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

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.

Objections to CFS045, CFS064, CFS160, CFS161, CFS074, CFS194, CFS169, CFS150, CFS020, CFS261
As a fellow civil servant and officer of the Foreign and Commonwealth Office, and having been a local to the area (we currently reside in Hockley, raised in Rayleigh) my entire life, I am concerned to see the amount of local land plans to build large amounts of houses that are both unsupported and unsustainable.

Plots CFS045, CFS064, CFS160, CFS161, CFS074, CFS194, CFS169, CFS150, CFS020 and CFS261 (to only list a few) will decimate the local infrastructure, wildlife and cause environmental hazards such as severe flooding. With report after report being issued by government approved environmental scientists that warn the UK is unprepared for climate changes including extremities in weather conditions, it is more important than ever to plan for the future.

To my understanding, there is no consideration given to:

- The current flood risk, or the new estimated flood risk this development would cause. This will in turn affect existing residents insurance, having massive financial implications and there will be increased risk to life.

- Nor are there clear plans for wildlife displacements, safe passages such as green corridors or general preservation of wildlife habitats.

- Air quality will reduce with increased traffic, and access to emergency care such as hospitals will be affected by this massive increase of residents and therefore traffic. My husband is an NHS radiographer and already sees the damage that pollutants are having on members of the public. Additionally, when on call for cardiac arrests, getting to the hospital is essential for him and his colleagues to save a life. Five minutes matter in that scenario. Heart attacks don't wait for congestion.

- Schools and pre school nurseries are already massively over subscribed will become even more untenable without appropriate funding and a local and general governmental understanding of what an increased population would bring a small town.

Not to mention a general loss of green land for activities, family time, activities to keep your people happy and healthy, something we've all come to cherish and appreciate more fully during lockdown.

As the elected party, I'm sure you're aware your duty remains to us, the voters that put you in positions of responsibility. In the same way I may officially report to the Foreign Secretary, my duty at the FCDO remains to all my fellow British citizens who reside outside our shores who require our assistance.

How we treat our environment and infrastructure now is key to living sustainably in 2, 5, 10, 20 years time. We have a duty to our children to leave more than we took and I don't need to remind anyone we are 9 years away from irreversible damage to our world.

I look forward to responses to these clear oversights and would welcome any further information.

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

I can only say that I am astonished at seeing the plan to build over 6,000 new homes in Hawkwell, Hockley and Ashingdon.

I have lived at various locations in all three areas for over 30 years and the build up of traffic congestion has been obvious during this time, the main pinch points being the Spa Roundabout and the roundabout by the bridge at Rochford station. The huge new development in Rawreth Lane clearly will exacerbate the issue. Most households have at least two cars now so we are likely talking about a minimum of 12,000 additional vehicles squeezing onto already much-too-busy roads. It makes no sense at all to compound the situation and is completely unacceptable.

These plans must be cancelled for the sake of quality of life for the existing residents.

MY objections for the Local Plan
CFS045 - 152 Houses
CFS064 - 214 Houses
CFS160 & CFS161 - 124 Houses
CFS074 - 498 Houses
CFS194, CFS169, CFS150 & CRS020 - 801 Houses
CFS261 - 4,447 Houses

My objections are: NO INFRASTRUCTURE. Do you know how hard it is for the Residence to get in to see a DOCTOR etc?

LOCATION. Proximity to existing centres. Road Congestion. Inadequate Bus Service.



HIGHWAY ISSUES. Road congestion on B1013 & Ashington Road. Do you know how hard it is to use these Roads in peak times?

FLOODING. For example CS194 Hawkwell Brook is designated a tidal river by DEFRA. The Council’s report omits the floods of 1968 and 2013 from this river.

I wish to object to the following site proposals:
CFS160,161,194,169,150,020,261.
ALL elements of local infrastructure are under tremendous pressure and an increase in the local population will dramatically worsen the environment from all aspects. Health services, traffic and air pollution, education, green areas and wildlife, will all be affected.
Please!! no more residential development in the areas under your jurisdiction.

Plans for the proposed new housing in the Hullbridge Rayleigh and Rochford areas.
We are horrified to hear of all the new housing designated for this area. As receivers of in excess of 500 new houses currently being built in Hullbridge and having to suffer the consequences of this building scheme we are horrified to hear of the further number being designated not only for us but also the outrageous quantity for our neighbouring towns.

Our infrastructure cannot take this!

Roads ,which are under stress at the normal time but in the frequent event of road works ,any repair works and improvements? The area comes to a standstill.

Hospital and health care which is under pressure and Covid has added to is going to take at least 5 years plus to get under control.

Our green spaces are disappearing fast farms and spaces for our horses to be stabled going.

Leisure facilities for our children and older residents and families are going fast.

The environment and habitats for wildlife is under serious threat. It seems our priorities are for ourselves only and we do not know how the disappearance of species will affect lives in the future

This is the turning point for our planet do not pay lip service to our problems we are the ones who will be judged in the future. You are supposed to be OUR representatives and OUR VOICES

To try and halt the destruction of our planet.

It seems we are trying to make things better with the pollution on things we have. or things we do but you are not considering the impact that all these house s which are

Adding at least 2 new cars and at least doubling the number of people to all of the above . It fills me with dread for mine and other families as to how their lives will be in years to come.

Education in this are is stretched and I wonder how it will cope with the extra children joining the system. New schools will have to be built with the extra cars as the parents take them to school.

| AM SURE I COULD LIST MANY MORE THOUGHTS AND OBJECTIONS BUT AT THE MOMENT IAM TOO UPSET AT THE THOUGHT OF SUCH FEW VOICES ARE SPEAKING FOR SO MANY OF US .(AS WINSTON CHURCHILL WOULD HAVE SAID)

I strongly object to any more building in this area (Hockley, Hawkwell, Ashingdon, Rochford, Hullbridge, Rayleigh).
In the UK there are over 600,000 (six hundred thousand) empty unused buildings. Why do councils not concentrate on bringing some of these buildings back into use.
My objections are probably the same as everyone else. Schools, doctors, hospital, wildlife, open spaces (small areas of green don’t count), large supermarket, roads, infrastructure, congestion etc.
Over 99% of meadows have been lost since the end of WW2. How can the council even consider building on land off of Greensward Lane (and other sites) some of the last remaining meadows around. A breathing space for people and animals.
Rochford mustn’t become like Westcliff, Leigh etc where there is no countryside.

