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

Yes all of the above, certainly need a greater healthcare provision and if we build more school spaces too. We have allotments in Great Wakering but maybe plots could be provided in Lt Wakering and Barling?

The reason I moved here is because it is quiet and away from the bulk of people. If you start building more houses, cramming in more people, adding more more more it's just ridiculous. Why can councils not appreciate we do not want more people and ameanities crammed in where we live?

A lot of the promoted sites considered to be made available are on existing green belt land. I think it is imperative that the preservation of green belt land is considered with the utmost importance both in the interests of the area itself, where these areas of open green space help contribute to the overall village feel and heritage of the area, and nationally in the interests of the very real threat of global warming and climate change. A substantial amount of the sites are also agricultural which again are key to preserve in the national interest.

This land is currently a field as it has always been. It is used for sileage and for horses. Presumably, it is green belt and should remain so. We cannot keep using up our fields to make way for development. What will be the impact (if allowedto be development land) on the roads, sewers, surface water drain off, electricity, gas, main water, doctors, police, ambulance service, fire brigade and hospitals. Great Wakering is a small village and should remain so,

CFS004. Ribbon development is well established along the local roads but that has resulted in little to no separation between villages. This is one of the last development opportunities along this section, thus it might be better to
use as a small woodland area. However, without a planning consent there would be no money forthcoming to encourage the land owner to set this land aside for that purpose. Therefor I do think it should a be a single line of dwellings (with flood precautions) along the building line of existing road and not around a culdesac development . I also think

Community infrastructure and local needs only.

Improving what we have that is currently useless or redundant is vital.

It will improve the area, make new homes ,new offices, new jobs and boost moral for not disturbing the environment and local heritage.

Without placing pressure on transport links

The villages should be protected from increasing in size.

As mentioned, there should be no further development as this would be detrimental to the nature of this area in that green belt and agricultural land will be eroded with all the environmental consequences this will lead to. The resources of the medical centre could be improved as it is often difficult to access this service.

No further development should take place on greenbelt land. All green belt sites should be removed from the local plan.

No further development should take place unless the infrastructure is improved in order to cope with the added pressure new homes and businesses will bring.

Promoted Site CFS057 Land east of Star Lane and north of Poynters Lane, Great Wakering
The western section of promoted site CFS057, that lays south of Starlane Pits Wildlife Site should be promoted as a Potential Regional Park, Other Open Space, Wildlife Site or Green Belt. This site should not be a promoted site for housing development, for the following reasons:
1) The Water’s Edge development by Taylor Wimpey that runs adjacent to the north of Starlane Pits Wildlife Site has had a detrimental impact on the Wildlife Site. What reassurances can be given that any further development to the south of the Wildlife Site on promoted site CFS057 will not have similar consequences? This is not a risk worth taking given the high volume of other promoted sites available for development.
2) The western section of promoted site CFS057 that lays south of Starlane Pits Wildlife Site should be promoted as an Open Space or Potential Wildlife Site or Regional Park. This would provide a natural extension to the existing Starlane Pits Wildlife Site, which is already teeming with wildlife and is ongoing works to improve the habitability of wildlife on the site even further. Therefore, by promoting this section of CFS057 that lays adjacent to an existing Starlane Pits Wildlife Site for Open Space / Regional Park / Wildlife site, it can provide a significant net biodiversity benefit as well as protecting and allowing enhancement of the Starlane Pits Wildlife Site.

Wakering has little employment potential,far too many new builds,
Should be left for minimum development,or will be merged into shoebury or Southend

Schools and education
• Limited nurseries in the village with many already unable to accept children without the added pressure of further housing and families.
• Primary education - Great Wakering is already at capacity, Barling Magna is close and currently has a class without a dedicated classroom – this is against the Department for Educations guidelines, we are already failing current pupils without increased pressure.
• Some secondary schools offer dedicated buses, however general connections and access is limited.
Connectivity i.e. public transport
Current public transport options are limited, schedules and availability worse. Consideration must be made into safe access for all residents across the village, road infrastructure and the impact that increased vehicles will have. Rail access is currently not viable on foot or cycling.

Traffic and pinch points/congestion
Already exist areas of concern due to traffic and congestion as well as safety due to blind bends, existing parking, pedestrians, horses, speed etc. There are limited roads in and out of the village, as many of us have experienced when road works are in place, problems very quickly arise. A great example was recent roadworks resulting in gridlock along Little Wakering Road at school pick up time when Barling Road was closed.

Parking
Roadside parking often leaves limited space i.e. single track traffic, often there are reports of access concerns for emergency services and safety risks as a result of limited spaces and increased vehicles within the village. The impact around schools result in tension and concerns for children’s safety. Consideration must also be taken for those with disabilities or wheelchair users who often find footpaths blocked by poor parking and few suitable access points/pathways.

Doctors and medical
The Doctors surgery is often a topic of discussion due to difficulties getting appointments, increased residents will simply impact this further. To my knowledge there is one medical centre for both villages and I would be interested to understand recommended capacity for care under the Department for health.
With regard to other medical services, I believe these are also limited, for example I don’t believe there is a dentist locally.

Wildlife and nature
There is great beauty in the local area, wildlife thrives, and some rare species have been observed. It is vital to protect green areas, to protect wildlife and insects as these all support human existence.

A127/A13 access
Access to the South East is widely limited to the A127 and A13, these roads are already congested and result in delays and pollution levels locally.

Parks and open spaces
Parks and public areas are also limited, living in Barling there isn’t a park in the village for local children. In fact the village only offers a church and a school, there are no shops, few pavements and a limited offering for new developments.

Drainage
Problems are already widely reported to exist in Little Wakering Road and Kimberly Road where recently human waste was washed into residents gardens due to increased rainwater and unsuitable drainage.

