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

We find options 1 and 2 to be totally unaccepable.
I have lived in Rayleigh all of my life and I now own my own home here and am raising a family with my husband - I want our town to be the best it can be for my daughter as she grows up here. Not over developed, crowded and polluted.
At the moment Rayleigh is constantly grid locked under the weight of traffic both entering the town and passing through to A127. The fumes from cars as you walk around town is unacceptable. I cannot ever get a doctor's appointment as Audley Mills is already over subscribed.
Rochford Council has already allowed large development along the A129 to the west of Rayleigh Town, the major area off Rawreth Lane and now a flats development behind Marks & Spencers. Your proposal for the Mill Hall and The Civic Suite sites have met with considerable opposition from local residents. It is clear how the residents feel - the town cannot handle further development.
Option 3 would be our preferred choice.
The only development suitable for any form of housing in Rayleigh is the Castle Road tip - which is totally inadequate, causes considerable traffic congestion and should have been relocated years ago.
I hope you listen to our concerns,

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In the short term, Persimmon Homes is aware that Rochford’s existing Local Plan is now out of date, as per the tests of the NPPF.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.

There are three questions for which I would appreciate a response. See below.

Whilst we accept that an enormous amount of work has gone into producing this options consultation I'm sure you would acknowledge that the average person would find these documents extremely complicated and somewhat difficult to understand.

However, having lived in Rayleigh since 1980 and witnessed considerable growth within the Rochford area as a whole we find options 1 and 2 to be totally unacceptable. I will not list all our concerns and objections since your own CONS for both options speak for themselves.

However Rayleigh itself is choking under the weight of traffic both entering the town and passing through, principally to gain access to the A127. To even consider intensification or extention would be madness. Rochford Council has already allowed considerable development along the A129 to the west of Rayleigh Town, the major area off Rawreth Lane and now a flats development behind Marks & Spencers. Your proposal for the Mill Hall and The Civic Suite sites has quite rightly met with considerable opposition from local residents. Surely that is a clear indicator that Rochford residents do not want further development within Rayleigh. This latter proposal even being within the Rayleigh Conservation Area!

Only this morning I returned on foot from the Rayleigh Wier back into the town along the A129 into the High Street. The traffic was solid and creaping along for the whole distance which further extended into Websters Way. The smell of petrol fumes was considerable and I had to cover my nose for most of the way. The current level of pollution is unacceptable and I even believe these roads have historically failed to meet the required standards for air pollution. The inevitable increase in traffic such centralised development would produce will only exacerbate the problem. I would also mention that we live in Highfield Crescent, very close to Websters Way and [redacted]'s asthma has worsened over the years, I believe as a direct consequence of this increase in traffic.

I also note that "National Policy also requires that Local Plans provide strategies that accommodate unmet need from neighbouring areas". You imply that your plans could help accomodate some of this need. There appears to be no mention of any reciprocal offers or arrangments. Are there any?

As general comment we are not in favour of random piecemeal development and as such options 3 would be by far our preferred choice.

The only development suitable for any form of housing in Rayleigh is the Castle Road waste disposal site which is totally inadequate, causes considerable traffic congestion and should have been relocated years ago.

Given this is a consultation document and emphasises that decisons are yet to be made can you explain why RDC has already embarked on a partnership with Voyage to develop a number of sites within Rochford including Rayleigh Mill Hall and the Civic Suite?

Have contracts been signed by RDC to develop these sites?

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

ROCHFORD NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION- SUBMISSION OF REPRESENTATIONS ON BEHALF OF SOUTHERN & REGIONAL DEVELOPMENTS LIMITED
Claremont Planning Consultancy have been instructed by Southern and Regional Developments Limited to prepare and submit representations to the new Local Plan: Spatial Options consultation.
Southern and Regional Developments are in control of two sites within the Rochford District; the land at Lower Wyburns Farm, Rayleigh, and Sutton Road, Rochford, with both sites previously promoted to the Council through the 2018 Call for Sites exercise for the emerging
Local Plan. For clarity, it has therefore been considered prudent to prepare and submit representations to the Spatial Options consultation separately considering each site separately.
As such, please find the following sets of representations enclosed:
• Lower Wyburns Farm representations to Spatial Options- Location Plan and Illustrative
Masterplan enclosed.
• Sutton Road representations to Spatial Options - Location Plan enclosed
We trust that these representations are clear and will be duly taken into consideration, however, if Southern and Regional Developments or Claremont Planning can assist with providing any further information in relation to the sites at Lower Wyburns Farm and Sutton Road, or the content of the representations submitted, please do not hesitate to contact me on the details below.

