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

South East Essex has too many people and too many cars. It does not have the infrastructure to handle it’s current populace. Building 360 homes every year is going to exacerbate the the already significant issues. I have lived in Rochford for the last 30 years. So many new homes have already been built, and these have significantly changed the landscape. Enough is enough, more homes will mean eventually a call for a Southend Bypass, which will run through our beautiful countryside , which is a home for much wildlife. Your view of building houses goes back to a bygone era. If any houses are built, they should be carbon neutral, like the homes suggested by the Squires family at Doggetts farm. I don’t support them being built there, but I do suggest that if you are going to embark on any more house building you think about global warming and the impact your houses will have.

Yes I agree with this vision

Over-developerment: meaning loss of habitats, bio-diversity, green space, green fields, nature; agricultural land; detrimental to one's mental and physical health.

Yes I agree it should remain a gateway to rural areas

From Ashingdon to Rochford is a very long walk
The road is congested
the air quality poor
there is limited cycle lanes
the bus stops do not all have laybys and cause congestion.
There is little in Ashingdon by way of facilities.
What is missing is anything for Ashingdon!
The facilities for Rochford are accurate.
Those close to Rochford get the station, shops, doctors, library etc
But how do we gain access those of us in Ashingdon?
Once we had a library bus - discontinued
could you consider doing something regarding the Ashingdon Road
improving the cycling, reducing congestion etc
But how about more facilities in and around Ashingdon?

I am writing in response to the consultation on the New Local Plan: Spatial Options Document 2021.
My opinions predominantly apply to the promoted site CFS013 (Land at rear of Newton Hall
Gardens, Ashingdon) and CFS119. To structure my response, I am referring to Q57 and its
subsections of the survey.
I believe the final allocation of promoted sites will say a lot about our community’s culture and vision
for the future. I hope to outline my own vision, and that shared of others I have spoken to, so the
council can best serve its lifelong residents, and returning residents with who are invested in the
community.
I am a 29-year-old secondary school teacher who grew up in Canewdon View Road. I moved out at
the age of eighteen for university but upon returning from university I struggled to afford a property
in the local area. After nearly a decade of saving and career progression buying a property in
Ashingdon with my partner was just about viable. I am therefore heavily invested in strengthening
our community such that others in my own situation can afford to live where they grew up.
However, any future development should not be to the detriment of existing residents and
communities, such that Ashingdon and Rochford become dormitory towns for London.
Rochford and Ashingdon need more affordable housing, However I believe that new developments
should occur away from current population centres and only where large-scale projects (500+
homes) can be constructed. This is so they can be accompanied with infrastructure investment with
an emphasis on GP surgeries, schools and social care. Any developments on the immediate
periphery of existing side roads to Ashingdon road will only worsen congestion and demand on
public services. Developments close to people’s homes would also damage trust with Rochford
residents, whom I’m sure the majority understand the need for new housing but do not wish it upon
their own doorsteps.
I have looked very carefully at the Spatial Options Map and it seems that CFS261 meets this criteria,
given its relative separation from existing population centres and closer proximity to Rochford town
centre. Albeit the section of this site that closely borders Lingfield Drive should not be developed out
of respect to the current homeowners.
I would now like to draw your attention to a promoted site that borders my own property CFS013
(Land at rear of Newton Hall Gardens, Ashingdon) and CFS119 (the adjacent plot).
Residents of Newton Hall Gardens and Assandune Close currently enjoy the benefits of living in a
Cul-de-sac, surrounded by open fields filled with horses. This was one of the many reasons my
partner and I chose to purchase our property two years ago. The benefits of good air quality, low
noise pollution and low levels of traffic all being key factors, especially with our intention of soon
starting a family. The cul-de-sac has a strong sense of community, with most neighbours being on
first name terms and group gatherings such as VE day parties and Jubilee celebrations being a given.
This sense of community is rare in the modern world and should be preserved, with the support of
our local council who should capitalise on and foster such communities. We are concerned that if
CFS013 or the adjacent CFS119 were to be developed in the future for housing or commercial
purposes, Newton Hall Gardens would become a through road. Many residents already park on the
road making it effectively single lane, young children enjoy playing around the road, this would be
unsafe if the road became access to a larger development.
If access were obtained by other routes, Newton Hall gardens would still suffer in terms of its
microenvironment due to the potential for reduction of green space surrounding the homes,
changes to noise and air pollution, and the prospect of being overlooked. North facing properties of
Newton Hall gardens (including my own of number 9) also enjoy stunning views of St Andrew’s
Church and the River crouch (see attached), this green outlook enriches our appreciation of the
property and surrounding countryside. If the small patch of CFS013 highlighted in a darker blue in
the picture below were to be developed, these views would all be imposed upon, as could the
market value of our properties.

It is my view that CFS013 and CFS119 should only be promoted for use as community infrastructure
e.g. open space, allotments or as an extension to King Georges playing field. These sites in their
historic proximity to Ashingdon hill and St Andrew’s church should not be used for commercial and
housing purposes. If one considers the view from the church itself it would be greatly damaged by a
modern, tightly packed housing development of gardenless mansions.
In conclusion, I plead that you protect our little slice of eden on the edge of residential Ashingdon by
denying the allocation of CFS013 and CFS119 as promoted sites in the New Local Plan but I also
encourage the council to promote sites that are away from existing population centres, and come
with the promise of new infrastructure to serve our communities.