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

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

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

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

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

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

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

Our Green Belt areas should NOT be built on.

We strongly object to the following :-
CFS 160 & 161, CFS 194,169,150 & 020. Also CFS261 These developments are outrageous as there is no infrastructure to support them. They will be feeding onto minor B roads already crippled with cars at peak times.
There are not enough school places, doctors or dentists plus a local hospital most of the time at capacity or overflowing.
The new houses are never affordable just look at the two developments in Hall Road where affordable housing is the smallest proportion and these already cripple the infrastructure.

Objection To Housing Development On Site CFS111
(Land north of Coombes Grove, Rochford)
According to the SITE ASSESSMENT PROFORMA: CFS111 this site has an area of 3.99 hectares and a potential Capacity of 104 houses. This gives a housing density of 26 houses per hectare. 104 four-bedroomed houses would accomodate at 520 peope assuming families of five
per household.
The Council's Document "Authority Monitoring Report 2016-18: Housing Statistics" states:-
The document also states that 35% of dwellings were completed at densities of between 30 and 50 dwellings per hectare. With a higher density a figure nearer 1000 residents might be possible on Site 111 .
Site CFS111 is immediately to the north of the Little Stambridge residential area which is bounded by the houses in Little Stambridge Hall Lane, Coombes Grove and the lower part of Stambridge Road.
This residential area has become part of the approach and departure zone for London Southend Airport. Instead of continuing in a straight line north-eastwards over open countryside after taking off, some aircraft turn left and fly right over the houses in Stambridge Road. They then continue over the gardens and houses in Little Stambridge. Some aircraft fly right along the line of the roofs of the houses in Little Stambridge Hall Lane before heading north-westwards.
In the case of some of these aircraft it is doubtful if they are much above 100 feet when they pass over the houses and gardens. Their engines are at full thrust – with the ensuing deafening, resonating noise. All conversation of those who are in their gardens is drowned out.
Larger aircraft which are landing at the north east end of the runway line up a long way out and follow a glide path. This used to be the case with virtually all aircraft. However, some pilots who are landing smaller aircraft now take a short-cut by flying over the houses in order to get to the runway threshold. On occasions some of these aircraft are very low.
Some aircraft appear to be making repeated circuits. The question arises as to whether they are being flown over the houses in Little Stambridge by trainee pilots.
If a pilot were to lose control or the aircraft suffer a mechanical failure while approaching the houses in Little Stambridge a crash could ensue with great loss of life.
There appears to be no control over the route which lighter, piston engined aircraft and helicopters have to take as they depart from or approach the north east runway threshold.
Aircraft under 5700kg are not subject to the Noise Preferential Route and may turn immediately after take off.
If the Little Stambridge residential area continues to be an arrival and departure zone for aircraft and helicopters then the number of houses over which these aircraft fly needs to be kept to a minimum. In the interests of public safety no further housing development should be
considered.
No housing development should be allowed where there is even the slightest danger of an aircraft crashing as it departs from or approaches the airport runway.

Objection To Housing Development on Site CFS12 4
(Land east of Little Stambridge Hall Lane, Rochford)
Implicit in the function of local authorities is a responsibility to safeguard the quality of life, physical health, mental health and safety of all residents. Rochford District Council is no exception to this.
If the Council were to allow any houses to be built, to the North-East of the airport runway threshold it would, in my opinion, affect this responsibility.
If the Council were to allow any houses to be built this would also materially change the basis of the Section 106 agreement which it reached with Southend Council and London Southend Airport. Part of this agreement depends upon the existence of fewer residents to
the North East of the runway.
Site CFS124 is about 1 mile from the threshold of the main runway of London Southend Airport.
All heavy jet-engined aircraft pass over the site when they take off or land. Executive jets, medium-sized turbo prop planes, small piston-engined planes and helicopters frequently pass over.
As they pass over the site after taking off, jet passenger and cargo aircraft are still climbing after take-off at very high thrust levels in order to gain height as rapidly as
possible. They create a very high volume of noise. Anyone who is walking along Little Stambridge Hall Lane by the side of this site has their voice drowned out and their ears bombarded with noise.
Engines are at high thrust and project sound downwards and to either side. Heavier aircraft have not yet reached the 1500 feet which they are required to attain before they can reduce power and change course.
The heavy jets which are coming in over the site are on their very final approach to the airport. They are at about 400 feet as they pass over. Their engines generate a high volume of noise. The sound builds up from quite a distance before they pass over the site.
If permission were to be granted for housing development all those who lived in the new residential area would be subjected to engine noise from heavy jets, executive jets, piston engined small aircraft, turbo-prop aircraft and helicopters flying right overhead or almost
right overhead. Piston engined smaller aircraft have a particularly loud, harsh, resonating and unpleasant impact on the ears.
The initial appraisal of this site on the Council website states that the area of land is 2.30 hectares. The assessment also states that the site is available for housing with a potential capacity of 63 houses. This gives a figure of 27.4 dwellings per hectare. Each housing site would therefore have an area of about 365 square metres.
A site around 365 square metres would be enough for a 4-bedroom house with a fairly large garden. Such a house would be suitable for a family of two adults and three children.
If 63 houses were to be built and each contained five people then the total number of adults and their children would be 315.
However the document "planningAppendixCSiteAssessmentForms” states an area of 3.14 hectares for the site. This would mean that about 86 houses could be built and about 430 adults and children would then be affected by aircraft both during the day and in the middle of the night.
If a higher housing density were to be allowed then a much higher number of residents would be affected by the adverse effect of planes flying over.
If permission was granted for the construction of houses then hundreds of people would live under or very close to the flight path of jet aircraft which are climbing at maximum thrust with all the high volume of noise which is entailed. As residents relaxed in their gardens all conversation would have to cease as planes passed over. This noise would reverberate and echo off the walls and roofs of nearby properties thus further increasing
the impact. Even with sound insulation the noise inside the houses would be noticeable.
Any open windows would let a considerable volume of noise in.
Aircraft engines emit nitrogen oxides, oxides of sulphur, carbon monoxide, partially combusted and unburned hydrocarbons, particulate matter and other trace compounds.
What is likely to happen to these chemicals when aircraft fly over the houses? What is the possibility that they will be breathed in by the residents? How much will be washed down on to the houses, gardens and vegetable patches when it is raining?
Is the Council really prepared to risk the long-term health of the children who live in these houses and play in their gardens as jet aircraft blast out exhaust fumes above?
Is the Council really prepared to risk the mental health and educational progress of children if they are woken up in the middle of the night by cargo planes?
Complaints about night flights have come from the residents of Leigh because of lack of sleep.
As part of the Section 106 agreement between Southend Airport and local councils a preferred runway scheme was introduced. This states:-
“Preferred Runway Scheme During the night period – when weather and safety conditions allow – London Southend Airport is committed to operate all aircraft movements from and to the north east (over Rochford) as this is a much less densely populated area than that to the south west of the airport.
During the daytime – when weather and safety conditions allow and movement volumes allow the runway direction to be changed – London Southend Airport agreed to ensure that more than 50% of aircraft operations occur to and from the north east of the airfield over Rochford.”
This agreement can only operate meaningfully if there is open land at the north-east end of the runway. If the population size and density to the north east is increased, then the basis of the agreement is affected and the residents of Leigh might no longer be protected.
One only has to read items from “Essex Live” and “Southend Echo” about the experiences of those who live in the Leigh Area to gain an indication of the possible situation if houses were built on Site CF124.
Is the Council really prepared to allow others to be subjected to similar experiences and stresses?
Section 10 of the government document “CONTROL OF DEVELOPMENT IN AIRPORT PUBLIC SAFETY ZONES” document states:-
“10. There should be a general presumption against new or replacement development, or changes of use of existing buildings, within Public Safety Zones. In particular, no new or replacement dwellinghouses, mobile homes, caravan sites or other residential buildings should be permitted. Nor should new or replacement non-residential development be permitted. Exceptions to this general presumption are set out in paragraphs 11 and 12.”.
The map of the Southend Airport Public Safety Zone shows that the zone extends into Site CFS124. The Civil Aviation Authority document “Proposal to Revise the Public Safety Zones at Southend Airport” contains relevant Annexes.
Aircraft which are taking off sometimes veer off the direct line from the runway and fly closer to the houses in Little Stambridge Hall Lane and Coombes Grove. On rare
occasions jet aircraft have actually flown over the houses in Little Stambridge.
In every airport zone there is the ever present danger of an aircraft crash soon after takeoff or just before landing. Site CFS124 is only a few minutes from the runway threshold.
Is the Council really prepared to allow housing development on a plot of land which contains part of a Public Safety Zone and is the main departure and final approach zone to an airport?
In my opinion no housing development should be allowed where there is even the slightest danger of an aircraft crashing as it departs from or approaches the airport runway.

