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?

Thank you for consulting Network Rail on the Rochford District Local Plan ‘New Local Plan Spatial Options Document (as part of the Local Plan). This Network Rail email (and both attached Asset Protection [ASPRO] document and email) is an operational and infrastructure response, as statutory undertaker, covering areas of Level Crossing updates and policy request, as well as safety and the maintaining of the railway.

Local Delivery updates, aspirations and key considerations for policy, including evidence for the Local Plan, securing development-led funding and determining the allocation of CIL payments, is of great value to Network Rail and something we wish to collaborate on further. However, at this initial Spatial Options Consultation stage Network Rail have provided, within the following sub-sections, a high level consultation response (as well as the attached ASPRO document and links below):

Response Sub-Sections
1. Level Crossing Update
2. Level Crossing Policy Request
3. ASPRO Further Information and Links (Including ASPRO Document, Email and Link)
i. Including consultation request of developments near the railway and level crossings, where suitable, beyond statutory minimums

1. Level Crossing Update

Any developments that may increase or alter the usage of the below crossings (including Barbara Close if not extinguished) will require mitigation to be installed, with solutions leading to closure of the level crossings, such as extinguishment, diversion, or replacement with a footbridge) being preferred.

The level crossings in Rochford currently are:
Norman Crescent
Blounts Wood
Blounts Farm
Woodstock Crescent
Barbara Close

Of these, Barbara Close is currently awaiting the Secretary of State's decision on extinguishment under the Network Rail (Essex and Others Level Crossing Reduction) Order 2021.

There are no live closure proposals in respect of the other 4 crossings.


2. Level Crossing Policy Request
Network Rail would seek improvements towards level crossings and level crossing safety. For example,

i. Policies should, where relevant, promote level crossing safety. This will preferably be through solutions which will lead to closure of level crossings, such as the extinguishment or diversion of a right of way or, where not feasible, the installation of a bridge. Where crossing closure by one of these methods is not feasible, mitigations to reduce the risk, such as installation of technology, should be considered.

3. Asset Protection (ASPRO) – Further Information and Links
i. Network Rail, as infrastructure manager within The Town and Country Planning (Development Management Procedure) (England) Order 2015, requests to be consulted on developments, where suitable, near to the railway or which could impact the operational railway beyond the statutory minimum as highlighted in both Schedule 4(j) (level crossing usage) and Schedule 16 (10 metres from relevant railway land).
For further Asset Protection information please find the following attached document, ASPRO email, and information link below:

• The integrity and safety of operational railway should be maintained at all times and Network Rail should be consulted during planning, design and construction stages for acceptances or no objections.

a. Works that could impact on the railway (or involving bridges) will need to be discussed with us in detail when the time comes.
b. Asset Protection (ASPRO) information, please see the Network Rail Asset Protection website below:
• https://www.networkrail.co.uk/running-the-railway/looking-after-the-railway/assetprotection-and-optimisation/

Network Rail look forward to continuing to work with Rochford Council, especially as projects progress (including those, if any, projects that are in initial feasibility stage).

I am writing to object in the strongest possible terms to a Change of Use of Rayleigh's Conservation Areas to Residential Use.

One area of contention, but amongst others, is The Mill Hall: a well used site by so many different groups, which brings people into the town, who will then use local shops, etc. The parking areas there are usually full, where will people be able to park, especially those with limited mobility, if there are no spaces at that end of town? Maybe they will decide to go elsewhere....

One vital question I do need to put to you is about air quality. I do remember that Rayleigh town centre had high levels of pollutants due to traffic a few years ago. Has this now been resolved? I think rather not. Do you have current figures on air quality? What are the projected levels expected to rise to when thousands more cars are using our local roads? Have you driven through Rayleigh yourselves recently? Even on a "normal" day it is slow moving. Have you noticed the gridlock conditions that arise when there need to be roadworks, or following a breakdown or accident? Even if that is at the Weir or further afield? Cleaner, all-electric vehicles are a long way off yet I fear.

I appreciate that whilst green open spaces are pleasant - I would say vital - for the residents and visitors alike, they don't necessarily bring in revenue do they? It's just a field or open space, doing nothing, it would appear. Housing does of course, but at what other costs to our lives?

I urge you to please reconsider your plans and ideas for our beautiful town of Rayleigh, to keep it that way for us and future generations to enjoy.

I would like to provide my general comments regarding the consultation on the Spatial Options document as follows;

 Based upon the government’s own statistics of 2.4 people and 1.3 cars per household, the proposed 7,200 new homes in Rochford district would equate to in excess of 17,000 additional people and over 9,000 additional cars, which when put into perspective, represents a similar population to South Woodham Ferrers.

 I note that most of the promoted sites are to the West of Rayleigh and this would inevitably mean those people would be drawn to Rayleigh which is already over developed and consequently overburdened in every respect.

 All of the major sites promoted are too far away to walk to Rayleigh or the station and that will force more people to drive exacerbating congestion, which is already at unacceptable levels, and indeed pollution.

 Promoted sites next to major roads, especially the A127, should not be considered due to air and noise pollution. The Rayleigh Weir junction is already overly congested as are the roads that lead from it.

 Any voluminous development in Rayleigh will be devastating and I am opposed to it.

 I am in agreement with the Liberal Democrat Group, there needs to be a more radical approach, a plan should be made for a whole new town/village incorporating all of the appropriate infrastructure and that this should do be done in conjunction with adjacent councils and not in isolation.

Following the many representations I've had regarding the Spatial Options Consultation, I would like the following issues included in the appraisal.

The Development Committee recently turned down the Bloor Homes planning application for over 660 homes to be built that would have directed traffic onto the Ashingdon Road and onwards to the B1013. The application was turned down on the grounds that traffic levels have become severe on the main roads through the Rochford District. I would therefore challenge any major site inclusion within any recommendations going forward for the New Area Plan that would direct traffic onto any of the roads noted above on the grounds that the roads are already at capacity (as documented in the case of the B1013 in the 1990's) and therefore not difficult to class the traffic levels as severe. I fail to see any improvements that can be made to the existing roads that would increase the capacity to cope with the increase. Sites marked as deliverable in the document, do not appear to have taken into account, this particular point.

I see very little within the proposed sites that will offer enhanced status for then areas that they are suggested to be in.

Many of the proposed areas for inclusion, note a flood risk. There is a strong chance of the 1 in 100 events, becoming much more regular with the advent of global warming. The natural conclusion therefore has to be to avoid recommending areas that are already noted as having a flood risk.

Many of the sites put forward are not within walking or public transport distance and therefore will inevitably encourage use of personal transport, which is not in line with the Councils aims for clean air quality.

As a representative for the Hockley Ward, I find sites marked CFS064, CFS160 and CFS161 particularly contentious and would ask that they be removed from consideration.

I trust these issues will be give due consideration in formulating the new area plan.

Following the many representations I've had regarding the Spatial Options Consultation, I would like the following issues included in the appraisal.

The Development Committee recently turned down the Bloor Homes planning application for over 660 homes to be built that would have directed traffic onto the Ashingdon Road and onwards to the B1013. The application was turned down on the grounds that traffic levels have become severe on the main roads through the Rochford District. I would therefore challenge any major site inclusion within any recommendations going forward for the New Area Plan that would direct traffic onto any of the roads noted above on the grounds that the roads are already at capacity (as documented in the case of the B1013 in the 1990's) and therefore not difficult to class the traffic levels as severe. I fail to see any improvements that can be made to the existing roads that would increase the capacity to cope with the increase. Sites marked as deliverable in the document, do not appear to have taken into account, this particular point.

I see very little within the proposed sites that will offer enhanced status for then areas that they are suggested to be in.

Many of the proposed areas for inclusion, note a flood risk. There is a strong chance of the 1 in 100 events, becoming much more regular with the advent of global warming. The natural conclusion therefore has to be to avoid recommending areas that are already noted as having a flood risk.

Many of the sites put forward are not within walking or public transport distance and therefore will inevitably encourage use of personal transport, which is not in line with the Councils aims for clean air quality.

As a representative for the Hockley Ward, I find sites marked CFS064, CFS160 and CFS161 particularly contentious and would ask that they be removed from consideration.

I trust these issues will be give due consideration in formulating the new area plan.

Dear Sir / Madam,

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

Thank you in advance for your attention to this matter.

Kind Regards,
Jane

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

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

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

Please see below our supportive comments on the Council’s Spatial Strategy Consultation, forming part of the new Local Plan process.

Q. 6. Balanced Option 4 .

Land North of Southend CFS 260 ( including the linked lettered sites ) is supported and should be able to provide a large tranche of new development that is required. The need for substantial land release is acknowledged, both for residential as well as employment. This site helps to fulfil the numbers for both Rochford DC and Southend BC. The site is large enough and capable of contributing to highway improvements to improve accessibility to the eastern end of the District and east Southend. Proximity to Temple Farm and Purdeys Industrial estates as well as the Airport is an advantage.

We would like to point out what could be misleading in the Site Appraisal Papers, …. CFS 261, Land to the East of Oxford Road, 147 Ha. is included in the North of Southend Cluster, instead of the East of Rochford Cluster. For clarification, our comments above on Q6 Option 4 do not refer to CFS 261.

As part of the Balanced Option, we support smaller schemes which can be brought forward whilst the larger strategic site is being worked up. They also have the benefit of a more diverse style of homes, spreading the commute journeys and meeting the demands of the market in terms of location. In particular we support…

CFS 126, North of Brays Lane. Besides proximity to The King Edmund School and Golden Cross Retail, this site has ready made access to Brays Lane. With release from Green Belt restrictions, construction could be undertaken at an early phase. Please note that under the Water Apparatus scoring that the main sewer passes through the site with 3 manholes accessible.

CFS 217 Land at Doggetts Chase, Rochford. Wedged between existing housing in Doggetts Close and the Public Open Space this site lends itself for development as sympathetically designed retirement housing.

CFS 218 Land at Oxford Road, Rochford . A small site at the end of Oxford Road and with two sides adjacent to the playing fields of the King Edmund School, this can no longer be accessed for agriculture. It is also compromised by manholes for the main sewer. Therefore its release from the Green Belt would be justified.


Q 53 Roads. In conjunction with Cluster North of Southend, CFS260, a new road could resolve a long-standing problem by linking the A 127 at Tesco /RBS roundabout, the Airport and eastwards towards Fossetts Farm and the east of the District.

Q 51. Connectivity. To improve the economic activity in Rochford Town Centre, especially for retail, efforts should be made to create a foot / cycle path more directly between Dalys Road and the Square. Currently the only way is via North Street where the pavements on both sides are very narrow as is also the road. When the development of the old hospital site took place, the NHS was reluctant to enter into a dialogue which would have created some community benefits out of this major development in the centre of Rochford. As a result there is a barrier across the town which should be addressed.

We live in Barling Magna and have done so for 35 years and never have we been so concerned about an issue.

I have serious concerns around the consultation document itself, it uses place names like ‘Stonebridge’ rather than a ward name, it has omissions of current ongoing developments , which when completed will add to the general congestion on some roads. Because, I was informed, they have consent they do not need to be shown as this reflects a call for new land. But surely we need to now about them to assess the overall amount of development in an area before we can assess if we can accept more.

It says, and Rochford has confirmed, ‘infrastructure first’, but there is no indication as to how or where this infrastructure would be - whether it be first or last, so how can one assess a site without knowing where the new road would go to get there?