Rochford District Council – Lower Wyburns Farm, Rayleigh
Representations to the Spatial Options
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local
Plan.

2. Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?

2.1. Claremont Planning, on behalf of Southern and Regional Development’s Ltd, are supportive of the settlement hierarchy proposed. The identification of Rayleigh as the only ‘Tier 1’ settlement within the District is supported, finding this proportionate to the settlement’s larger population and comprehensive service base, which is of both local and regional prominence. The proposed settlement hierarchy correctly recognises the strategic location of Rayleigh which affords the settlement a functional relationship with the adjacent
Southend, Basildon, Chelmsford, and London Districts.
2.2. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy. The proposed hierarchy of settlements evidences that Rayleigh benefits from a wide range of retail, employment, and community facilities and therefore represents a highly sustainable location for development. In accordance with the provisions of Paragraph 16 of the National Planning
Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is advisable that the overall distribution of growth is informed by this imperative, and a larger quantum of
growth apportioned to those settlements which are identified by the hierarchy as being most sustainable, chiefly Rayleigh. To accommodate the necessary growth of Rayleigh a full review of the settlement boundary should be undertaken through this plan review process, with Green Belt release of suitable sites promoted to ensure that Rayleigh can accommodate the level of growth its position in the settlement hierarchy requires.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Strategy Option 1: Urban Intensification
2.3. It is advised that Strategy Option 1: Urban Intensification is not advanced on its own. The current standard method identifies a housing requirement of 7,200 dwellings for the district across the next 20 years, however the consultation document establishes that only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
2.4. It is recognised that Strategy Option 2, which seeks to spread development across several development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would see growth delivered at the most sustainable settlements in the District. In accordance with the proposed settlement hierarchy, the allocation of urban extensions at Rayleigh, the District’s largest and most sustainable settlement, should be prioritised if this option is taken forward. When considering urban extensions, they should not prohibit the appropriate review of a settlement’s boundary and site releases from the Green Belt for development elsewhere. Co-ordinating urban extensions that are typically large scale developments
alongside smaller site allocations will facilitate the delivery of small to medium sites as advised by the NPPF at Paragraph 69; which will enable the continual supply of housing through a maintained trajectory.
Strategy Option 3: Concentrated Growth
2.5. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported on its own at this time. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond.
As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of
these allocations arise. Topic Paper 9: Housing prepared in support of the Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing
completions to meet the local housing need identified for the new Local Plan. The Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider the allocation of small and
medium sized sites, such as the promoted land at Lower Wyburns Farm, which can contribute directly to the next 5 year supply and be delivered quickly, making a more
immediate contribution to housing supply alongside this Strategy.
Strategy Option 4: Balanced Combination
2.6. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2).
Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not
adversely affect housing delivery in the District.
2.7. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. The southern and northern parcels of the land promoted by Southern and Regional
Developments at Lower Wyburns Farm have been recognised by the Council within their Site Assessment Paper 2021, with references CFS068 and CFS069 respectively; for their potential to deliver growth through Option 2, small urban extensions. Claremont Planning
strongly support the Council’s recognition of the land’s potential and note that the land occupies a highly sustainable location adjacent to the District’s only Tier 1 settlement.
Furthermore, the promoted site should be recognised as a suitable location which could contribute towards unmet need arising from neighbouring authorities due to its close geographical proximity to adjacent districts, particularly to the Castle Point Borough and
Southend-on-Sea Districts, whilst also benefitting from a close functional relationship these due to its proximity to the strategic highway network, namely the A127.

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

3.1. National policy, chiefly paragraph 161 of the NPPF, is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future
impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the
District is affected by Flood Zone 3 with flood risk likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rayleigh which are the areas within the District at lower risk of flooding.
3.2. The land at Lower Wyburns Farm, Daws Heath Road represents one such suitable location for development if the sequential approach to flood risk is adopted. With respect to the parcel of land south of Daws Heath Road, only a very small area along Daws Heath Road, is affected by Flood Zone 2. With respect to the promoted parcel of land north of the road, this is more heavily influenced by flood risk, being completely covered by Flood Zones 2 and 3. Previous representations submitted to the Council through the SHLAA/Call for Sites process by Claremont Planning have considered the flood risk present on the site at length and it is advanced that the flood zone 3 areas should be removed from consideration for development and instead contribute toward public open space provision and ecological enhancement measures. Any development on the northern parcel should be focused upon redeveloping the existing dwelling on the site, away from the flood prone
areas and towards the frontage with Daws Heath Road.
3.3. When assessing the flood risk of the promoted land at Lower Wyburns Farm within their initial site assessments, the Council also recognise that the majority of the promoted land is at low risk of flooding, scoring the northern and southern parcels of the site as 3 and 4 respectively for flood risk on a scale on for which 5 represents the best performing sites.
Given that the vast majority of the promoted land at Lower Wyburns Farm south of Daws Heath Road is located within Flood Zone 1, and the Council’s recognition that the site performs strongly in respect of flood risk; Claremont Planning consider that the
development of this land would be in accordance with the recommended sequential approach to flood risk in the Plan.