Flood risk
I believe the creek originally travelled to Barling pond, should water levels continue to rise as expected, considerations must be taken into future viability.

Complimentary Designs
It is vital that any developments are complimentary in their designs to any existing properties and the village feel. Sadly developments already completed are not in keeping with historic buildings.
The tip road which was argued against and supposedly temporary, remains in place. The mounds as a result are now visible from several areas across the village and pollution caused by large vehicles still travelling back and forth extremely unfortunate.

Perhaps some of these areas could be used to support the infrastructure, for instance, School extension, Medical buildings or more shops. Allotments are also a good idea.

If development is approved in the Wakerings then area CFS057 could be developed with a secondry school on Star lane. Playing fields on NE corner of CS057 adjacent to designated nature areas. and the flood management pool for the new estates, whose construcion has effected signiifcant damage to lakes east of Pointers and south of wakering high street. Mature wildlife including some fish weighing 20kg are dying because of the imapct to the water course in this and adjacent areas. The envitronment agency are now actively involved
Playing fields in this location would preserve the land and water courses.

The sites outlined for housing are not viable in my due to the complete lack of infrastructure. There is also a concern that there are historical areas in the identified sites (CF057 in particular) that have been identified in the document at this link (https://humanities.exeter.ac.uk/media/universityofexeter/collegeofhumanities/archaeology/documents/Stonebridge_Park_report_FINAL.pdf). The risk of losing potentially historically significant sites (the possibility of a roman road and villa in and around CF057, and the regional park outlined to the west of Star Lane) is key here.

No.
Housing has recently been developed twice, any more will spoil the rural village character contrary to vision.
Commercial will take away from rural village character running against the vision.
Community currently meets all the above mentioned infrastructure needs.

Please keep in mind these are rural villages. New home owners to the area such as my self, wife and daughter moved there for a particular type of life style which further development could threaten.

Houses are required in all towns however there are far too many being build in the Rochford district and Wakering will not feel like a village for much longer. There will also not be enough school places around here if this carries on. Village life is not being maintained

i - A small amount, amongst the existing village - find ways for affordable housing to stay that way - people should move on when they can afford too. Bungalows for older people would be a good idea.
ii - Commercial - again a small amount to existing area
iii - Secondary school required
- Better health care - available appointments/ availability of blood test service
- maintain open spaces well, cut the verges so villages don't look such a mess, adopt new roads so the developments are not 'private'
iv - provide sports facilities - Our end of Rochford District is forgotten about.

Having viewed the online Spatial Options Consultation I am writing to make my feelings and opinions known to you.

We are all aware that there is a housing shortage in this country and that there is an urgent need for affordable housing around the entire country. However, seeing the quotas which the Westminster government are insisting be shouldered by this area and the rest of Essex, there is no question we are being expected to shoulder an unfair and unreasonable share of the burden, due to our convenient proximity to London. Since the government have committed to ‘Levelling Up’ the country I consider this most hypocritical. The South East is already far too congested, our infrastructure in terms of roads, schools and hospitals is at bursting point and there is no doubt that expanding infrastructure in the area will not keep pace with the proposed expansion.

Your Vision Statement for Wakering:
In 2050, the Wakerings and Barling should have retained their rural village character and sense of relative tranquillity. More services should have developed locally to reduce its reliance on neighbouring towns, whilst any new services introduced should be located so that those located on the edges of the settlement are able to access them sustainably. The villages should have become more self-sufficient when it comes to homes, jobs and community facilities, including education. Development that takes place should be locally-responsive and aimed at meeting the ongoing housing and employment needs of local residents.

It is obvious that it is impossible to live up to this statement and at the same time press forward with the level of development proposed in the Rochford area.

At the moment Wakering and Barling are beautiful rural villages. However if an area so close to Southend and London has not been developed more in the past, we can assume there are solid reasons and that the land here does not offer a friendly environment for too much housing. We are on the Creek, close to marshland and with rainfall predicted to rise due to climate change it is imperative the water table is maintained to prevent serious flooding. This means leaving open land for adequate drainage not only for proposed developments but for the residents already in situ. The current roads are single lane and many of the residents have to park street side because older houses do not have off road parking. This reduces traffic flow still further for most of the time (Little Wakering Rd is particularly susceptible to this.)

Much of the proposed building would be on currently agricultural land. It may well be that the encumbant farmers are tempted to sell up and retire on the proceeds but whereas this may suit them individually it would be criminally negligent of the authorities to allow this land to switch use because once it has done so, it will never return to the original purpose. We are living in times of global upheaval. Brexit means the UK will have to consider producing far more of our own food if we are to maintain present standards of living at minimal cost. Furthermore, combatting climate change (already officially recognised as affecting Britain) means we need to be sourcing food locally as possible and paying far more attention to ecology and our wildlife. Destroying the agricultural benefits of Wakering would be cutting off our noses to spite our faces.

I will finish by pointing out that one of the main ways to access Wakering is via Shopland, which feeds into Sutton Rd and thus into Ashingdon Rd. It is no secret that the traffic flow in these areas is close to gridlock for a lot of the time and further traffic feeding in from the Wakering area would be unworkable.

I am aware that Basildon and Southend councils are lodging objections and resisting the pressures from government to overdevelop their respective areas. It is obvious if they are successful the onus will simply be slope shouldered and further pressure put on surrounding councils like Rochford. Please, stand up for our area and join them in resisting these directives. The greenbelt was conceived for a reason and I can think of no time when we have needed to commit to this principle more!

Be loyal to Rochford, not to party politics.