The Council should not reach any conclusions until Government Housing Policy and numbers to be found has been confirmed.

The consultation has divided large swathes of offered land up into small parcels and invites comments on the parcels rather than the overall principal of a development in that area. This contributes to a very difficult to follow consultation made far worse by poor software running the consultation.

On the above points alone I question the validity of this consultation.

The consultation invites comments on the future categorisation of land, residential, employment, green etc. However, most of the land that has been put forward is currently green belt land, and it’s development would be against current RDC policies.

“The land in question forms part of the Metropolitan Green belt. Such land can only be developed for ‘Exceptional circumstances’ as detailed in the Planning Policy Guidance Note 2 (PPG2), and states in para 143 that Inappropriate development is by definition harmful to Green Belt’’ and in Para 145 that ‘’A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt.” There are exceptions but these do not include house building on anything other than a minor scale.

I suspect that most of the residents would wish it to remain green belt. What is the point of having green belt land if, just because it is easier to build on than brownfield it becomes an option in the next consultation etc. Government policy has indicated that the use of green belt land should not be assumed and indeed this classification could be sufficient to rule out its use other than for minor applications.

Now, more than ever, development should look to be sustainable, indeed it is beholden on our Cllrs and our Council Planning Dept to ensure that it is.

Sustainability comes in many shapes, from the loss of a land use, through the materials used for building plus a plethora of issues like heat pumps, solar, glazing etc and this must include the sourcing of such items, through to accessibility, congestion, new roads needed and reliance on various forms of transport, easy access to work, education, health etc. Economic sustainability must also be assured and this goes beyond economic delivery but also includes the longer term economic viability for both new and current residents.

Based upon the above I would make the following comments-

• No housing development, from Rayleigh eastwards, in the current green belt or on agricultural land should be permissible on sustainability grounds other than small infill of ribbon development areas, extension to existing dwellings in green belt and ‘granny flats’ where space and neighbour privacy permits etc. Allow residents to make the most of their properties rather than needing to move.
• All current green belt land adjoining woodland, parkland, ancient copses etc should be retained and reinforced as protected green space and backfill towards these important wildlife havens and CO2 catchments should be prohibited.
• The destruction of arable land should not be permitted. We need to be as self sufficient in food matters as we can be, importing from Canada or France for example is far less sustainable and could become more difficult in the future.
• Access to and through Hockley, Ashingdon and Rochford is beyond capacity and cannot be expected to take any more traffic. A journey that 15 years ago took 15 mins now takes 30 minutes minimum and often more. Traffic around Rochford is often at a standstill due to parking, deliveries etc and at the morning and afternoon busy times it is totally snarled up.
• Brown field sites and intensification of existing dwelling areas should only be developed with a very light touch unless easy access to jobs, schools etc without adding to road congestion can be imposed and maintained.
• Rochford should not accept development that is accessed by highways that are not within the district or where necessary facilities including jobs are not able to be provided within close proximity preventing the need for more vehicle movements on already over congested roads.
• Reliance on Southend facilities, the A127 within Southend and Bournes Green Chase etc. should not be countenanced. Southend has high unemployment in many wards and high deprivation in the central wards, good jobs that provide good incomes are scarce in Southend, Shoebury, Rochford, Wakering, Barling, Paglesham etc. Thus any new residents moving into the area will be driving in and out each day or trying to access trains with limited parking.
• The lack of suitable employment the further east you go is also a major factor in the sustainability of the economic issues. Barling on good run is 30 mins from Rayleigh Weir, more development can only slow this even more.
• All construction materials will have to get to the east of Rayleigh via already tired and congested roads causing yet more delays, polluted air and disruption for residents and importantly businesses in the east of Southend. The greater the congestion into Southend the fewer returning tourists and the fewer jobs in Southend!

On a more positive note and in recognition that RDC, BDC and SBC all have to provide some new dwellings that will probably not be able to be fully accommodated within the town centres or brown field sites there are a few areas where I consider development would be sustainable,
• Along the north side of the A127, accessed by a new slip road off the A127.
• Land adjoining or close to the A130 in the south Rawreth area, (CFS146,147,167,144,168,145,137,055,121 ) here sufficient development could take place in conjunction with Basildon and Southend to absorb much of the dwelling numbers currently required by Government whilst at the same being large enough to sustain education facilities, healthcare, small retail and supermarkets etc alongside leisure and sports. Good access is here for work with A130 to Chelmsford, A127 to Basildon and Rayleigh, A13 to Thames corridor etc and those commuting by train can access Rayleigh Station relatively easily (or even a new station). As when and if the A127 is ever upgraded into Southend adequately and as when and if their unemployment rates improve then more work opportunities will open up.

• I support strategy option 3a a massed development west of Rayleigh, indeed I see a small new garden town as the only sensible, sustainable and long term economic option. This would not destroy the country side around existing villages nor lead to more traffic and congestion issues east of Rayleigh. It also allows for co-operation from different authorities to work together for benefit of their residents.
• I do not support the other strategy options as a means to provide any significant numbers of dwellings.

More specifically


CFS064, CFS264, CFS040, CFS161, and any further development along or requiring access to the roads Church Road, Folly Lane, Folly Chase, High Road, Main Road, Aldermans Hill etc and all the way through to Rochford Town Centre via Hall Road and Stroud Green should be considered as over-development and an undesirable change of use.
These roads cannot be improved to accommodate the already excessive traffic. Some sites along or close to these roads are encroaching on potential wildlife areas and others are on the periphery of woodland etc. None of these sites would generate enough to provide the necessary highway improvements, even assuming this were possible, Rayleigh has singularly failed to sort out its traffic congestion problems despite many attempts to do so. Nor would they generate sufficient for the other infrastructure contributions that would be needed to make these areas better, more attractive areas to live in for both new and existing residents. The result would be a significant loss of amenity and worsening living conditions for the existing residents.

CFS004, Barling, this site could take a few houses as extension of ribbon development but the land would be better suited to be used as woodland or wild flower meadow to the rear, and form parking for the school to the front of the site if agriculture is no longer viable. The numbers suggested to be built on this site are way more than sensible, not least due to the location near a school, the specifics of the road there, the very difficult parking in the area and the risk of flood. 29 new homes means at least 29 if not far more vehicles going into and out of the village each day, more school places etc,.

All development in Barling, Little and Great Wakering on greenfield or agricultural sites should not be considered further. I have already discussed the sustainability of areas to the east of the district and here more than ever that is important. Also, however, this land offers a real buffer against the muddling of Southend and Rochford, which is intrinsic to the identity of the 3 areas and also offers open space and leisure for Southend residents in the east of the borough . Green space is hardly prolific in this sector of Southend. I also disagree with the ‘convenient’ adding of these three areas together to form a tier, Barling is not part of nor similar to the Wakerings and should be considered along with tier 4 villages.

The roads in the Barling area are small narrow roads often without pavements, there are sharp bends and ditches etc, these are rural roads and should remain so.

Most of us live in these areas and especially in Barling because we like the rural feel of the area. We want to preserve that way of life and major developments
taking years to build and then thousands of residents with cars causing congestion and poorer air quality will destroy it forever. Given the way the estuaries divide up our district we need to preserve the countryside within each estuary sector. Thames - Roach and Roach - Crouch.

I trust you will carefully consider the above points when deciding the outcome of the consultation and that you realise the strength of feeling of residents.

Thank you for taking the time to read our concerns and suggestions

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Strategy Options.
Q6. Option 3a should be the preferred option as it naturally produces the required supporting infrastructure and is the least likely of all options to increase pressure on the existing infrastructure in the rest of the district. It could possibly be combined with a small amount of development elsewhere but that should be restricted to providing local employment opportunities and the housing needs of an ageing population, both of which should have less effect on infrastructure than general housing. However, it should be remembered that most of that ageing population are owner-occupiers who have spent their lives in houses with gardens and may not wish to move to apartments. If there were no bungalows developed for them with at least minimal gardens, they may be likely to stay where they are and so not free up family homes for others. This problem has already been exacerbated by the conversion of many bungalows in the district to chalets or houses.

Transport and Connectivity.
Q51. Option 1 is clearly the only way to minimise environmental damage.
Q53. The A127 should be the main East-West route and there may be potential to widen it from 4 to 6 lanes from the M25 to as far East as The Bell without major impact on more than a few adjoining properties. Additional traffic should not be encouraged on Lower Rd due to congestion at Hullbridge and the previously-suggested Rochford Outer Bypass or any similar proposal should continue to be rejected as it would increase pressure for development in greenbelt along its route, particularly where it linked to local routes.

Planning for Complete Communities.
Hullbridge.
Q60a. While I generally agree with the vision, I do not consider it practical for Hullbridge to be more accessible by river-based transport or for the coastline to be opened up without damage to the river’s environmental importance.
Q60b. It might be possible to develop a small business park for offices and light industrial uses on that part of site CFS100 on the West side of Burlington Gardens as that is a brownfield site, albeit in greenbelt.
Q60c. No other sites are considered suitable as most put forward are wholly or largely outside walking distance of the majority of services and are extremely unlikely to provide any additional services.
Q60d. If High Elms is included, Hullbridge will already have seen a20%+ increase in dwellings over the last 10-15 years so all other areas should be protected. Of the sites put forward, many are at least partly at risk of flooding, notably in Northern areas and along Watery Lane and its junction with Lower Rd/Hullbridge Rd and also Pooles Lane/Kingsmans Farm Rd. Those Northerly sites should also be rejected due to their proximity to the environmentally sensitive and protected River Crouch. Other sites should be rejected as they reduce the greenbelt distance between Hullbridge and Rayleigh/Hockley or are to the West of the High Elms development which RDC described as providing a ‘defensible greenbelt boundary’.

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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


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


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


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

Q5. Do you agree with the settlement hierarchy presented?


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


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

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

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

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

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

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


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

Spatial Themes

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


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


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


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


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


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


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


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


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

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


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

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

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


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

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

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


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

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

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

Housing for All

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


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

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

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

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


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

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


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

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


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

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

Employment and Jobs

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


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

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

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

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


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

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

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


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

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

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

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


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

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


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

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

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


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

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

Biodiversity

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


YES

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

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

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


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

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

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

Green and Blue Infrastructure

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


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

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


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


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

Community Infrastructure

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


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

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

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


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

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

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

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


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

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

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

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


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

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


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

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


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

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


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

Heritage

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


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

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


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


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

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


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

Town Centres and Retail

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


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

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

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


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

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

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

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


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

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


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

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

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


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

Transport and Connectivity

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


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

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


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

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

Green Belt and Rural Issues

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


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

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

Planning for Complete Communities

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


N/A


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


N/A


Q56d. Are there areas that require protecting from development?


N/A


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


N/A

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



N/A

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


N/A


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


N/A


Q57d. Are there areas that require protecting from development?


N/A



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

N/A

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

N/A

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

N/A

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


N/A

Q58d. Are there areas that require protecting from development?


N/A



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


N/A


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

N/A

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


N/A




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


N/A





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


N/A


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


N/A


Q60a. Do you agree with our vision for Hullbridge?


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

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

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


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

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


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

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


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

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


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

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


N/A


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


N/A


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


N/A


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

N/A

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

N/A



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


N/A


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


N/A


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

N/A



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

N/A



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


N/A





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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A

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


N/A


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


N/A


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


N/A


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


N/A


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


N/A


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


N/A






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


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

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


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

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


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

Create a Country Park to the west of Hullbridge.

