in principle the options that are suggested for meeting community infrastructure needs through the Local Plan. The options should be
maintained as being non-exclusive, so flexibility can be maintained to allow infrastructure needs to be met in the most appropriate manner for each settlement and site location.

2.36 The infrastructure that will be required to support the delivery of Taylor Wimpey's interests in Hawkwell will be set out in further detail in the Infrastructure Delivery
and Funding Plan that is to be prepared by the Council. However, Taylor Wimpey is committed to investing in complementary infrastructure that is evidentially
required to support the delivery of new homes at this location. It is noted that
Hockley (including Hawkwell) is a sustainable settlement containing many of the services and facilities required to support the day-to-day needs of residents.
Contributions could be made towards this existing infrastructure as required to ensure sufficient capacity exists for the services to continue supporting existing and
new residents. The site also has the potential to provide new community infrastructure, such as land for education and/or healthcare which will complement existing facilities, subject to viability and clear evidence that additional infrastructure is required.

Question 38. 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?
Question 41. 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?

2.37 The proposed Option 4 is of direct relevance to Taylor Wimpey in this instance, as it suggests requiring new developments to provide new open space or contribute towards enhancing existing infrastructure. Taylor Wimpey fully supports the objective of ensuring the open space and recreation needs of residents are met.

2.38 As illustrated on the submitted Development Framework Plan (Appendix C), the masterplanning for the site has been heavily influenced by the landscape strategy. This strategy seeks to maintain and enhance existing green infrastructure as explained in our response to Question 34 above. Nearly 50% of the site area is to
be maintained as green infrastructure and public open space, significantly above planning policy requirements. This will have the dual benefit of creating a defensible
boundary with the Green Belt, and creating new public open space to be enjoyed by all members of the local community, delivering enhanced opportunities for
recreation and social interaction, alongside the health and well-being benefits this brings.

2.39 In addition to the amenity green space that can be enjoyed for both leisure and activity, circular footpaths will be provided around the open space to encourage
walking within and through the open space. New woodland and orchard planting will provide visual amenity within the open space, as will the 'blue corridor' of ponds or swales. Formal play areas will be provided in accessible locations within the scheme, that will be open for use by all residents both new and existing. This will
therefore help to increase access to play space for residents of Hockley (including Hawkwell) in the vicinity of site CFS074. The objectives put forward by the Council are supported by Taylor Wimpey as contributing towards meeting the requirement in the NPPF (paragraph 92) for healthy places with accessible green infrastructure.

Question 46. 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?

2.40 Taylor Wimpey supports the objective of ensuring the continued vibrancy of the District's town and neighbourhood centres, including those at Hockley and
Hawkwell. We do not seek to provide an opinion on how the Council can best plan to achieve this objective, however it is considered important to understand that
new growth is required if vibrancy and vitality is to be maintained. This will bring new custom for existing businesses in centres, and provide opportunities for new
business to come forward.

Question 51. 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?

2.41 Taylor Wimpey considers the options presented are logical approaches to explore further towards the goal of improving connectivity within the District. Option 2 is
relevant to Land South of Mount Bovers Lane, Hawkwell, and Taylor Wimpey would support appropriate contributions that are evidenced by a robust Infrastructure Delivery Plan as being required to support the development.

2.42 It is to be noted however that Land south of Mount Bovers Lane (CFS074) is located in a sustainable location that benefits from convenient access to local services and facilities via various modes of sustainable travel. This is demonstrated in the Sustainability Appraisal which accompanies these representations (Appendix D).

2.43 There are pedestrian and cycling routes leading towards the centre of Hawkwell where several services are located within comfortable walking or cycling distance of the site. This would reduce the reliance on day-to-day travel by private car. For locations further afield, travel by bus and train is available from bus stops adjacent to the site and Hockley train station located around 20 minutes' walk from the site. Both modes of public transport receive frequent services.

Question 58a. Do you agree with our vision for Hockley and Hawkwell? Is there anything you feel is missing?

2.44 The vision statement presented is broadly supported and as highlighted above site CFS074 provides clear opportunities to contribute positively towards the green lung of the Upper Roach Valley through the provision of new woodland landscaping and
biodiversity net gain. Moreover, the aim to address housing affordability is fully supported, but will only be addressed through the provision of viable market
housing developments capable of delivering Affordable Housing.