ROCHFORD DISTRICT COUNCIL – THE SPATIAL OPTIONS DOCUMENT CONSULTATION
(REGULATION 18)
LAND EAST OF STAR LANE, GREAT WAKERING, ESSEX
PowerHaus Consultancy has been appointed by Citizen Housing (the trading name of Lenrose Housing
Ltd and hereafter referred to as “Citizen”), who represent the landowners, to submit representations on
its behalf to Rochford District Council (RDC), in relation to the Regulation 18 (Reg 18) consultation for
the Spatial Options Document. It concerns land interest to the east of Star Lane, Great Wakering,
Essex.
This representation has been drafted using the information available at the time of writing comprising:
the Spatial Options Document, Site Appraisal Paper, and associated evidence base documents, as
listed on RDC’s website.
Site Description
The site, for the purpose of this representation comprises 21.59 hectares of undeveloped land bounded
by Star Lane to the west and Poynters Lane to the south, situated on the western edge of the settlement
of Great Wakering. Great Wakering is situated in the southernmost part of Rochford, located between
Foulness to the northeast and Shoeburyness to the south. A site location plan showing the site in
context of the surrounding area, incorporating a potential zoning plan is attached at Appendix 1.
Located directly north of the site is the former Star Lane Brick Works, which is now a housing
development. Phase 2 of the development is currently under construction by Taylor Wimpey. Located
to the north east of the site is Star Lane Pits, which is a designated Local Wildlife Site. The wildlife site
is a collection of disused brick pits of Star Lane Brickworks and a mosaic of scrub, rough grassland and
aquatic habitats. The pits are stocked with fish and are a notable site for fishing syndicates.
The site has excellent public transport accessibility; bus routes are readily available on Star Lane and
Southend Road. Thorpe Bay Train Stations is located approximately 2km away providing access to
London Fenchurch Street. The site also benefits from links to the strategic road networks and is located
approximately 1km away from the A13 providing access to the wider hinterland. The site is therefore
highly accessible by public transport with cycle and walking options.
2
The site is located within walking distance of local amenities including Great Wakering Primary
Academy, Great Wakering Post Office, Wakering Medical Centre, Rowlands Pharmacy and the Co-op
Food Convenient Store. The site is located in a highly sustainable location.
Part of the site (3.2ha) is currently allocated under Policy NEL2 of the Allocations Development Plan
Document (adopted February 2014) for employment land to accommodate businesses displaced from
Star Lane Industrial Estate. The types of uses permitted on the site currently include B1 (business), B2
(industrial) and B8 (storage and distribution). The Allocation DPD does not provide an individual target
for each of the sites. Part of the site is located within Green Belt. There are no locally or statutorily listed
buildings near to the site. The site is within the defined Flood Zone 1 (lowest probability of flooding).
Rochford Housing Need
The comments provided in this section are formed from a review of the available evidence base
documents, listed on RDC’s New Local Plan Evidence Base. The following paragraphs assess the level
of housing need in Rochford, before considering this in the context of the site.
The South Essex Strategic Housing Market Assessment (SHMA) (May 2016) and SHMA Addendum
(SHMAA) (May 2017), prepared by Turley, are the most up to date evidence base documents relating
to the assessment of housing needs within South Essex, covering a period between 2014 and 2037.
The May 2017 SHMAA identifies an Objectively Assessed Housing Need (OAN) range of between
3,750 – 4,000 dwellings per annum (dpa) for South Essex. Paragraph 3 of the SHMAA states that the
figure was reached using the 2014-based sub-national housing projections as a ‘starting point’, which
indicated a need for approximately 3,021 dpa for South Essex (paragraph 7). This figure increased to
the range given above when accounting for assumed net migration from London to TGSE locations,
associated job growth, and the issue of affordability. Whilst this was an appropriate means of calculating
the OAN at the time, it does not reflect the standard methodology published in the new National Planning
Policy Framework (NPPF) (July 2021).
Accordingly, Paragraph 61 of the NPPF is applicable for calculating housing need. It requires all local
planning authorities to calculate the minimum number of homes needed using the standard
methodology, as set out in the National Planning Practice Guidance (PPG). The standard methodology
involves a three-step approach; (1) use of the national housing growth projections to calculate the
average annual projected household growth figure (also known as the ‘baseline’ or the ‘starting point’);
(2) adjusting the baseline to take account of affordability by using the most recent median workplacebased affordability ratios; and (3) applying a cap on the level of any increase in the minimum annual
housing need figure an authority can face. The cap is calculated based on the status of relevant strategic
housing policies.
As the relevant housing policies within the adopted RDC Core Strategy (2011) were adopted over 5
years ago, the SHMAA ‘starting point’ figure of 361dpa would need to be adjusted under step 2, and
the increase (step 3) would also need to be capped at 40 per cent above the projected household
growth for the area over the 10-year period since no adopted policy remains which sets an average
annual housing requirement figure.
The Council’s latest Annual Monitoring Report (AMR) for 2019/20 sets out the Council’s position in
terms of the number of new homes completed in the monitoring period, the number of homes under
construction as of April 2020, and the capacity of land within the district to provide homes into the future.
The AMR outlines the historic shortfall of houses with Rochford only delivering 47 per cent of the plan
period target.
3
The SHMAA recognises that there are affordability issues across the sub-region and identifies a need
for 238 affordable dwellings per annum within Rochford. The AMR states that between April 2019 and
March 2020, there were 72 (net) affordable housing unit completions. This is significantly below the
identified need highlighted in the SHMAA.
The Housing Delivery Test measures net dwellings provided in a local authority area against the number
of homes required. Based on the number of homes delivered in Rochford over 3 years, between 2017-
18 and 2019-20, Rochford returned a delivery measure of 95 per cent. However, it must be noted that
this figure was adjusted due to the Coronavirus pandemic, reducing it by a month. In the preceding
year, Rochford achieved 77 per cent of their target, resulting in the authority having a 20 per cent buffer
imposed on their housing land supply requirement.
Page 40 of the New Local Plan Spatial Options Document states that the current housing need has
been largely based on the housing market analysis undertaken for the South Essex SHMAA. Paragraph
61 of the NPPF requires the level of housing need to be calculated using the standard method, as set
out in the Planning Practice Guidance (PPG). To accurately assess the level of need and take into
account the shortfall of delivery, RDC should undertake and fully demonstrate a revised calculation. We
note that the Council intend to commission an update to the SHMA to gain an up-to-date understanding
of the specific housing needs of different groups in the community and urge that this is actioned prior
to the progression of the plan.
Allocation of Star Lane for Residential Use
Chapter 5 of the NPPF relates to the supply of homes, with paragraph 60 identifying that a sufficient
amount and variety of land is required to help support the Government’s objective of significantly
boosting the supply of homes.
Paragraph 62 of the NPPF requires planning policies to reflect the needs of different groups in the
community for housing of different sizes, types and tenure. This is explained in more detail within the
National Planning Practice Guidance (NPPG), which explains that housing needs refer to the scale and
mix of housing and the range of tenure that is likely to be needed in the housing market area over the
plan period.
NPPF paragraph 68 states authorities should have a clear understanding of the land available in their
area through the preparation of a strategic housing land availability assessment. Form this, planning
policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability
and likely economic viability. Planning policies should identify a supply of specific, deliverable sites for
years one to five of the plan period and specific, developable sites or broad locations for growth, for
years 6-10 and where possible, for years 11-15 of the plan.
Based on the above policy context and RDCs housing need evidence, it is apparent that significant
levels of housing will be required within Rochford during the plan period. Accordingly, the paragraphs