4. 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?

4.1. Meeting the need for different types, sizes, and tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2, is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are
more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and midsized semi-detached and detached dwellings. Claremont Planning consider that the release of Green Belt land, including the site at Lower Wyburns Farm should be strongly considered by the Council whereby the release of this land will both assist the Council in
meeting their overall housing need and facilitate the delivery of an appropriate mix of housing. In particular this will assist delivery of family sized housing which is better suited to delivery on greenfield land than constrained urban sites.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality
green and blue infrastructure is valuable, this must be balanced against the region’s need for growth. It is therefore recommended that identifying general objectives for strategic green and blue infrastructure through the plan (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced
alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on-site improvements to be delivered.
Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy establishes in Chapter 3 of the NPPF the role that strategic policies should play, which is to set the overall strategies for the pattern, scale and design quality of places. As such, policies relating to site specific provision of green and blue infrastructure would be more appropriately dealt
with through the preparation non-strategic level Plans and Policies such as those in Neighbourhood Plans.
5.2. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas and waterfronts. Whilst Option 3, requiring certain new
developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development.
Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy, meeting that criteria for soundness as identified in the NPPF.

6. 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?
6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in
continuing to support the vitality and viability of town centres. It is considered important however, that the Council recognise the importance of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the
consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development and growth at a settlement could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need and confirms that early discussions with adjacent authorities has not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed and supported that the emerging Local Plan will be able to
demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) forming the evidence base to this consultation contains detailed site assessments that identify the contribution made by promoted sites to the purposes of the Green Belt. Within
this report, the land at Lower Wyburns Farm was assessed as making a strong contribution to the purposes of the Green Belt, finding that the site presents a strong openness and has a closer relationship with the surrounding countryside than the urban area. Likewise, the initial assessment proformas prepared by the Authority also rated the identified site as relatively strongly performing Green Belt. These conclusions are refuted and it is considered that these assessments failed to recognise several key features of the promoted land which diminish its contribution to the Green Belt. Notably, assessments of the land around the site have failed to identify that both the north and south parcels of the site are currently in use and developed; with the original farmhouse and livery stables in the southern parcel alongside a range of buildings and yards that accommodate B2 Industrial uses with external storage areas and further Sui Generis horticultural and
residential uses located within the northern parcel. As such, a large quantum of the promoted site’s area represents previously developed land and should be prioritised for development.
7.3. The Joint Green Belt Study however establishes that the environmental and sustainability effects of development need to be considered when releasing land from the Green Belt, where it may be that the most sustainable locations for development may not be
appropriate or sustainable, with this pragmatic approach to Green Belt release strongly supported by Claremont Planning where it accords with the provisions of paragraph 142 of the NPPF. Specifically, paragraph 142 of the Framework recommends that plans should give first consideration to land which is previously developed and/or well served by public transport when considering Green Belt release. It has been established that a proportion of the land promoted by Southern and Regional Developments at Lower Wyburns Farm
represents previously developed land, as previously recognised in the Council’s 2017 SHELAA assessment of the southern parcel (CFS068), with built form existing on the southern parcel of the site in particular with a variety of B2 industrial sheds alongside an established concrete hardstanding and occupied by structures extending up to two stories in height, obscuring any view of the wider countryside and significantly reducing the land’s openness. Moreover, the industrial units occupying the land at present host a variety of established uses, including a lawn mower repair shop and vehicle servicing, alongside a camping and caravan site, whilst the northern parcel of land is used as a plant nursery. As
such, both parcels benefit from established activity and transport movements further reducing openness characteristics attributed to the site.
7.4. At present the Green Belt Study does not adequately consider the characteristics of the site with respect to its established uses, built form and recognitions as previously developed land. This is demonstrated through the Parcel Assessments included in the Green Belt Study, with the promoted land included incorrectly within Parcel 21 alongside undeveloped farmland. The parcel sizes identified through the study vary considerably in
shape and size, with specific characteristics of land informing the parcel sizes. An example of this and the resulting assessment of Green Belt factors is Parcel P29 that covers the land off Rayleigh Down Road and The Drive, where residential buildings and area of external caravan storage alongside/ horticultural/agricultural buildings have been recognised within a smaller parcel area and assessed as having less contribution to
Green Belt as a result. This approach of applying a smaller parcel should also have been identifeid for the land at Lower Wyburns Farm, which would have enabled its assessment separately from the woodland, playing fields and pasture that makes up the rest of parcel
21 to the east. The Green Belt Study undertaken has therefore not allowed for the appropriate assessment of edge of settlement sites that would otherwise be considered as sustainable allocation options and be taken forward for further consideration through the
Local Plan process.
7.5. The reduced openness and lack of rural character afforded by the existing structures on site reduces the land’s contribution to the Green Belt considerably. In accordance with the principles established by the Joint Green Belt Study, alongside the reduced contribution of
the land to the purposes of the Green Belt, the highly sustainable location of the site adjacent to Rayleigh and the accessibility of local services and facilities from the site, should also ensure that the land at Lower Wyburns Farm is identified as a suitable candidate for Green Belt release.