Question 58b. With reference to Figure 46 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Hockley and Hawkwell?
i. Housing [market, affordable, specialist, traveller, other]
ii. Commercial [offices, industrial, retail, other]
iii. Community infrastructure [open space, education, healthcare,
allotments, other]
iv. Other

2.45 As mentioned in answer to Question 6, Taylor Wimpey supports following a strategy that allows growth in all settlements across the District, including Hockley and Hawkwell, at a level that is appropriate to the sustainability of each settlement. Hockley and Hawkwell is identified within the adopted Core Strategy (2011) as a
Tier 1 settlement, and the current Spatial Options Document proposes Hockley (including Hawkwell) as a Tier 2 settlement below only Rayleigh. This is
commensurate with the settlement being one of the most sustainable in the District, and its ability to support additional housing. It is clear that Hockley and
Hawkwell are eminently sustainable, as illustrated on Figure 43 which shows that residents are within walking distances of the range of services and facilities that
are available.
[see attached document for image]

2.46 For this site in particular, the following range of services and facilities are located close to the site, as further expanded within the accompanying Sustainability
Appraisal (Appendix D):
[see attached document for table showing accessibility from site to key destinations and facilities]

2.47 Hockley Train Station is also located just 1.5km / 20-minutes walking distance to the north.

2.48 Hockley, which is in close proximity to the site, supports a further range of local retail and employment opportunities.

2.49 On this basis, Taylor Wimpey strongly supports the 'allocation' of site reference CFS074 for up to 400 new homes and significant green infrastructure as illustrated
below. The site is also capable of contributing towards appropriate on-site or offsite social / physical infrastructure if further evidence demonstrates a need for such infrastructure.
[see attached document for masterplan of site]

Site Deliverability
2.50 The suitability and benefits of this site have been comprehensively presented in previous submissions to the Local Plan-making process, including in
representations to the Regulation 18 Issues and Options Consultation in 2018. This submission was accompanied by technical input and Taylor Wimpey are committed
to working collaboratively with the Council to ensure the timely delivery of the proposed allocation. The following seeks to further reiterate the deliverability and
suitability of the site for residential development in response to the 'scoring' of the site in the RDC Site Appraisal Paper (2021) as presented below. The scores given follow a scale as replicated in the figure below
[see attached document for screenshot of site appraisal criteria]

Drainage
[see attached document for screenshot of site appraisal scores]
2.51 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, and the score of 5 (best performing) is agreed with.

2.52 The score of 2 for 'critical drainage risk' appears to have been informed by a highlevel view of the surface water flood risk for the site. Mapping on the Environment
Agency long term flood risk website illustrates that the central valley of the site is associated with low to medium risk of flooding from surface water, with some areas
on the eastern boundary and areas within the western half of the site being associated with low to high risk of flooding from surface water.
[see attached document for screenshot on EA surface flood risk map]

2.53 However, 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 Illustrative Landscape and Ecological Masterplan (Appendix B) illustrates how the
matter of surface water flood risk can be mitigated, through the inclusion of SuDS basins and swales through the centre of the site where the valley is located. The
location and design of the basins and swales 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.

Green Belt and Landscape Impact
[see attached document for screenshot of site appraisal criteria]

2.54 The site is located within the Green Belt, albeit being directly adjacent to the existing settlement edge of Hawkwell. It is acknowledged that the Green Belt
designation carries significant weight as a material consideration, with the NPPF being clear that Green Belt boundaries should only be altered in exceptional
circumstances (paragraph 140). The site is also located within the Upper Roach Valley Landscape character area which seeks to protect a ‘green lung’ and landscapes of value (noting it also aims to promote recreation).

2.55 As explored earlier, Rochford District is highly constrained with limited opportunities to accommodate sufficient levels of growth outside the Green Belt.
The evidence base produced by the Council indicates there are not sufficient nonGreen Belt sites available to meet local housing needs. The Urban Capacity Study
(2020) found that urban sites may deliver between 3,300 and 5,000 sites over 10-
15 years. The Council has identified the need for a minimum of 7,200 new homes to be delivered over the Local Plan period, and at least 10,800 homes when a buffer is applied and the potential to accommodate unmet need from neighbouring authorities is taken into account, as Taylor Wimpey considers is required.
Furthermore, the most sustainable sites that are going to be available for potential allocation and development will be within the Green Belt, as the settlements identified in the settlement hierarchy as being the most sustainable and capable of accommodating new growth lie within the Metropolitan Green Belt.