below make a case for the inclusion of Land East of Star Lane as an allocated mixed use site containing
housing and employment uses within the new Local Plan. The land has previously been assessed as
being both appropriate for employment and potentially suitable for residential. The site has little to no
constraints to fulfilling its development potential in providing an optimum level of homes on a highly
accessible site.
Part of the site was assessed as part of the Council’s Strategic Housing Employment Land Availability
Assessment (2017). It was noted that the site is sustainably located and could be suitable for residential
development. It should be noted that the surrounding land to the north of the site is already being
developed for residential and part of the site already has an employment allocation to accommodate
businesses displaced by the residential development to the north.
4
In order to create a mixed, inclusive and sustainable community, the site would be brought forward with
a mix of housing types which could include retirement homes and general market housing. An initial
masterplan/zoning plan (attached at Appendix 1) has been prepared to demonstrate the proposed
residential accommodation. 9.9 hectares of the site is proposed for residential with the potential to
provide 346 units (35 units/ha). A further 3.3ha could be provided for retired accommodation with the
potential to provide 115 units (35 units/ha). Inclusive would be a commitment to a policy compliant
affordable housing units. Considerable weight can be attributed to the provision of a policy complaint
affordable housing promotion, particularly in the context that levels of affordable housing have been
historically low in the district. On this basis alone, it is considered that the promotion of this site should
be viewed favourably.
Our clients, Citizen Housing (“Citizen”), are strongly committed to working collaboratively with Local
Authorities to deliver housing schemes that truly meet the structural needs of the local community. This
is demonstrated by Citizen’s partnership with Southend-on-Sea Borough Council at the Fossetts Farm
and Roots Hall development sites, both of which are proposing to deliver high quality sustainable
housing schemes with policy compliant affordable housing, including over 400 affordable rented units
across both sites with rents in line with Local Housing Allowance rates. This is in addition to substantial
levels of shared ownership homes.
Citizen is therefore proposing to work collaboratively with the Rochford District Council to determine the
appropriate mix of housing at the Star Lane site, including the amount and type of any affordable
accommodation and the level of specialist housing (such as retirement living) to is required to meet the
needs of the district. More information on Citizen can be found at www.citizenhousing.co.uk
Any development would be accompanied by significant landscaping buffer to prevent the merger of
Great Wakering with Shoeburyness and the borough of Southend to the south. The initial masterplan
demonstrates a green buffer of 5.4 hectares north off Poynters Lane following the natural line of the
field. A buffer may need to also be considered to the west of the site, creating a defensible long term
Green Belt boundary. This would also ensure visual impacts on the approach from the south along Star
Lane and east along Poynters Lane are minimised. Such landscaped buffers will prevent the
coalescence of settlements, which is anticipated to be a local concern to residents.
Key to unlocking the site’s full potential is the removal of its Green Belt designated which is allocated
over part of the site. The site was previously assessed as part of the Rochford District Council and
Southend-on-Sea Borough Council Joint Green Belt Study (February 2020). The site was assessed as
part of a large parcel of land comprising 775.6ha to assess its contribution to the five purposes of the
Green Belt. Due to the potential coalescence with Shoebury/Southend to the south and the flood/
special designations for the area it was discounted as further potential for meeting Rochford's future
potential housing needs. Given the scale of the land assessed it is clear why this judgement was
reached. It is therefore recommended that the site be assessed as part of the land just to the south of
Great Wakering.
Section 13 of the NPPF addresses Green Belt Land. Paragraph 137 states that the fundamental aim of
Green Belt policy is to prevent urban sprawl by keeping land permanently open. Paragraph 138 states
the five Green Belt purposes:
a) To check the un unrestricted sprawl of large built-up areas;
b) To prevent neighbouring towns merging into one another;
c) To assist in safeguarding the countryside from encroachment;
d) To preserve the setting and special character of historic towns; and
e) To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
5
In consideration of an allocation and the five Green Belt purposes, we note the following:
• The function of the Green Belt in terms of checking the unrestricted sprawl of large-built up
areas would be restricted by the boundary of an allocation.
• An allocation and good design could ensure that any proposed development creates a future
defensible position by the inclusion of a green gap between the allocated land and
Shoeburyness to prevent the coalescence of settlements. A 5.4ha green buffer is proposed off
Poynters Lane taken from the natural line of the field.
• Whilst the site does retain some degree of openness, it is influenced by the urbanisation of
developments to the north. The initial masterplan proposes approximately 346 residential units
and 115 retired accommodation. Inclusive would be a commitment to a policy compliant
affordable housing units. On this basis alone, the promotion of this site should be viewed
favourably and in keeping with the boundary of Great Wakering.
• The site forms no part of the setting of a historic town and does not contribute to its special
character.
• The proposed site allocation would not affect the ability to regenerate and recycle urban land
within settlements outside of the Green Belt.
It is therefore considered that the release of land from Green Belt would not have an impact on the
integrity of the Green Belt, considering the above. It is also considered that the site has a stronger
relationship with the urban area both to the north and east of the site than with the wider countryside.
The exceptional circumstances for reviewing the Green Belt boundaries are apparent in the housing
need evidence base that needs updating to conform with current NPPF guidance.
Allocation of Star Lane for Employment Use
The Allocations Development Plan Document (DPD) was formally adopted by the Council February
2014. The Allocations Plan allocates specific sites and sets out detailed policies for a range of uses,
including residential employment, education and open spaces. Part of the site (3.2ha) is currently
allocated under Policy NEL2 for employment land to accommodate businesses displaced from Star
Lane Industrial Estate. The types of uses permitted on the site currently include B1 (business), B2
(industrial) and B8 (storage and distribution). The Allocation DPD does not provide an individual target
for each of the sites.
The site is located to the south of the residential envelope of Great Wakering and is well connected to
the strategic road network. The site also offers access to public transport and could offer local
employment opportunities. Providing a pedestrian route along the eastern side of Star Lane would be
required to unlocking the sites potential. In considering the detailed layout of the site, consideration will
be given to the proximity of any residential development brought forward and the impact on residential
amenity.
The initial masterplan/zoning plan attached at Appendix 1 proposes 2.8ha for employment land with
the potential to provide up to 135,000sqft of industrial floorspace. In addition, two access points are
proposed along Star Lane, one to accommodate the industrial element of the site and the other to
accommodate the residential. Due to the direct access to the major road network and the relative
proximity to Great Wakering, it is considered that there is great potential for employment growth in this
location as part of a sustainable mixed-use development.
Conclusion
The site offers an appropriate balance in terms of providing much needed housing in the area (including
affordable), employment floorspace and providing generous open space for both existing and new
communities and contributing towards employment infrastructure. It is therefore recommended that this
site should be put forward for residential and employment land and would support its inclusion within
6
the future Regulation 19 draft Local Plan. The technical considerations of the number of homes and
location within the site would be a matter for detailed site investigation and supporting technical reports.
Please do keep us informed of all future consultation events and evidence base updates. If you wish o
discuss this further please contact either Mary Power (07496 611110 or
mp@powerhausconsultancy.co.uk) or Harriet Young (0203 897 6700 or
hy@powerhausconsultancy.co.uk).