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

8.2. Promoted sites CFS068 and CFS069 (Land at Lower Wyburns Farm) identified on Figure 44 should be made available for residential development. Although land at Lower Wyburns Farm promoted by Southern and Regional Developments is not identified on the walking completeness score map presented within the ‘Complete Communities’ Topic Paper, the site is located adjacent to areas afforded attributed a walking completeness score of 8-10 showing that reasonable levels of services and facilities are located within the ‘walking catchment’ of the land. Notwithstanding this, it is recommended that the
Council be pragmatic in applying walking completeness scores where the Topic Paper confirms that being located outside of the comfortable walking catchment for a specific facility does not mean that the facility is inaccessible. This assertion is particularly relevant
for Rayleigh, where the Topic Paper establishes that 56% of the settlement is located within the walking catchment of a frequent bus service. A review of the promoted land’s context confirms that the site is located within a 5 minute walk from existing bus stops sited along the Eastwood Road. These bus stops provide very frequent services to a range of destinations including, Southend-on-Sea, Shoeburyness, Rayleigh, and Basildon Town
Centre. As such, Claremont Planning recommend that the Council recognises the highly sustainable location of the promoted land at Lower Wyburns Farm for residential
development, given both the variety of services and facilities located within the land’s walking catchment, and the site’s close proximity to frequent public transport services.
8.3. Moreover, the vision for Rayleigh advanced by the Consultation Document sets out the ambition to provide for a diverse range of housing which meet the needs of all in the community. The 2017 Strategic Housing Market Assessment (SHMA) establishes that both within Rochford, and across the South Essex region, the greatest additional demand for housing will be generated by households requiring family housing with three bedrooms. As such, it is considered that the release of the land at Lower Wyburns Farm from the Green Belt, and its allocation for residential development can strongly contribute to delivering housing to meet this need where greenfield land is considered to be more appropriate for
the delivery of family-sized housing. It is also advised that the Authority acknowledge the strategic location of the land at Lower Wyburns Farm in close proximity to the District boundary and connection to the A127 as a location which may be appropriate to meet any unmet need for family housing arising from the wider South Essex region.
8.4. It has been established that Rayleigh benefits from high levels of completeness, with a large percentage of the settlement located within the walking catchment of education, sport, leisure, and health facilities however, the ‘Complete Communities Topic Paper’ identifies that only 18% of Rayleigh is located within the walking catchment of green infrastructure. Previous representations made to the Authority promoting the land at Lower Wyburns Farm have identified that the site’s development will include provision of an area of public open space to the north west of the site. As such, it is considered that the allocation of the site will both continue to ensure that development at Rayleigh is located in the most sustainable locations, that are areas within the walking catchment of a good range of services and facilities, whilst also seeking to address deficiencies in green infrastructure provision in Rayleigh.
Enclosed: Site Location Plan: Lower Wyburns Farm, Daws Heath Road, Rayleigh
:Dwg SK001 Illustrative Masterplan

I am writing with reference to the above consultation to provide my views on the unsuitability of proposed houses in and around the Blower Close, Rayleigh vicinity.

I visited the Council stall in Rayleigh High Street on 25 August and had a very informative conversation with your council planning colleagues.
We discussed the proposal of building many houses on the farmer's land behind Blower Close and the impact on the surrounding areas nearby.