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

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

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

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


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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2. SPATIAL OPTIONS DOCUMENT
2.1 This section responds to questions posed by the Spatial Options consultation that are relevant to Penland Estate Limited's interests in Rochford.
Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
2.2 The technical evidence that has been prepared and is yet to be prepared by the Council is supported as being required to inform the production of a sound Local
Plan in accordance with the provisions of the National Planning Policy Framework (NPPF 2021).
Q2. Do you agree with our draft vision for Rochford District?
2.3 Penland Estates Limited considers that the Draft Vision for Rochford District Council provides a sound basis for preparing a spatial strategy. Land to South of Pooles Lane, Hullbridge, will deliver upon the draft vision of Rochford District by providing a high-quality, well-designed development in a sustainable location with good
access to services and facilities which will foster vibrant and healthy communities.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
2.4 Penland Estates Limited broadly agree with the importance of adopting a range of separate visions for each of the District's settlements to help apply the district-wide vision and objectives at more localised settings. Nevertheless, there is likely to be considerable cross-over between the specific visions for individual settlement, and
as such, the benefits of this approach might not be fully realised.
2.5 Furthermore, this is likely to be quite a time-consuming exercise for the Council's Planning Policy Team to create separate visions for each of the District's
settlements. The Draft Local Development Scheme (2021-23) anticipates that the Local Plan could be submitted to the Secretary of State for independent
examination by Spring 2023, thus providing a short timescale to prepare and submit the emerging Local Plan. Therefore, it is considered that the resource of the
Planning Policy team is likely to be better deployed in other more pressing aspects of the emerging Local Plan process.
Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?
2.6 The Spatial Options document identifies five ‘Strategic Priorities.' Strategic Priorities one (meeting the need for homes and jobs in the area) and five (making suitable and sufficient provision for climate change mitigation and adaptation, conservation, and enhancement of the natural and historic environment, including landscape) are of particular interest to our client's site.
2.7 Our client is promoting Land South of Pooles Lane, Hullbridge, for the allocation of residential development through the emerging Rochford District Council Local Plan (RDCLP). It is estimated that the site is capable of delivering up to 226 new homes towards meeting the housing need target for the RDCLP. In addition to delivering much-needed market and affordable housing, the site will deliver upon the draft strategic priorities of the RDCLP as follows:
2.8 Meeting the need for homes (Strategic Priority 1 and 2) – Penland Estates Limited prides itself on working with developers that deliver well-designed, highquality, and sustainable homes for all to enjoy. Any scheme delivered on the site would provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include affordable housing provision which would be tenure blind in terms of design and well-integrated into the scheme to enhance social cohesion and generate community spirit. It is agreed that the
delivery of new homes sufficient to meet local housing need should be assigned great importance.
2.9 Climate change (Strategic Priority 5) – Any scheme would provide modern high-quality living with housing that meets the latest Building Regulation requirements in respect of energy and water consumption. In addition, the site is located in a highly sustainable settlement, within walking distance of a range of shops, services and pre and primary schools. The site’s location and proximity to
the local service provision in Hullbridge would assist in reducing travel by car and thus assist in reducing carbon emissions.
2.10 Natural environment (Strategic Priority 5) – Any scheme brought forward would aim to achieve a net gain in biodiversity through the retention, protection and enhancement of any on-site habitats, provision of extensive new public open space and high-quality landscaped areas. Existing vegetation at the site would be retained and enhanced through new planting to enhance the potential for habitat creation. In addition, drainage attenuation basins, required as part of the surface water drainage strategy, offer further potential to boost on-site biodiversity.
2.11 Furthermore, whilst the site is currently located in the Green Belt, the evidence provided in our representations and accompanying Green Belt Appraisal demonstrate that the site performs poorly against the five purposes of Green Belt as set out in the NPPF and is capable of coming forward for development without unduly damaging the integrity of the Green Belt. The evidence gathered by the Council clearly illustrates that the District's housing need cannot be sufficiently met
through urban and previously developed land only. Some release of Green Belt land in appropriate locations should be recognised as being necessary where 70% of the
District is designated as Green Belt. The release of Green Belt sites such as Land South of Pooles Lane, Hullbridge, will allow the continued sustainable growth of existing settlements, and would be consistent with the NPPF.
2.12 Historic environment (Strategic Priority 5) – The evidence provided in our representations, the accompanying Heritage Appraisal (see attached at Appendix A) and the Council's Initial Heritage Assessment of Submitted Sites (October 2020)
demonstrates that the site does not adversely impact any nearby heritage assets either directly or indirectly.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
2.13 The Options Spatial Paper includes a draft settlement hierarchy based on the 2021'Settlement Role and Hierarchy Study,' which uses various factors (including population size, availability and range of services and transport accessibility) to assess the relative sustainability of the District's multiple settlements.
2.14 The Adopted Core Strategy (2011) categorises Hullbridge (and Great Wakering) as a second-tier (out of four) settlement, where there is considered to be a more
limited range of services and access to public transport is judged to be relatively poor. The Spatial Options paper shifts Hullbridge into tier three (out of four) of its
draft settlement hierarchy. This appears to be due to the sub-division of Tier 1 of the Adopted Core Strategy into Tier 1 and 2 of the draft settlement hierarchy, with
Rayleigh remaining in Tier 1 and Rochford (including Ashingdon) and Hockley (including Hawkwell) shifting down into Tier 2 2.15 In addition to Hullbridge, the new proposed Tier 3 includes Great Wakering and
Canewdon. Penland Estates Limited, as outlined below, considers that Hullbridge is better related to the Tier 2 settlement of Hockley in terms of access to services,
population, geographical size, and transport accessibility, compared to the Tier 3 village Canewdon:
2.16 Population – according to the Parish Council website, Hullbridge's population is approximately 7,300, which is markedly greater than that of Canewdon (Tier 3) at circa 1,100. The other Tier 3 settlement of Great Wakering (including Little Wakering and Barling) has a similar population to Hullbridge at circa 7,200.
However, it is recognised that Hullbridge has a growing population, particularly through strategic allocations, such as the 500 unit Lower Road development in southwest Hullbridge (adopted Policy SER6 – South West Hullbridge). It is also anticipated that Hullbridge's population will continue to grow through strategic
allocations in the emerging Local Plan, given the sustainability of the settlement and its ability to support continued growth. This means that the population of
Hullbridge is anticipated to move closer to the suggested Tier 2 population threshold of 10,000.
2.17 Access to public transport – Hullbridge is serviced by the frequent no. 20 bus route operated by Frist Group (every 30 minutes between 7.00 to 21.00 Monday
to Saturday) to Southend via Rayleigh, where wider connectivity into London via the Greater Anglia train service is available. Great Wakering is similarly wellconnected as Hullbridge to public transport links; however, Canewdon is only serviced every two hours by the 60 bus route to Southend via Rochford. It is
recognised that neither Hullbridge nor Great Wakering includes rail links, as available in the Tier 2 settlements. Nevertheless, the frequent bus journeys to these rail station destinations from Hullbridge (and Great Wakering) provide accessible sustainable transport options for residents of these settlements.
2.18 Range of services and facilities – the village of Hullbridge has a good range of services and community facilities capable of meeting the everyday needs of
residents. These include three convenience stores, a dentist, GP surgery, library, pharmacy, a pre-school and primary school and public houses, fast food outlets
and restaurants. In comparison, Canewdon does not possess any such range of services facilities, with only a primary school, a convenience store, and a public
house. Great Wakering has a few more facilities, including a primary school, medical centre, and pharmacy and two public houses, albeit not to the extent found
in Hullbridge.
2.19 It is recognised that Hullbridge does not include a secondary school. Nevertheless, the no. 20 bus route provides a regular service (every 30 minutes) to the
settlements of Rayleigh and Hockley, which contain secondary schools as well as higher order retail services.
2.20 Access to jobs – several small-scale businesses are positioned around Hullbridge and at the various facilities and services mentioned above, which could
accommodate some local employment opportunities. It is considered that such employment opportunities would not be available at the Tier 3 settlement of Canewdon.
2.21 On the above basis, it is considered that the range of existing services and facilities available in Hullbridge mean that the village is better related to Tier 2 of the
settlement hierarchy than Tier 3. It is important that the Council has due consideration of the sustainability of Hullbridge when determining what level of growth is appropriate. The designation of Hullbridge as a Tier 3 settlement should not in itself be taken as a reason for allocating a certain level of growth. This is especially important as the Spatial Options document recognises that Hullbridge (and Great Wakering) are larger settlements than Canewdon; the scale of new
growth that would be appropriate for the settlements would therefore differ.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
2.22 Penland Estates Limited strongly agree with the identification of a housing requirement of 7,200 homes based on the standard method, which is in accordance
with paragraph 61 of the NPPF. The acknowledgement that this housing requirement forms the minimum housing needs for the District is also strongly agreed with; the Council must explore all opportunities available to accommodate additional growth above the minimum requirement and take on unmet need from neighbouring authorities that are constrained in the level of housing growth they are able to deliver.
2.23 The Spatial Options Document recognises that there is potential for Rochford District to accommodate unmet need from neighbouring authorities. The District's
neighbours are burdened with constraints to identifying sufficient land for housing, such as significant areas of Green Belt land which envelops existing urban areas
and areas of high flood risk. The authorities located within the same housing market area as Rochford have also struggled with maintaining sufficient levels of housing
delivery, further highlighting the importance of this matter. We therefore consider it to be highly likely that there will be unmet need arising from neighbouring authorities. In particular, early evidence issued for the Southend-on-Sea Local Plan preparation has indicated that Southend will require some of their housing requirement to be delivered in Rochford District (Issues and Options consultation,
April 2019). It is therefore vitally important that Rochford District pursues a growth strategy that includes a buffer in excess of the minimum housing required to meet local needs.
2.24 On the basis of the above, Growth Option 1 should be discounted as the strategy would not secure the level of housing required to meet the identified minimum
housing requirement. A sound Local Plan could not therefore be produced following this strategy.
2.25 Of the remaining options which would deliver sufficient housing growth, Penland Estates Limited is strongly supportive of Option 2 (Urban Extensions), particularly Option 2b 'Urban extensions dispersed to settlements based on hierarchy.'
2.26 Firstly, it is recognised that Rochford District Council have had a historic record of housing under-delivery, which in 2020 resulted in the Council having to publish a
Housing Delivery Test Action Plan as their 2019 Housing Delivery Test (HDT) was calculated at 77%. The 2020 Action Plan noted that the delayed delivery of several
strategic sites was a key factor. In particular, this was due to prolonged landowner and developer negotiations, delays at the planning application stage, and the time
taken to discharge pre-commencement conditions. The growth strategy for the Local Plan should therefore limit any over-reliance on large-scale strategic urban
extensions for delivering the required amount of housing.
2.27 Consequently, our client considers that the Council should identify available and deliverable small and medium-sized sites (10 and 1,500 homes) dispersed to
settlements based on hierarchy. This approach would be consistent with Paragraph 69 of the NPPF (2021), which states that "small and medium sized sites can make
an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly." The delivery of sites at this scale also helps to
ensure sustainable growth can take place across the District in a dispersed manner that allows all settlements to grow organically. 2.28 The NPPF allows for revisions to be made to the Green Belt boundary through the
Local Plan process where there are exceptional circumstances. As explained earlier, release of Green Belt land is required if the Local Plan is to deliver sufficient housing to meet the local housing needs for the District. This forms the exceptional circumstances required for the release of land from the Green Belt in appropriate locations. The delivery of small and medium-scale sites released from the Green Belt, such as Land South of Pooles Lane, will also play an important role in the Council meeting their five-year housing land supply as required by paragraph 68 of the NPPF.
2.29 Land South of Pooles Lane, Hullbridge, is available and deliverable within the Local
Plan period and should be considered further by the Council. Secondly, Option 2b will support existing services by directing further growth to villages like Hullbridge to support the vitality of local services. This approach is consistent with NPPF 79 of the NPPF (2021), which outlines that "planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services."
Consequently, sites in sustainable locations with good access to a range of services and facilities (generally Tier 2 and 3 settlements) should be selected to ensure the
sustainable and effective growth of settlements across the District.
2.30 The Council's Settlement Role and Hierarchy Study assesses the relative sustainability of individual settlements by considering its 'completeness'. The
theory is that the more services a place has, and the easier to access those services are, the more complete that place is. The 'completeness' assessment is shown in
the form of a heatmap, and for Hullbridge, this is shown on Page 82 of the Spatial Options Paper. Land to the South of Pooles Lane adjoins the north-eastern
settlement boundary of Hullbridge, which benefits from a 'walking completeness score' of between 11 and 13, which is the highest score in Hullbridge and is in the