On behalf of Thorpe Estate Limited (my client), please find our comments on the Rochford Local Plan Spatial
Options Consultation (SOC). My client is the owner of some 90 hectares of land to the north of Bournes
Green Chase and to the east of Wakering Road. It lies to the south west of Great Wakering. It is identified
on the plan attached.
The majority of the site falls within the administrative boundary of Southend on Sea Council (SoS) apart from
a small part of the site in the north east corner which falls within the administrative boundary of Rochford
District Council.
My client is in the process of producing an illustrative masterplan for their site, which will be supported
technical analysis on key topic areas, including transport, flood risk and ecology. This will be provided to the
Council in due course.
This masterplan for the site will be produced in conjunction with a wider masterplan and promotion of
neighbouring parcels of land by Cogent Land LLP. A collaborative approach is being taken with Cogent, which
includes co-ordination in respect of transport and other critical infrastructure.
These representations are made in the context of not having had the opportunity to engage with officers at
the Council and we would welcome a meeting at the earliest opportunity.
My client is the owner of the land, which should assure the Council that it is a site which is deliverable and
that there are no legal or ownership hurdles to overcome.
The legislative requirements for the production of Local Plans are set out in Part 2, Local Development, of
the Planning and Compulsory Purchase Act 2004 and in national guidance within the National Planning Policy
Framework 2021 (NPPF).
Paragraph 11 of the NPPF requires that ‘plans should promote a sustainable pattern of development that
seeks to meet the development needs of their area; align growth and infrastructure…..’.
It also requires that ‘strategic policies should, as a minimum, provide for objectively assessed needs for
housing and other uses, as well as any needs that cannot be met within neighbouring areas’.
Chapter 3 of the NPPF then goes onto set out the detailed requirements for plan making, including the
requirement set out in paragraph 24, that each authority is under a ‘duty to cooperate’ with each other on
strategic matters that cross administrative boundaries.
The objective of the plan making process is to be able to put forward a plan that is ‘sound’ and meeting the
requirements set out in paragraph 35 which are:
1. Positively prepared – to meet the area’s objectively assessed needs; and is informed by agreements
with other authorities, so that unmet need from neighbouring areas is accommodated;
2. Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on
proportionate evidence;
3. Effective – deliverable over the plan period, and based on effective joint working on cross-boundary
strategic matters that have been dealt with rather than deferred, as evidenced by the statement of
common ground; and
4. Consistent with national policy – enabling the delivery of sustainable development in accordance
with the policies in this Framework and other statements of national planning policy, where relevant.
Whilst we note that the plan is at a very early stage, we do not consider that the plan is heading in a direction
where it is likely to be considered to accord with the four requirements of soundness and therefore is not
likely to be found ‘sound’.
Our overarching concern is that the Council does not appear to be discharging its responsibilities under the
duty to co-operate in respect of strategic/ cross boundary matters and specifically in relation to my clients’
interests, with SoS Council in respect of housing and infrastructure.
At this stage we would note the number of plans that have been rejected by Inspectors at submission/
examination stage on this very issue, including Sevenoaks District Council, St Albans City and District Council
and Wealden District Council.
We would urge the Council to review its approach to ensure that the Local Plan that gets put forward for
examination accords with the requirements of paragraph 35 of the NPPF.
Our comments below focus on the high-level strategic issues, although, my client will wish to comment on
policies not addressed below at later stages in the plan making process.
The National Picture
The Council are bringing forward their Local Plan at a time of significant challenges facing the country,
particularly because of the Covid-19 pandemic which has exacerbated historic issues of under-delivery of
housing over the past few decades.
This lack of supply is causing substantial issues in the housing market, particularly in relation to affordability
and suitability. The government has estimated that housing need in England is 345,000 homes per year.
The government has therefore set its ambition to achieve 300,000 homes per year.
Whilst the supply of housing has been increasing year on year, only 244,000 homes were delivered in 2019-
20, according to a Government research briefing, ‘Tackling the under-supply of housing in England’.
Housing Need in the Region
At a regional level, there are six South Essex authorities, which are listed below, along with their performance
against the Governments Housing Delivery Test, which measures delivery against housing requirement over
the previous three monitoring years:
1. Basildon – 45%;
2. Brentwood – 69%;
3. Castle Point – 48%;
4. Rochford – 95%;
5. Southend – 36%; and
6. Thurrock – 59%.
Not one of the six authorities have met their target and these delivery rates are amongst the lowest in the
Country and, on average, are delivering only slightly more than half (59%) of the regions housing need.
Clearly this is an issue that needs addressing urgently to avoid disastrous social and economic consequences
for the region.
We note from the SOC that Rochford is likely to have sufficient available land to accommodate its OAN which,
for now, we take at face value, albeit that we are aware of a recent refusal of planning permission on an
allocated site. It may be the case that my client decides to challenge the Council’s supply against the tests
set out in Annex 2 of the NPPF.
It is very clear from the draft SoS Local Plan, that they do not have a supply of homes that gets anywhere
close to meeting their OAN without the release of Green Belt land within their own administrative boundary,
see further commentary below. For SoS’s OAN to be met in full, neighbouring authorities, would need to
accommodate the shortfall estimated to be in the region of 3,550 to 4,300. However, given the historic
undersupply within the neighbouring authorities, who have their own challenges, it is difficult to see how
this could realistically be accommodated.
Clearly radical steps are required to address this issue.
Strategic Plan Making
It is not clear what the latest position is with the South Essex Plan. It is disappointing that this doesn’t appear
to be moving forward to allow strategic policies and growth requirements across the six neighbouring
authorities to inform and lead Local Plan production.
We are also disappointed that the Joint Part 1 Local Plan between Rochford and SoS appears to have now
been abandoned. We do not believe that an update to the November 2019 Statement of Common Ground
(SoCG) with SoS has been prepared setting out what the approach is in relation to cross boundary strategic
matters and this clearly should have been agreed before publication of the SOC.
We would particularly note the statements made at 4.3 and 4.5 of the November 2019 SoCG, which stated:
Providing Sufficient Homes – housing need is high across the area and a large amount of land is being
promoted for development either side of the Rochford/Southend administrative boundary. There is a need to
ensure that preparation of a spatial strategy, site assessment and selection is consistent across both authority
areas;
Transport Infrastructure and connectivity - Developing appropriate integrated and sustainable transport
networks to support the efficient movement of people and goods, including strategic transport corridors
(including A127, A13 and A130) recognising the requirements of both Essex and Southend local transport
plans, including modal shift, sustainable travel, new technology, rail franchisee investment plans, footpath
and cycle networks, and any access mitigation to enable strategic scale development across administrative
boundaries, and future proofed internet access to all new development;
We consider these to be two fundamental parts of the plan making process which require cross boundary
co-operation and yet seem to have been abandoned.
In the absence of this plan moving forward to take an overarching view of growth requirements for the
region, we would strongly contend that the Council should re-engage with SoS to update the SoCG as
required in paragraph 27 of the NPPF. These statements will need to demonstrate how strategic policy
making is being addressed and what steps are being taken to accommodate the significant un-met housing
need, because it is not at all clear how this requirement is satisfied in the draft version of the plan.
These statements should be updated and made publicly available for review at each stage of the plan making
process.
Release of Green Belt Land
Paragraph 140 of the NPPF sets out the tests for the release of Green Belt land and confirms that it should
only be altered where ‘exceptional circumstances are fully evidences and justified, through the preparation
or updating of plans’.
Paragraph 141 goes onto set out the steps that need to be undertaken as part of the justification for
‘exceptional circumstances’. These are:
1. makes as much use as possible of suitable brownfield sites and underutilised land;
2. optimises the density of development in line with the policies in chapter 11 of this Framework,
including whether policies promote a significant uplift in minimum density standards in town and city
centres and other locations well served by public transport; and
c) has been informed by discussions with neighbouring authorities about whether they could accommodate
some of the identified need for development, as demonstrated through the statement of common ground.
Given the scale of housing need in the region, it must be the case that there are exceptional circumstances
that would justify the release of Green Belt land.
Within the context of the above, we have set out our comments on the SOC below.
Spatial Options Map
The Spatial Options Map put forward with the SOC shows my clients land, and neighbouring sites, designated
as Regional Park, which is an interpretation of a concept set out in the South Essex Green and Blue
Infrastructure Study.
Whilst, my client would be content for some of their land to be provided as parkland as part of a
comprehensive masterplanned approach to release their site from the Green Belt for housing led
development, they would not release it solely for the purpose of it being used as parkland.
Critically, the failure to allocate their site would seriously compromise the ability for SoS to deliver homes to
be able to meet their Objectively Assessed Need.
The Spatial Options Map therefore fails all the tests set out in paragraph 35 of the NPPF in relation to the
allocation for my client’s site at parkland as it would not be deliverable.
Rochford in 2050
We agree with the thrust of the Draft Strategic Priorities and Objectives, particularly:
1. Strategic Objective 1 – provision of sufficient homes to meet local community needs in partnership
with South Essex neighbours;
2. Strategic Objective 2- provision of a mix of homes to support current and future residents;
3. Strategic Objective 9 – provision of infrastructure; and
4. Strategic Objective 10 – working with neighbouring authorities and the County Council to deliver
infrastructure.
The objectives identified above are consistent with the requirements of the NPPF, particularly in its
requirements to work strategically with neighbouring authorities to meet housing need and provide
appropriate supporting infrastructure.
However, for the reason set out below, we do not consider the SOC provides the necessary framework to
deliver on these objectives. We consider the reverse is likely to be the case and, as drafted, it would prevent
the current and future need of the area being met.
Strategy Options
It is difficult to properly understand what is proposed within this chapter. The spatial plans (Figures 18-21)
lack clarity and in the absence of a key we cannot be certain what the Council are proposing.
We would ask that at the next stage, much improved plans with a meaningful key are provided to make it
clear what is proposed and where to avoid ambiguity.