I am a resident of Blower Close and feel very strongly that the proposals for building over 100 houses nearby should not be considered for the reasons stated below:

1) My house was flooded during the torrential downpour we endured on 24 August 2013. 8 homes (in a row) were flooded in Blower Close because the drainage system underground could not cope with the vast amount of rain water. At the time, we were advised that Rayleigh had been built on a 'one pipe' system which is no longer able to cope with increased housing and development.

2) With the number of houses being proposed nearby, I am extremely concerned that concreting over the land we have around this area will only further increase the risk of flooding that we already have to monitor in Blower Close and the surrounding roads. As residents, we are extremely vigilant whenever we have heavy rainfall because the impact of being flooded is devastating. The waterways/drainage couldn't cope in
2013 and it won't be able to cope with over 100 new houses being built - only adding to the problems.

3) If Napier Road is being considered as an entry route/trunk road to the new houses, this will inevitably mean it will join Albert Road and become a 'rat run' for motorists trying to gain fast and easier access to The Chase in Rayleigh. This will make Albert Road a busier and more dangerous road because cars already park on each side of the road and it currently only allows single file traffic. I am very concerned that any emergency vehicle access would be compromised and the extra volume of vehicles would make for increased noise and pollution. There are also many children using Albert Road to walk to school via Victoria Park (green open space adjacent to Betjeman Close) and this would make the road more dangerous as they walk to Edward Francis and The FitzWimarc Schools.

4) Finally, I wish to say how disappointed I am that Green Belt land is now being considered for development. I can see there are many sites on the proposal that would be better suited for development. Rayleigh is already gridlocked with traffic most of time, regardless of the time of day you travel and I chose to live in this part of Rayleigh because of the green open spaces we still have. Rawreth and Hullbridge have undergone major building projects in recent years with temporary traffic light systems in place everywhere! Surely, we can keep our Green Belt land to enjoy for walking/nature and look to develop on other sites, if required.

To whom it may concern,

Please stop building huge housing estates in Rayleigh!

(I prefer the garden village option).

Our towns infrastructure CANNOT support these additional homes:
I can never get a doctors appointment because they have too many patients.
The roads are always busy.
Our roads are a state.
The water mains have been bursting all over town under the strain.
Our secondary schools have been disrupted with building work to accommodate the additional places needed, on top of COVID these kids have not had a fair school life experience.
If you allow housing to be developed between Wellington Road and Albert road I am concerned that we will be affected by flooding, without the fields and trees to drain the rain water.
Stop building on farm land, a growing population needs food, if you build on all of the arable land we are not going to have enough food to support ourselves.
I am totally opposed to the plans for the Mill Hall site. A town that has grown so much needs a large space to host events, it also needs to be fit for purpose; your plan’s aren’t.
Before COVID the trains were always busy, with many commuters having to stand for their journey. As people start to return to work are they even going to be able to get on a train; with everywhere along the line having increased their populations by hundreds of people?
Please do something about the recycling centre on Castle Road, it is ridiculous the amount of traffic jams it causes with people waiting to use it.

I have studied the planning suggestions and do not believe that planning a number of individual developments is the solution to the current housing needs.
Anyone who lives in Rayleigh (I have for 51 years) will know that are roads are already terribly congested and services stretched. Also a plan that just provides houses but no new infrastructure, jobs etc is not the complete answer to the problems.
Dotting houses around the town, slotting in 50,100,500 houses in areas that will use the existing roads and services will only cause more problems.
The needs of the existing people in our towns, as well as the welfare of new residents should be considered very carefully.
Building a whole new community or “garden village” would provide not only the houses but would generate the need for additional services. Potentially doctors, clinics, nurseries, shops perhaps even schools creating a significant number of local jobs instead of pushing even more people onto the commuter trains that are already over subscribed.

With regard to the Proposed Local Plan

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

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

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

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

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

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

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

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

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

Rochford Local Plan Regulation 18 Spatial Options Consultation
Representations on behalf of Rydon Homes
Responses to Questions
Q2. Do you agree with our draft vision for Rochford District? Is there anything missing from the vision that you feel needs to be included?
A : The draft ‘Vision’ for Rochford contains many appropriate and supportable elements, but it should contain a commitment to delivering sufficient high quality homes to meet need.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
A : Yes, there should be separate ‘Visions’ for each of the main settlements. This will help capture their diversity and distinctiveness. It may be necessary to have a a generic ‘villages / hamlets’ Vision for the smallest communities.
Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?
A : The strategic objectives are generally supported. However, the number should be expanded to cover cross-cutting themes. An example would be to make the link between the objective for zero carbon and the concentration of new development in sustainable locations (ie. the larger towns) explicit.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
A : Yes, the settlement hierarchy is sound. It correctly identifies Rayleigh as the Tier 1 primary settlement in the District.