I refer to all options listed but more specifically to those listed below.

The Rochford district is a unique geography, occupying an isthmus that is surrounded by water on three sides. It has suffered from over development without, the accompanying infrastructure considerations. Rochford district council has presided over the the poor previous development, and has ignored all previous concerns of residents. There exists a complete lack of trust in the motivations of RDC in this process. How can you suggest further development when the impact of current proposals are not yet understood pr deliberately ignored.

CFS045
CFS064
CFS160
CFS161
CFS074
CFS194
CFS169
CFS150
CFS020
CFS261

I object to all of the above for the following reasons.

Location
Most of these are Green Belt, and will impact the immediate area due to lack of road infrastructure.

Highway issues. Congestion a complete lack of road development. Currently the roads are not maintained to cope with the current increasing volumes of traffic. Additionally the main arteries out of Essex are already close to maximum capacity.

Infrastructure: The council has not invested in travel alternatives like cycle ways or buses, additional development will cause further congestion and pollution.

Green Belt this is continually eroded, changing the very nature of the area, with no serious attempts at conserving nature.

Impact from other districts. These developments should not be considered in isolation of development in other districts, Southend and Castle point will also impact the Rochford district. this is a disingenuous way of consulting the residents.

I refer to all options listed but more specifically to those listed below.

The Rochford district is a unique geography, occupying an isthmus that is surrounded by water on three sides. It has suffered from over development without, the accompanying infrastructure considerations. Rochford district council has presided over the the poor previous development, and has ignored all previous concerns of residents. There exists a complete lack of trust in the motivations of RDC in this process. How can you suggest further development when the impact of current proposals are not yet understood or deliberately ignored.

CFS045
CFS064
CFS160
CFS161
CFS074
CFS194
CFS169
CFS150
CFS020
CFS261

I object to all of the above for the following reasons.

Location
Most of these are Green Belt, and will impact the immediate area due to lack of road infrastructure.

Highway issues. Congestion a complete lack of road development. Currently the roads are not maintained to cope with the current increasing volumes of traffic. Additionally the main arteries out of Essex are already close to maximum capacity.

Infrastructure: The council has not invested in travel alternatives like cycle ways or buses, additional development will cause further congestion and pollution.

Green Belt this is continually eroded, changing the very nature of the area, with no serious attempts at conserving nature.

Impact from other districts. These developments should not be considered in isolation of development in other districts, Southend and Castle point will also impact the Rochford district. this is a disingenuous way of consulting the residents.

Spatial options consultation- Rochford
The current infrastructure of the town is already somewhat at its capacity. Ashingdon Road during term time is an absolute nightmare for traffic (due to the proximity of three schools in a small area) and traffic is often at a standstill in both directions.

Rectory Road is also not a viable alternative route for these additional homes - as this road often suffers the same gridlock first thing in the morning.

This is before an additional 2,000 homes are added to that. Pollution is already increasing and it is simply not viable to add this many homes, people and vehicles to the area.

As a dormitory town, Rochford does everything we hope it could. Sadly, however - no matter how much money is spent, the A127 won't cope with the additional traffic and the station and rail network doesn't seem as if it would be able to cope sufficiently once rail passenger numbers return to normal. The lull in rail passenger numbers during the covid pandemic will create a false sense that the transport network can cope. The numbers over the past two years are neither realistic, nor sustainable and further investigation clearly will be required.

I also have concerns on the way that education provisions will be made. Where are these additional numbers to be educated?! Undoubtedly this will mean expanding class sizes and this can only have a negative impact on the way our children will learn.

The town has a wonderful and rich history - which was one of the things that attracted us. I fear that such a development will erode this hugely and will cause that identity to be lost - Rochford will become just another housing development.