2.56 There will be harm associated with the release of Green Belt land. However, the inherent shortfall in brownfield land available for development and the ability of Green Belt land to delivery sustainable patterns of development provides, in our view, the exceptional circumstances required to amend the Green Belt boundary.
The Green Belt Study (2020) prepared by the Council concludes (the Stage 1 Assessment) by stating at paragraph 3.39 that other than a few pockets of Green
Belt, the majority of the assessed land continues to serve the Green Belt purposes well.

2.57 It is noted here that our 2018 submissions included an independent Green Belt Assessment of the site which concluded that the site makes limited or no contribution to four of the Green Belt purposes, except for purpose 3 'safeguarding the countryside from encroachment' to which it was considered a partial contribution is made. Taylor Wimpey considers this appraisal remains valid and the value of this site to the Green Belt is limited and that any harm arising from its removal from the Green Belt would also be limited.

2.58 Notwithstanding this, paragraph 3.39 of the Green Belt Study (2020) does go on to state that the most sustainable sites for potential allocation may be located in areas that make a strong contribution to the Green Belt purposes. The contribution that a site makes must therefore be weighed against other relevant factors that
determine the suitability of a site for development, such as the existence (or lack thereof) of site-specific constraints, proximity to sustainable settlements and
transport connectivity.

2.59 A Landscape and Visual Appraisal, including Green Belt Appraisal (Appendix B), has been prepared to accompany these representations. The report considers the landscape and visual constraints the site is subject to, based on the potential impacts arising from the proposed development. This appraisal has in turn informed the creation of an Illustrative Landscape Masterplan, which demonstrates that a residential scheme that is led by robust landscape principles can be created that will be 'physically contained and have clear defensible boundaries', as well as make 'a positive contribution to the recreational aspects of the landscape in respect of the Upper Roach Valley.' A significant area of open space is proposed on the western half of the site (far in excess of policy requirements) which will further
contain the built form to remain in line with the existing extension of the settlement edge into the landscape.

2.60 With the implementation of the proposed landscape strategy, which will be formulated further as detailed design takes place, to create an appropriately designed residential scheme, the Appraisal demonstrates that the site would have only limited landscape and visual effects at a localised level and that such impacts can successfully be avoided or reduced through appropriate mitigation. The proposed inclusion of substantially improved areas of local green and blue infrastructure in addition to open greenspace will also allow the creation of a defensible Green Belt boundary, limiting the risk of additional 'sprawl' as well as creating an appropriate interface between the settlement edge and the wider
countryside.

2.61 Consequently, development of site CFS074 would complement the character of the wider landscape context and enhance the function of the Upper Roach Valley's as
a 'green lung' through the District. Any limited impacts can be mitigated and enhanced through the proposed landscaping strategy, with recreational benefits
arising from the proposed green infrastructure which will provide new health and wellbeing outcomes for existing and future residents of Hawkwell. An appropriate,
robust and enduring boundary to the Green Belt can therefore be created.

2.62 As such, the low scores given on Green Belt and Landscape Impact by the RDC Site Appraisal are challenged for the reasons set out above and should not preclude consideration of the site for allocation. Notwithstanding this, the discussion on other factors in answer to question 58b clearly demonstrates the suitability and sustainability of the site; this must be weighed against the potential harm caused to the Green Belt and in our opinion provides sufficient reason for further consideration of this site in later Local Plan stages.

Biodiversity
[see attached document for screenshot of site appraisal criteria]
2.63 Taylor Wimpey supports the scores given to the site relating to biodiversity. A Preliminary Ecological Appraisal has been undertaken which confirms that that the site is of limited ecological interest.

2.64 The proposed strategy set out in the Illustrative Landscape and Ecology Masterplan would therefore have the benefit of providing a measurable improvement of habitat and biodiversity net gain on the site.

2.65 The site itself is not covered by any statutory habitat designations. However, the site is located close to the Hockley Woods SSSI which is a nationally designated
ancient woodland. While development of the site would not result in any direct impacts on the SSSI, there is the potential for indirect impacts through additional
recreational pressure resulting from new residents. The site proposes to provide a significant amount of greenspace on the site, which will effectively mitigate the
recreational pressure that might otherwise be generated on surrounding environmental designations.

Heritage
[see attached document for screenshot of site appraisal criteria]
2.66 The scores relating to heritage are not considered to be accurate. A Heritage Statement has been prepared (Appendix E) which contains an assessment of potential impacts arising from the proposed development on the historic environment. In terms of archaeology, a review of the available recorded data indicates that there are unlikely to be any below ground remains which are of
historical interest. The potential for significant archaeological remains from any historical period is considered to be low. The score relating to impact on
archaeology should therefore be a 5 (i.e. best performing), as any potential impacts can be comfortably mitigated by way of a planning condition at the planning
application stage, which would control development of the site until the desktop findings have been confirmed through further investigation.