second-highest category overall.
2.31 This is because the north-eastern section of Hullbridge includes Hullbridge preschool and Riverside Primary School, Hullbridge Community Centre, and a bus stop providing a frequent bus service to Southend and Rayleigh (one bus every 30 minutes). These services and facilities are less than a five-minute walk from Land
to the South of Pooles Lane. Additional services and facilities, including convenience stores, a dentist, GP surgery, library, pharmacy, and other fast food outlets and
restaurants, are within a 10-minute walk from the site. By affording sustainable levels of growth to sites such as these, it will assist in safeguarding existing services, public transport links and infrastructure which local people currently rely upon and support vibrant rural communities.
2.32 For the reasons set out above, Penland Estates Limited strongly supports the pursuance of Growth Option 2b, with concentrated growth dispersed to settlements based on hierarchy. This includes allocating growth in high performing and sustainable Tier 3 settlements, such as Hullbridge.
Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
2.33 Penland Estates Limited supports the Council's ambition of ensuring future growth takes place in a manner that is aligned with the national objective of transitioning towards a zero-carbon economy. Penland Estates Limited intends to work with developers that will create high-quality, energy-efficient buildings, which could
incorporate energy generation and conservation technologies, in line with the Council's strategy to reduce carbon emissions.
2.34 Notwithstanding this, there needs to be a balancing act in order to meet this target against the need to deliver a viable scheme. It is clear that further consideration is
required regarding the expected capital uplifts in the emerging Local Plan to ensure that energy efficiency is considered alongside viability. In doing so, the guidance
should consider the Government's figures in their Draft Future Homes Standard which will be in place by the time homes allocated by the new Local Plan are likely to be built. Any policy brought forward on this matter should therefore be supported by appropriate evidence that has investigated potential impacts on viability. The policy itself should include wording to reflect the importance of considering the overall viability of a scheme when determining the application of energy efficiency
initiatives over and above that required by Building Regulations
Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?
2.35 The Council should be consistent with the Government's Draft Future Homes Standard that proposes to remove the ability of local planning authorities to set higher energy efficiency standards than those in the Building Regulations. This is because the Government considers the situation confusing, particularly as the application of energy efficiency standards across local authority boundary lines often means that homes need to be built to different technical specifications. This inconsistency creates inefficiencies in supply chains, labour and potentially the quality of outcomes.
2.36 Nevertheless, Future Homes Standard outlines that changes to the Building Regulations are expected to mean that between 75- 80% fewer carbon emissions
are released into the atmosphere from new development compared to ones built to the 2013 Part L requirement. Requiring new developments to achieve energy
standards higher than the proposed changes to the Building Regulations would need robust evidence identifying the need for such a requirement.
13. How do you feel the plan can help to support the local generation of lowcarbon and renewable energy? Are there locations where you feel energy generation should be supported?
2.37 The Council should promote the idea of the Local Plan supporting renewable energy developments by designating appropriate locations within the District for lowcarbon and renewable energy generation projects. The Council could consider a
'call for sites' process for potential low carbon and renewable sites submitted by landowners, site promoters or developers. The Council could then assess the suitability of submitted sites using relevant criteria.
Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
2.38 Penland Estates Limited broadly supports the principles contained in the draft place-making charter, which sets out a number of key principles for how new
development is expected to be delivered in a way that contributes positively to their setting and wider environment. In taking this charter forward however, it should be made clear what weight will apply to the principles contained in the charter at the development management stage, as well as how the charter will interface with development management policies.
2.39 Penland Estates Limited prides itself on working with developers that deliver welldesigned, high-quality and liveable schemes for all to enjoy. Place-making and
creating a sense of identity is at the heart of the scheme design shown on the enclosed Development Framework Plan (see attached at Appendix B), with a
consideration of the opportunities and constraints of the site (see plan attached at Appendix C). New dwellings would be modern but sensitively designed to complement the character of the local area, and public open space would be delivered to a high standard to stimulate on-site recreation and interaction between residents. The development would be a positive and environmentally friendly place to live, work and play.
Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
2.40 The production of new design guides, codes or masterplans alongside the new Local Plan could provide applicants with clarity about design expectations at an early stage. However, there are two important considerations to take into account.
Firstly, site-specific design guidance is likely to be useful only in cases where the development proposed is at a strategic scale or there are unique constraints which
design guidance would help to overcome. For the majority of small and mediumscale development, development management policies relevant to urban design and placemaking are sufficient in securing a high-quality design.
2.41 Additionally, the production of design guidance requires time and staffing resources. The Council should consider the level of detail required in a design code
and the possible impacts of delays due to detailed discussions and negotiations between applicants regarding a scheme's compliance with a design code. Given the Council's historic under-delivery of strategic housing sites, which has in part been attributed to delays at the planning application stage, it is considered that with the preparation of design guides and masterplans is likely to slow housing delivery rates further if required for all sites.
2.42 The suggestion that design guidance is produced alongside the Local Plan preparation would also potentially delay the Local Plan process; which would mean further delaying the delivery of much-needed homes, given the delays experienced in the Local Plan process thus far. It would also require developers to invest in upfront work with no certainty that their particular site would be allocated in due course.
2.43 As such, Penland Estates Limited considers the preparation of design codes, guides or masterplans should be limited to large-scale strategic sites or sites with particularly complex delivery strategies only. All other developments can be brought forward appropriately without specific design guidance, as development
management policies related to design will ensure the correct design principles are followed.
4 Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing?
2.45 Penland Estates Limited recognises the importance of providing a mix of homes to meet the identified local housing needs. Option 2 is supported as providing a logical and flexible approach to ensuring that each new development provides a mix of housing that is appropriate to its location, taking into account all relevant sitespecific factors. This would ensure schemes can provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include an element of affordable housing provision which would be tenure blind in terms of design and be well integrated into the scheme to enhance social cohesion and generate community spirit.
Q31. Do you consider net gains for biodiversity are best delivered on-site or offsite? Are there specific locations or projects where net gain projects could be delivered?
2.46 National guidance outlines that biodiversity net gain can be achieved on-site, offsite or through a combination of on-site and off-site measures. Schemes should come forward with the aim of achieving a net gain in biodiversity through the retention, protection and enhancement of any on-site habitats, provision of extensive new public open space and high-quality landscaped areas wherever
possible. However, the option of achieving net gain through off-site contributions or habitat creation should not be discounted, as there may be site constraints such
as viability which limit a site's ability to provide net gain on-site.
2.47 Existing vegetation at Land South of Pooles Lane site would be retained and enhanced through woodland belt planting to enhance the potential for habitat creation, as shown on the illustrative Development Framework Plan (Appendix B). In addition, surface water detention basins, required as part of the surface water drainage strategy, offer further potential to boost on-site biodiversity. All opportunities will therefore be taken to enhance the biodiversity of the site.
Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?
2.48 National policy outlines that strategic plans should take a strategic approach to green and blue infrastructure to help promote active and healthy lifestyles, combat climate change and alleviate air quality issues. Well-designed green infrastructure can provide a sustainable alternative to car use through a connected network of
public rights of way and greenways. Proposed option 3 is supported, as the delivery of new and enhanced green infrastructure on new development sites will assist in
creating an improved network of green infrastructure throughout the District.
2.49 In reference to Option 2b ('Urban extensions dispersed to settlements based on hierarchy'), the Council should select sites that are in close proximity to the existing and proposed green and blue infrastructure networks to ensure that future residents have a sustainable alternative to car use. Land to the South of Pooles Lane is located within the Option 2b strategic area, and there is an existing 'secondary greenway' (ref PROW 287_6) approximately 300m to the east of the
site, running in a north-south direction as indicated on Figure 32 of the Spatial Options Document. To the north, this greenway connects to a network of existing and proposed coast paths along the River Crouch, which is less than a 5-minute walk from the site. To the south, this 'secondary greenway' connects to a network of primary greenways circulating Hockley.
2.50 The Land South of Pooles Lane, Hullbridge, promoted by our client Penland Estates Limited, is well placed to encourage a shift away from the private car. As shown by the submitted Framework Plan, any development at the Pooles Lane site will integrate into the existing highway network by providing vehicular, pedestrian and cycle access points. The Council's Site Appraisal (2021) recognises the accessibility of the site to existing walking and cycling infrastructure, as Land South of Pooles Lane (ref CFS03) is scored at level 5 (highest category), as the site is within 400m of an existing cycle or footway.
2.51 In contrast however, the Site Appraisal (2021) scores the site at level 2 for accessibility to public rights of way (the second-lowest category), as there are
adjudged to be no PROWs with 400m. However, a PRoW (ref 287_12) does indeed run along part of the site's eastern boundary, as indicated on the submitted Framework Plan and connects to the 'secondary greenway' (ref PROW 287_6), further to the south. Future residents of the site will significantly benefit from the existing and proposed green and blue infrastructure, which is directly connectable from the site. This inaccuracy within the Council's site assessment should be rectified to correctly reflect the sites accessibility in all ways, including to the PRoW network.
Q36. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new or improved community infrastructure?
2.52 There is the potential for new development to contribute towards the upgrade and maintenance of existing facilities. Penland Estates Limited would welcome the opportunity to engage with the Council and local stakeholders in Hullbridge to understand local community needs.
Q41. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
2.53 In reference to Strategy Option 2b ('Urban extensions dispersed to settlements based on hierarchy'), the Council should support sites that can help improve open space or sports facility accessibility or provision. This would be in line with proposed option 4 for meeting open space needs through the Local Plan, which proposes requiring new developments to provide on-site open space or contribute towards improving existing recreational facilities.
2.54 Land South of Pooles Lane is located in the Option 2b settlement of Hullbridge. As identified in the 2009 Rochford District Council Open Space Study, Hullbridge has deficits against the local minimum standards of natural and semi-natural greenspaces (-2.05ha), amenity green space (-0.11ha) and children's play space (-0.01ha). Incidentally, Hullbridge has the second-highest deficit in the District for the provision of natural and semi-natural greenspaces. The provision of sports facilities is 0.53ha above the local minimum standards. It is recognised that the Open Space Study informing the evidence base is slightly dated. Nevertheless, it is
expected that the settlement's deficits (or low provision levels) of semi-natural greenspace and amenity green space, and children's play space are likely to still
exist in the village.
2.55 Taking this information into account, Land South of Pooles Lane has the potential to provide around 3ha of open space throughout the site, serving a range of
different purposes. Open space will be landscaped with a variety of natural and semi-natural areas, such as new woodland belt planting and mixed grassland areas
to promote biodiversity. Circular walking routes are provided, integrated into the wider network of public rights of way in the area. A centrally located locally equipped area for play (LEAPS) can also be provided. The open space would be delivered to a high standard to stimulate on-site recreation and interaction between residents. The development would be a positive and environmentally friendly place to live, work and play.
2.56 Land South of Pooles Lane achieves the highest score for access to public open space in the Council's Site Appraisal (2021) paper, given that Hullbridge Playing
Field is located directly opposite the site. Hullbridge Playing Field contains various existing sports facilities, including a BMX track, skate park, basketball court, sports pitch, as well as play equipment. Furthermore, Hullbridge Yacht Club, located on the River Crouch, is less than a five-minute walk, providing future residents with a wider range of sports and leisure facilities. The Council should consider allocating sites, such as Land South of Pooles Lane, in the emerging Local Plan that are well placed to provide accessible open space and sports facilities, either on-site or within
close walking distances.
Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
2.57 Paragraph 104 of the National Planning Policy Framework (NPPF) identifies that transport issues should be considered from the earliest stages of plan-making,
which includes opportunities to promote walking, cycling and public transport. The importance of encouraging a shift towards more sustainable modes of transport is
recognised as this will assist in reducing climate change and congestion levels on roads.
2.58 The four options set out in the Spatial Option document are considered to be logical approaches to take in addressing transport and connectivity issues. The Rochford Local Plan should also promote sustainable forms of transport by allocating housing sites in sustainable locations in established settlements which possesses good quality public transport links, including; bus services, footways and cycleways. The preparation of an Infrastructure Delivery Plan or Cycling Delivery Plan would provide clear evidence of the infrastructure improvements that may be required to further support and achieve sustainable development.