1.0 Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options on behalf of Bellway Strategic Land in relation to Land North of Brays Lane, Ashingdon (‘the Site’).
1.2 The Site has previously been submitted into the Call for Sites, references CFS126 and CFS007, which Bellway Strategic Land are promoting together to ensure a
comprehensively planned extension to Ashingdon.
1.3 Representations were submitted to the New Local Plan Issues and Options consultation in 2018 to further promote the allocation of the Site to help meet market and affordable housing need in a logical way at the edge of an existing settlement.
1.4 The only current constraint to development is the location of the Site within the Green Belt, with it being unconstrained in other regards. The Site can be used much more effectively to deliver around 250 new market and affordable homes to meet the identified needs within the District and provide new public open space.
1.5 A Vision Document (Appendix A) is submitted as part of these representations to provide further detail about the Site and its proposed development.
2.0 Response to Spatial Options Consultation Questions
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
2.1 A vision for each settlement could be helpful, but we would highlight that these should not be too restrictive. Given the length of time the Local Plan will cover, there will be changes in the local areas, some of which could be significant. It is important that the visions do not stop development reacting to such changes or the potential responding to new technology, and does not stifle innovation.
Q4. Do you agree with the strategic priorities and objectives we have identifies? Is there anything missing from the strategic priorities or objectives that you feel
needs to be included?
2.2 We suggest that objectives of the Local Plan should include to improve the affordability of housing for people of Rochford District.
2.3 The RLPSO notes (page 12) that:
“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times to average annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”. (RLPSO,
page 12).
2.4 The most recent data available reports that the median house price in the District is 11.57 times the median gross annual workplace-based earnings (‘the affordability ratio’). This is significantly greater than the national average, and indicates housing affordability
has worsened drastically in recent years.
2.5 In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69
– significantly below the District’s 11.57.
2.6 In addition, the longer term impact on housing demand resulting from the Covid-19 pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Whilst empirical data is currently limited, there are early indications there has already been an increased desire to move from more to less urban areas, due to a greater desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.
2.7 At the same time, the pandemic has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely expected there will be a degree of return to office-working, it is anticipated that the need for employees to be physically present within a particular office will be substantially reduced.
2.8 As a consequence, it can be readily predicated that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London. As a consequence, the area may well prove an increasingly popular destination for those migrating out of higher density areas in and around London. This in turn is likely to put considerable pressure on the housing market. If insufficient homes are provided, it is also likely to result in a significant worsening of affordability. Ensuring a sufficient supply of homes will be imperative if the Council is to tackle the issue of housing
affordability in the District.
2.9 The RLPSO’s proposed Strategic Objective 3 is:
“To facilitate accelerated growth in our local economy through supporting the delivery of suitably located land which meets businesses needs at each stage of their lifecycle (including delivering grow-on space to enable local businesses to flourish), the continued functioning of London Southend Airport as a thriving regional airport,
serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park”
2.10 We support this and, in addition, suggest this objective should recognise that the critical role house-building plays in supporting the local economy, and the economic benefits house builder would have for the District.
2.11 As the Local Plan Spatial Options recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.
2.12 Employment relating directly to the construction of the development will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.
2.13 Development of additional homes in the District will also engender sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of new homes on first occupation, on home set up cost, and on an ongoing basis in local shops and services in the area.
2.14 Furthermore, ensuring the provision of sufficient, suitable accommodation is important to securing investment and employers in the District.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
2.15 We agree that Rochford, including Ashingdon, should be highly ranked within the settlement hierarchy to reflect the wide range of services and facilities available,
alongside sustainable transport options and employment opportunities.
2.16 As the RLPSO recognises, Rochford and Ashingdon together form a functionallyconnected settlement.
2.17 Its ranking as Tier 2 is justified given the range of facilities available, but we would highlight that it would be beneficial for the settlement hierarchy itself to state ‘Hockley, Rochford and Ashingdon’, rather than referring to Ashingdon in the accompanying text only. This will be clearer and provide greater clarity to the decision maker.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
2.18 Given the market and affordable housing needs, affordability issues and heritage and environmental constraints in the District, it is important that the overall strategy seeks to provide a wide range of housing options throughout the Plan period in suitable locations. As such, the strategy should utilise a range of different sites to maximise options to bring forward these new homes and associated infrastructure.
2.19 The temporal dimension of any strategy will also be an important consideration. The Local Plan should seek to ensure that homes can be provided across the plan period, including within the early years. Indeed, it is particularly important for the strategy to deliver homes in the early years of the plan period, given current, acute housing needs.
2.20 For the Local Plan strategy to be sound, we consider that it will need to direct a significant proportion of housing growth to Rochford / Ashingdon.
2.21 As the RLPSO recognises, Rochford and Ashingdon together form a functionallyconnected settlement home to around 18,000 residents. Between Rochford town centre and a number of neighbourhood centres located throughout the wider settlement, the Rochford provides for a wide range of services and business spaces, including a number of specialist employment areas supporting nearby London Southend Airport. The
settlement also benefits from a railway station and has good public transport links, particularly when compared to much of the District.
2.22 Rochford / Ashingdon is characterised as a top tier settlement within the current Development Plan, i.e. one of the most sustainable settlements to which to direct
additional growth.
2.23 The Census 2011 suggested that Ashingdon Parish has an ageing population, with a
median age of 45, compared to the nation median of 39. Nevertheless, in 2011 over
20% of the population of Rochford and Ashingdon were aged 17 or under – children / young adults still make up a significant proportion of the local population, suggesting a
relatively large cohort of young people growing up in the area who may well wish to form their own households within the community in which they were raised. However, in the last 10 years, the average price paid for a homes in Ashingdon has increased 61% and the current average dwelling value is estimated to be £337,818. This suggests a lack of housing supply compared to need in the area.
2.24 Rochford and Ashingdon benefit from a range of facilities, services and employment opportunities, many of which are located in Ashingdon, as shown in Figure 2 and discussed in the previous section of this document. This resulted it being categorised (along with Rochford) as a top tier settlement in the District’s hierarchy within the current Development Plan
2.25 Ashingdon was identified as a suitable location to accommodate a proportion of the District’s housing needs through the Rochford Core Strategy (2011) – an approach that was confirmed as sound through a robust examination of proposals. The characteristics of Ashingdon remain broadly the same as they were 10 years ago, and it is evidently still a sustainable location to accommodate some growth.
2.26 One of the options presented by the RLPSO is considered far less likely to result in a sound Local Plan or to deliver sustainable development: Option 1 (urban intensification).
The RLPSP states this option entails making best possible use of our existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification
could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations). The RLPSO claims this approach could deliver 4,200 dwellings over the next 10 years.
2.27 It is important to recognise that in order to be consider sound, the Local Plan is required to meet objectively assessed housing needs. The RLPSO reports that the minimum housing requirement for the District over a 20-year period is 7,200 dwellings.
2.28 If Option 1 were to deliver 4,200 dwellings, this would result a significant housing shortage in the District. This would result in significant negative social and economic impacts – it would not deliver sustainable development.
2.29 Furthermore, we question whether urban intensification would deliver as many as 4,200
new homes.
2.30 To achieve this would require an average of 420 dwellings per annum (dpa) to be sustained over a 10-year period.
2.31 The Council’s Annual Monitoring Report 2019/20 reports that over the10-year period between April 2010 and March 2020, the District averaged delivery of 176.8 dpa
2.32 The 1,768 dwellings delivered over this period included a significant number from allocations made through the Rochford Allocations Plan (2014), and did not merely comprise dwellings provided through redeveloped of previously developed land / urban intensification.
2.33 It is also relevant to note that over the last 10 years, local and national policy has supported the redevelopment of suitable previously developed land for residential use. It is likely that much previously developed land that is suitable and viable for residential development has already been redeveloped for housing.
2.34 Even if urban intensification could meet housing needs in full, it would be highly questionable as to whether such development would be suitable. To deliver such a quantum of development within existing settlement boundaries would clearly necessitate
significantly greater densities of development than existing. This in turn would likely result in harm to the existing character of the District’s settlement, and risk harm to amenity of existing residents.
2.35 In addition, it is unlikely that such urban intensification could meet the range of different
housing needs. The RLPSO appears to suggest that it would deliver a low proportion of affordable housing (only 800 out of a total of 4,200).
2.36 A further concern is whether urban intensification would result in the same level of infrastructure improvements and other community benefits that larger allocations are capable of delivering.
2.37 Finally in relation to Option 1, it is unclear what the spatial distribution of housing would be through this approach, and whether it would result in a sustainable pattern of growth.
2.38 Rather than relying on urban intensification, it is clear that if the Local Plan strategy is to be sound and is to deliver sustainable development, it will be necessary to release some Green Belt and allocate land for residential development.
2.39 The NPPF confirms (paragraph 140) that it is appropriate for Local Plans to make alterations to the Green Belt boundary, provided there are exceptional circumstances for doing so, and that these are justified and evidenced.
2.40 Exceptional circumstances are not defined in national policy or guidance. However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:
 The scale of the objectively assessed need;
 Constraints on supply/availability of land with the potential to accommodate
sustainable development;
 Difficulties in achieving sustainable development without impinging on the Green
Belt;
 The nature and extent of the harm to the Green Belt; and
 The extent to which impacts on the purposes of the Green Belt may be mitigated as
far as practicable.
2.41 Given the scale of the District’s objectively assessed need faced, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green Belt through the preparation of this Local Plan.
2.42 Overall, we consider that a balanced combination of utilising appropriate small scale and larger sites, on both brownfield and greenfield sites is the best approach to seek to meet identified housing needs within the District.
2.43 A balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.
2.44 Bellway Strategic Land’s Site north of Brays Lane can form part of this approach, delivering around 250 homes in a sustainable location. The Site is relatively
unconstrained and can start delivering homes early in the Plan period, continuing to deliver in the medium term. It has the potential to deliver much needed new market and
affordable homes to the area at a density and layout that reflects the existing pattern and character of development in the locality.
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?
2.45 We caution against applying the same approach everywhere in the District as different areas within Rochford are very different to one another.
2.46 With over 300 listed buildings and 10 conservation areas in the District, clearly some areas have a historic nature that needs to be considered, whereas others, such as east of Ashingdon, do not have such heritage considerations.
2.47 Should the Council seek a District wide place-making charter, this will need to be relatively high level to ensure that it does not unduly restrict development and prevent it from being appropriate to its context, as recognised in Section 12 of the NPPF. A small scale proposal on brownfield land in the middle of a town, for example, will have very different design requirements to a larger scheme of homes on the edge of a settlement.
2.48 Any place-making charter should be formulated through consultation with stakeholders, including developers, to ensure that it is realistic, achievable and does not result in development becoming unviable. Such a charter should be published as part of the Local
Plan to ensure that all parties have an opportunity to comment and input.
Q16a. Do you consider the new design guides, codes or masterplans should be created alongside the new Local Plan?
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?
2.49 Given the pressing housing and affordability needs within the District, it is important that homes are delivered as soon as possible. This is particularly pertinent given that adoption of the Local Plan is not anticipated until late 2023 at the earliest. If the Council seek to deliver design guides or codes, these should be developed alongside the Local Plan with input from stakeholders to ensure that once the Plan is adopted development can commence without delay.
2.50 There is otherwise the risk that the Council adopt a Plan but development is significantly delayed, to the detriment of residents in need of new homes.
2.51 An alternative could be to allow developers to produce design guidance for allocated sites with input from the Council, local community, etc. As set out in the submitted Vision Document, Bellway Strategic Land has begun to consider the design of the land north of
Brays Lane and how development could appear.
2.52 This has been based on technical work and an assessment of the nearby area, building on the successful scheme opposite. Whilst we are keen to engage with the Council, stakeholders and local community in relation to the layout to progress this further, it is not considered that detailed design guidance is required to deliver a successful scheme on this site given the work already undertaken and success of the scheme opposite.
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes and tenures of
housing?
2.53 With areas within the District having different characteristics and development over the Plan period likely to be of varying scales, it is important for developments to be able to provide homes suitable for the site and location.
2.54 Option 1 appears too inflexible in this regard and does not recognise that individual areas have different needs in terms of housing requirements. Such an approach risks being overly restrictive and not allowing development to be appropriate to its context.
2.55 Option 2 does provide such flexibility, which is welcomed and the option we believe the Council should proceed with. It also recognises that different scales of development can be better placed to provide greater flexibility of types of housing, such as self-build.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
2.56 Utilising a range of sites across the District, especially edge of settlement extensions,
can provide significant opportunities for new green and blue infrastructure.
2.57 As set out in the Vision Document, land north of Brays Lane can provide significant new public open space, connecting to footpaths in the wider area. This will assist in delivering new green infrastructure for both existing and future residents.
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing?
2.58 Whilst we agree with the principles of the vision, it should also include reference to the provision of new homes to meet local needs and help sustain the existing services and facilities.
2.59 Not providing any new homes in the area risks affordability issues worsening and negative social and economic impacts.
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?
2.60 Land north of Brays Lane should be utilised to provide new market and affordable homes, alongside new public open space, site references CFS007 and CFS126.
2.61 Utilising such locations already benefitting from infrastructure allows development to commence early in the Plan period to start delivering homes.
2.62 As set out in the Vision Document, the Site is within a sustainable location in close proximity to a wide range of services and facilities within easy reach by sustainable
transport methods.
2.63 The Site represents a logical infill adjacent to the existing settlement, extending no further east than existing development to the south.
2.64 The Site is currently defined as being within the Green Belt, being the only constraint to its development.
2.65 Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’) considered the Site as part of Parcel 61 in the Stage 1 Assessment. Parcel 61 is a large area of land covering the entire eastern side of Rochford and Ashingdon. Clearly an assessment of this size parcel of land has limited use when assessing specific sites given that the characteristics are very different. We would caution the Council against giving this weight in the assessment process. Instead, as identified through the Welwyn Hatfield Local Plan Examination, it is important that Green Belt is considered at a sufficient fine grain. In the Examination of this Local Plan, the Inspector advised as follows: “The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied
to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might reasonably be considered further”. (EX39 of the Welwyn Hatfield Local Plan Examination, December 2017).
2.66 The Green Belt Study (2020) Stage 2 assessment did not consider the Site specifically in detail. The Site was considered as assessment area AA112. However, only a brief assessment is provided with an overall conclusion on the level of harm rather than a detailed assessment against each purpose of the Green Belt.
2.67 The Green Belt Study (2020) found that the Site makes a moderate contribution to preventing sprawl of the built-up area and a strong contribution to preventing
encroachment on the countryside. For any site not already within a built up area, these conclusions are highly likely to be similar, which must be recognised. Furthermore, as the Site is bounded by existing residential development on three sides, it is important to
consider how its development would be perceived, which is as an extension to the built up area rather than a site within the countryside.
2.68 The Site would ‘round off’ the existing settlement pattern and is already well connected to existing development. As such, it is considered to have low potential to lead to unrestricted urban sprawl when considered against purpose 1 of the Green Belt.
2.69 In relation to purpose 2, the Site is some distance from the nearest other settlement, being approximately 2 miles from Canewdon to the east. Its development would not have any risk of either actual or perceived coalescence of Ashingdon with any other
settlement.
2.70 In respect of purpose 3, there is no existing, strong defensible boundary between the urban area and adjoining countryside. There are hedgerows associated with existing garden boundaries, but no dominant landscape feature. Existing development is present
and visible within the landscape, with the site providing an opportunity to reframe this edge. The Site is not currently considered to strongly assist in safeguarding the
countryside from encroachment.
2.71 The Site is not adjacent to a conservation area or any listed buildings. Ashingdon itself has a limited number of listed buildings, with two to the very north and to the south a considerable number within Rochford. This is pertinent given that there are over 300 listed buildings within the District. The Site makes no contribution towards preserving the setting and special character of historic towns in respect of purpose 4.
2.72 In respect of purpose 5, this is only applicable where development needs can be met in full on previously developed land. For Rochford District, this is not an option as the amount of market and affordable homes that could be delivered is significantly below the
identified need.
2.73 The above assessments have been informed by the site-specific Landscape / Visual
Appraisal prepared for the Site and previously submitted to the Council. Overall it is
considered that the Site makes limited contribution towards the purposes of the Green Belt, and its residential development would not undermine the strategic purposes of the Green Belt.
2.74 The Council’s SHELAA 2017 considered that the Site is available and achievable, with the suitability dependent on an assessment of the Green Belt purposes. It was considered suitable in other regards. As set out above, the Site is considered to make limited contribution towards the Green Belt purposes and should be considered suitable, available and achievable.
2.75 As set out in greater detail in the submitted Vision Document, the Site is unconstrained and located in an already sustainable location. It can provide around 250 new homes, including a mix of sizes, market and affordable.
2.76 With infrastructure already in place, homes can start to be delivered early in the Plan period to meet identified needs.
2.77 The proposal on the Site is of a scale suitable for its surroundings, reflecting its location
adjoining the built up area of Ashingdon. It can reflect the popular and well received
Bellway development opposite on the south of Brays Lane, continuing this high quality design to provide new homes and public open spaces.
2.78 Overall, the Site is well placed to deliver much needed homes for residents, whilst contributing towards local infrastructure, both directly from the development and in the long term from spending in the local economy by residents. With the exception of the Green Belt policy constraint, it is unconstrained and represents a logical ‘filling in’ of the existing development pattern.

3.0 Comments on Integrated Impact Assessment
Assessment Framework
3.1 At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups
in the community; and 2) maintain and enhance community and settlement identify.
3.2 In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs
of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities,
including specialist services for disabled and older people?
3.3 We support the above decision-aiding question, but suggest that, in addition to meeting
the District’s housing needs (including affordable housing), the Local Plan should seek
to improve the affordability of housing for local residents.
3.4 The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened
significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national
average of 4.13. By 2020, the national affordability ratio had increased to 7.69 – significantly below the District’s 11.57.