Furthermore, I have concerns about the impact caused to our wildlife. Rochford has such a diverse range of wildlife for us to enjoy. The noise, pollution and disruption could have a real negative impact. As a former resident of a new-build estate, I saw just how badly the local wildlife was affected. There was widespread displacement and it took a number of years for just a fraction of wildlife to return.

I also think it is important to mention our plans for flood defences. Excess rainwater needs somewhere to travel and to go. Our weather is becoming more and more unpredictable and the sewage system around the Holt Farm Estate looks as though it is currently coping. However, during the summer deluges we experienced, the drainage did seem to struggle, even though it held up.

New build developments are largely paved and concreted spaces with small drainage bowls designed to prevent the estate from flooding. But where else is the excess water supposed to go?

We cannot expect that the areas around Wallasea Island and Paglesham can consistently be a site for drainage and should the River Roach burst it's banks, the whole entire area is in serious trouble.

The cynic in me suggests that the housing developers are putting through such a large application in order to sneak a smaller one in. It is often a ruse by developers to offer to pay for an install new roundabouts as part of the deal. This simply won't be enough and the cost of the infrastructure that would be required would immediately be enough to make any suggestions an untenable position.

Please reject the application to build any homes on the Brays Lane/rear of King Edmund site. Whilst I acknowledge the need for additional housing, these developments should be far smaller - a maximum of 5-10 homes per development and to allow the area to grow organically, as opposed to dumping a widescale development and changing the entire footprint and landscape of one of the most important towns in British history.

Please accept this email as objection to the following:

CFS045, CFS064, CFS160, CFS161, CFS074, CFS194, CFS169, CFS150, CFS020, CFS261, CFS023 and COL38

The local area does not have the facilities, capacity or environmentally to allow such big builds. Everything is overstretched already.

This can not happen.

I have become aware, through a residents’ newsletter, of some sites earmarked for building.

I should like to say that I vigorously oppose these proposals.

CFS045 Hawkwell. Belchamps. 152 houses.
CFS064 Folly Chase-Community centre. 214 houses.
CFS160 AND CFS161. Hockley water tower. 124 houses.
CFS074. Hawkwell opposite Rawalpindi Nursery. 498 houses.
CFS 194 CFS 169 CFS 150 CFS 020. From Clements Hall to Victor Gardens, Rectory Road etc. 801 houses.
CFS 261 Off Brays Lane. 4447 houses.

Firstly, is it green belt or woodland?
Secondly, the infrastructure. The B1013 is already one of the busiest roads in Essex.
Thirdly, increased traffic.
Fourthly, wildlife. Since the Christmas Tree farm development we no longer see jays or woodpeckers. Where do they go? Conversely we have seen more rats and foxes (displaced from their habitat).
Fifthly, many of these places are used by walkers and dog walkers and horse riders. Will their paths be protected?
Sixthly, CS194 Hawkwell Brook is designated a tidal river by DEFRA. Is there a flood risk? The brook flooded in 1968 and 2013.
Seventhly, we are emerging from a pandemic, slowly, and Hawkwell and Hockley have a large proportion of elderly residents. They will be more at risk (and of COPD generally) with the inevitable reduction in air quality.
Eighthly, can the local schools and surgeries cope with this influx? How far are some of these houses from services?
Ninethly, why are these areas earmarked? We have building in Hullbridge and Rayleigh (London Road and Rawreth Lane). About 600 houses were built in Hall Road and Hawkwell had the Christmas Tree farm development. There has already been building in Folly Lane and Brays Lane, Cherry Orchard Lane is undergoing substantial development and there is a housing development near Fitzwimarc school. People moved/retired to Hawkwell because of its exclusivity and rural feel, but it’s becoming harder to see the borders between Rochford, Hawkwell/Hockley and Rayleigh.

So much building in one area is preposterous. Is the council trying to build another Basildon?

Objections to New Local Plan Rochford/Hawkwell
Living behind Rectory Road and Ashingdon Road I do not believe the road system can deal with anymore cars. We have many dips and holes in the roads and when we have roadworks there are even more traffic jams and delays than normal. Thursdays are a nightmare when we have dustbin day. Any deliveries, removals, broken down cars, I can go on, make for long queues, tailbacks, as the roads are not wide enough for others to pass. How are more cars going to get through the traffic lights under the railway bridge at Rectory Road? With so many houses being considered and being fed into B1013 which already has congestion this should not even be considered.
The land at the back of King Edmund School for a potential 4,447 houses all with at least 2 cars directed onto Ashingdon Rd is ludicrous.
Air quality will be decreased making it not ideal for walking or cycling. It is dangerous now to cycle anywhere but cycle paths which there are not enough of with people riding on the pavements where others are trying to walk.
Infrastructure is not sufficient for people already living here. Try getting an appointment into a doctors surgery! Schools are packed, people get essentials from the small grocery
shops which are not cheap, we need a larger supermarket within walking distance, not one to drive too. Rayleigh is the nearest shopping centre, Rochford has too many charity shop shops and cafes. Where will all the wildlife go? We already have foxes and badgers in our gardens leaving holes and faeces. This part of Essex is already a bottleneck to come in and get out off. Unless we have a better way of getting here things can only go down hill!!