Our overarching concern with this chapter is that none of the development options set out in this chapter
take account of the development options that are being put forward within SoS’s ‘Refining the Plan Options’
version, which includes the release of my client’s land, and neighbouring parcels, from the Green Belt for a
residential led development.
Indeed, it would appear that it will only be possible for SoS to meet its OAN through the development of my
client’s land along with neighbouring parcels promoted by Cogent Land LLP and a neighbouring authority
(potentially Rochford) accommodating any shortfall. However, there may be pressure from the other three
South Essex Council’s for housing shortfalls to be accommodated beyond their administrative boundaries.
In order for SoS OAN to be fully addressed, section 2.3i – Requirement for New Homes of the SoS draft Local
Plan identifies that between 3,550 to 4,300 new homes would need to be accommodated either in Rochford
or another neighbouring authority.
At the very least the SOC should include this within its options, including taking account of provision of
strategic infrastructure, particularly roads.
Strategy Option C of the SoS draft Local Plan shows the development of my client’s land, with neighbouring
sites and associated infrastructure.
Strategy Option D shows this growth extending into Rochford, which would allow SoS’s housing OAN to be
met in full.
At the very least, the Council ought to be fully engaging with SoS about its housing need and under its duty
to co-operate required by paragraph 35 a) of the NPPF and testing these options at consultation stage as
part of its SOC. Not to do so is a serious failure of proper planning in this region.
The options currently being promoted within the SOC would likely prevent SoS being able to deliver Options
C or D within its draft Local Plan and therefore prevent it from getting anywhere close to meeting its OAN.
Spatial Themes
My client is generally supportive of the thrust of this chapter and the principles to guide development coming
forward. In particular, the requirements for new development set out in ‘A Place-Making Charter for
Rochford’. We believe the 13 (or 14) points identified will enable the provision of good quality development
consistent with the NPPF.
We don’t have specific comments to make in respect of the questions raised, other than in respect of 16a to
16c. Whilst we feel that design codes will be helpful, these should be kept high level and not specific, unless
in relation to areas of very strong character or of heritage or landscape value. More specific design codes
could be readily formulated at outline permission stage.
Overly prescriptive codes at this stage in areas that are not constrained potentially stifle innovative design.
Housing for All
In relation to questions 17 to 19 It is important that the Council’s policies relating to housing units within
schemes are not overly prescriptive and take a flexible approach. We would expect a definitive policy is
likely to result in most developments being unable to meet that policy for a variety of reasons, such as site
constraints, viability, location, access to services/ public transport etc.
It is our experience that the unit mix that comes forward on each site, should be tailored to the individual
circumstances of that site, having regard to identified need.
We would therefore agree that a combination of Options 2 and 4 would be the most appropriate.
We agree that all homes should meet, or exceed, Nationally Described Space Standards, unless exceptional
circumstances prevent that from being possible, such as conversions or co-living schemes.
We agree that all homes should meet M4(2) of the Building Regulations, again, unless exceptional
circumstances prevent that from being possible.
Finally, we also agree that a ‘suitable’ proportion of new homes should be built to M4(3) of the Building
Regulations. However, we would strongly suggest that evidence ought to be produced to identify and justify
any prescriptive requirement set out in policy to ensure is is not overly onerous and proportionate to the
likely level of need.
Green and Blue Infrastructure
Our comments in relation to this chapter concern my clients’ landholdings which are shown in Figure 32 as
providing Regional Parkland. As the majority of this land is within the administrative area of SoS, we would
recommend that the Council’s immediately look to co-ordinate their approach. Not to do so, risks any
positive conclusions in respect of the duty to co-operate. The approach suggested within the SOC is at odds
with that shown within SoS’s draft plan, particularly in relation to the options that show my clients land being
released from the Green Belt for housing led development.
At no stage has my client put forward its land for regional parkland and, even if it is not released from the
Green Belt for development, it would remain in private ownership. This proposal is therefore not deliverable
and not consistent with paragraph 35 of the NPPF.
We would therefore strongly suggest that the Council review this chapter with the relevant landowners to
understand what is capable of being delivered.
My client would however be prepared to dedicate some of their site to parkland as part of a wider master
planned approach, but only as part of a residential led scheme.
Community Infrastructure, Questions 35 to 37
We agree with the Council’s approach, that it is critical that appropriate infrastructure if planned for to take
account of future growth. However, where we do not agree with the approach taken by the Council is in
relation to the concerning apparent lack of cross boundary discussions with neighbouring authorities about
their future growth and how infrastructure provision may need to be planned for to take account of those
requirements.
Consistent with comments made above, we would strongly urge the Council immediately engage with its
neighbouring authorities so that a cross boundary approach is taken to infrastructure provision that will
address future needs.
Infrastructure should be provided for as part of a cross boundary approach and as part of ‘walkable
neighbourhoods’ to ensure communities have facilities on their doorstep.
Transport and Connectivity
We enclose comments from Arup who are my clients transport and highways advisors in respect of this
chapter of the SOC.
The Wakerings and Barling, Questions 59a to 59e
We do not agree with the vision for The Wakerings and Barling shown in the SOC for reasons previously
explained. It would prejudice the ability for SoS to meet its housing need and the Council should be
discussing the potential release of surrounding Green Belt sites and other strategic cross boundary matters
to facilitate this.
Summary and Recommendations
Thank you for allowing us the opportunity to comment on your SOC. Whilst there are a great many aspects
of the plan that my client fully supports, for the reasons set out above, it does not meet the requirements
for plan making set out in national guidance. If it were to move forward on this basis, we do not believe it
would be capable of being found ‘sound’ in accordance with the tests set out in paragraph 35 of the NPPF.
Chiefly amongst our concerns is that the Council appear to have abandoned its engagement with SoS, and
taking a co-ordinated approach to strategic policy making to meet the need for the region, particularly in
relation to housing growth.