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council’s in-house development arm, in support of the release of Land to the south of the former Adult Community Learning Centre (ACL Centre), Rocheway, Rochford (hereby referred to as the “Site” or the “Rocheway Site”) from the Green Belt and allocation for residential development.
1.2 The site is owned by Essex County Council (ECC) and is currently designated as existing open space in the adopted Local Plan. The Site has been used under license for 10 months of the year by Hambro Colts FC, a local youth football team. However, at the end of the 2020/1 football season the Colts relocated to a different ground in Hullbridge, which means that the Rocheway
Site is now without a community sports user and is not open for general public use.
1.3 The New Local Plan presents Rochford District Council (RDC) with an opportunity to take a
comprehensive approach to the consideration of open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate.
1.4 In this context, we therefore consider that the site has excellent residential redevelopment potential taking account of its sustainable location within walking and cycling distance of Rochford town Centre and the opportunity presented by the extant planning permission for the redevelopment of the former ACL Centre, granted under 17/00102/FUL, which would provide means of vehicle access to the site from the north.
1.5 Coupled with this, we propose that the loss of the existing vacant playing pitch space can be compensated for through better provision in terms of quantity and quality in an alternative suitable location

2.0 Background to the Site
2.1 The extent of the Site is shown on the accompanying plan at Appendix 1 of this document. The Site is currently designated as open space under adopted policy OSL1 and it falls within the Green Belt.
2.2 The Site is formed of playing fields to the south of the former Adult Community Learning Centre site (“ACL Centre”), constructed in the mid-1930s as a school which was later converted into its use as an ACL Centre. The designated open space to the south of the ACL was therefore originally intended as a playing field for the school and not as a purpose-built open space.
2.3 The Site is defined by strong physical hedgerow boundaries to its western, southern and eastern sides. Designated amenity open space at Millview Meadows is immediately to the west of the site and arable agricultural land is to the east. The Site located within easy walking distance of Rochford town centre’s many services, facilities and retail offer via safe, convenient and well-lit
pedestrian routes. Rochford town centre also offers regular bus routes to Southend-on-Sea and Rayleigh and mainline railway links to London Liverpool Street and London Southend Airport. The Site is considered to be sustainably located.

Planning History
2.4 The ACL Centre site directly to the north of the Site is subject to a planning consent, granted under 17/00102/FUL in March 2018 by Rochford District Council, for the redevelopment comprising a 60 dwelling Independent Living Residential Care Home (Class C2) and 14 dwelling houses (Class C3). The development is being implemented.
2.5 An extract from the approved layout plan is shown below. It includes a proposed spine road that would provide access to the dwellings to the west and the Independent Living scheme to the east. The access road extends through the site to its southern boundary with the playing fields.

[see document for image]

2.6 The development is phased to enable delivery of the 14 residential dwellings prior to the delivery of the C2 scheme. As part of this approach it was necessary for a displacement car park facility to be provided for the playing fields so that the future use of the playing fields would not be prejudiced. Therefore, application 17/00807/FUL was submitted to and in November 2017
approved by Rochford District Council for the provision of a car park and area for demountable buildings for use as a changing room to serve the playing field. This planning permission is subject to conditions, amongst others, requiring that:
● The car park area in its entirety should be constructed and operational prior to the commencement of the Phase 2 development on the former ACL Centre site.
● The demountable buildings forming the changing room and W.C facilities should be provided and made available for use prior to the beneficial use of the car park

2.8 From the above it is possible to confirm that the delivery of the displacement car park and changing facilities on the playing field land is triggered by the commencement of the Phase 2 part of the development on the ACL site.
2.9 The Phase 2 part of the development is yet to commence. The facilities consented under 17/00807/FUL are therefore yet to be delivered onsite.

3.0 Responses to the Spatial Options Questionnaire
Hierarchy of Settlements
Question 5 – Do you agree with the Settlement Hierarchy presented?
If not, what changes do you think are required?
3.1 Yes, we agree with the Settlement Hierarchy. It suitably recognises the availability of services and connections within each of the settlements and appropriately categorises them into tiers based on how the towns and villages perform in relation to both sustainability and employment.
3.2 Rochford is identified as a Tier 2 settlement and we consider this is appropriate in light of the range of services and community facilities it offers, and its overall sustainability. It would therefore be appropriate for a commensurate level of the District’s growth to be directed to Rochford town.
Spatial Strategy Options
Question 6 – Which of the identified strategy options do you consider should be taken forward in the Plan?
3.3 As a general comment, we note that the Council correctly identifies that the minimum number of homes it should be planning for over a 20-year period is the 7,200 homes arrived at using the standard method. However, this is the minimum number of homes that needs to be planned for and the Council will need to carefully consider whether a higher housing requirement is
necessary to support economic growth, infrastructure improvements or address the needs arising from neighbouring authorities.
3.4 In particular it will be important for the Council to work closely with Southend Borough Council (SBC) which has a minimum housing requirement of 1,180 new homes per annum using the standard method. As the Council will be aware, SBC set out in its latest consultation that even
with Green Belt release, it is only able to deliver around 20,000 new homes to meet its total requirement over the plan period of 23,620 homes. It is clear that SBC will need support from Rochford and other neighbouring boroughs to meet its housing needs in full. Rochford District Council should therefore plan for a level of housing growth that meets both their own needs as
well as the unmet needs of SBC.
Strategy Option 1 – Urban Intensification – we do not support this option.
3.5 In light of our comments above, this option must be ruled out as it fails to meet the needs of Rochford, let alone neighbouring areas.
3.6 This option alone would not provide the necessary quantum of land to meet the identified housing need. This strategy requires the least use of greenfield land and, by definition, would involve no further release of land from the Metropolitan Green Belt. We recognise that focusing purely on brownfield and under-utilised land provides opportunities for infill development, however this does
not allow for the necessary larger scale development options, would fail to deliver new infrastructure, and is not a sufficient option to provide the unit numbers and infrastructure Rochford requires.
Strategy Option 2 - Urban Extensions – we support option 2a insofar as it is relevant to the growth of Rochford town.
3.7 Option two is split into two sections. Section 2a focuses urban extensions in main towns. Option
2b looks to deliver urban extensions dispersed to settlements based on hierarchy.
3.8 Option 2 provides significantly better opportunities to deliver the housing and infrastructure
targets than Option 1. Option 2a ensures development is focused in sustainable locations where transport connections are established and sustainable to support the development, including Rochford town. New urban extensions focussed on the main towns in Option 2a gives the opportunity to provide additional services and facilities and provide improvements to existing
infrastructure to support the new development in addition to the existing communities.
3.9 Insofar as this option is relevant to Rochford town, we support the proposals in Option 2a to direct growth to suitable deliverable sites in and on the edge of Rochford.
3.10 We would be unsupportive of Option 2b if it would result in large scale development being directed to less sustainable locations in the district, such as the Tier 3 settlements, at the expense of suitable alternative locations in higher tier settlements such as Rochford town, including the Site at Rocheway. This would not be justified and a Plan based on this approach would therefore be unsound.
Strategy Option 3 - Concentrated Growth – we do not support this option.
3.11 A strategy option that seeks to deliver the whole local plan requirement for housing in a concentrated development (or concentrated developments) runs the very serious risk of being undeliverable. Too often local plans focus allocations on a small number of large strategic sites that inevitably come forward later in the plan period, or worse, fail at Examination. Whilst such
sites can be an important part of housing supply, their allocation should not be to the detriment of deliverable small and medium sized sites, such as the Site at Rocheway.
3.12 A clear example of the risks of concentrated growth is the North Essex Authorities, where three new Garden Communities were proposed to deliver a proportion of housing across three local authorities later into the Plan period. In 2020, following the Examination, the Inspector concluded that two of the three garden communities were not viable and therefore not deliverable, leaving the authorities without 37,500 planned new homes for the Plan period and beyond.
3.13 Another current local example of this is in Maldon, whose Local Plan (adopted in 2017) places a
substantive reliance on the large-scale Garden Suburbs. The latest 5-year housing land supply statement confirms that the supply of housing arising from these allocations is falling below the previously anticipated trajectories. This means that the Council cannot currently demonstrate a 5-year supply of housing.
3.14 We therefore consider that this option runs the very serious risk of non-delivery and is unlikely to be capable of being found sound at Examination.
Strategy Option 4 – Balanced Combination – We support this option insofar as it relates to the allocation of suitable available Greenfield sites on the edge of Rochford town.
3.15 Option 4 provides a balanced approach, allocating a variety of sites both in terms of size and location which would have far greater potential to deliver a wide mix of housing types and style whilst also ensuring homes come forward consistently across the whole Plan period.
3.16 This Option also increases the opportunities for small and medium sized housebuilders to deliver
homes in the District. It provides good opportunities for sustainable growth within Rochford with an appropriate scale of development based on the settlement hierarchy. This option is not restrictive on the location or scale of development.
3.17 Based on the response set out above we are supportive of Options 2a or 4 insofar as they direct
proportionate levels of growth to the higher order settlements in the hierarchy, including Rochford
town. Our support for either of these two options is conditional on the proposed allocation of the
Rocheway Site, which is suitable, deliverable and sustainably located.
Open Spaces and Recreation
3.18 Our responses to Open Spaces and Recreation questions are in the context of the current designation of the Rocheway Site in RDC’s Allocations Plan as an area of Existing Open Space.
Question 38 – With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
3.19 We support Option 3 as suggested by RDC which proposes to “embed a hierarchy approach into policy that seeks to prioritise and direct investment to the most important recreational facilities, including potential hub sites and key centres”. This would ensure that the funding and resource is appropriately directed to the most important, larger, locations where they are needed the most, to enable the provision and maintenance of higher quality facilities in the district in areas of high
utilisation. Coupled with this, we would support the rationalisation of low value playing pitch sites
that are rarely used and/or are without appropriate ancillary facilities, such as the Rocheway Site. As the landowner of the Rocheway Site, Essex County Council is also prepared to make a financial contribution towards the creation, improvement of, or extension to an existing multi-pitch hub site or key centre as identified in the Local Plan, to ensure that there is no net loss of pitch space.
3.20 We would therefore support the review of open spaces which do not feature within the list of hub sites and key centres, including those that are rarely used and without appropriate ancillary facilities, so that the case for rationalisation can be suitably planned for in the event such a course of action is deemed appropriate as part of the wider Local Plan proposals.
3.21 Land to the south of the former ACL Centre, Rocheway, is currently unused by the community
following its vacation by the Hambro Colts football club in 2021. This is not picked up in RDC’s Playing Pitch Strategy, which was published in 2018 and is now already three years old. The Hambro Colts were the sole users of the Site but now that it is vacant, following their move to alternative grounds in Hullbridge, the future of the Rocheway Site is uncertain. It would therefore be inappropriate for the Rocheway Site to be identified as a facility of “local importance” until an update to the Playing Pitch Strategy is undertaken in line with its own recommendation1 , which identifies that “without any form of review and update within this time period [three years] it would be difficult to make the case that the supply and demand information and assessment work is
sufficiently robust.”
3.22 The Rocheway Site is comprised of grass pitches and, in an era of challenging public sector budgets, their ongoing maintenance without a user in the community is an unnecessary burden.
This is compounded by the fact that local authorities, including Essex County Council as landowner of the Rocheway Site, are not eligible for Grass Maintenance Fund grants2
.
3.23 The Playing Pitch Strategy acknowledges on page 7 that “as the resources to improve grass pitches are limited, an increase in 3G provision could help to reduce grass pitch shortfalls through the transfer of play....”. The Local Football Facility Plan (LFFP) for Rochford, [repared by Knight, Kavanagh and Page (KKP) with support from local partners including The FA, Essex County FA,
Football Foundation, Rochford District Council, Sport England and Active Essex, was published in 2018. The purpose of the LFFP is to enable investment in football facilities to be accurately targeted. The LFFP is the go-to document for football facility investment in Rochford and aims to:
● create a network of 3G Artificial Turf Pitches;
● improve grass pitches;
● develop and improve changing rooms and pavilions; and
● develop small-sided football facilities, particularly for informal football.
3.24 The LFFP identifies eight priority projects for potential investment. Prioritisation has been
informed by local partners with the rationale of selecting sites in the poorest condition, that were most well utilised or of strategic focus to improve Local Authority pitches. These include:
● John Fisher, Rayleigh;
● Ashingdon Recreation Ground;
● Fairview Playing Field, Rayleigh;
● Great Wakering Recreation Ground;
● The Warren, Rawreth;
● Hullbridge Sports Association;
● Apex Sports Ground, Hockley; and
● Rochford Recreation Ground.
3.25 It should be noted that the Rocheway Site does not feature as a target for future investment within the LFFP.
3.26 In line with the conclusions of the Playing Pitch Strategy, we consider that where there are low value playing pitch sites that are rarely used and/or are without appropriate ancillary facilities, such as the Rocheway Site, they should be rationalised, coupled with a contribution towards the creation, improvement of, or extension to an existing multi-pitch hub site or key centre as identified in the Local Plan.
Question 40 – Are the listed potential hub site and key centres the
right ones? Are there other locations that we should be considering?
3.27 In line with our response to Question 38 above – yes, we agree that the hub sites and key centres referred to in the table are correct. We do not consider that “all other facilities” should be identified as being of local importance until the 2018 Playing Pitch Strategy has been updated to reflect changes of circumstance on sites that have occurred in the past three-year period, in line
with its own recommendations. This specifically affects the Rocheway Site, which is no longer with a user in the community and should not automatically be subject to continued designation as open space in light of this change in circumstance.
Question 41 – With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
3.28 Yes, there is an opportunity to allocate the Rocheway Site for residential development, which is
now without a community sports user, to help deliver improvements to sport facility provision onthe hub sites and/or key centres in Rochford. This approach would deliver tangible planning benefits because the Rocheway Site is in a highly sustainable location near to the core of
Rochford town centre. It would therefore be extremely well suited to residential development.
Coupled with this, financial contributions collected as a result of the allocation and development of the Site could be directly used to help fund (and expand upon the scope of) the planned improvements to hub sites and key centres as identified in the Local Football Facility Plan for Rochford. This would provide a clear planning benefit that would accord with Sport England guidance and NPPF paragraph 99, which requires the “loss from the development to be replaced by equivalent or better provision in terms of quality and quantity in a suitable location”.
3.29 For ease of reference an extract from Figure 45 of the consultation document showing the sites
put forward for the development in and around Rochford is shown below.
[see document for image]
3.30 It may be seen that the Site is identified as an area of “Other Open Space”. Without a user of the playing pitches on the Site, it is of no benefit to the community in this retained use as it is not open for public use. It should therefore be re-allocated for residential development, as part of a wider strategy involving contributions from its development to help fund improvements to other
nearby sports facilities.
Question 42 – Are there particular open spaces that we should be
protecting or improving?
3.31 Yes, we consider that Millview Meadows in Rochford should continue to be protected and identified for improved accessibility, on the condition that an allocation for residential development of the adjacent Rocheway Site is key to unlocking these improvements.
3.32 Millview Meadows is a 4.5 hectare park located directly adjacent to the west of the Rocheway Site. The park is identified on the satellite image below
3.33 The most up-to-date evidence base that audits the quality of this park is RDC’s 2009 Open Space Study. It is identified as an “Amenity Greenspace” with the following description:
“Poor accessibility (situated between houses), no information sign identifying the area, pathway around open space, grass area with planting, some seating and bins provided, broken fence to rear of playing field, no lighting”.
3.34 The only formal means of access to Millview Meadows is via a narrow alley between two residential properties at Spindle Beams to the west, as correctly described in the Study. Access is convoluted and tortuous for any visitor who does not live in the adjacent estate.
3.35 The accessibility of Millview Meadows has not increased since 2009 despite its relative quality and maintenance staying the same. In light of its size and proximity to existing and future potential residents in the core of Rochford town, Millview Meadows is severely let down by its lack of formalised access point(s).
3.36 RDC notes that feedback from the Issues & Options consultation was clear about the importance of residents having access to well-maintained and accessible open and green spaces. The Rocheway Site offers the significant potential to improve access to this underused and underappreciated local park. But access improvements that maximise the benefit of this existing
local resource can only be delivered as part of a masterplanned approach involving the residential development of the adjacent Rocheway Site.