I am extremely concerned about the proposed developments in Hockley, Hawkwell, Ashingdon and Rochford. There does not seem to be any regard for sufficient infrastructure planning.
All these areas have traffic congestion already, the B 1013 is frequently plagued by traffic jams. It serves all the above villages, not to mention non-local traffic. Although the road is narrow in many places, HGV's are very common. The Ashingdon Road in particular, is narrow, often congested and dangerous. Several schools are alongside this road, drop off and pick up times are horrendously dangerous. The many pedestrian crossings cause frustration and irresponsible driving. When a traffic survey was done on this road, it was conducted during school holidays. What a cynical idea,it could not possibly reflect the true usage.
The newly built estate of houses in the Hall Road area was supposed to include Doctor and Dental practices, schools, shops, etc. These never materialised as, apparently, a change of Building contractor meant that the conditions were no longer enforceable. The proposed new builds will put incredible strain on all services. How on earth can the area of CFS261, at the rear of King Edmund School, amounting to 4,447 families,be accommodated by the existing infrastructure?
This extra traffic will affect Air Quality and impact the health of residents.
CS194, Hawkwell Brook is designated a tidal river by DEFRA. The Council's report seems to omit the floods of 1968 and 2013.
Lastly, but by no means least, wildlife has not been properly considered. An "expert" declared the fields close to Rochford Garden Way, had no particular wildlife. In fact, they are home and/or feeding sites for many birds,mammals,reptiles, amphibians and insects. My daughter, who lives nearby, has frequently seen raptors hunting over the fields, which means there must be prey. I have only heard a Skylark in recent years, singing over that field. Lapwings,gulls and smaller birds feed there and sometimes Herons are spotted. Foxes, Badgers, mice, frogs andd toads hunt there.So many butterflies, moths, ladybirds, beetles, bees and other pollinators live there.The trees and hedgerows are nesting sites to countless birds. I won't carry on the list any further, but it is clear that they were all "not at home" when the expert visited.
I am also curious as to why the Cul-de-Sac at the end of Rochford Garden Way is considered a good road to provide entry and exit to the new estate. It is very narrow, unlike the road further along, "The Drive", which is wider.
I would appreciate your consideration of the points I have raised in this email. It is not the fact of new homes being built that I object to, it is the lack of firm plans for infrastructure and services.

Objections to planning policy
I would like to raise our objections to Rochford council plan for house building in Rochford district. The land stretching from Clements Hall to the railway line(CFS194) (CFS169) (CFS150) (CFS020) is a great area for wildlife with lots of old hedgerows and mature trees ,it would be criminal to knock all this down. The land around the old Clements hall at the bottom of Victor Gardens and around the old Green Acres site has been left for many years and has naturally developed int a fantastic wildlife site with plenty of Bats ,Badgers ,Muntjac deer, Tawny Owls and many other species of all sorts.
And is also criss crossed with well used footpaths and bridle paths ,there are lots of stables and horses around here where will they go? As for the other sites in and around Hockley and Hawkwell it would be awful to ruin the lovely vista around the St Mary’s Church and the view across the fields at the Mount Bovers site. We should be preserving our farm land for production of food to feed us and not to become reliant on imported food. As for the infrastructure the B 1013 is already overwhelmed at peak times and if there any temporary traffic lights for road repairs it’s totally gridlocked and is in very poor state. It’s very difficult to get a doctors appointment at the best of times and Southend Hospital is at times overwhelmed, if we are going to build all these houses we need massive investment in the local Hospitals , Doctors , Schools , Roads.
As for the proposal for 4000 houses on Brays lane feeding on to Ashingdon road is total madness , the road is overwhelmed now and and if there is any hold up in traffic in Rochford town in Southend road or Sutton road due to road works or someone in Sutton road having a delivery or rubbish collection the traffic comes to a stand still creating more pollution and poor air quality . I know we need more housing but I think the answer is to build new towns with the correct infrastructure to accommodate the population not to keep building in existing areas with exhausted roads , Hospitals, schools etc.

I believe any large site to the east of Ashingdon Road would put an unbearable strain on the surrounding roads. Access to these areas of Rochford are already restricted by poor road infrastructure. Crossing Ashingdon Road to head towards the A127 often requires that in you have to pass via pinch points created by narrow railway bridges in Hall Road & Rectory Road. The Ashingdon Road is already heavily congested with through traffic to and from Southend, at commuter times traffic often tails back from the Anne Boleyn pub to Rectory Road. Any roadworks, accidents or bin collections along the Ashingdon Road, Southend Road or Bradley Way results in Rochford town being grid locked with traffic queuing back to Stambridge Road/ Malting Villas Road junction.

We object to the proposed development of the following sites
CFS261 4447 Homes Land East of Oxford Road
CFS141 231 Homes Stewards Elm Farm Great
Stambridge
CFS116 411 Homes Land South Coombes Farm

CFS111 104 Homes Land North Coombes Grove

CFS124 63 Homes Land East Little Stambridge
Hall

I object to all the above sites as all would increase existing traffic problems on access routes via Ashingdon Road, Bradley Way the Rochford One Way system Stambridge Road and would have a negative impact to those living in these areas due to increase noise pollution and added inconvenience of negotiating more congested roads.

In addition the site CFS116 is not suitable for housing due to close proximity with the Purdeys Industrial estate any homes on Coombes with suffer from the industrial noises and odours of materials that are handled on the site. Should homes be built on Combes site said properties would be under the flight path to Southend Airport and as a result residents would be plagued by aircraft noise too.

I also raise objection to the any further development to areas
COL83 Millview Meadows
CFS050 Land Of Former Adult Community College
These areas are much used safe amenity for the local community and any loss of this green space would have a negative impact to all that enjoy use of this land.

I would support the following developments
CFS084 251 Homes Land South of Hall Road
CFS078 360 Homes Land West of Cherry Orchard

These sites will have little impact on the congested roads of Rochford Town, said sites would also have good access onto the A127 and the train station is easily walkable from these sites.

Of all the sites proposed we believe the sites closest to the A127 would be the best location for development
CFS121 1347 Homes Land North of A127
CFS222 3491 Homes Land Dollymans Farm

I feel these large developments in close proximity of A127 could provide new neighbourhoods built with all essential services like Schools Retail and Healthcare each neighbourhood could have its own unique identity.


I note the report states Rochford has an ageing population, we would hope that due consideration would be given to providing more homes suitable for the retired including bungalows and possibly retirement villages. At present it seems the only retirement properties being built in the area are in the form of blocks of flats, retirees may want a smaller property to suit their changing needs but not all want to give up a garden and be left with just a balcony, building homes suitable for the senior market would give opportunity for those occupying large family homes to move to more suitable accommodation and free up larger homes for young families.

It has been bought to our attention that there are ’New Local Plan/s’ for new homes in the area we live in Hawkwell and the neighbouring areas Hockley, Rochford and Ashingdon, all of which would have a devastating effect on the local area and collapse the already struggling infrastructure and the natural environment and habitat for the wildlife. The B1013 is already struggling to cope with the amount of traffic due to the huge amount of new houses already built over the past years, why build more!!
Whilst we agree that there is a need for new houses we feel there is an in balance on the % for the above areas. If there is that much need for new houses then the Government and Councils should be looking into areas that they can build the necessary roads and infrastructure not piggy backing off existing ones!