2.59 The Land South of Pooles Lane, Hullbridge, is exceptionally well placed to encourage the shift away from the private car. As shown by the submitted
Framework Plan (Appendix B), any development at the Land South of Pooles Lane site will integrate into the existing highway and pedestrian infrastructure by
providing vehicular, pedestrian and cycle access points in appropriate locations. 2.60 By utilising the proposed access points, residents of the scheme will have
convenient and sustainable access (via walking or cycling) to education, a range of shops, and services capable of serving their day-to-day needs. The public transport links available to residents of a scheme at Land South of Pooles Lane are summarised in the schedule below. Access to these services could be further
improved through new development resulting in an increased level of users.
Public Transport Links
Bus stops outside Riverside School, Ferry Road:
No 20 bus service from Hullbridge to Southendon-Sea via Rayleigh:
Monday to Saturday- every 30 minutes
between 7.00 to 21.00, and hourly between
22.15 and 23.15
Sundays- every 30 minutes between 9.00 to
21.30
(0.3km – to bus stop, 3-10 minute walk)
Hockley train station,
Station Approach Hockley SS5 4BG
(6.2 km, 19 minute cycle, 10 minute car)
Rayleigh train station, 1 Castle Dr, Rayleigh, SS6 7HT
5.1 km
(18 minute cycle, 9 minute car,15 minute bus)
Q60a. Do you agree with our vision for Hullbridge?
2.61 Penland Estates Limited broadly support the draft vision of Hullbridge becoming self-sufficient and accessible by sustainable means and to make the most of its location by opening up its coastline as a more attractive and usable space for both residents and visitors. Any development should respond to meeting the housing needs of local residents, and it should be acknowledged that the aims of meeting housing needs and Hullbridge becoming self-sufficient are interlinked. The growth of service provision would be supported by new housing and new customers, which would encourage new businesses as well as support the vitality of existing
businesses.
2.62 The vision currently references the need to provide suitable housing for the elderly, which our client supports. However, the vision should be expanded to incorporate
the needs of young families and parishioners seeking local and affordable housing to ensure a diverse and sustainable settlement can be maintained.
2.63 Land South of Pooles Lane would seek to provide a range of housing types and tenures to meet local needs and the needs of the wider District. This would include
a provision of affordable housing which would be tenure blind in terms of design and be well integrated into the scheme to enhance social cohesion and generate
community spirit.
Q60b. With reference to Figure 48 and your preferred Strategy Option, do you think any of the land edged blue should be made available for any of the following uses?
Housing [market, affordable, specialist, traveller, other]
Commercial [offices, industrial, retail, other]
Community infrastructure [open space, education, healthcare, allotments, other]
Other
2.64 As mentioned in answer to question 6 above, Penland Estates Limited supports Growth Strategy Option 2b. This strategy would provide new development in
sustainable locations across the settlement hierarchy, of a scale that is suitable to the services provision in the relevant settlement. Land South of Pooles Lane (ref
CFS190), promoted by Penland Estates Limited to provide a medium-sized housing scheme, is exceptionally well placed in this regard. It would adjoin the north-western boundary of Hullbridge and lead to the natural extension of this sustainable settlement. The site is incredibly well related to existing services as illustrated on
the walking completeness score replicated below. Development of the site offers the potential to increase permeability within this part of the village, improving
access for existing residents located north of Pooles Lane. 2.65 This accessibility has been reflected in the Council's Site Appraisal Paper (2021), which aims to provide an indication of the relative sustainability and suitability of potential housing sites. For example, the site scores in the highest accessibility (category five) for access to a primary school (less than 400m), a bus (more than 10 bus services provided per hour within 400m), and walking and cycling infrastructure (less than 400m from existing footway and cycle paths). This assessment is strongly supported as reflecting the location of the site in relation to services and facilities, as illustrated in the summary table below.
[see document for table]
2.66 However, the site scores poorly in the following categories: green belt impact (level two), agricultural land classification (level one), access to a train station (level one), access to a secondary school (level one), town centre (level one) and employment site (level one). Additional information is outlined below to provide a more robust assessment of the site's credentials against its poorly performing categories from the Site Appraisal Paper and demonstrate the deliverability of the site.
Green Belt
2.67 Given the extent of the Green Belt across the District and drawn tightly around sustainable settlements such as Hullbridge, it is vital that specific parcels of Green
Belt land adjacent to settlement boundaries are subject to a detailed Green Belt review process. Notwithstanding its Green Belt designation, this land will often provide a sustainable location for growth by virtue of its proximity to the local service provision and public transport links. We consider that this is the case of Hullbridge, where our client is promoting Land South of Pooles Lane, Hullbridge.
Indeed, this is recognised in the Rochford District and Southend-on-Sea Borough Joint Green Belt Study (February 2020) undertaken by the Council, which at paragraph 3.9 states that the most sustainable sites for allocation may be located in areas that make a strong contribution to Green Belt purposes.
2.68 As explained earlier in these representations, the exceptional circumstances required to justify the release of land from the Green Belt are considered to exist
by virtue of the evidence base demonstrating there is insufficient non-Green Belt land available to accommodate the growth required during the Local Plan period. Paragraph 130 of the NPPF readily acknowledges that the plan making process can incorporate the review of existing Green Belt boundaries in exceptional
circumstances. Penland Estates Limited believe that exceptional circumstances exist to warrant such a review and consider that a modification is required in order
to deliver economic and housing growth which is recognised by the Government to be of national and potentially international importance.
2.69 Central to this review should be an assessment of specific parcels of land with development potential against the five purposes of Green Belt as set out in the
NPPF. Sustainable sites for housing growth which are found to not contribute to the five purposes of the Green Belt should be released and subsequently allocated for
development. It is strongly contested that this is the case for the Land South of Pooles Lane. The evidenced and justified release of this land from the Green Belt will allow development to come forward which will meet the objectives of achieving sustainable development as set out in paragraph 8 of the NPPF and assist in
delivering growth of regional and national importance.
2.70 In respect of Land South of Pooles Lane, an independent Green Belt Assessment of the site has been commissioned. The Assessment, produced by Pegasus Group, is appended to these representations (Appendix D). The Green Belt Assessment draws on the recently published Green Belt Study (February 2020) but applies a
finer-grain assessment in order to provide a comprehensive and robust, yet concise
assessment. The conclusions in respect of Land South of Pooles Lane contribution to the Green Belt purposes, is outlined below:
• Purpose 1: To check the unrestricted sprawl of large built-up areas. Site Contribution is assessed as Low/weak.
• Purpose 2: To prevent neighbouring towns merging into one another. Site Contribution is assessed as Low/Weak.
• Purpose 3: To assist in safeguarding the countryside from encroachment. Site Contribution is assessed as Moderate.
• Purpose 4: To preserve the setting and special character of historic towns. Site Contribution is assessed as Low/Weak.
• Purpose 5: To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Site Contribution is assessed as n/a.
2.71 The detail underpinning the above listed conclusions is evidenced in the Pegasus Group report. In light of the specific assessment against each Green Belt purpose,
the Green Belt Appraisal provides an overarching conclusion which confirms that Land South of Pooles Lane provides a low contribution to the NPPF Green Belt
purposes. In respect of bringing forward development at the site, the Appraisal concludes that:
2.72 “the Council agree that there are exceptional circumstances to justify the release of land from the Green Belt to accommodate development needs, then the Green Belt land immediately around Hullbridge – the site, would be suitable for such release.”
2.73 It is strongly recommended that the Council review the Green Belt Assessment alongside the other submitted evidence from their Site Appraisal Paper and Green
Belt Review study. The results of the Green Belt Assessment have strongly influenced the formulation
of the Framework Plan, in particular with regard to the incorporation of landscape mitigation measures. These take the form of a substantial landscape buffer along
the length of the eastern boundary, which will comprise new woodland planting and will integrate with and enhance existing vegetation. The landscaping strategy for
the site will aid in creating a strong defensible Green Belt boundary, as well as create a scheme that responds sensitively to the countryside character, with a soft
transition from built development to rural countryside.
Agricultural Land Classification
2.74 The Site Appraisal Paper (2021) scores Land South of Pooles Lane (ref CFS190) level one (the lowest category), as the majority of the site is adjudged to contain Grade 1-3 agricultural land (best most versatile or BMV). The other sites in Hullbridge also mostly score level 1, with a few scoring level 2 (i.e. any part of the site contains Grade 1-3 agricultural land). The assessment is based on Natural England Agricultural Land Classification mapping. However, the Natural England maps' scale is intended for strategic use and is not sufficiently accurate for the assessment of individual fields. Given that the site is currently used for arable grazing, it is unlikely that the land will be classified as BMV agricultural land.
Nevertheless, it is clear that the loss of some agricultural land will be necessary if Hullbridge is to continue growing in a sustainable manner. The sites available for
development in this area are of a similar agricultural value, and it is considered the benefits of sustainable development would be sufficient to outweigh the loss of
agricultural land.
Drainage
2.75 The site is located within Flood Zone 1 (lowest risk) as defined by the Environment Agency. The site is therefore considered sequentially preferable for residential development in flood risk terms.
2.76 The score of level two for 'critical drainage risk' appears to have been informed by a high-level review of the surface water flood risk for the site. Mapping on the
Environment Agency long term flood risk website illustrates that the majority of the site is in an area of low or very low surface water flood risk. There are small,
localised areas of medium and high surface water flood risk, associated with low spots within the site or near watercourses. 2.77 This is a matter that can be suitably addressed through any future planning application, which would be supported by a surface water drainage strategy
incorporating Sustainable Urban Drainage Systems (SuDS). The Framework Plan which has been produced has been informed by a high-level Flood Risk and
Drainage Constraints Plan (Appendix E) which illustrates how surface water flood risk can be appropriately mitigated through the inclusion of detention basins in
appropriate locations. The location and design of the basins will be subject to further detailed drainage assessment, however it is considered that a scheme can
be designed that effectively mitigates the risk of surface water flooding.
Access to a train station
2.78 The nearest train station to Land South of Pooles Lane (ref CFS190) is located in Rayleigh approximately 5.2km, which is just over the 5km threshold for a level one score. However, the assessment should take into account where opportunities exist for linked trips via other sustainable modes of transport such as by cycle or public
bus. Land South of Pooles Lane is located less than two minutes' walk from the nearest bus stop, where there is a frequent bus service (every 30 minutes) to Rayleigh railway station, with the journey taking approximately 15 minutes (including walking to the bus stop). This provides a very sustainable option for future residents of this site, and the Council should consider this factor when
assessing the site's sustainability.
Access to secondary school
2.79 It is recognised that Hullbridge does not include a secondary school, and as a result, the site scores level one in the Site Appraisal Paper. However, as mentioned above, the frequent no. 20 bus route (every 30 minutes between 7.00 to 21.00 Monday to Saturday) between Hullbridge and FitzWimarc School, in Rayleigh takes
approximately 15-20 minutes. This is considered to be an acceptable distance for secondary-aged pupils who often travel by bus, bike or even train to get to school.
The Council should therefore consider the accessibility of secondary schools by modes of public transport when assessing the relative sustainability of a site.
Access to a town centre
2.80 The nearest town centre of Rayleigh is around 6.2km from Land South of Pooles
Lane (ref CFS190), which is therefore within level one threshold, as the site is more than 2.3km from the town centre. However, it should be recognised that Hullbridge
contains a range of services, which could be found on a high street, with three convenience stores, medical centre, a pharmacy and other facilities. These services
are therefore capable of supporting the day-to-day needs of residents within Hullbridge, limiting the need to travel beyond the village on a frequent basis.
2.81 The site is also less than two minutes' walk from the nearest bus stop, where there are frequent bus services (every 30 minutes) to Rayleigh town centre, with the
journey taking approximately 15 minutes. This provides a very sustainable option for future residents of this site. Furthermore, due to the impacts of the COVID-19
pandemic, there has been a greater focus on online retail shopping; thus, it is considered that the 2.3km threshold is unjustified adopted by the Site Appraisal Paper, particularly where residents of Land South of Pooles Lane could either access retail facilities by public transport or online.
Employment site
2.82 The nearest designated employment (Imperial Park) area is 4km from Land South of Pooles Lane in Rayleigh, which is just over the level one threshold of 2.3km.
However, this employment site can be accessed by frequent bus service (every 30 minutes), with the journey taking approximately 20 minutes, providing a
sustainable option for future residents of this site. The Council should also consider the impact of the COVID-19 pandemic with increased levels of working from home
practices when considering the relevant proximity of employment sites.
Conclusion
2.83 Penland Estates Limited consider that Land South of Pooles Lane, is suitable, available and achievable for development, taking into account the evidence that it
has prepared to support the site’s promotion so far. The site should be allocated in order to achieve a sustainable and deliverable development strategy for Hullbridge,
consistent with the Local Plan strategy as a whole.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Dear Mr Stephenson,