Planning for Complete Communities
Question 57a - Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing?
3.37 Yes, we agree with RDC’s vision for Rochford and Ashingdon. In particular, we note that the Vision Statement says that “its town centre should be reimagined to become a more sustainable and vibrant space whilst retaining its historic character. It should make the most of its proximity to key employment sites and London Southend Airport to significantly grow its economic potential and the range of jobs it provides for.”
3.38 The Vision is appropriate given the Tier 2 status of these two settlements. The best way of ensuring that the Vision is realised is by allocating suitable available deliverable sites for residential development on the edge of Rochford. Land south of the former ACL Centre,
Rocheway is capable of delivering residential development that would maintain the town centre’s
vibrancy and make the most of its proximity to key local employment sites.
Question 57b - 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?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare,
allotments, other]
4. Other
3.39 We consider that promoted site CFS050 should be allocated for housing. CFS050 is the Land south of the former ACL Centre, Rocheway.
3.40 The proposed development is market led residential housing. As CFS050 is a greenfield site, it is
capable of accommodating a policy compliant quota of affordable housing and infrastructure provision. As the Site’s promoter is also the landowner, Essex County Council, we can ensure that, if allocated, the loss of the existing vacant playing pitch space can be compensated for through better provision in terms of quantity and quality in an alternative suitable location, in
accordance with Sport England guidance.
3.41 There are few comparable sites in Rochford which offer such an opportunity to maximise the potential to enhance the completeness of the town. Land south of the former ACL Centre would enhance the completeness of Rochford
3.42 The NPPF states at paragraph 142 that when drawing up Green Belt boundaries, the need to
promote sustainable patterns of development should be taken into account. At paragraph 105 the NPPF states that “the planning system should actively manage patterns of growth in support of [sustainable transport] objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine
choice of transport modes”.
3.43 Allocation of this site for development would substantially improve the completeness of Rochford
because it is located within a highly accessible location very close to the town centre. This is perfectly encapsulated within the Walkability Map extract below, which shows that the Site is within the only part of the town where the highest scoring walking completeness area (shown by the yellow shading) overlaps with the open countryside to the east. A lack of any residential
development in this location would fail to capitalise on this excellent location which can help meet
RDC’s strategic objectives

[see document for image]

3.44 Further residential development to the eastern side of the town centre would capitalise on this location’s high walkability and access to services/facilities which, in recent decades, have not been realised as the town has essentially grown in other directions primarily to the north and west, with substantially lower walkability than the land south of the ACL Centre site at Rocheway.

3.45 Coupled with the above, the Site is only 800 metres (or a 10-minute walk) from Rochford train station, which provides regular mainline services to Southend Victoria, Southend Airport and London.
3.46 The Site is also within cycling distance of the district’s major employment areas including Southend Airport, Purdeys Industrial Estate, Rochford Business Park and the emerging Saxon Business Park.
3.47 Further development to the east, specifically at Site CFS050, would therefore plainly improve the
completeness of Rochford.
Land south of the former ACL Centre is suitable
3.48 The Site is a suitable location for development, is free from technical constraints and is unencumbered. To justify this assertion, we have extracted the Appraisal for the CFS050 site from RDC’s Site Appraisal paper as contained within the evidence base – see below.

[see document for image]

3.49 Against the assessment criteria in the Site Appraisal paper, site CFS050 scores very well. Most of its assessed criteria fall into the green (i.e. performing well/unconstrained), scoring either 4 or 5 out of a possible 5 points in respect of its suitability. The Site is noted as being deliverable for housing, subject to policy. We agree with this assessment, as there are no overriding constraints to development. In this respect it will be noted that the Site performs well against the criteria relating to ecology, resource, air quality, site conditions, access to facilities and Green Belt impact.
3.50 In respect of Green Belt, we note the findings of the Green Belt Study (Assessed under parcel AA120) and propose that the existing Green Belt boundary is re-drawn along the Site’s existing eastern boundary, which is formed of mature trees and hedgerow and could be strengthened as part of a scheme’s masterplan, so that the Site is included within a revised development
boundary for Rochford, in accordance with NPPF paragraph 143f).
3.51 In only one case does the Appraisal attribute a low score of 1 out of 5 – relating to “access to bus services”. Allied to this it should be noted that the Site scores 4 out of 5 against the “distance to bus services” criterion. We agree with this as the nearest bus stops to the Site are
less than 400 metres away, on East Street/North Street. But we do not agree that the Site has poor access to bus services. The extract from the Essex Bus Map3 below shows that the numbers 7 and 8 buses, frequent services at every 15 minutes, pass through East Street/North
Street on their way to local destinations including Rayleigh, Hockley, Southend Airport, central Southend and Shoeburyness, amongst other local villages. School services also offer transport to secondary schools in Rayleigh and Southend.

[see document for image]

3.52 Based on these observations, when assessed against the Appraisal’s methodology, the “access to bus services” score should instead be at least 3 out of 5.
3.53 In two cases the Appraisal attributes a low score of 2 out of 5 – relating to heritage (built assets)
and site conditions and hazards (water).
3.54 In respect of the Built Heritage, RDC’s Conservation Area Appraisal & Management Plan shows
that the nearest designated heritage assets (Grade II listed 26 and 28 East Street and the
Rochford Conservation Area boundary) are approximately 200 metres from the Site. It should be
noted that the development of the former ACL centre (consented under 17/00102/FUL) directly to
the north, there was no suggestion that the scheme would cause any harm to heritage assets.
According to the methodology, we therefore consider that the Site should be attributed a score of 3 out of 5 on the basis that, at the very least, any impacts could be mitigated through scheme design.

3.55 In respect of site conditions and hazards (water), the Appraisal attributes the Site a score of 2, which is defined in the methodology as “containing water supply apparatus or easements”. It should be noted that the development of the adjacent former ACL centre, which historically formed part of the same site as CFS050, is currently being delivered onsite. This means that the
presence of any water apparatus should not present an insurmountable constraint to development and would be accounted for as part of the design.
3.56 Taking account of the above, we consider that the Site is entirely suitable for development.
Land south of the former ACL Centre is available and deliverable
3.57 Land south of the former ACL Centre is in single public sector ownership and is wholly within the
control of Essex County Council. Essex Housing on behalf of Essex County Council has a growing track record of securing viable planning permissions for and then delivering sites for new housing across the County, including sites at Goldlay Gardens and Moulsham Lodge in Chelmsford, Norton Road in Ingatestone, the former County Hospital in Colchester, and the former ACL Centre at Rocheway adjacent to the north of this Site, which is currently being delivered. As the Site’s promoter is also the landowner, Essex County Council, it can be ensuredthat the loss of the existing underutilised and poor-quality playing pitch space can be compensated for through better provision in terms of quantity and quality in an alternative suitable location, in accordance with Sport England guidance.
Increasing the accessibility of Millview Meadows

3.58 As set out above, the release of the Rocheway Site from the Green Belt and allocation for residential development as part of the new Local Plan brings with it the opportunity to vastly enhance the accessibility to Millview Meadows, the public park to adjacent to the west of the Site which suffers from very poor accessibility despite being open to the public. It should be possible
to create new pedestrian access points into the park as part of a masterplanned new development on the Rocheway Site.
Enhancing local sports facilities
3.59 As set out under the relevant chapter heading above, the development of the Rocheway Site
offers the opportunity to direct financial contributions towards the substantive improvement of other local sports hub sites and/or key centres identified in the Local Plan and through the supporting evidence base, to ensure that there is no net loss of pitch space

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

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

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

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

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

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

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

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

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

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

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

I would like to put forward my comments for the 20 year plan of Rochford.

As a 20 year old, I will be hopefully looking to buy a house within the next 3-5 years, and I would like to be able to buy a house which is sustainable, eco friendly and has working solar panels and similar technology. Personally, I wouldn’t necessarily enjoy living in one of the recent developments which seem to have many problems with the houses and are not sustainable and are extremely expensive to buy for the amount of space you get in my opinion.

Also, I think that something should be done to reduce traffic around Rochford, either by utilising other roads or finding ways to encourage walking/ making walking to places around Rochford easier for the locals.

I would love to continue living in Rochford as it’s where I have grown up, it has good transport links to London which I will require and all of my family are nearby, but at the moment there is not very much in Rochford Square left, and there is very few places to walk through nature, which is a real shame.

I am sending you a letter with our responses to the questions relevant to the Croudace development in Rochford. I have also attached a copy of the area Croudace propose to build on in relation to Question 57b. I hope you find these comments constructive and informative.