We live on Spencers in Hawkwell which is a development of 40 houses, it was built 35 years ago and is accessed off the B1013 main road into Thorpe road into Spencers. This was not too much of a problem until recent years when the Govenment Core Strategy / Councils struck a deal to build the 167 houses on the Christmas tree land. We now have trouble getting out of Thorpe Road onto the B1013 at particular times of the day.

CFS074 in Hawkwell, earmarked for 498 houses, is of great concern for the following main reasons
- The B1013 is not a road that can be made wider and has so many bottle necks along its route especially in the areas that would be affected by the ‘New Local Plans’. The condition of this road is awful and continually breaks up due to the heavy amount of traffic already!
- the impact that it would displace the wildlife let alone the endangered species. We have so much wildlife around this area including badgers, Bats.

- the increase of air pollution. Our clean air is being violated no one is thinking about protecting the environment we live in.

- the flood risks. We back onto Hawkwell Brook which already reaches high levels at points during the year if heavy rain fall, especially near Clements Hall since all those extra house were built.

- Our doctors , Jones Family Practice’ cannot cope with the number of people on their books as it is. When we call last week for an appointment we were number 22 in the queue. We hear other surgery’s are the same.

- not enough school places

- what about the water and sewage ! The drains cannot cope as it is.

Perhaps people should think about spending money on repairing or improving the vital services in place not adding strain to them.


Just combining the known below
CFS074 earmarked for 498 houses
CFS160 & CFS161 earmarked for 124 houses
CFS194, CFS169, CFS150 & CFS020 earmarked for 801 houses
CFS261 earmarked for 4,447 houses

Totals 5,870 houses planned in our immediate area all potentially having at least one car if not two feeding into/onto the B1013 how can anyone say the infrastructure can support or sustain this!

PLEASE PLEASE PLEASE don’t let this happen

I wish to lodge my objections to the New Local Plan concerning the following sites:

CFS045 HAWKWELL
CFS064 HOCKLEY
CFS160 HOCKLEY
CFS161 HOCKLEY
CFS074 HAWKWELL
CFS194, 169,150, 020 ADJACENT SITES
CFS261 LAND AROUND KING EDMUND SCHOOL

Reasons are given as follows:

We have already seen a large growth in housing over recent years with the consequential rise in traffic leading to gridlock type conditions. This has resulted in extremely poor air quality and pollution affecting ours and children's health. The further loss of already diminished green areas and open spaces will have a dreadful impact on wildlife where we already experience a high number of foxes and badgers roaming our streets and gardens plus an increase in vermin as they are driven from their habitats.

The loss of public footpaths and bridleways and green open spaces that is proposed cannot be tolerated.

Immense pressure will be placed on Doctors, Hospitals and Schools where there has been no increase in provision of these services so far especially for recent expansion.

The increased building will mean even more concreting and paving over land that should be left to cope with the increased rainfall that we are experiencing and will also place extreme pressure on water and sewage services.

We are seeing less and less of maintenance of our roads and pavements so how can you expect to address this problem when you contemplate building even more.

To not properly look at the infrastructure and not offer a true solution to the immense problems that will occur and to take away our open spaces is appalling.

I hereby totally and thoroughly object to these proposals.

I wholeheartedly agree that there needs to be an infrastructure assessment first and foremost.

I would have objections to the sites of CFS194, CFS169, CFS150 & CFS020 for the below reasons:

Location – There is already growing road congestion as cars often park in the road and this can cause major delays with an increase of continuous traffic and this would be made worse. Currently there is only 1 bus route (unregular) that goes via Rectory Road so this would not be viable with the proposed increase. Currently it is used as farmland too.

Highway issues - the traffic has been increasing year on year with a vast amount using for access to Ashingdon Road or the B1013. Ashingdon Road needs to be carefully thought about as it cannot sustain more traffic, so this would need to be avoided at all costs. The obvious choice would be sites CFS074, CFS160, CFS161, which can then feed up through Hockley and easier access to the A127 or alternatively CFS261 would be able to feed onto the B1013 via Hockley or alternatively Lower Road for the A130 & A127.

Infrastructure – as the site proposed here does not have easy transport links, the station for Hockley is still over 30 minutes walking and not enough by way of bus links it will increase private car journeys.

Green corridor for wildlife – currently there is a bridleway that runs through these sites and is used all the time. Taking away a regularly used footpath and bridleway would be a terrible shame. To take this away would destroy links out to other very nice routes. It would also have a major impact on the nature reserve owing to the decrease in air quality. Without access to nature spots this would have a major impact on residents wellbeing and mental health.

Flooding – as it is already very widely recognised, these sites are near a Water Course, in particular CS194 and is a designated tidal river by DEFRA. This has seen flooding in the past.

Air Quality – naturally an increase of households will generally bring more pollution to the area and where this is already a very populated area it will effect a vast amount of residents who already live in the area. The obvious choice would be to have proposed site which is more rural and would not effect as many residents.

Accessibility to vital services – as mentioned above, whilst it would run next to the train line it is not quick or easy to gain access to the train station at Hockley which would be closer, otherwise, it would

Education – currently there are not enough schools in the local area to support an increase of 801 houses. And no easy solution as to where these schools would be placed. Given the size of the surrounding area, I would have thought that CFS261 would have the best infrastructure to accommodate new schools and doctors etc.

In conclusion for the above reasons I do not feel that CFS194, CFS169, CFS150 & CFS020 would be suitable.

I am of the view that the most viable options would be CFS261 and although the largest, it would negate the need for building on smaller sites in the future whilst still allowing for a very large area of natural wildlife. Alternatively, CFS160 & CFS161 or CFS074.

I would like to register my objections to the following sites, with reasons stated;

- CFS045 (Belchamps): Local amenity and community activities
- CFS074 (Mount Bovers): Traffic on the B1013
- CFS081, CFS082, CFS083, CFS080, CFS078 (Hall Road/Cherry Orchard): Reason: Urban sprawl/loss of distinct individual communities
- CFS064 (Folly Chase/Betts Farm): Reason: Traffic on B1013 and loss of ancient woodland
- CFS160 (High Road) Reason: Traffic on B1013

I am writing to complain about the proposed building of houses at the back of King Edmund School in the Ashingdon/Rochford area. It is already incredibly built up and their are already far too many vehicles on the road resulting in major traffic every day.