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

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

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

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

Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character?
A : The Coastal Protection Belt and Upper Roach Valley should have continued protection.

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

Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?
A : This may not be necessary since the Government is already proposing to strengthen Building Regulations to deliver high energy efficient standards. If the Local Plan was to propose even higher standards, this would need to be rigorously tested in terms of the impacts on both viability and delivery.

Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas?
A : Yes, a high level ‘place making charter’ would be useful, in principle to provide guidance whilst not being inflexible.

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

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

Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
A : A single Design Guide for the whole District would become too generic and fail to identify what makes each settlement unique. Settlement specific design guides would be most effective, as long as they do not stifle innovation and can allow alternatives approaches,
where fully justified.

Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?
A : It is important that any documents are not too prescriptive and allow a degree of flexibility. All documents should include a date by which they will be reviewed.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of housing?
A : The appropriate response is to negotiate a site specific mix which is appropriate to the settlement and the characteristics of the site itself (Option 2). National Space Standards are appropriate. The approach to Part M4 of the Building Regulations could reflect that adopted in the London Plan.

Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
A : Option 4A is the most appropriate solution to meeting open space needs if they can all be met on site. Any needs which cannot be met on site should be met by off site contributions.

Q46. With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How can we also ensure our village and neighbourhood centres remain vibrant?
A : Option 2 (incorporating Town Centre policies in the Local Plan) is the most appropriate approach.

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

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

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

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

I know the government require you to build housing, but to do what you propose to do to the Mill Hall is so sad and wrong.

I have attended many functions and classes at the mill hall & have lots of Happy memories, and I am sad that this will be taken away from the younger generation.

Also the parking at the Mill hall is really needed & to take this away when you are building so many houses in this area just does not make any sense at all.

I suffer from panic attacks & agoraphobia & parking anxiety and being able to use Mill hall car park & Mill hall public toilets was a life-line for me that you have sadly taken away from me. I was hoping that this was just due to covid, but with your plans for Mill hall this will be permanent, and will sadly stop me being able to shop and support the shops in my own shopping area.

Have you been to any of the shows that are put on in the Mill hall? These will no longer be able to go ahead as your proposed hall will be too small for them to be able to do this, another valuable asset lost.

It already takes 45 minutes to get from the hungry horse area to the rayleigh weir if you go via the high street prior to lockdown, once all the new housing has been built & with no proper infrastructure in place I dread to think how long that journey will take?

The cost of the houses are not designed for our youngsters to stay in the area either, the only way they can get on the property ladder is to move out of the area, so you are not building these houses for the benefit of Rayleigh residents.

I therefore urge you to reconsider your plans and think of the residents already here before you proceed.

Dear Sir,
I write to submit feedback on the proposed new housing development sites in our area.

(New Local Plan: Spatial Options Document 2021) https://rochford.oc2.uk/document/207/28308#d28422

In common with the majority of residents I believe Rayleigh and surrounding areas already have enormous new build projects underway. We should stop further housing sprawl especially on the outskirts of towns such as Rayleigh where upgrading the road system is impractical. The uncertainty of the situation is causing anxiety amongst my friends and neighbours who maybe directly impacted.

My concerns are the usual ones:
• Loss of greenbelt and wildlife habitat
• Traffic congestion and associated air pollution
(Inability to widen the narrow residential roads in Rayleigh)
• Surface water drainage
• School and GP services

Fundamentally I fear we are on a path of infinite housing growth that surely cannot be sustained without deterioration to our quality of life. I feel we should halt all new housing developments on town borders (greenbelt land) and create new towns with the required infrastructure instead.

Thank you for the opportunity to provide my feedback, please find my responses to the questions enclosed.

RDC/Spatial Consultation 2021 Questions

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

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

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

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

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

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

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

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

You are aware that there is a growing movement in progress to save the Mill Hall in Rayleigh from demolition and redevelopment.What Rochford Council is planning to do amounts to the vandalism of a town that at the moment is a nice place to live, you will be taking away a cultural hub that in the past (pre pandemic) was contrary to what the council alleges was well used.
Please do not do to our town what Thurrock council did to Grays,they took the soul out of it.By following your plan you will take the soul out of Rayleigh

I most 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 a future residential development site.

Although I would normally voice my objections by using my own words, the following strong and clearly set out arguments, precisely sum up my feelings about these plans.

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 an COL20 would be detrimental to the Rayleigh Town Centre.