Spatial Options Consultation

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]
We agree with the draft vision for Rochford District, especially in relation to the delivery of high quality homes supported by accessible and responsive services and facilities, creating healthy and sustainable 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? [Please state reasoning]
We agree with Strategic Priority 1, Objective 1, facilitating the delivery of high quality and sustainable homes that meet your local community needs. Whilst we agree that previously developed land should be an important part of meeting needs for development, the council needs to be realistic about how much of the district’s need for development can be accommodated on previously developed land.
We agree with Strategic Objective 2 of Priority 1 which states that Rochford need to plan for a mix of homes to support current and future residents. It is important that the council take into account the types of dwellings required when allocating sites, considering the likely sizes and types of dwellings likely to be accommodated on any given site. Sites such as that at Hall Road, Rochford, being promoted by Croudace, offers an important opportunity to provide a diverse portfolio of housing, addressing the affordability issue that Rochford currently struggles with. From 2016-2019 Rochford only delivered 677 of the 876 new dwellings set out in the housing delivery test (2020). This rate of delivery also falls short of the South Essex Strategic Housing Market Assessment of May 2016 and June 2017 which stated that between 331 and 361 new dwellings should be delivered per annum up to 2037.
We agree with Strategic Objective 6 of Priority 1 which states that the council want to ensure that all new homes “are built to the highest attainable quality, design and sustainability standards”. Croudace prides themselves on the quality and design of the housing they build and we are certain we will meet the council’s standards for development.
We agree with Strategic Objective 11 of Priority 3 which wants to encourage sustainable travel within the district such as walking and cycling. Croudace’s two sites, CFS081 and CFS082 at Hall Road in Rochford, are within walking distance of Rochford town centre, encouraging residents to walk or cycle to the town centre. This factor should be given significant weight when appraising possible Greenfield and green belt releases.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required? [Please state reasoning]
We agree with the settlement hierarchy presented as we think it is reasonable to have Rayleigh, the largest town should be at the top of the hierarchy with Hockley and Rochford in tier 2 and the smaller settlements in the tiers below.
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan? [Please state reasoning]
Of the identified strategy options we believe Option 2b should be taken forward by the Plan. Option 2b would see urban extensions dispersed to settlements based on hierarchy. We agree that spreading the housing supply across a number of builders is the correct and less risky strategy and means that more housing can be delivered sooner, relieving Rochford of its affordable housing supply shortage. We believe that some of the better sites for sustainable development are within the greenbelt so as Option 2b states, some Green Belt land will need to be released. Option 2 would deliver 3,000 – 5,000 more dwellings than Option 1, which already delivers 3,000 – 5,000 homes, with 1,000 – 2,000 of these new houses being affordable, giving a potential total of 10,000 new houses of which 4,000 are affordable houses. We believe this is the correct solution to solving the affordable housing issue in Rochford. As stated in the 2021 draft Local Plan for Rochford, for every 10 additional homes the local community sees the benefit of creating or sustaining 9 local jobs and bringing in £250,000 in additional local spend from new residents.
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]
For residential development, the Planning Practice Guidance (paragraph 012) is clear that any energy performance standard required by a local policy should not exceed the equivalent of Level 4 of the Code for Sustainable Homes. The building regulations remain the most straightforward way of the country as a whole meeting the challenge of climate change. The Government is working on its Future Home Standard for significantly reducing the carbon emissions of homes, with a challenging but achievable timetable for introduction over the period to 2025. Local policies on the subject can add value where there is a locally-specific justification or opportunity, but the council needs to be clear that the policies it proposes on this front are justified, will add value, and will be capable of implementation without creating substantial duplication of work for both council and applicant that is more simply administered through the building regulations system.
Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas? [Please state reasoning]
The plan should include a place-making charter that informs relevant policies. However, the same principles should not apply everywhere in the district because some policies would not be relevant in a residential development for example.
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]
The principles set out in the draft place-making charter are commendable but it is important that the Council set out in policy what they require regarding place-making in the district. These policies will have to be financially budgeted for and may slow down development.
Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
It would not be necessary to create new design guides, codes or masterplans alongside the new Local Plan as this would create an additional burden on the council and potentially delay the release of the new Local Plan. Any design guides, codes or masterplans could be created once the new Local Plan was published.
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]
The best method to ensure Rochford Council can deliver different types, sizes and tenures of housing is to allocate different types of sites to be available for builders to buy. Ranging from brownfield sites in urban areas to Green Belt land being released for new housing developments, making available different types of sites will ensure a mix of housing types, size and tenure are built. It is also important to take into account when creating policy regarding the development of housing that the demand for different type, size and tenure will fluctuate as the demographic and requirements in relation to services of the district change. For this reason, it is important that some flexibility be designed into the policy when determining what size, type and tenure of housing is to be built on a site and that this be determined when the application is received taking into account the current local housing context. With regard to affordable housing, we expect the council to calculate how many affordable houses they need for a given period so as to not slow down the application process with lengthy negotiations. We also want to raise the issue of all the other policy measures and building regulations that builders have to comply with when assessing the number of affordable houses that need to be built, and taking into account the financial feasibility of these requirements.
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]
For Sites CFS081 and CFS082 at Hall Road, Rochford, Strategy Option 2b would be suitable for the specific housing approach which would see a mix of 1 to 4 bedroom houses built on these parcels of land. The suitable housing tenure for these sites would be a mixture of owner occupation and affordable houses falling under affordable rented tenure and intermediate (shared ownership) homes. What is required to meet the housing needs in these areas are an increased land supply to provide more housing for Rochford. Rochford has become one of the most unaffordable district counties in the country, with house prices increasing by 70% in the past 15 years. The 2016 and 2017 South Essex SHMA calculated that Rochford district council needed to build at least 360 houses for the next 20 years, however, Rochford currently build on average 166 new houses per year, which falls below the government requirement set out in the SHMA. If Rochford continue to undersupply new dwellings, housing-related issues such homelessness and concealed homes, where young people are forced to stay or move back in with their parents longer than they would want to, will become an increasing issue within the district.
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]
By providing well designed, high quality and affordable housing Rochford will be able to attract more potential workers and businesses to the district and prevent young people moving away from the area in search of affordable housing. This will ensure a stable and able work force whilst also providing jobs to the local population during the construction period of the new dwellings.
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?
The foundations of long-term economic growth is through having affordable housing young people can afford. This will decrease the likelihood that they will move away, taking their skills with them, whilst also attracting potential businesses to the area to provide services. Providing this housing will also create new jobs during the construction phase which can up-skill workers over a prolonged period of time.
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?
We believe net gains for biodiversity are best delivered off-site. This ensures there are no unforeseen costs during a development and we believe it is more beneficial to the environment to have biodiversity in specific areas than have it spread through developments.
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]
We think the best plan to ensure Rochford’s town centre remains vibrant is through option 6, specifically providing sustainable connections from any large-scale new housing development to Rochford town centre. Building new housing developments within a 20 minute walk of the town centre is a method of providing sustainable connections to existing town centres, and sites CFS081 and CFS082 fall within these parameters. Additionally, providing accommodation for more residents will provide greater footfall to the businesses within the town centre, further sustaining the services and employment opportunities for Rochford district.
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing? [Please state reasoning]
We agree with your vision for Rochford and Ashingdon, however, the allocation for housing has not been covered. Providing new housing will support Rochford and Ashingdon’s town centre business and provide more sustainability to services.
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?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other
We believe that site CFS081 and the eastern part of CFS082 (as shown on the attached plan) should be made available for housing market falling under Strategy Option 2b. This could improve the completeness of Rochford and Ashingdon by providing the required ‘critical mass’ in terms of housing density for additional services such as a more frequent bus services or an additional bus stop on the proposed site. This will improve the site assessments access to a bus service from a 1 to a 5 and improve the access to bus services assessment. Site CFS082 is missing from Figure 45 when it is included on the Interactive Consultation Map. We propose to build on half of the total site, preventing Rochford and Hawkwell coalescing and retaining and protecting part of the metropolitan green belt. With these two sites combined, over 600 houses could be delivered for Rochford, which would provide three main benefits. The first benefit would be to local businesses, as an increasing population would bring additional income to the business, which would allow local businesses to grow. The second benefit is that with an increasing population, other firms would view the district as a viable location to establish themselves in, further increasing employment opportunities in the district and providing more services to the area. The third benefit would be Rochford and Southend Borough District would avoid housing-related shortage issues such as homelessness and concealed households. Building more housing would also prevent young people moving away in search of housing they can afford, preventing an ageing demographic which would present its own challenges to the district.
Q57c. Are there areas in Rochford and Ashingdon that development should generally be presumed appropriate? Why these areas? [Please state reasoning]
Sites CFS081 and the Eastern half of site CFS082 should be presumed appropriate for development as they are within sustainable walking distance to Rochford town centre, and therefore offer a highly sustainable way of accommodating the housing needs of the town, a factor which we believe has been given inadequate weight in the council’s published site assessments. As well as meeting housing needs, building these developments would provide jobs over the construction period and prevent homelessness and concealed households becoming an issue within the district. These developments would also increase footfall for local businesses, making local businesses more sustainable, and potential businesses seeing Rochford as a viable area to locate their business. These factors bring the added benefit of greater sustainability to the local businesses and employment opportunities to the wider community.
We acknowledge that sites CFS081 and the eastern half of CFS082 are currently in the green belt. As we are only proposing building on the eastern part of site CFS082, the green belt harm assessment should be re-examined for this site to ensure that it has been fairly appraised relative to all other sites being considered. Limiting development to the eastern part of CFS082 reduces the potential harm caused to green belt purposes, preventing Rochford and Hawkley merging into one another in line with paragraph 138 subsection b of the 2019 NPPF.
The recent development of 620 homes to the east of sites CFS081 and CFS082 has demonstrated that growth of Rochford town in this direction can be successfully accommodated. There is a strip of land along the western edge of that development which remains designated as green belt, providing public open space. We believe the council needs to assess sites CFS081 and CFS082 (east) in light of the fact that the open space there is now not countryside, but is meeting the open space needs of the urban area. If sites CFS081 and the eastern part of CFS082 were to be released from the green belt they would effectively continue the urban area around this open space.
We also question the impact on Built Heritage assessments for sites CFS081 and CFS082 labelled at 1 and 2 respectively. We can only conclude that this low score is due to the nearby Pelham’s Farmhouse, which is a grade II listed building. However, on a site the size of CFS081 there is scope to plan the open space on site so as to minimise direct impacts which may arise to that heritage asset.
We question the assessment for site CFS081 in regards to the access to bus stop being scored at 2. CFS082 assessment scored a 4 and we propose linking the two sites allowing site CFS081 better access to bus stop services, and the area is closer on foot to the town centre. CFS081 and the eastern part of CFS082 are also large enough that they would reasonably be expected to make contributions toward new bus stops and improving bus services. We would also like the access to bus services re-appraised if were given permission to develop on the two sites as the increase in population density may provide the ‘critical mass’ to make the sites viable for the Rochford SS4 1NL bus service to come more frequently then it currently does. This would improve the appraisal score and make the development more sustainable.
The access to secondary schools for site CFS081 is appraised at a level 4 whereas site CFS082 is appraised at the lowest level of 1. With these two sites side by side, with access to the same road network as each other, we question why site CFS082’s access to secondary schools was appraised so low. If needs be, we can provide a financial contribution to a local secondary school to improve the facilities and size of the local secondary school.
We would like the access to town centre for site CFS082 to be reappraised as it is only a level 1 whereas site CFS081 is appraised at a level 4. With the two sites being developed on, a pathway through site CFS081 could be created for site CFS082 allowing it better access to Rochford town centre. The two sites fall within a 20 minute walk of Rochford town centre which should mean the appraisal for site CFS082 is higher.
We also question the appraisal for the access to employment site for site CFS082 at level 2 when CFS081 is appraised at level 4. With both sites having access to the same road network, these appraisals should be the same. We also question if the town centre has been considered as an employment site as it often is a major source of employment within a town. The town centre is only a 15 minute, 1 mile walk away or a 3 minute drive so the access to employment site for site CFS082 should be appraised higher.
We question why both sites CFS081 and CFS082 are appraised at levels 3 and 2 respectively for distance to strategic road network when both have access to the A127 being only 6 minutes away and 2 miles in distance via Cherry Orchard Way.
We would also like the appraisal for access to train services for site CFS082 to be reappraised as site CFS081 is appraised at level 3 whereas the former is at level 2. Through the development, site CFS082 will have access to Rochford train station like site CFS081. Rochford station is only a 15 minute walk or 3 minute drive away from the sites, at a distance of 1 mile from both sites. We therefore argue that the appraisal for access to train services for both sites should be higher.
We would also like the appraisal for site CFS082 proximity to water apparatus to be reassessed as it is a level 1 whereas neighbouring site CFS081 is appraised at a level 5. The River Roach does flow south of both sites and there is Rochford Reservoir only 1 mile away.
The assessment for Critical Drainage Risk for site CFS082 can be improved from a level 2 with implemented drainage systems for the proposed development.
We also question the level two assessment of impact on Ancient Woodland for site CFS082 being at a level 2 when the site is currently used as an agricultural field with no Ancient Woodland currently existing on the site. Site CFS081 with no ancient woodland on it as well was assessed at level 5 for impact on Ancient Woodland.