2.67 In terms of built heritage, there are a few Grade II listed buildings in the vicinity of the site but only two that may be impacted by the proposed development. The
Grade II listed Sweynes Farmhouse is located north-east of the site, however it is considered the site does not contribute to the significance of this asset and is not
a constraint to development of the site. The Grade II listed Mount Bovers is located to the west and a small part of the site was historically associated with the function of the heritage asset. To preserve the significance of the listed building, it is therefore proposed that a setback is maintained in the western part of the site, with an associated enhancement of vegetation on the north-western boundaries. As the emerging masterplan for this site proposes the retention of the entirety of the western half of the site as open greenspace with significant new planting, this setback will be comfortably provided for and maintained and it is considered that there will be no impact on this designated heritage asset. The score relating to built
heritage should therefore be at least a 4 (better performing).

Sustainability
[see attached document for screenshot of site appraisal criteria]
2.68 The scores relating to the sustainability of the site are broadly agreed with, although a Sustainability Appraisal (Appendix D) has been prepared which refutes
the scores given on some elements, as will be explored below.

2.69 The existing bus stops are located close to the site boundary on Main Road and Hall Road, at most around 10 minutes' walk for homes located furthest from the Hall
Road bus stop – with most homes being located at a much closer distance. Given the close proximity and convenient access to bus stops the score should be a 5
(best performing).

2.70 Similarly, the score for access to bus services is currently too low and should be at least a 4 (moderate positive). The no.8 bus service provides a regular and frequent service (every 30 minutes) on a weekday, allowing convenient access towards Hockley Town Centre, Rayleigh, Southend-on-Sea and Great Wakering. This bus service provision also means the score for access to town centre should be at least a 4 (moderate positive) rather than 1 (negative), as Hockley town centre is very accessible from the site, if not by bus then also by walking and/or cycling.

2.71 Other bus services are also available, and whilst less frequent they provide travel options to other settlements. There are bus shelters available for 3 of the 4 closest bus stops to the site, with the potential for improvements to be made to encourage use of the bus services.

2.72 The bus services available include providing travel to Hockley train station, which is otherwise around 20 minutes' walk from the site. This is considered to offer good access, making travel by train to settlements further afield or for commuting a feasible option. Indeed, the station provides frequent and regular trains towards
Southend Victoria and London Liverpool Street. The score for access to train services should be at least a 5 (positive).

2.73 The score of a 5 for access to walking infrastructure is strongly supported; the site is extremely well-connected and as the evidence within the Spatial Options Document illustrates there are plenty of opportunities to walk to everyday services and facilities within Hawkwell or even to Hockley centre. The footways are of a good quality and attractive, being safe and traversable. The score of 3 (moderately performing) for cycling is accepted, as while the roads in the vicinity of the site are suitable for cycling to local facilities, there is no formal infrastructure that can be utilised to encourage cyclists with less confidence.

2.74 The relevance of the scoring for access to the strategic road network is not clear. The A127 and A130 are accessible from the site, and are of a similar distance from the current site as they are from elsewhere in the district. The sustainability of the site lessens the reliance on the strategic road network. Furthermore, this is a
residential scheme where trips for day-to-day needs will be made locally – the SRN is not as significant as it would be for an employment scheme.

2.75 Turning to the scores given for access to facilities such as primary school, healthcare and any other centre (in this instance Hockley centre). The scores given are broadly agreed with as they acknowledge the sustainability of the site given the close proximity of these services. It should be acknowledged however that
certain services within Hockley centre such as the Co-Op (Supermarket), Pharmacy and Post Office are very close to the site (around 10 minutes' walk) and could
therefore be given a score of 5 (best performing). Similarly, the Practice Hawkwell (health centre) is also around a 10-15 minutes' walk from the site and could also be given a score of 5 (best performing) rather than a 4 (moderate positive).

2.76 With respect to the secondary school, the closest is Greensward Academy which is up to 30 minutes' walk or 10 minutes' cycle from the site. However, the journey
can also be made by bus in around 11 minutes (not accounting for waiting time). This is considered to be relatively normal travel times for a secondary school, where journeys are made independently by older children by bike, bus or walking. The score of 1 should therefore be at least a 4 (moderate positive) to reflect this.