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

To close I would like to say that the impact on Rayleigh going ahead with these projects will probably not be felt by me in my lifetime. However I have children and grandchildren on whom it will most certainly have an impact on their future enjoyment, health, education and well-being. Rochford District Council should be protecting the Heritage sites and Conservation areas rather than allowing them to disappear due to the greed of a minority of fat cat developers and their enablers. We don't need more housing in the town centre, there is enough housing going up on the other sites released by the planning department. Rayleigh shouldn't end up looking any more like Basildon than it does already. The horrendous 60 style buildings we already have due to poor planning decisions in the past have made Rayleigh into a no go area for better class shops. A case in point, we are about to get a Poundland next to M&S.

Please reject these proposals and at least try to keep Rayleigh and it's Heritage and Conservation areas a pleasant place to visit and to shop.

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

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

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

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

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

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

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

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

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

STRATEGY OPTIONS

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

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

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

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

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

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

SPATIAL THEMES

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

HOUSING FOR ALL


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

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

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

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

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

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

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

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

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

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

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

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

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

EMPLOYMENT & JOBS

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

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

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

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

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

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

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

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

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

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

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

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

BIODIVERSITY

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

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

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

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

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

On-site.

GREEN AND BLUE INFRASTRUCTURE

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

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

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

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

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

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

COMMUNITY INFRASTRUCTURE

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

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

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

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

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

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

OPEN SPACES & RECREATION

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

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

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

All-weather facilities should be considered where
appropriate.

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

The potential sites seem acceptable.

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

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

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

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

HERITAGE

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

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

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

Areas of precious woodland should not be taken for
housing.

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

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

TOWN CENTRES AND RETAIL


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

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

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

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

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

N/A

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

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

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

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

TRANSPORT & CONNECTIVITY

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

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

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

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

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

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

GREEN BELT AND RURAL ISSUES

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

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

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

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

PLANNING FOR COMPLETE COMMUNITIES

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

N/A

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

N/A

How could that improve the completeness of Rayleigh?

N/A

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

N/A

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

N/A

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

N/A

iv. Other

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

N/A

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

N/A

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

N/A

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

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

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

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

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

N/A

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

N/A

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

N/A

iv. Other

N/A

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

N/A

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

N/A

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

N/A

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

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

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

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

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

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

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

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

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

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

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

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

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

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

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

N/A

Very silly to build yet more and more houses in Rayleigh. Need to stop before it gets far too busy.
Why are you building these houses, say NO!

We need more infrastructure not houses.
- Stop the traffic
- Build services not houses
- Build a community
- The Council works for us

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

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

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

We prefer options 3a & 3b.

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

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

Rayleigh has enough houses. The road is gridlock most of the time, we don't have enough services for the amount of people, schools, doctors, dentists.

Dear Sirs

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

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

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

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

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

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

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

Too much development in Rayleigh.

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

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

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

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

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

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

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

NEW LOCAL PLAN: SPATIAL OPTIONS CONSULTATION PAPER: 2021

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

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

This is due to :-

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

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

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

Cultural Characteristics

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

Environmental Characteristics

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

Economic Characteristics

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

Draft Strategic Priorities/Objectives for 2050 p.21

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

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

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

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

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

Strategic Objective 2

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

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

Strategic objective 4

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

Strategy Options

Hierarchy of Settlements

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

Growth scenarios

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

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

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

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

Planning for housing growth

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

Planning for economic and retail growth

Completed Area Action Plans have provided enough retail space.

Levels of growth needed to deliver infrastructure

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

Spatial Strategy Options

1. Urban intensification

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

2. Urban extension Would sacrifice Green Belt

Option 4

Your comments at CONS say it all.

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

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

Climate change and resilient environments

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

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

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

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

Place-making and design Q14-16

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

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

Housing for all

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

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

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

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

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

Need for affordable housing

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

Employment and Jobs

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

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

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

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

Future of Southend Airport

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

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

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

Green/Blue Infrastructure

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

Q.35-37

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

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

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

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

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

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

Heritage

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

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

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

Town centres and retail

Plan Objectives

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

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

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

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

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

Transport and connectivity

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

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

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

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

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

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

Green Belt - Rural Issues

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

Planning for Complete Communities

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

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

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

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

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

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

Draft Local Plan

I would like to make some observations about the above for consideration.

1. Judging by the map showing proposed sites for development, Rayleigh appears to be ringed on all sides, more building making it into a very large town which cannot cope with what is already happening, let along any more. The people of Rayleigh have strong ties with other towns and cities, including London, but we have no wish to become part of an area as large as a city, or to be joined to these other towns. As I'm sure they'll feel the same.