1.0 Introduction

1.1 These representations are submitted to the Rochford Local Plan Spatial Options (RLPSO) on behalf of M Scott Properties Ltd (‘Scott Properties’) in relation to Land North of Doggetts Close, Rochford (‘the Site’).

1.2 The Site has previously been submitted into the Call for Sites, reference CFS217, with representations submitted to the Issues and Options consultation in 2017.

1.3 Scott Properties is promoting the Site for specialist accommodation for the elderly to meet an identified need. The benefits of such accommodation include the provision of the homes themselves, and that it enables people to ‘rightsize’, releasing typically larger family homes back into the general market.

1.4 The Site is currently located within the Green Belt, this being the only significant constraint in bringing forward this land for specialist accommodation. The Site is otherwise unconstrained and is in a sustainable location, particularly for the specialist homes proposed.

1.5 These representations are also accompanied by a Summary Vision Document (Appendix A) to provide further information on the Site and the proposals for specialist accommodation.

2.0 Response to Spatial Options Consultation Questions

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

2.1 Strategic Objective 2 refers to providing a mix of homes, including support for the ageing population. However, this is referred to as being through the provision of private and social care schemes.

2.2 Whilst some older people will need to utilise a care scheme, many do not and simply need access to more appropriate housing. This includes the provision of bungalows, which can provide an attractive option for people as they age and as mobility may become more challenging.

2.3 Age-restricted bungalows sold on the open market also provide residents with an opportunity to retain the freehold ownership of their home, something that Scott Properties has found is desired by many older people.

2.4 Providing such housing gives people an option to ‘rightsize’ into suitable accommodation at an earlier stage in their life and can help avoid unnecessary falls and mobility issues later in life, when moving home can also become more of a challenge.

2.5 Strategic Option 2 should recognise the importance of providing such homes alongside the provision of care schemes.

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

2.6 Rochford is home to a wide range of services and facilities and we agree that it should be highly ranked within the settlement hierarchy. As one of the larger settlements in the District, it is important that this is recognised so that proportionate growth reflecting its characteristics can be directed to it.

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

2.7 Any option taken forward should also recognise the importance of providing suitable homes for older people. With the ageing population in the District and a 46% increase in over 70s by 2040 compared to current levels, it is particularly important that suitable housing is provided.

2.8 Specialist homes should be located in sustainable locations so that residents have easy access to services and facilities within close proximity. To reflect this, such sites should be within or at the edge of existing settlements, in locations that provide easy access to local amenities.

2.9 There are limited potential sites within existing settlements, and these are in any case often either too small to accommodate specialist housing as part of a mix of dwellings, unsuitable for such a use, or unviable. Edge of settlement sites are ideal for providing specialist housing schemes as they are well located in relation to services whilst being large enough to deliver a sufficient quantum of homes to create a local community, and more likely to be viable for such development.

2.10 As part of any strategy for growth, in order for the Local Plan to be sound, it will be necessary to direct a relatively large proportion of housing growth to Rochford. The Rochford and Ashingdon area is categorised as a top tier settlement within the current Development Plan, i.e. it has been confirmed as one of the most sustainable settlements to which to direct additional growth.

2.11 As the RLPSO recognises, Rochford and Ashingdon together form a functionally-connected settlement home to around 18,000 residents. Between Rochford town centre and a number of neighbourhood centres located throughout the wider settlement, Rochford provides for a wide range of services and facilities.

2.12 The RLPSO also recognises that Rochford benefits from good walking access to most services, and that the only parts of Rochford with particularly poor access to services are around Purdeys Industrial Estate and the residential neighbourhoods of Ashingdon village.

2.13 Development around Rochford and Ashingdon forms part of Strategy Options 2 and 3, with a potential urban extension under Option 2 and larger scale concentrated growth under Option 3. Under Option 4, it could also form part of the strategy, with this comprising a mix of previous options.

2.14 Given the existing size of Rochford and the services and facilities available, it will be important for any option taken forward to include growth directed to Rochford. This is of further importance given the need for housing in the short and medium term, with housing adjacent to the existing settlement of Rochford able to be delivered quickly given the infrastructure already available.

2.15 In relation to Option 1 (urban intensification), we do not consider this to be a realistic option on which to base the Local Plan strategy.

2.16 The RLPSO describes this option as making best possible use of existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations).

2.17 The RLPSO suggests that at least 4,200 homes will be built over the next 10 years under Option 1 and notes the Urban Capacity Study suggests up to a further 1,500 homes could be built through a mixture of maximising the capacity of planned housing developments and taking a more permissive approach to higher densities in urban areas.

2.18 Clearly, it will be appropriate for the Local Plan to encourage an element of urban intensification and the efficient use of previously developed land to help meet housing needs. However, the approach cannot be relied upon to meet development needs in full.

2.19 The NPPF (paragraph 60) stresses that it is a Government objective to significantly boost the supply of housing and to meet local housing needs. Furthermore, as per paragraph 35 of the NPPF, it is a specific requirement of a sound Local Plan for it to seek to meet the area’s objectively assessed needs, as a minimum.

2.20 Option 1 alone cannot meet objectively assessed needs in full. The RLPSO suggests a need to plan for at least 7,200 additional homes, but that Option 1 would only deliver 4,200 homes over 10 years. This would leave the District significantly short on housing.

2.21 In any case, we question whether it is realistic to project delivery of 4,200 homes over 10 years through such an approach. To provide this number would require an average of 420 homes to be delivery per annum over a 10-year period. The Council reports that between 2010 and 2020 the District average was 176.8 dwelling completions per annum. It also reports that this number included contributions from strategic site allocations made by the Rochford Allocations Plan. It is totally unfeasible, therefore, to suggest that this rate can be more than doubled without any further allocations, particularly when one considers that there is only a finite supply of previously developed land suitable and viable for residential redevelopment, much of which is likely to have already been redeveloped.

2.22 One of the tests of soundness for a Local Plan is its effectiveness – whether it is deliverable. We do not consider that a strategy which relied on urban intensification to deliver 4,200 homes would be effective.

2.23 A further concern with a strategy that relies principally upon urban intensification is its ability to deliver the types and tenure of homes that are required. It is likely urban intensification would deliver primarily smaller dwellings and on individual sites each comprising a relatively small number of dwellings. As such, this approach is unlikely to provide a range of different accommodation types to meet the needs of all future residents. Furthermore, it is unlikely that this approach would deliver a range of different tenures of accommodation, including affordable housing, in a manner that may be expected from larger developments. Additionally, it is unlikely that such sites will be able to deliver other community benefits on top of housing, or significant infrastructure improvements.

2.24 We would also question whether a strategy that sought to significantly increase densities would be appropriate for the District. Such an approach is likely to be of detriment to the character of the District’s settlements, and potentially harmful to the amenity of existing and future residents.

2.25 We consider that in order to ensure a sound Local Plan, deliver sustainable development that meets the needs of all of the District’s residents, and to formulate a Local Plan that complies with national policy, it will be necessary to revise the existing Green Belt boundaries and allocate additional sites for development.

2.26 It is entirely appropriate for revisions to the Green Belt boundary to be made through the Local Plan, as the NPPF confirms at paragraph 140. The NPPF also states that alterations to the Green Belt should only be made where exceptional circumstances are fully evidenced and justified; and that strategic policies should establish the need for any changes to Green Belt boundaries.
2.27 Exceptional circumstances are not defined in national policy or guidance. However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:

• the scale of the objectively assessed need;
• constraints on supply/availability of land with the potential to accommodate sustainable development;
• difficulties in achieving sustainable development without impinging on the Green Belt;
• the nature and extent of the harm to the Green Belt; and
• the extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.

2.28 Given the scale of the District’s objectively assessed need, and the inability to sustainably meet the range of different needs without revising the Green Belt boundary, it is evident that there are exceptional circumstances that justify alterations to the Green Belt through the Rochford Local Plan. The Local Plan will need to make revisions to the Green Belt boundary in order to provide a sound, sustainable strategy for the District.

2.29 As such, this directs the Local Plan towards Options 2, 3 or 4.

2.30 Under Option 2, sites could be utilised at the edge of sustainable settlements, which should include Rochford, to deliver a range of housing growth. This option provides the flexibility to utilise smaller sites to deliver homes earlier alongside larger sites to meet the overall housing need.

2.31 Both Options 2a and 2b include development to the east of Rochford, which we consider is appropriate and necessary to assist in meeting the housing need, direct growth to sustainable locations and provide choice for residents.

2.32 Option 3 comprises concentrated growth of 1,500+ dwellings. A potential location is shown to the east of Rochford, Option 3c. Whilst this scores negatively in the Integrated Impact Assessment (IIA) in relation to landscape, environmental quality and natural resources, some of these impacts will depend upon the exact scale of development chosen and there are likely to be opportunities to utilise smaller sites which can come forward sooner and may have less of an impact.

2.33 In relation to environmental quality, this negative effect seems highly uncertain given that the impacts on air quality cannot be known at this time, especially considering that mitigation could be provided if needed.

2.34 Option 4 comprises a balanced combination of the previous options. This scored most highly within the IIA given the flexibility to provide a tailored approach.

2.35 We agree with this conclusion and consider that Option 4 will provide the best approach to meeting housing, and other needs, within the District. For specialist homes for older people in particular, it is important that specific sites are allocated in sustainable locations to meet this high need. A balanced approach under Option 4 gives the flexibility to be able to do this.

2.36 The Site promoted by Scott Properties is in a sustainable location and can deliver specialist housing for older people (in the form of bungalows) early in the Plan period. The location of the Site adjacent to the existing developed area of Rochford enables it to utilise existing infrastructure and it could form part of Options 2, 3 and 4.

2.37 Whichever option is taken forward, the allocation of the Site to provide housing for older people should form a key part of this to deliver much needed homes to meet the requirements of the ageing population of Rochford.

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?

2.38 Any place-making charter should reflect that areas of Rochford District are different to one another and that different forms of housing have their own characteristics and requirements.

2.39 Providing specialist housing for older people, for example, requires a different approach to traditional family homes, with different requirements and character of development. Bungalows require a greater land take than two-storey homes, with it important to consider and reflect this to ensure that design is not stifled and schemes can respond to their surroundings and individual requirements.
2.40 Should the Council wish to provide a place-making charter, it will be important that this is through engagement with stakeholders, including developers, especially in relation to specialist housing.

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

2.41 To provide suitable specialist homes for older people, it is important that these are carefully considered and specifically allocated for.

2.42 Whilst requiring all new homes to be built to Part M4(2) and a proportion to Part M4(3) of the Building Regulations can help ensure homes are available for a wide range of people, it does not specifically ensure provision of homes to meet the needs of older people, as the NPPF instructs. At paragraph 61 of the NPPF, it emphasises the need to ensure the housing needs of different groups, including but not limited to older people and people with disabilities, are met.

2.43 It is necessary for the new Local Plan to specifically consider the housing requirements for older people, and make specific provision, rather than meeting this through a requirement for housing to be generally in compliance with Parts M4(2) or M4(3).

2.44 The best way to plan for housing for older people is to allocate specific sites to meet this need. This then allows such sites to come forward without needing to try and compete with developers seeking to build general open market housing, which specialist housing providers are often unable to do.

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?