Response to Rochford District Consultation on New Local Plan

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

General Points

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

Background

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

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

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

Geography

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

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

Transport Corridors and Constraints

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

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

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

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

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

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

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

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

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

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

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

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

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

Pressure on NHS Services

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

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

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

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

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

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

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

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

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

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

Pressure on Education and school places

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

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

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

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

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

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

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

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

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

Flood Risk

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

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

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

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

Summary

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

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

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

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

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

Introduction

The purpose of this letter is to provide my feedback to your current public consultation .

I appreciate the hard work that you have put in at the time of the pandemic in putting this together.

I also appreciate the difficulties that the District Planners face, given the current hiatus in the governments new approach to planning, plus given the difficulties in predicting what our economic future will be post-pandemic.


Comments on the Consultation itself

For a public consultation it seemed very technical and full of planning jargon, rather than being written in plain English.

In my view there were far too many questions. At times these read more like a set of examination questions about Spatial Planning rather than a public consultation.

Questions written by experts for experts to answer, with lots of references to “showing your reasoning”. This gave them an off-putting rather than engaging appearance.

Please note therefore that in providing this response I have followed specific Section / Chapter headings rather than reply to each individual question asked.


District Profile

Population Statistics = a strange change of approach.

Population growth statistics are probably the most important single metric in the whole planning document, yet you have chosen to abandon the parish based method shown in the current plan (2011) and the previous options paper (2018), replacing instead with the vaguely defined Settlements table.

Presenting a confusing and contradictory picture

I found your approach here very confusing.

You have rolled parishes up and/or split them into different units making comparison difficult, compromising the consistency of the information provided, thereby making understanding the figures significantly more difficult.

For example your 2018 paper showed the population of Great Wakering as 5587 and Barling Magna as 1740, giving an total of 7327.

Yet your current stats show a rolled up total of 6225. These imply that the population has shrunk by over 1000 people, which is definitely not the case. Such shifting sands provide no firm basis for robust and rigorous analysis or decision making.

Use proper hard credible metrics

The current table is confusing and not based on a solid administrative foundation = the Civil Parishes.

I suggest you return to using a standard consistent basis for showing population change by using the current administrative parishes for these figures, splitting them below Parish as you think necessary to show specific locations (Stonebridge/Sutton, Little Wakering)

By all means use this in addition to Parish statistics but not instead of the Parish ones, because they are the unit of financial disbursement of Council tax precepts.

And here as a starting point instead of using estimated growth, you should have solid figures for every year up to the current one, based on the disbursement of precept year-on-year from the District to each Civil Parish which I understand is based on the population for each Parich.

A suggested alternative

I would produce a table as suggested below showing figures for each Civil Parish within the District

2011 census figures 2018 Precept figures estimated precept figures, , for 2023*
* to reflect position as at 2023 = the start of the new plan.

Figures should include known and agreed developments already taking place and likely to be completed by that date, for example in Great Wakering = Star Lane Brickworks (100+ dwellings), land South of High Street / West of Little Wakering Road = 250 dwellings =

= an overall village population increase of some 500+ residents.


Presenting your figures in this way should give you, your council members, and the residents a much clearer, more rigorous, more robust, less abstract, more understandable and more justifiable and defensible basis for this particular round of the new District Plan, than using only the table as currently shown.


Spatial Strategy Options

Option 3a = the best strategic solution

Option 3a based to west of Rayleigh is the only sensible place to put the bulk of the new dwellings, based on its proximity to the A127 / A130 corridor, the ONLY major road links into / out of the District.

This option assumes that ECC can actually start doing something about improving the Fairglen interchange rather than just talking about it.

Here it can be noted that since the date of the last local plan in 2011, Southend Unitary Authority has done 3 significant changes to the A127 junctions (Cuckoo Corner, Kent Elms and currently The Bell ), while the County seems to have done little for the road users in the District at all. Certainly nothing of note to the roads between Rochford and GW.

Unless a major new road is built into the District to relive the increasing pressure on East / West travel in / out of the District, and this is a highly unlikely development in the next 20 years at least, then approving new developments away from the two major arterial routes referred to above, to elsewhere in the District, just places further burdens on the already over-stretched and over-stressed largely minor road network in the rest of the District, and the further east you go the worse it gets.

Such poor travel links as well as being a burden on residents also compromises the ability to attract into and keep business in the area.

Option 2 is tactical not strategic

Option 2 of just “bolting-on” more and more developments at the tactical level on the side of existing locations is not the answer because this approach delivers none of the benefits that a strategic solution, with planned-in transport, digital, education, health and other essential infrastructure, would bring.


Spatial Themes - suggested additions

Waste and Recycling

I didn’t see many specific references to this subject.

It is strange because the District has much to be proud of in promoting recycling through the weekly bin collection.

In comparison the County provision is poor. For GW residents with items to recycle, a 20mile+ round trip to the Rayleigh tip is the only option. The monthly "in village" collection only covers non-recyclables.

If districts are to deliver on their agendas it is time the County did it’s bit to improve and extend such facilities. Make it easy to recycle and people will recycle, as the District has successfully proved, time and again


Digital Infrastructure

Given its importance to every aspect of modern life, I would add a specific subject here i.e. the need to upgrade digital facilities and telecommunications capability across the district, especially for existing remoter areas.

For example, you will only be able to deliver the digital health facilities you mention, if there is sufficient connectivity and bandwidth to do so. Yet much of GW’s telecoms infrastructure is still through copper wire carried by telegraph poles.

Integrating this infrastructure is much easier for new developments, but plans need also to be put in place to modernize the existing infrastructure throughout the District as well.



Green Belt Policy

Worryingly your paper talks about “less valuable Green Belt”. I’m not sure what this is or who decides which bits are more or less valuable.

Given that in West Great Wakering, the two major developments approved under the current plan, plus the proposed new business park, have already eroded this green belt buffer.

If you are serious about maintaining the character of the village, to ensure that GW remains “vibrant and distinctive’, to deliver on your excellently worded “Draft Vision", will require you to vigorously and robustly defend the village from further developmental incursions into the village’s surrounding Green Belt land. In particular, to ensure it is not subsumed into other neighbouring areas, especially North Shoebury, by avoiding the threat of such coalescence.


Bio-Diversity

Wildlife / natural environment pretty much goes hand in hand with a strong adherence to Green Belt policy. Your recognition of the valuable role played by Star Lane LWS / local Geological site is welcomed but it will be placed under considerable stress if what remains of the Green Belt in WGW is further eroded.


Spatial Themes - Flood Risk

Most of the flood prevention measures refers to maritime flooding, but recent climate events have shown increasing vulnerability to extreme pluvial flooding events as well.

Paving over more Green Belt especially in those areas where significant new building has already taken / is currently taking place, further increases this risk. This is especially so in low-lying areas, as precious soak-aways have been lost and it becomes a vicious circle = more building = less natural ground = more risk of flooding as previously robust and resilient locations lose that capability and become unable to cope with heavy rainfall.

Building more new homes on flood risk areas will just leave new residents unable to get flood insurance and puts existing residents at increased risk as well, as existing mains drainage of varying age and vintage is found to be inadequate.


Transport and Connectivity

Public Transport

A lot of fine words with virtually no chance of being delivered.

The inverted pyramid is fine in theory but fails in practice because the public transport links from/to GW are so poor.