Not only are there not enough doctors, dentists and schools to accommodate the amount of people in the area but there is only one road in and out of Rochford - Ashingdon Road. It already worries me considerably that should my child be ill or have an accident at school it would take me far too long to reach the school (which is a local school just up the road from where I live), we cannot allow more residents and vehicles in the area.

The air pollution will be even worse from all the additional vehicles on the road where children are walking every day to school. The wildlife will suffer as there will be less green spaces.

With regard to the proposals in Hawkwell the traffic will be coming from Rectory Road onto Ashingdon Road this is in my view incredibly irresponsible.

I sincerely hope the planned works do not go ahead.

We would like to preface everything we are about to say with the following. Our district cannot take anymore housing. We do not have the infrastructure. Government targets, or no government targets, what you are allowing to happen to our communities is permanently destroying what has made this area such a beautiful place to live for many, many generations. Council officers and councillors need to have much more integrity when carrying out these consultations and making planning decisions. There needs to be more determination to stop this endless destruction. There are many stories from around the country of councils and councillors that are being creative and taking a few more risks in order to save and preserve their communities and their heritage. We expect to see more of this from Rochford District council in the years ahead - be more tenacious - we are counting on you. The residents in Ashingdon have shown us this can be done with their successful campaign against SER8 - now it's time for the Council to step up to the plate. It's time to start representing your residents and the people that pay your wages!

We strongly object to any development on green belt land. We are in the middle of an environmental crisis - the evidence of which is all around us. The council must immediately cease to approve any further development on green belt sites and only brown belt sites must be considered moving forwards. With this in mind, all proposed green belt sites must be removed from the local plan in order to make green belt development as difficult as possible.

Furthermore, we would add that the local infrastructure simply cannot cope. Medical facilities are all vastly over-subscribed. There is a lack of doctors and NHS dental places, not enough school places and already over-sized classes. The County Council have proved how utterly inept they are at even attending to the most basic repairs on some of our most seriously damaged roads. We simply cannot allow more traffic to go through the district's roads until all outstanding repairs have been addressed and a proper strategy has been drafted, presented and agreed with the residents of our district for how the roads will be managed and maintained proactively going forwards. The county council have clearly demonstrated they cannot be trusted to get on with this and now need to be put under pressure by the district councils and their residents.

Road capacity is another serious issue. This can be evidenced if you try and travel anywhere by car on a Monday to Friday during rush hour or on a Saturday (if, heaven forbid, you try and go anywhere to possibly try and enjoy your spare time away from your home). This view is clearly widespread among many residents and councillors based on the reasoning for the recent rejection of SER8.

Any further development that is approved (for example, on brown belt sites) must have ample infrastructure included within the proposals. This must also factor-in the infrastructure deficit we are already running due to existing developments having been allowed to go ahead without adequate controls and safeguards being in place to ensure that supporting infrastructure is also delivered. Therefore, any new developments must deliver not only their own infrastructure needs but also help 'pay down' some of the deficit that has been built up. The council must (we repeat - MUST) make sure the infrastructure is secured and committed to. Furthermore, the infrastructure must (we repeat - MUST) be delivered before any housing is allowed to be developed. This must be a prerequisite. The council must not allow another Hall Road situation to materialise. It is actually beyond a joke that Hall Road still does not have a school, with no sign of one appearing anytime soon. The word incompetence just doesn't do the situation justice.

In addition to the above, we would like to add the following specific objections to the following sites:

CFS074 - Land south of Mount Bovers Lane, Hockley
This land must be removed from the Local Plan. The house building would ruin the landscape and views that are available from Hawkwell Chase, Hawkwell Common and from Main Road Hawkwell (looking towards Gusted Hall). This land should be kept out of the local plan and (when the opportunity allows) used to extend the natural areas around Cherry Orchard and Gusted Hall.

CFS045 - Belchamps Scout Site, Holyoak Lane, Hawkwell
CFS251 - Land at Peartree Cottage, Holyoak Lane, Hockley
CFS191 - Land at Mount Bovers Lane, Hawkwell
CFS074 - Land south of Mount Bovers Lane, Hockley
CFS160 - Northlands Farm, 65 High Road, Hockley
CFS161 - 57 High Road, Hockley, Essex, SS5 4SZ
CFS083 - Land south of Hall Road and west of Ark Lane, Rochford
CFS078 - Land west of Cherry Orchard Way and south of Cherry Orchard Lane, Rochford
CFS079 - Land west of Cherry Orchard Way and east of Cherry Orchard Lane, Rochford
CFS135 - Land at Flemings Farm Road, Eastwood
CFS059 - Land at Sandhill Road, Eastwood
CFS037 - The Ramblers & Dahlia Lodge, Eastwood Rise, Leigh
CFS134 - Land between Eastwood Rise and Rayleigh Avenue, Eastwood
CFS027 - Land north of Bull Lane, Rayleigh
CFS029 - Land at Turrett Farm, Napier Road, Rayleigh
CFS098 - Land north of Napier Road, Rayleigh
CFS053 - Land south of 38 and 39 Wellington Road, Rayleigh
We would like to request that this land is removed from the Local Plan. The location falls within, or very close to, the Upper Roach Valley Special Landscape Area. This area has been afforded a special status for good reason and therefore these sites must be removed from the Local Plan. We would also request for the Special Landscape Area to be extended to encompass the land in the above sites. Losing any land within, or close to, the Special Landscape Area would result in a permanent loss or deterioration of very special green spaces - these must be protected for environmental and wildlife reasons as well as to be enjoyed by future generations.

CFS064 - Land north and east of Folly Chase, Hockley
This land must be removed from the Local Plan. This field offers a unique home for wildlife and is one of the few remaining rural landscapes and walks for residents living on Betts Farm. Hockley Primary school would also not stand any chance of catering for the number of places a development of this size would require. Even with a possible extension, the school, surrounding roads and facilities were simply not built/designed to cater for the number of additional residents a development would bring. There are also significant issues with road access from Folly Lane which is already an extremely hazardous road.

CFS264 - Land at Greenacres Nursery, Hockley
CFS040 - Eastview House and Haslemere, Church Road, Hockley
These sites must be removed from the local plan due to the damage to wildlife, the environment and the effect on the landscape within the area. There are also already significant road safety issues with Church Road, Folly Lane and Fountain Lane. All these roads are very dangerous to navigate based on current traffic levels and this would be made significantly worse with any/all of these developments taking place. There are also regular flooding issues on Church Road which would only get worse with further building on surrounding land.