2. Before any further development is even considered the infrastructure must be looked at carefully. Any traffic or road survey must also be carried out at 'busy times' to reflect the enormity of the traffic problem already existing in the Rayleigh area.

3. This map shows far more development than was agreed in the previous plans. In Local Development Framework - Allocations DPD Reg.25, it was stated that there would be 'public park land providing a buffer between the built environment and A1245'. Proposed sites (CFS146 and CFS147) show proposals right up to the A1245, which if joined to the existing development would most likely add at least another 1000 dwelling to an already over populated and under infra-structured area.

4. With the number and size of the sites shown as Rayleigh and Rawreth proposed sites map, it is difficult to see how the natural and historic environment can be 'conserved or enhanced'.

5. Rayleigh is already a town that at times is gridlocked, it is often used as an extra road to Southend when the A127 is blocked by frequent hold ups, (Sunday 19th September is a one) adding more development will just increase the frequency of this happening.

6. Building dwellings in the middle of the town and reducing the facilities is not the answer to the need for housing. In fact how many of the recent proposal would be of a price to attract first or young buyers? Some of this land is very close to listed buildings and a scheduled ancient monument which would undoubtedly suffer if surrounded by dwellings. How long would it be before the residents became upset by noise from these facilities and then they are closed down? These are part of the heritage of Rayleigh and should be preserved along with the Mill Hall.

7. Having large conurbations of housing on the edge of any town does not mean that the business (money) will be brought into the town centre, in fact money will most likely go to large shopping malls and the town centre will die, as has been witnessed in a number of towns in the midlands. Does the local authority really wish the towns of this country to resemble the towns of the USA? We need to preserve our heritage.

8. I believe there is a place for a separate development, such as a garden village which could be built with its own infrastructure.

I do not think it is sensible to live in the past but it is important to look after this country and preserve its character, which after all also attracts visitors and brings in revenue.

I hope you will take these observations into consideration when making any decisions.

COL7 & COL20 are two sites being made residential, surely Rayleigh has had enough development in the few square miles around it, couldn't the housing I know the Gov wants be on outskirts, possibly as a new village development, with its own infrastructure i.e. doctors, schools etc.

Mill Hall is a great venue for learning and leisure, and so nice to have a cafe for social use on site. Rayleigh seems to be traffic locked most of the time. We are encouraged to walk, but where without fumes, unless you drive to venue which defeats purpose. Please don't turn my lovely Rayleigh into a concrete nightmare with a real parking problem and no green spaces.

Mill Hall COL07 and Civic Suite COL20

Since I moved to Rayleigh in 1978 a considerable amount of new houses have been built; both as estates and in-fills. The bungalow is an endangered species in Rayleigh! Hockley, Hullbridge and Hawkwell have also been markedly developed as extra housing.

No new westward routed roads have been built and the current main roads (A13 and A127) are worn out and much congested. Rayleigh is used as a through route, and these proposals are designed to remove the last civic amenities that the town possesses and turn an ancient market town into a non-community.

If the Mill Hall is under-used (ignoring Covid) it is due to a lack of proactive management and council support, Proper advertising would help! This also applies to the Windmill - surely a landmark worth showcasing for the many not obscuring for the enjoyment of a few flat dwellers.

As for the Civic Suite - it is a lovely building - perhaps the Town Museum could use it. Or is that the next thing to go!?

Re: The proposed building of 8,000- to 10,000 houses in Rayleigh.

I am disgusted by the plans of Rochford council (mainly Conservative) to build most of 8,000 to 10,000 houses they are required to build in Rayleigh (WHY RAYLEIGH). The new houses should be spread in the Rochford council area (Hockley, Rochford etc), Rayleigh is already the most crowded town. Driving around Rayleigh is already a nightmare and the infrastructure cannot cope with more housing.

COL07 and COL20 is land owned by the Council. It is ours! Developers are not pressing to build on this land. It is the historic heart of Rayleigh. Next to Mount, the Windmill and the Church. I feel proposed building would obscure the Windmill, which is such an attractive view. The historic heart of Rayleigh should become a pleasant area for the Rayleigh community. Plans for the demolition of the Mill Hall should be scrapped and a more imaginative plan devised.

I like the idea of a garden village proposed by the Liberals using option 3a and 3b close to Fossetts Lane.

I am a Conservative voter through and through but will never, ever vote Conservative in a local election again. I know many, many Conservative voters in Rayleigh who feel the same as me. Conservative councillors in Rayleigh suffered at the last election due to Mill Hall proposals. If this housing proposal is approved, things will be worse for Rayleigh councillors at the next election (local). A Conservative councillor representing Rayleigh will be rarer than a Yeti.