2.45 The recognition of the need to plan for specialist housing is welcomed.

2.46 However, this should include housing for older people.

2.47 The housing needs of older people have often been overlooked, to the detriment of older people, as well as the housing market more generally. The housing needs of this ageing population are not being met at a national level. A 2020 study by the Centre for the Study of Financial Innovation found that since 2000, retirement housing has only accounted for 2% of all new homes built nationally – around 125,000 homes. However, each year approximately 700,000 people in the UK turn 65.

2.48 Separately, the increasing under-occupation of the national housing stock caused by a rapidly ageing population has been blamed for a dysfunctional housing market, in which first-time buyers find it difficult to get on the housing ladder and families find moving to larger homes prohibitively expensive.

2.49 The NPPF requires (paragraph 61) planning to meet the housing needs of different groups, including but not limited to older people and people with disabilities, are met.

2.50 Planning Practice Guidance (PPG) is clear on the importance of planning for housing to meet the needs of older people. The PPG expressly states:

“The need to provide housing for older people is critical” (Paragraph: 001 Reference ID: 63-001-20190626, emphasis added).

And;

“The provision of appropriate housing for people with disabilities, including specialist and supported housing, is crucial in helping them to live safe and independent lives.” (Paragraph: 002 Reference ID: 63-002-20190626).

2.51 The NPPF recognises that ‘older people’ are not a homogeneous group, but that older persons have a variety of differing accommodation needs. It defines older people for the purposes of planning as:

“People over or approaching retirement age, including the active, newly retired through to the very frail elderly; and whose housing needs can encompass accessible, adaptable general needs housing through to the full range of retirement and specialised housing for those with support or care needs”. (NPPF Annex 2)

2.52 The PPG confirms the need to recognise that there are multitude of different types of specialist housing designed to meet the diverse needs of older people, and that needs cannot be met simply through extra-care or sheltered housing. It notes that specialist housing for older people includes age-restricted general market housing. It states that this type of housing is generally for people aged 55 and over and the active elderly, and that it may include some shared amenities such as communal gardens, but does not include support or care services.

2.53 The PPG also states that specialist housing for older people can include retirement living, with limited communal facilities and generally without care services, but with some support to enable independent living (for example, the potential for 24 hour on-site assistance through an alarm system).

2.54 Many people do not require care but wish to ‘rightsize’ into a more suitable homes, often releasing equity in the process. With the ageing population expected to significantly increase in the District, as the RLPSO acknowledges, it is important that suitable homes are provided accordingly.

2.55 Currently residents are often left with no choice but to remain in larger family homes, sometimes as a single person household. Scott Properties’ proposal seeks to provide older people with an option at a point in their life before they require care.

2.56 Providing suitable homes in, and close to, existing settlements allows people to remain within their local community in more suitable housing. Providing a cluster of specialist homes together can create a community within the scheme itself, a further benefit of allocating specific sites.

2.57 In addition to the obvious benefit to older people who would directly benefit from the provision of such accommodation, an attractive rightsizing option for older people which still allows them to live independently and own their own home can help reduce the under-occupancy rate of the existing housing stock, and free-up larger dwellings for families currently in housing need.

Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing?

2.58 Whilst we agree with the principles of the vision, it should also include the provision of suitable homes for older people to enable them to live in appropriate housing in their local community, reflecting that this is evidently an important issue for the District and one the NPPF instructs Local Plans to address.

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?

2.59 The Site promoted by Scott Properties (CFS217), should be made available for specialist homes for older people.

2.60 As set out above and reflected in the Spatial Options document, the District has an ageing population and it is important to deliver new homes to meet this need, as required by the NPPF.

2.61 The provision of specialist homes also has a further benefit that it releases larger family homes back into the general market as residents move out of those homes and into more suitable homes.

2.62 To reflect the differing needs of older people in respect of housing, the Site should be allocated to provide specialist housing in the form of bungalows.

2.63 The Site is located in a sustainable location close to existing services and facilities, with many within walking distance. As a triangular and relatively small arable field it is currently underused and could be utilised much more efficiently to provide homes suitable for older people.

2.64 New residents on the Site would bring an additional benefit in terms of increased spend in the local area, helping to maintain the vitality and viability of Rochford town centre and support the proposed Vision Statement for the town centre as set out in the RLPSO.

2.65 It should be recognised that the development of the Site for specialist housing for older people would have a very different impact on local infrastructure than a general residential allocation. For example, it does not have any impact on early years, primary or secondary school infrastructure. In addition, it has a very different impact on the highway network, generating very little additional traffic at peak times compared with a general residential development. Not only are there likely to be significantly fewer vehicular movements associated with commuters generated by this development, but there will also be a lack of traffic generated associated with the school run. This is of particular relevance given the significant impact vehicular movements associated with transport to and from schools has – the sustainable transport charity Sustrans estimated in 2014 that school traffic contributed, nationally, to 24% of all traffic at peak times.
2.66 The Site itself is currently constrained by being designated as Green Belt, but has no other constraints as recognised in the SHELAA 2020. This recognised that the Site is deliverable, achievable and potentially suitable (subject to Green Belt review).

2.67 The Stage 2 assessment within the Council’s Green Belt Study 2020 states that the Site’s designation within the Green Belt limits harm to the Green Belt beyond. However, this is not a reason for keeping the land within the Green Belt. If the Council considers the wider land necessary to remain within the Green Belt that is a different consideration to whether the Site itself should be released from the Green Belt, and this should not be a reason for keeping the land as Green Belt.

2.68 In respect of the purposes of the Green Belt, the Site is contained by a Local Wildlife Site to the west and north, Doggetts Chase to the east and Rochford itself to the south. The Site is not located in close proximity to another settlement and its development would not result in actual or perceived coalescence.

2.69 Whilst Rochford does have numerous listed buildings, development of the Site will not adversely impact these and is such would not harm the historic setting of the town.

2.70 Whilst the current boundary to Doggetts Chase itself is relatively open, the hedgerow to the east of the track does provide a defensible boundary and there is an opportunity to provide significant new landscaping and a new boundary to the open countryside beyond.

2.71 A Green Belt Report in respect of the Site has previously been prepared and submitted to the Council, and is re-provided again here for completeness as Appendix B.

2.72 Overall the Site is in a sustainable location and well-placed to provide much-needed specialist homes for older people. Its removal from the Green Belt will enable this unconstrained Site to start delivering homes in the early part of the Plan period to meet the needs of the ageing population, with other resultant benefits for the District.

2.73 As set out above, the allocation of the Site can form part of strategy Options 2, 3 or 4. It could be an urban extension under Option 2, form part of larger scale development under Option 3, or either Option under 4. Whilst we consider that Option 4 is the most appropriate, the allocation of the Site to meet a specific need should be part of any option taken forward, as any sound strategy will need to include sites that can sustainably deliver in the short-term, and sites that can meet the needs of older people – allocation of CFS217 does both. 

3.0 Response to Integrated Impact Assessment

Assessment Framework

3.1 We welcome the recognition within the Integrated Impact Assessment (IIA) (at A.3) that “delivery of suitable homes for an ageing population…is a particular issue for the district”.

3.2 Furthermore, we agree with the findings of the IIA at A3 that medium and higher growth options provide greater opportunity for a wide range of different types of homes to be delivered, including specialist housing for older people.

3.3 However, we are concerned that, despite the recognition of this as being a particular issue for Rochford District, there is otherwise very little within the IIA regarding the need to ensure appropriate accommodation for older people is delivered.

3.4 Table 1.1 of the Integrated Impact Assessment (IIA) sets out the assessment framework for the IIA. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identify. We support these objectives.

3.5 The IIA then sets out assessment questions intended to be used to assess whether options will meet these objectives. This includes:

Will the option / proposal promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?

And

Will the option / proposal meet the identified objectively assessed housing needs, including affordable, for the plan area?

3.6 We suggest that, given the requirements of the NPPF and PPG to address the diverse range of accommodation needs for older person, together with the acknowledgement that delivery of suitable homes for ageing population is a particular issue for the District, the IIA should include an assessment question which specifically asks whether options / proposals would help meet the accommodation needs of older people.
 
4.0 Conclusion

4.1 These representations have been submitted in relation to Land North of Doggetts Close, Rochford, to promote the allocation of the Site to provide much needed specialist accommodation.

4.2 The Site has previously been submitted into the Call for Sites, reference CFS217, with representations submitted to the Issues and Options consultation in 2017.

4.3 As set out, we consider that Strategy Option 4 will be the most appropriate to utilise a range of different options across the District and seek to provide housing across the Plan period. Option 4 should include some smaller sites in already sustainable locations which can start delivering earlier in the Plan period, being highly important given the high housing needs.

4.4 Being located adjacent to the existing developed area of Rochford, Scott Properties’ Site at Land North of Doggetts Close is one such site that is in a sustainable location and capable of delivering homes quickly.

4.5 The only significant constraint to the Site is the current Green Belt designation. As detailed above, the Site does not make any meaningful contribution towards the five purposes of including land within the Green Belt, with this designation preventing a sustainable site from delivering much needed homes for older people. The Local Plan provides an opportunity to rectify this and remove the Site from the Green Belt.

4.6 As recognised within the RLPSO, the District has an ageing population and, as set out in national policy and guidance, it is important for the Local Plan to seek to meet the needs of this age group. Whilst some older people will unfortunately require a care home or sheltered housing, many people simply wish to ‘rightsize’ whilst maintaining their independence. The Local Plan must reflect this and allocate specific sites to meet this need, as otherwise it risks failing to meet an identified need contrary to national policy.

4.7 Scott Properties’ Site at Land North of Doggetts Close is well located to provide bungalows for older people to help meet this need, providing residents with a choice of housing whilst enabling them to live independently in their local community. The accompanying Summary Vision Document provides further information about the Site and the proposals but we are also keen to discuss further with the Council to support its allocation.

Rochford District Council – Land to the north of Sutton Road, Rochford
Representations to the Spatial Options Consultation
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.

Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
1.2. Claremont Planning on behalf of Southern and Regional Development’s Ltd are generally supportive of the settlement hierarchy proposed. Rochford is identified as a ‘Tier 2’ settlement within the hierarchy recognising the settlement’s sizeable population and comprehensive local service base. Whilst it is acknowledged that Rochford has a considerably smaller population than
that of Rayleigh, meriting its location below Rayleigh within the settlement hierarchy; the placement of Hockley and Rochford within the same ‘Tier’ in the hierarchy is disputed. Although the populations are of a similar size, the proposed settlement hierarchy fails to account for the
strategic location of Rochford adjacent to London Southend Airport. The close proximity of Rochford to the airport provides the settlement with key transport infrastructure which connects Rochford to the wider South Essex region and rest of the country. As such, it is considered that Rochford should be distinguished from Hockley within the proposed settlement hierarchy by
virtue of its local and nationally strategic location.
1.3. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy 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 larger quantum of growth apportioned to those settlements which are identified by the hierarchy as being most sustainable. The proposed settlement hierarchy acknowledges the sustainability of Rochford for development, whilst these representations have also sought to illustrate the strategic location of
the settlement due to the presence of the London Southend Airport and its planned continued expansion to provide additional employment floorspace and associated employment opportunities.