Since the previous plan the foreign-owned Arriva Bus Company has got rid of the main service 4/4A, pretty much a dedicated service to and from the village to Southend, and replaced it by the much poorer extended 7 /8 service. This change seriously compromised its convenience, punctuality, reliability so much so that people have left the village because of it. I used to use the old service a lot, the replacement has sent me back to my car.

Put the 4 / 4A (or an equivalent) back on and see if it persuades private car drivers to get back on the bus, because although Stephenson’s 14 service is much better than Arriva's, = more reliable / punctual, it runs less frequently, So using a car is so much more convenient, comfortable and reliable than current public transport options.

And as for Sundays, the service has been cut it back to only a 2 hourly service = 4 buses for the whole day in each direction. This is no way to incentivise anyone to move from car to bus, unless you have absolutely no other means of transport at all.

Walking

Walking within the village is OK but to go beyond it, forget it, until significant upgrade to pavements and road crossings in the area are made.

For example, the Star Lane / Poynters Lane junction is a horror-show. To encourage more people to walk, they need to feel safe doing so. A significant upgrade to current pavements out of the village would be required to deliver on this agenda, but in the last 10 years under the current plan nothing has happened to improve this aspect at all.

This paper is full of fine words and aspirations. But as was the current plan, sadly it is just all words and no action, in spite of the fact that developments in the area which might have been expected to bring such improvements, but have so far not delivered them.


Conclusion

I trust this is satisfactory and you find these comments of use.

Thank you for providing residents with the opportunity to comment on the future of the District.

I look forward to receiving details of the future development of the plans for the District'


The following occurred to me at lunchtime today, for possible inclusion under the Spatial Themes heading.

Electronic Car Charging

The government has stated its intention to promote the adoption of electronic car use, by phasing out the building of new petrol and diesel based vehicles.

This initiative is due to come into effect during the lifetime of the new District plan.

To be succesful it will require the installation of potentially significant amounts of charging facilities and supporting infrastructure.

This will present the District with significant Planning challenges:

1. to ensure that ALL new developments have sufficient car charging facilities and capability, built-in from the very start of the Planning process for such developments

2 this will include ensuring that the requisite electrical supply and delivery capability exists for individual dwellings, shared dwellings, other types of premises e.g. garages, retail, business premises.

additional electrical supply infrastructure might also be needed to be planned in here.

3 consideration of the impact of these rerquirerments on the existing installed base of all types of residential, business, retail, community premises.

this will be easier in some places which have their own private driveways, parking facilities, etc.

but it will present a considerable challenge for older properties, especially residential premises with on-street parking in narrow car-crowded streets, where parking outside ones own property might be difficult.

4. this would argue for the development, location and installation of community charging facilities, all of which will need to be planned for.

Rochford District – Regulation 18 Local Plan Spatial Options Consultation
I refer to your consultation on Spatial Options for the ongoing preparation of the Rochford District Local
Plan.
I also refer to your letter of the 6th August 2021 enquiring as to whether Castle Point Borough Council can assist Rochford District Council in accommodating its development needs in locations outside the current
extent of the Green Belt pursuant to paragraph 141 of the National Planning Policy Framework.

Unmet Development Needs
I will address your letter of the 6th August first. As you will be aware, Castle Point Borough Council submitted its draft Local Plan to the Secretary of State for examination in public on the 2nd October 2020.
That submitted plan, to accommodate the needs for development arising in Castle Point, includes several
allocations within the current extent of the Green Belt. The submitted Castle Point Local Plan is in the process of being examined, and hearing sessions into its soundness and legal compliance took place in May and June 2021.

The Castle Point Local Plan states that it is not possible for Castle Point to meet its own development needs without incursion into the Green Belt. The supply identified across the urban area in Castle Point is
sufficient to provide 3,148 homes which amounts to around 53.4% only of the borough’s own development
requirement. To this end, Castle Point Borough Council is not able to assist Rochford District Council in meeting its development needs to 2040 in non-Green Belt locations.

Spatial Options
With regard to the Spatial Option Consultation, I note that you currently have capacity for housing within the existing urban area and on existing allocations for around 4,500 homes. This is not sufficient to meet the requirement for housing in Rochford District as derived from the Standard Methodology set out in the Government’s National Planning Policy Framework and Planning Practice Guidance of 7,200 homes to 2040. You are therefore exploring spatial options for meeting this additional need within the extent of the Green Belt in Rochford District.

The Spatial Options Consultation sets out three broad options, numbers 2 to 4 which enable Rochford District Council to explore opportunities for development in Green Belt locations. All three options include the potential for development to the west of Rayleigh.
Under option 2 consideration is being given to sites which would form an extension to Rayleigh. It is noted
that combined sites CFS121, CFS146 and CFS147 which sit to the west of Rayleigh could deliver 2,838
homes.

Under option 3 consideration is being given to concentrating growth to the west of Rayleigh. This option
appears to include sites adjacent to Wickford with a combined capacity of over 5,000 homes.
Option 4 allows for the different spatial scenarios to be combined which means that there is scope for
Rochford District Council to bring forward both an extension to Rayleigh and concentrated growth to the
West of Rayleigh delivering close to 8,000 homes in this location.

Rochford District Council will be aware that Castle Point Borough Council are considering growth in the North West Thundersley area in a review of its local plan, which sits to the south of the A127 and the south of the sites being considered for development to the West of Rayleigh.

Delivery of any development in the North West Thundersley area will depend on access from the Fairglen Interchange.

Castle Point Borough Council has therefore been in early discussion with Essex County Council as the Highway Authority about joint working to bring this location forward alongside long-term proposals for the Fairglen Interchange.

If Rochford District Council are similarly considering the potential to concentrate growth near the Fairglen
Interchange, then there is scope for the authorities to work collaboratively to open up development
opportunities around this junction. Castle Point Borough Council would therefore ask Rochford District Council to work jointly with them on planning for this area if the decision is taken to concentrate all or some of the growth within the Rochford Local Plan to the west of Rayleigh. We recommend that Basildon Council also be part of the that discussion as their borough boundary also abuts and incorporates elements of the Fairglen junction.

Sustainable Travel
I notice from the consultation material that you are seeking to emphasise a shift towards more sustainable
modes of travel through the Rochford District Local Plan. The use of Walking Completeness scores for each of the settlements will enable Rochford District Council to identify which sites will contribute best towards the creation of more sustainable walkable communities, and it will therefore be interesting to see how these scores are used to select sites and plan for the provision of community infrastructure and services.

It is however noted that the majority of Rochford residents work outside the district, and many of your
residents live in smaller settlements where the range of services is more limited. There is therefore a need to improve public transport provision alongside the growth in the Local Plan. Castle Point has similarly come to this conclusion, and will need to see service improvements across the Borough as set out in our Infrastructure Delivery Plan.

With regard to the A129, Essex County Council is developing a route improvement strategy for the stretch
from Victoria House Corner in Hadleigh to the Rayleigh Weir with an emphasis on promoting more
sustainable modes of travel. However, journeys and especially sustainable travel journeys being made by
foot, bicycle or bus do not stop at the borough boundary but continue into Rayleigh from Castle Point and
vice versa. There is therefore a need for Castle Point and Rochford Council’s to work together with Essex
County Council to ensure that the route improvement strategy, especially in relation to sustainable travel
modes extends all the way into Rayleigh town centre and to Rayleigh station.

Duty to Cooperate
Based on the comments above Castle Point Borough Council believes that there are potential strategic
cross-boundary issues to be addressed through the preparation of the Rochford District Local Plan in
relation to:
a) Any development proposed to the west of Rayleigh
b) Sustainable travel on the A129
Castle Point Borough Council is willing to work cooperatively with Rochford District Council to ensure that any issues or opportunities arising from these matters are addressed.
To date, officers of both Councils have met on the respective local plans and worked closely on ASELA
projects, including strategic planning issues. The Council submitted to the Castle Point Local Plan Inspector a statement on Duty to Cooperate within South Essex which can be found at:
https://www.castlepoint.gov.uk/download.cfm?doc=docm93jijm4n5855.pdf&ver=9609
Separately, I note that you have used evidence base jointly prepared across South Essex to inform the
Spatial Options consultation and the approach you are proposing to some matters. I welcome your use of this shared evidence base as it helps to improve the consistency of planning between the different
boroughs in South Essex.

I also note that your proposals incorporate the South Essex Regional Park, the potential for which was
identified through the South Essex Green and Blue Infrastructure Strategy. Your incorporation of the
Regional Park within the proposals for the Rochford Local Plan is also welcomed as it will aid in the delivery
of Green and Blue Infrastructure across the wider South Essex area.

Castle Point Borough Council is willing to continue working with Rochford District Council and all other
South Essex partners as appropriate to prepare a joint evidence base, to bring forward a Strategic Planning
Framework for South Essex, and to deliver the priorities of the Association of South Essex Local Authorities.

I trust this response is of assistance to you in taking forward the preparation of your Local Plan. If you have
any queries, or if you wish to meet to discuss our comments please do not hesitate to contact the Planning
Policy Manager, Amanda Parrott – aparrott@castlepoint.gov.uk

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

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

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

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

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

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

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

Heritage

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

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

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

Highways

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

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

Housing

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Q56b. With reference to Figure 44 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other

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

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

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

Consultation Representations
Our responses and representations to the questions from the above consultation are set our below. We have replied to some specific questions and used cross references where appropriate to avoid duplication.
• Introduction
o
 Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
Agree
 Q4. Do you agree with the strategic priorities and objectives we have identified?
Agree
• Strategy Options
 Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
We prefer taking forward Option 4 Balanced Combination with the following comments, preferences and concerns regarding risks.
In general, the preference is for a ‘selective’ ‘Strategy Option 4’ approach by combining Strategy Option 1 Urban Intensification; Option 2 Urban Extensions and Option 3a Concentrated Growth in the west of Rayleigh. This would need to be in specific sites and it will be easier to quantify for housing targets if we were to identify sites that we would not support.
We would not support Option 3b North of Southend and 3c Focused East of Rochford and the land allocations from Rochford to Hockley in the 2017 Strategic Housing and Employment Land Availability as well as some other sites in Lower Hockley and Rayleigh. These are transport infrastructure and risk related objections whilst there are others that negatively impacting heritage, character and setting.
The specific areas of allocations of concern are listed below:
CFS035 land west of Rochford hall 1.25 hectares
CFS041 Lee valley farm 2.54ha
CfS074 land south of Mount Bovers Lane 14.22ha
Cfs077 land north of Great Wheatley’s Road 7.5ha
CFS084 land south of hall road 7.16
CFS085 land west and north of Hall Road 2.22
CFS087 land between Western Road and Weir Farm Road 3.08
CFS121 land north of A127 38.48
CFS150 land on the north side of Victor Gardens 1.73
EXP12 land adjacent 44 Great Wheatley Road 0.12
These will exacerbate the B1013 ‘rat run’ causing huge congestion and comprised emergency evacuation with the potential risk of:
• global warming repeating ‘1950’s scale flooding’ in South East Essex,
• nuclear contamination (Bradwell) and
• airport / rail disaster.
Any development must be matched by adequate transport solutions. Until this document is available then it is difficult for consultees to make informed representations and the Council to make evidence based decisions. The whole approach is somewhat ‘chicken and egg’. The transport solution should be the first document given the historic challenges and earlier consultation responses. Once this is available, the context of spatial options can be evaluated on sound evidence as community and population safety will be of paramount concern.
Assuming there is no radical bypass, which we would not support anyway given the intrusion into Crouch Valley conservation, solutions must be found to the key rail bridges and Rayleigh Weir underpass. These are high risk pinch points for local population and egress in particular:
Rochford Bridge / Hall Road
Hockley Bridges (Greensward Lane & Church Road)
Rayleigh station (London Road)
A127 Weir underpass
As a minimum, solutions must be found to these bottle-necks - widening the bridge underpasses, flyovers etc. If certain developments were to go ahead, flooding and the increased congestion of Options 3a, 3b and the proposed allocations along B1013 will potentially lock-in and lock-out population from their homes, shops, work and living in safe communities.
• Employment and Jobs
 Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system?
Any growth must be contingent on the transport infrastructure comments in this representation, without this future growth is limited. In addition, it is important for quality of living that night flights are stopped and pollution and noise controls are enhanced.
• Green and Blue Infrastructure
 Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?
We refer you to our comments and sites outlined at Q6.
• Heritage
 Q43. With reference to the options listed in this section, or your own options, how do you feel we can best address heritage issues through the plan?
Remove allocations that threaten the key heritage sites in the District e.g. CFS035, CFS084, CFS085
 Q45. Are there any buildings, spaces or structures that should be protected for their historic, cultural or architectural significance? Should these be considered for inclusion on the Local List of non-designated assets?
Grade 1 Rochford Hall and setting.
Rochford Conservation Zone
Crouch Valley
• Town Centres and Retail
 Q48. With reference to Figures 38, 39 and 40, do you agree with existing town centre boundaries and extent of primary and secondary shopping frontages in Rayleigh, Rochford and Hockley? If not, what changes would you make? [Please state reasoning]
As regard Hockley town centre we have previously stated our preference to develop an imaginative town setting that brings Hockley Woods into the town e.g. shop ‘timber’ facades, woodland street furniture etc thus celebrating the setting of Hockley in its ancient woodlands and Spa.
• Transport and Connectivity
• We refer you to our responses under Q6 and Q28

 Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?
We refer you to our responses under Q6 and Q28
 Q52. Are there areas where improvements to transport connections are needed?
We refer you to our responses under Q6 and Q28
 Q53. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new transport connections, such as link roads or rapid transit? What routes and modes should these take? [walking, cycling, rail, bus, road etc.]
We refer you to our responses under Q6 and Q28

• Planning for Complete Communities

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

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

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

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


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

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

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

Re: Rochford District Council, New Local Plan: Spatial Options Consultation Paper 2021
Consultation regarding the proposed Spatial Options identified by Rochford District Council identifying the
range of challenges and opportunities relating the proposed growth within the Rochford District over the
next 20 years.
Essex Police welcome the opportunity from a designing out crime and crime suppression perspective to comment on the Rochford District Councils – New Local Plan: Spatial Options Consultation Paper 2021.
After review of the documentation, the ‘Essex Police – Designing out Crime Office’ (DOCO) would wish to raise the below for further consideration and would welcome further consultation regarding the below observations.
Please note that it wouldn’t be appropriate for Essex Police to make comment on questions that are commercially sensitive or where the question relates to a specialism outside of the Designing out Crime remit.

Q2. Do you agree with our draft vision for Rochford District?
Essex Police value the importance of addressing the natural environment and health and wellbeing within communities and would request embedding within the vision statement, a focus on promoting and designing a safer community. Implementing designing out crime measures will ensure a sustainable community, where crime is designed out, promoting a feeling of safety.
Appreciative of the holistic vision, Essex Police would welcome the embodiment of ‘safe and secure’ concepts within the vision for Rochford and embedded within such Strategic Documentation. Such an inclusion will ensure that safety has been considered within new proposed allocations.

Q4. Do you agree with the strategic priorities and objectives we have identified?
With regard to the specific strategic priorities and objectives, Essex Police have the following comments and observations:
Strategic Objection No. 5:
Consideration of adopting the principles and accreditation to SBD Schools.
Strategic Objection No. 6:
We would recommend seeking accreditation to SBD Homes and application of CPTED principles throughout the design lifecycle.
Strategic Objection No. 9: Please see the response to Question 51 regarding embedding sustainable transport links
Strategic Objection No. 10:
Essex Police would advocate adopting the ‘Safe Roads Approach’ when designing road infrastructure to ensure the safety of all road users.
Strategic Objection No. 11
Consideration is required to ensure the design embeds the appropriate level of permeability with connectivity
Strategic Objection No. 14
We would recommend the completion of a Health Impact
Assessment, (further information can be found within Q8)
Strategic Objection No. 17
The Essex Police DOCOwelcome the inclusion within this Strategic Objection of engaging with the ‘designing out crime’ team to ensure that all ‘new developments and the public realm are well designing and safe environments’.
Strategic Objection No. 18
Consideration of adopting the principles and accreditation to SBD Schools.
Strategic Objection No. 22 Please see the response to Question 43 regarding heritage and the built environment.
The Essex Police DOCO would welcome when designing safe and secure environments adopting Secured by Design (SBD)principles. As the preferred enabler to mitigate crime, Essex Police advocate both applying ‘Crime Prevention through Environmental Design’ (CPTED) principles and seeking the various accreditations incorporated within the applicable SBD schemes.

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

Constructing well designed places, buildings and communities that promote both sustainable
communities and health and wellbeing is an objective that the Essex Police DOCO widely supports; however, it is imperative that they must also be safe, secure, and accessible. This can similarly be evidenced within the Health Impact Assessment, as mitigating the opportunities for crime is not only about reducing and preventing injury and crime, but it is also about building strong, cohesive, vibrant, and participatory communities.

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?

Secured by Design (SBD) seeks to achieve sustainable reductions in crime through design and other approaches to help communities live in a safer society. Achieving SBD Homes Gold Accreditation will satisfy the security needs assessment requirements within BREEAM, but also address many of the associated security risks.
Academic research has proven that the application of crime prevention and SBD can see up to 75%
reductions in burglary and 25% for Vehicle crime and ASB. There are substantial Carbon cost savings
associated with building new communities to SBD standards, i.e. replacing not only poor-quality doors and windows, but also the stolen property as a result of criminal acts. This will ensure that designing out crime and crime reduction is considered throughout, be that residential, businesses and commercial space.
When considering the lifecycle and increasing the lifespan of building materials and security hardware, (such as doors and windows), Essex Police would recommend utilising companies that have achieved Secured by Design (SBD)Police Preferred Specification.
There are substantial Carbon cost savings associated with building new communities to SBD and SBD
Preferred product standards, i.e. replacing not only poor-quality doors and windows, but also the stolen property as a result of future criminal acts.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
Essex Police DOCO would welcome the potential inclusion for consultation on all proposed Design
Guides / Codes and or Masterplans to embed designing out crime concepts from the initial stages. To supplement this consultation, Essex Police DOCO would strongly recommend local authorities engage with the DOCO to embed designing out crime and CPTED principles throughout.

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?
Essex Police DOCO would advocate that across the various Design Guides / Codes and Masterplan’s a
consistent approached is garnered when approaching designing out crime and mitigating any potential security risk. The perception of crime and the fear of crime can be an influential factor in determining the synergy and ongoing sustainability of the wider community. Essex Police would recommend the developer considers the foreseeability of crime and maximise on the opportunity to embed CPTED principles, as these crime types can potentially be ‘designed out’ and minimised with due consideration. This will in turn prevent the need for bespoke situational crime prevention measures in the future and promote a sustainable community.

Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?
When designing new homes and community amenities, it is imperative to consider crime as a material consideration. The perception of crime and the fear of crime can be an influential factor in determining the synergy and ongoing sustainability of the wider community. Essex Police would recommend developers consider the foreseeability of crime and maximise on the opportunity to design such issues out, as to prevent the need for bespoke situational crime prevention measures in the future.
It is imperative that design specifications of buildings and the surrounding community are risk commensurate (i.e. correlate to the Security Needs Assessment) and it is important that an effective and realistic level of physical security is commensurate with the risk.
Encouraging residents and users of places to feel a sense of ownership and responsibility for their
surroundings can make an important contribution to the safety of a community. This can be facilitated by clarity in where public space ends and where communal, semi-private or private space begins (intermediate space). Uncertainty of ownership can increase the likelihood of crime and ASB going unchallenged. Inclusive of the above, Essex Police actively encourage the following generalised considerations:
• Access and movement – places with well-defined routes, spaces and entrances that provide for convenient movement without compromising security.
• Structure – places that are structured so that different uses do not cause conflict.
• Surveillance – places where all publicly accessible spaces are overlooked.
• Ownership – places that promote a sense of ownership, respect, territorial responsibility, and community.
• Physical Protection – places that include necessary, well-designed security features.
• Management and maintenance – places that are designed with management and maintenance in mind, to discourage crime in the present and future.
Essex Police would recommend all developments seek accreditation to the various Secured by Design (SBD) Guide or at a minimum the SBD principles.

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?
With regard to future proposals for the design of Gypsy and Traveller Sites, we would recommend
consideration of the following:
• Careful consideration appertaining to the road infrastructure into the proposed sites, as this will not only promote a safe haven for occupants but may also discourage criminal activity.
Appropriate Emergency Service Access (including necessary turning circles) is required to ensure appropriate access onto the sites.
• Road access to the site and the ongoing farm raises concerns over access and egress onto the site for emergency services and safety of the staff. Along that stretch of road what traffic calming measures will be in place, will this be replicated across the development?
• Necessity for detailed border treatments for the site as judicious planting may not be of a robust nature.
• Boundaries delineation between the public and public realm space needs to be clearly defined, with any open spaces displaying features which mitigate any potential unauthorised access.
• Consideration of the ‘Communities and Local Government, Designing Gypsy and Traveller Sites, Good Practice Guide’ when fine tuning the detail across the site.
• Early liaison with the Designing out Crime Team at the appropriate state of the design to ensure ‘CPTED principles’ are embedded within the design.

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?
Heritage indirectly features within designing out crime in many respects to ensure that any developments within the conservation areas, (containing listed buildings or other features of value), are protected from crime and ASB within those early planning considerations.
Sometimes heritage becomes an afterthought and measures put into place within a building development that may be to the detriment of a heritage asset, for instance an asset that once had good natural surveillance and passage of the public, becomes within an isolated location with little natural surveillance.

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?

To create environments that are healthy, accessible, and well-designed, there will be a need to reimagine the way that developers and landscapers deliver key service functions that are effective, and positively influence the design of public realm space. It is important to ensure that the design is such, that any community spaces and broader public realm, do not become a central point for ASB, thus having an adverse effect on those communities. Careful consideration is required around
desired levels of permeability and access and egress (i.e. wayfinding) to ensure that crime is not generated as a result.
Consideration is requested by developers and designers to adopt the “Safe system approach” when designing local roads, access road and transport links across proposed development. This will take into consideration the various road user groups who wish to access these roads.
We appreciate that it is important to create a sense of place and build communities with the provision of accessible services and facilities that encourage walking and cycling etc. It is also important to ensure that the design is such, that any community spaces and broader public realm, do not become a central point for ASB or generate a fear of crime when using that space, thus having an adverse effect on those communities.
With a focus on sustainable travel across the site, consideration needs to be given to the secure external storage facilities and bicycle security, be this within the home environment or within communal bicycle stores.

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

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

Infrastructure

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

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

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

Housing Developments

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

Crime and Policing

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