CFS082 - Land between Ironwell Lane and Hall Road, Hawkwell
CFS081 - Land at Stroud Green, north of Hall Road, Rochford
CFS002 - Land at Nursery Corner, between Rectory Road and Hall Road, Hawkwell
These sites must be removed from the local plan due to the total number of new dwellings that they could represent (in particular CFS082 and CFS081). The area is already unable to cope with traffic and infrastructure demand. The views from Ironwell Lane out onto these sites have been enjoyed for hundreds of years. They have already been permanently compromised by the Hall Road development and no further destruction of the area can be allowed to take place.

CFS132 - Ivanhoe Nursery, Ironwell Lane, Hawkwell
CFS219 - Ivanhoe, Ironwell Lane, Hockley, Essex, SS5 4JY
CFS240 - Old Parsonage, Ironwell Lane, Hawkwell, Essex, SS5
CFS118 - The Paddock by Clements Hall Way, Rectory Road, Hawkwell
CFS140 - Old Nursery, Ironwell Lane, Hawkwell
CFS018 - Land between The Grange and Red Roof in Ironwell Lane SS5 4JY
CFS036 - Land adjacent to Rectory Terrace off Rectory Road, Hawkwell
These sites must all be removed from the local plan due to the surrounding roads already being significantly oversubscribed thanks to the Clements Gate development. They are nowhere near any schools (resulting in yet more traffic) and will also detract from the otherwise beautiful countryside that can be enjoyed when walking up Ironwell Lane.

CFS194 - Land North of Rectory Road, Hawkwell
CFS169 - Meadowlands, Victor Gardens, Hockley, SS5 4DY
CFS020 - Land rear of St Marys Church, Rectory Road, Hawkwell
These sites must be removed from the local plan due to their proximity to St Mary's church. The surrounding landscape has always been farmers fields and countryside and it must stay this way. The area is already unable to cope with traffic and infrastructure demand. The views from St Mary's and the public footpaths out onto these sites have been enjoyed for hundreds of years. They must continue to be left as green belt countryside.

CFS093 - Greenacres and adjacent land, Victor Gardens, Hawkwell
CFS017 - Greenacres, Victor Gardens, Hawkwell
CFS093 - Greenacres and adjacent land, Victor Gardens, Hawkwell
These sites must be removed from the local plan in order to protect the amount of green space around a densely populated area. The surrounding landscape has always been farmers fields and countryside and it must stay this way. The area is already unable to cope with today's traffic and infrastructure demands. The views from Clements Hall and the public footpaths out onto these sites have been enjoyed for hundreds of years. They must continue to be left as green belt countryside.

CFS216 - Land at Fambridge Road, Ashingdon
This site must be removed from the local plan due to the potential number of houses (which the surrounding roads and local infrastructure cannot support) and the fact the land is within the Coastal Protection Belt Special Landscape Area. The Coastal Protection Belt Special Landscape Area must be protected and enlarged.

CFS121 - Land north of A127, Rayleigh
CFS261 - Land east of Oxford Road, Rochford
CFS222 - Land at Dollymans Farm, Doublegate Lane, Rawreth
CFS163 - Land at Lubards Lodge Farm, Hullbridge Road, Rayleigh, SS6 9QG
CFS164 - Land at Lubards Lodge Farm, Hullbridge Road, Rayleigh, SS6 9QG
CFS148 - Land north of Rawreth Lane, Rawreth
CFS171 - Land to the North of Rawreth Lane, Rawreth
CFS146 - Land at Rawreth Hall Farm, Rawreth Lane, Rawreth
CFS147 - Land north of London Road, Rayleigh
CFS099 - Land to the west of Hullbridge
CFS149 - Lane Field and Hullbridge Hill, Watery Lane, Hullbridge
CFS172 - Land At Cracknells Farm, Hullbridge
CFS265
CFS067 - Three Ashes, land to the south of Tinkers Lane, Rochford
These sites must be removed from the local plan due to the potential number of houses - which the surrounding roads and local infrastructure cannot support.

COL27 - Freight House Car Park, Rochford
COL13 - The Freight House, Bradley Way, Rochford
These sites must be removed from the local plan and retained in their current form. They should continue to be made available to the residents of the district as community facilities.

COL07 - The Mill, Bellingham Lane, Rayleigh
This site must be removed from the local plan and retained in its current form. It should continue to be made available to the residents of the district as a community facility.

CFS063 - Land south of Watts Lane, Rochford
CFS067 - Three Ashes, land to the south of Tinkers Lane, Rochford
Sector D (All references)
These sites must be removed from the local plan due to the inadequate roads in the area. Even with new or enlarged roads the existing roads already struggle with the volumes of traffic that they need to cater for today.

We respectfully ask you to make sure our views and those of our family (including our two sons - Arthur and Henry Watson) are fully and robustly represented in this process and during the subsequent stages of the local plan being written and implemented.

CFS216/CFS133 promoted sites
I’ve found the website/links a bit tricky to navigate so I’m hoping that I can e mail my objections to the above promoted sites?

I thought the first site was on Coastal Protection Belt and shouldn’t be built on? As agricultural land it has been successfully farmed since anyone can remember.
Building on this land would ruin the visual amenity of the area. The school has always been semi-rural and this proposed development site would ruin that.

It would also cause issues with traffic at an already busy and dangerous junction that is subject to discussion already.

The second site is opposite the school (CFS133) has again been successfully farmed for years, and regularly floods at the bottom. This again is an inappropriate location, again ruining the visual amenity of the area, would again compromise the planning framework for urban sprawl.

For both sites, in terms of transport, there is an overloaded Roman Road with a dangerous junction, speeding drivers with a previous serious accident site too. Adding another road junction in there is unsafe. There are no cycle paths or means to incorporate one. The pavements remain to be overgrown and have been for the last 40+ years, narrowing to a ridiculous point which remains dangerous for the children walking to school. Today I witnessed a lady with a pushchair having to cut back over growing brambles etc to be able to walk past safely.

Having looked at the map of Ashingdon and proposed developments, I would like to think that, as the ashingdon road is over capacity NOW, none of these should take place until the infrastructure has been significantly improved.

Something needs to be done about this road anyway.

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