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

Strategy Option 1: Urban Intensification
1.4. It is advised that Strategy Option 1: Urban Intensification is not advanced. The current standard
method identifies a housing requirement of 7,200 dwellings in the district across the next 20 years however the consultation document establishes that approximately 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
1.5. It is recognised that Strategy Option 2, which seeks to spread development across a number of 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 therefore see the largest quantum of growth apportioned to the most sustainable settlement settlements within the District as established by the proposed settlement hierarchy and it is therefore recommended that growth at sustainable settlements such as Rayleigh and Rochford should be prioritised if this option is taken forward.
1.6. Moreover, the land north of Sutton Road at Rochford as promoted by Southern and Regional Developments, has been identified within the initial appraisal undertaken by the Council as making a potential contribution to Strategy Option 2. It is agreed that the promoted land off Sutton Road could make an effective contribution to the delivery of this Strategy Option where the land abuts established areas of residential development at the settlement and is located in close proximity to employment opportunities at the Purdeys Industrial Estate. As such, the land at Sutton Road is considered to represent a logical location for the further expansion of Rochford should Option 2 be advanced by the Authority.
Strategy Option 3: Concentrated Growth
1.7. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported. 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 allocating sites of a variety of sizes which can be builtout relatively quickly and make a more immediate contribution to housing supply.
Strategy Option 4: Balanced Combination
1.8. 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.
1.9. 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. As established, the land at Sutton Road as promoted by Southern and Regional Developments has been assessed by the Council under reference CFS067 within their 2021 Site Appraisal Paper prepared in support the Spatial Options consultation. Within this assessment, the land at Sutton Road is positively considered by the Authority and its availability and deliverability for residential development recognised.
Moreover, Claremont Planning assert that the Council should recognise that the land at Sutton Road performed strongly through this assessment in relation a wide variety of criteria including but not limited to flood risk; landscape harm; site hazards and conditions; and access to facilities and services. As such, the land at Sutton Road should be strongly considered for allocation
through the emerging Local Plan, given both its environmental, and social sustainability.

2. 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?

2.1. 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 influenced by high flood risk that is 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 Rochford and Rayleigh which are the areas within the District
at lower risk of flooding.
2.2. The land at Sutton Road promoted by Southern and Regional Developments represents a suitable location for development if the sequential approach to flood risk is adopted. Although an inappreciable area to the extreme south east of the land is located within Flood Zone 3, the
Environment Agency’s flood map for planning identifies that this area of the site also benefits from flood defences; whilst the rest of the land promotion is located within Flood Zone 1, being at low probability of flooding. 2.3. Within the 2021 Site Appraisal Paper, the Council identified that the promoted land at Sutton Road performs very strongly in relation to flood risk, recognising that this small area of flood risk on site is not detrimental to the land’s deliverability. The pragmatic approach advanced by the Council in relation to flood risk on site is therefore supported. Moreover, any development scheme proposed on the site would be designed such to sensitively respond to the risk of flooding on site, through the promotion of this area as public open space. This would ensure that flood
risk on site can be suitably accommodated whilst also enhancing the quality of any development scheme pursued through the provision of high quality public open space. Given that the vast majority of the promoted land at Sutton Road is sited within Flood Zone 1, alongside 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 recommend sequential approach to flood risk in the Plan.

3. 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?

3.1. Meeting the need for different types, sizes, 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 mid-sized semi-detached and detached dwellings.
Claremont Planning consider that the release of Green Belt land, including the promoted land off Sutton Road 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 the delivery of family sized housing which
is better suited to delivery on greenfield land than constrained urban sites.

4. Future of London Southend Airport
Q28. With reference to the options listed above, or your own opinions, how do you feel we can best manage the Aiport’s adaptations and growth through the planning system?
[please state reasoning].

4.1. Following the adoption of the current Joint Area Action Plan for the London Southend Airport in 2014, the context for the Airport’s future growth has altered substantially. The consultation document establishes that the Airport’s development will need to respond to the emerging Government Aviation Strategy. Moreover, the COVID-19 pandemic has substantially impacted the Airport, with planned growth now envisaged to take place over a much longer time period than initially anticipated. Claremont Planning therefore agree that it is prudent to prepare an updated Joint Area Action Plan which accounts for both the changed policy, and economic
context of the Airport’s growth.
4.2. The regional importance of the airport, alongside its strategic cross-boundary location within Southend but adjacent to Rochford necessitates that a joint approach for the Airport’s growth is advanced in accordance with a coherent vision. Although Option 2 would satisfy the need for a joint, cross boundary approach to the Airport’s growth, national policy is clear that strategic policies should be focussed on setting overall strategies for the pattern scale and design. As such, development at London Southend Airport would more appropriately be considered within a detailed Area Action Plan rather than through Local Planning Policy. As such, Claremont
Planning would support the pursuit of Option 4, where this Option will ensure that any resultant Area Action Plan can be prepared in accordance with policies contained within the new Local Plan.

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 to the wellbeing of Rochford residents, 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 (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.
5.2. 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 established in Chapter 3 of the Framework the role those strategic
policies should play, which is to set out the overall strategies for the pattern, scale and design quality of such places. As such, policies relating to the site specific provision of green and blue infrastructure would be more appropriately dealt with through the preparation of non-strategic level Plans and Policies, such as those in Neighbourhood Plans.
5.3. 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 in 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 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 viability and vitality of town centres. It is considered important however, that the Council recognise the important 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 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 have not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed 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) supporting this consultation contains detailed site assessments of the contribution made by promoted sites to the purposes of the Green Belt, including an assessment of the promoted land north of Sutton Road at Rochford that is within a wider Parcel 63. The assessment of the land presented within the Green Belt study is supported, where the assessment recognises the diminished contribution
made by the site to the purposes of the Green Belt, particularly safeguarding the countryside from encroachment and preventing coalescence, by virtue of the site’s relative enclosure by the established Rochford settlement. When the harm of the Parcel’s release was assessed at Stage 2 of the Study, it was concluded that moderate harm to the Green Belt would result. Claremont
Planning contest this conclusion, and assert that instead the harm resulting from the Parcel’s release is instead low, or low-moderate. The Stage 2 assessment undertaken recognises that this parcel of land is weaker performing Green Belt due to its high level of containment, going on to establish that by virtue of this containment the release of land in this area would be of no harm to adjacent Green Belt parcels. Due to the recognition within this assessment that the release of
this land from the Green Belt would not be detrimental to the wider Green Belt, the subsequent conclusion that moderate harm to the Green Belt would result, is not considered to be robustly justified.
7.3. National planning policy, chiefly paragraph 142 of the NPPF, sets out that where exceptional circumstances are demonstrated, a pragmatic approach to Green Belt release, giving first consideration to land which is previously developed and/or well-served by public transport, should be advanced. Claremont Planning support the assertion made within the Joint Green Belt
Study paper that the environmental and sustainability effects of Green Belt release need to be considered alongside the harm to the Green Belt of release, where the most sustainable locations for development may not be the areas which would result in the least harm to the Green Belt. Where this nuanced approach to Green Belt release is considered, Claremont Planning contend
that the merits of releasing the promoted land off Sutton Road are especially evident where it has been established that the site represents a both a highly sustainable location for development at one of the District’s main settlements, and a location at which harm to the Green Belt arising from the land’s release is limited. In light of both the limited contribution made to the Green Belt by this parcel, alongside the negligible harm arising from the land’s release and highly sustainable location, it is strongly recommended that the Council consider the promoted land at Sutton Road
for Green Belt release.

8. Planning for Complete Communities
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you
feel is missing?
8.1. The proposed vision statement for Rochford and Ashingdon is generally supported by Claremont
Planning, where it proposes the further growth and development of the settlement. In particular, the vision statement’s recognition of the settlement’s strategic location close to key employment sites and London Southend Airport, and intention to bolster its regionally significant role is strongly supported. However, it is considered that the proposed vision statement places too great an emphasis on economic growth at the settlement. Instead, Claremont Planning recommend
that the proposed vision statement be amended to include a more balanced and holistic approach
to growth, where it is considered that the Council should recognise the role that residential development has in supporting both the vitality and viability of town centres, alongside a recognition that economic and jobs growth must be supported by sufficient housing provision to
support the local workforce. Moreover, as a ‘Tier 2’ settlement in the District, Rochford represents a highly sustainable location for residential development and should therefore represent a location for significant growth through the emerging Local Plan to assist in meeting the District’s housing needs. As such, it is advised that the vision statement be revised to recognise the role of residential, alongside economic development in realising the growth ambitions of the district.
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?
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 site CFS067 as identified on Figure 45: Map of Rochford and Ashingdon, should be made available for residential development. Through these representations to the Spatial Options consultation, Claremont Planning have sought to identify that the central location of the promoted land at Sutton Road within the Rochford settlement establishes the land as both a highly sustainable, and logical location for further residential development. This assertion is complemented by the 2021 Complete Communities Topic Paper prepared by the Authority within with the promoted land is located within an area identified as having a high walking completeness score of 11-13, meaning that there are a large number of services and facilities located within walking distance of the site. However, the Complete Communities Topic Paper also identifies that whilst the most complete areas in the settlement are located near the town centre, there are areas of low population density in and around the centre where future growth might optimise proximity to services. As established, the land off Sutton Road is entirely enclosed by the established Rochford settlement, and abuts existing residential development and employment
land at all elevations. Given the high walking completeness score of the land, the development
of the site represents an opportunity to both locate development at the most sustainable locations
within the settlement, whilst increasing the number of residents living in ‘complete’ areas.
8.3. The Complete Communities Topic Paper demonstrates that Rochford has good levels of
completeness in respect of access to education, health, civic, and sport and leisure facilities whilst only 8% of the settlement is located within the walking catchment of green infrastructure. It is considered that the release of the promoted land off Sutton Road for residential development represents an opportunity to address this shortfall. Within the south of the site at Sutton Road is
a small area of Flood Zone 3 which is promoted for use as public open space / access arrangements through any development proposal advanced. Moreover, the north-easternmost corner of the land is located within the Southend Airport Public Safety Zone within which
development potential is restricted. As such, this area is also promoted for and provides an opportunity to deliver public open space and ecological enhancement. Through careful scheme design it is therefore considered that any proposed development on site will deliver a connected series of public open spaces and green infrastructure, supporting both recreational activities and
delivering biodiversity gains. Given the relative enclosure of the site by established development, it is considered that both future occupants and residents of the wider site area will benefit from this enhanced green infrastructure provision.
Enclosed : Site Location Plan

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

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

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

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

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

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

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

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

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

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

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

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

Strategy Options

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Yours faithfully

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

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

RDC/Spatial Consultation 2021 Questions

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

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

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

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

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

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

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

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

're the spatial options consultation we are concerned at the amount of local land being put forward for possible future development.

Whilst we agree affordable housing will be needed for future generations, the blue areas shown are really not reasonable for the following reasons:

Ashingdon is a village, how do you expect the road infrastructure to carry all the extra traffic? Ashingdon Road can't cope now and Rectory Road is not ideal as an alternative 're flooding in bad weather.

One area is situated around Ashingdon primary school, this is not good for the children due to environmental issues and will also take away lovely open spaces that are becoming rarer to find

If the Bloor plan goes ahead this will make the traffic situation bad enough without adding more building shown in blue on the plan. The roads will be gridlocked, especially by the small roundabout at Rochford station.

All those houses in Hall Road and nothing has been planned in for the road infrastructure.

Please do not destroy anymore green space there will be chaos and environmental issues.

The sites we have particular concern over are:
CFS216, 133,019,013,261

On looking at the interactive map the knock-on effect from other areas , Hawkwell, Hockley for example will have further impact on the surrounding area re traffic congestion and pollution.

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

[Please see individual representations to questions]

I object to any of your options until you do something about the infrastructure. I have lived in the same address for 41years and in that time you haven’t done anything to improve the infrastructure other than a few dustbin roundabouts.

The roads cannot take any more traffic than it already does.
The Doctors Surgery cannot cope
The Hospital has an abnormal waiting list and this was even before Covid.
There is no substantial super market for the population, they have to travel by car to the nearest one. This is bad planning from the start.
The list goes on, as you probably and hopefully must realise.
As daft at it seems we desperately need another water reservoir for the area. Had a meeting a few months ago and we will soon be running out of drinking water. Desalination processing units around the country were not an option as the whole pipework network is not capable in its present state. At present we are getting new Building Regulations passed through the Government that would help to, reduce the amount of water wastage at present.

As for filling your form in many people have given up as its to complicated. So how will you state it is a fair Consultation and you have reached every resident any way possible.

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.

Rochford and area are saturated. Any more development is crazy, we cannot cope. Hospitals full. Roads grid locked at certain hours. Doctors 3 weeks for appointments. The council must tell the Government we cannot take 7,500 houses in Rochford area, and 23,500 homes in Southend. They must stop building in this area. It is making life intolerable for us. Our houses are noisy now with constant traffic, covered in exhaust dust and we are breathing in the fumes.

Read the placards in Rochford, no more development.