As identified above, the South Essex region is catastrophically failing to deliver homes to meet need and has
produced only slightly more than half of its requirement. It is difficult to see what further ‘exceptional
circumstances’ would be required to justify the release of Green Belt land and to use the plan making process
to take a co-ordinated approach to housing and infrastructure delivery.
We would strongly encourage the Council engage with its neighbours and key stakeholders, including my
client, to agree a strategic approach to accommodating housing need in the area and associated
infrastructure. This is a requirement confirmed in paragraph 25 (and elsewhere) of the NPPF. Ideally, the
Council should re-engage with SoS and produce a joint Part 1 plan to deal with cross boundary strategic
issues. Failing that, we would request that the Council provide an up-to-date Statement of Common Ground
prior to the publication of each plan making stage (in accordance with paragraph 27 of the NPPF) to clearly
set out how it is looking to work with its neighbour on cross boundary strategic issues moving forward.
We note that the Council plans to undertake a transport study that will look at, amongst other things, any
requirements for new road infrastructure. It is essential that this happens only once there is a better
understanding of cross boundary issues, particularly housing, so that this infrastructure can be planned in a
way that facilitates the growth required for the region.
We would very much welcome an opportunity to discuss my client’s land and the strategic growth in the
region with officers at a meeting in the near future. As currently formulated – this plan is seriously flawed
and requires amendment.