2.77 Turning finally to employment, the score of 2 (moderate negative) is contested. Firstly, there has been a noticeable shift to homeworking which means there is less need for reliance to be placed on workers needing to be close to their place of employment. Nevertheless, there are employment sites located in the north of
Hockley within an accessible distance from the site and regular train services into London from Hockley Station as highlighted above, and this score should therefore
be upgraded to 4 (moderate positive).

2.78 In summary, these representations expand upon previously made submissions to demonstrate that Land south of Mount Bovers Lane, Hawkwell, is capable of
delivering a residential development in a sustainable and accessible location. Exceptional circumstances exist for the Local Plan to release land from the Green Belt, and the evidence submitted demonstrates development of this site will not adversely harm the Green Belt and a sensitively designed landscape-led scheme will help to mitigate and enhance the local landscape and deliver biodiversity net gain, alongside recreational improvements and the associated health and wellbeing outcomes this brings for existing and future residents. The District, and Hockley (including Hawkwell) in particular, has a pressing housing need and
affordability issue, which the delivery of this site can contribute significantly towards addressing. The site is capable of being delivered in the early stages of the
new Local Plan period, and Taylor Wimpey is willing to collaborate closely with the Council to ensure this can be achieved.

Site Availability
2.79 The site remains under single ownership and comprises managed agricultural land on the southern edge of Hawkwell. There are no legal constraints to the availability of the land for development.

2.80 The landowner is willing to make the site available for development and the site is under option and being promoted by Taylor Wimpey, one of the UK’s largest housebuilders, through the emerging Local Plan in addition to engaging with local stakeholders as part of this process.

2.81 The expertise offered by Taylor Wimpey ensures that subject to the removal of the current Green Belt designation through the Local Plan-making process, that the site will be available for development immediately and capable of delivering new homes in the early part of the New Local Plan.

Site Viability
2.82 The site will be expected to contribute to the provision of infrastructure, through a variety of mechanisms, including Section 106 and Section 278 Agreements, Community Infrastructure Levy (CIL) and appropriate Planning Conditions, provided such conditions are necessary and relevant to the proposed development and also where Planning Obligations are:
i) Necessary to make the development acceptable in planning terms;
ii) Directly related to the development; and
iii) Fairly and reasonably related in scale and kind to the development.

2.83 The full Infrastructure requirements in relation to this site are as yet unknown but will be set out within RDC’s forthcoming ‘Infrastructure Delivery Plan’.

2.84 The site comprises managed agricultural land (i.e. Greenfield land) and accordingly, it is not anticipated that there will be any abnormal costs associated with the
development of this site as may be expected on previously developed (brownfield) land.

2.85 As such, and subject to further ongoing site investigations and review of RDC’s Infrastructure Delivery Plan, CIL, Local Plan Viability Assessments and emerging Planning Policy wording once finalised, which will provide further details with regards to likely infrastructure requirements arising from the development of the site, it is to be anticipated that the site will be capable of delivering the Council’s emerging policies, including with regards to Affordable Housing provision.

3. SUMMARY AND CONCLUSIONS
3.1 This representation has been submitted on behalf of Taylor Wimpey Strategic Land in support of their land interests at:
• Site Reference CFS074: Land south of Mount Bovers Lane, Hawkwell

3.2 The representations respond to the questions raised by the consultation to reaffirm the deliverability (suitability, availability and viability) of the above sites and set out the exceptional circumstances in support of a minor revision to the Green Belt. The representations support the taking forward of this site to create a site-specific policy that allocates the site for residential development in the emerging Local Plan to deliver a high-quality and sustainable residential development to contribute positively towards meeting the District’s significant housing needs.

3.3 Site CFS074 represents a deliverable site and Taylor Wimpey is keen to work collaboratively with RDC and local stakeholders in the preparation of the new Local
Plan to ensure a positive policy position for the site is taken forward to deliver real benefits for the local community and the District as a whole.

NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION PAPER: 2021

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

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

This is due to :-

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

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

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

Cultural Characteristics

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

Environmental Characteristics

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

Economic Characteristics

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

Draft Strategic Priorities/Objectives for 2050 p.21

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

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

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

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

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

Strategic Objective 2

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

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

Strategic objective 4

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

Strategy Options

Hierarchy of Settlements

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

Growth scenarios

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

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

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

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

Planning for housing growth

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

Planning for economic and retail growth

Completed Area Action Plans have provided enough retail space.

Levels of growth needed to deliver infrastructure

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

Spatial Strategy Options

1. Urban intensification

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

2. Urban extension Would sacrifice Green Belt

Option 4

Your comments at CONS say it all.

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

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

Climate change and resilient environments

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

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

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

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

Place-making and design Q14-16

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

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

Housing for all

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

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

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

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

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

Need for affordable housing

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

Employment and Jobs

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

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

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

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

Future of Southend Airport

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

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

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

Green/Blue Infrastructure

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

Q.35-37

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

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

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

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

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

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

Heritage

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

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

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

Town centres and retail

Plan Objectives

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

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

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

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

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

Transport and connectivity

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

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

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

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

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

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

Green Belt - Rural Issues

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

Planning for Complete Communities

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

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

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

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

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

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

Transport, Homes, Infrastructure, Bio-diversity

1. Rayleigh is already an over-developed area. More housing being built in Hall Road and Rawreth lane sites.
2. No infrastructure considerations - utilities, medical resources, roads, open spaces etc.
3. AIR POLLUTION. Air quality is already very poor in our area -queuing traffic - Crown Hill, Daws Heath Road and Castle Road (fir re-cycling centre) etc. More traffic will increase congestion and air pollution even worse.
4. Housing. Garden village, option 3a and 3b supported. Away from existing suburban sprawl. Co-operation with Southend in option 3a and 3b areas would be good for Rochford District and relieve extra pressure on Rayleigh.
5. Environment. Protection of wildlife habitats are being destroyed by over-development. Plant more trees for improved air quality and wildlife.
6. Well designed open spaces / parks for all ages.
7. Housing - use of brownfield sites; re-purpose empty houses / flats unoccupied for more than 2 years.
8. Town centre (Rayleigh). Encourage more independent retailers by offering fair, not exorbitant rents from greedy landlords.

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

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

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

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

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

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

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

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

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

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

Climate Change
So many recent reports from established bodies highlighting the grave concerns over climate change, I believe the Local Plan should be put on hold and the Council should concentrate on climate change issues. Councils should await the outcome of the meeting of many nations on this subject later in the year.

Homes
Once again, the number of houses proposed to be built is so very high. There is already over development in the area and this latest number must be reduced. No building on green belt or arable land should be allowed. the mantra must be "build in better places" and not "build back better". Many people in the district now have further worries of how the Plan will affect thir quality of life.

Social Care
This is a major problem at the moment with the Government at present, raising taxation as a means to fund this care. The pressure that further homes in the area would have on providing social care would be considerable.

Transport
The Council must provide an infrastructure assessment Plan so that a sound analysis can take place before land allocations are suggested for housing.

The strain on public services, roads etc and will education services have the capacity to cope.

Our roads are already crowded with traffic volumes on the increase and air pollution will have health affects on residents.

Open Spaces
Must be improved or, at least kept in good order. An expansion in open spaces would be so welcome to our youth who have had to suffer so much during the pandemic. Also, no car parking charges should be levied at open spaces.

Planning
Councils must also have the right to appeal if the Inspector changes their original decision and not be constrained by financial issues. That would help residents and also be a true sense of democracy.

I really hope the Local Plan is postponed due to climate change. Also, it is plain common sense to reduce the number of houses to be built.

I object to the field site (CFS064) being used for housing. Housing on this field site will impact greatly on the traffic flor through the Betts Farm Estate. The B1013 is frequently congested and this CFS064 will increase the traffic. In the event of an emergency it is difficult to navigate swiftly, local residents experience slow moving traffic, increased traffic fumes and delays in journey times. Local doctors and schools are oversubscribed. There is no infrastructure in place to accommodate the additional planned housing. Losing yet more green land deprives residents especially children of footpaths and spoils the woodlands. There is no viable exit/entrance route that does not spoil the environment.
At a time when health of residents and especially children should be a higher priority than building on an area surrounded by woodland and removing the designated pathways would appear to take little account of the need for exercise, nor the hope of encouraging children to take an interest in their environment.

Housing on CFS064 will place 214 houses and probably a minimum of 321 additional cars in a vicinity already experiencing traffic congestion. Minor roads on the estate are not suitable for additional car use. Planning should take account of current residents and certainly of the infrastructure required for an additional 214 houses. Placing possibly 400+ adults and 400+ children requiring local services, this needs careful consideration. Are local services, e.g. fire, police, ambulance, refuse collection, schools, doctors, hospitals, clinics actually able to cope effectively with so many additional demands?

Certainly roads will be overcrowded. Cycling will not be a viable option. Child road safety will become an issue and yet children need to be able to play outside. The plan does not seem to work in the interests of a more healthy and greener Britain.