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

Q. 6. Balanced Option 4 .

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

Based upon the above I would make the following comments-

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

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

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

More specifically


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Based upon the above I would make the following comments-

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

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

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

More specifically


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

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

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

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

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

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

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

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

EXECUTIVE SUMMARY
There is a compelling case for the allocation of the subject landholding at Tithe Park, Poynters Lane
in the emerging Rochford Local Plan. The proposal at Tithe Park will deliver up to 525 homes, facilitate the provision of a secondary school including scope for SEND and also contribute towards green and blue infrastructure by way of enhanced connections through the site, along with the extension of Friars Park.
The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive Contribution to housing delivery in the early years of the Local Plan.
The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. Furthermore, our client has undertaken a range of technical assessments in respect of the subject site which reinforce the Council’s evidence and
demonstrate that there are no impediments to this site in coming forward.
Crucially this area is assessed as being of medium to low landscape quality, value and sensitivity. It does not perform a strong Green Belt function. The development of this site will provide a logical planned extension which would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, to form a robust and consistent boundary to the redefined Green Belt.
The site is highly sustainable particularly given the high frequency local bus services which currently serve the site, with an average of 13 bus services per hour. Moreover, the provision of community infrastructure on this site would greatly enhance the sustainability credentials of the local area including Great Wakering.
The emerging Rochford Local Plan must meet their own housing needs, along with examining the potential to accommodate some of the unmet need arising from Southend-on-Sea Borough. Given the lack of undeveloped brownfield sites in RDC available for development, it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford. The Framework requires that in such instances first consideration needs to be given to land well served by public transport, such as the subject site.

There are currently no secondary schools in the south-eastern part of Rochford District to serve the site and settlements such as Barling, Great Wakering and Little Wakering, indicating that pupils from these areas need to travel some distance to facilities in other parts of Rochford or Southend/Shoeburyness. Moreover, the schools that are in the wider locality are poorly performing. There are currently no specific Special Educational Needs & Disability (SEND) facilities within
Rochford. While there are limited facilities in Southend, the school performance of these SEND schools is poor when compared to authority and national averages. The NPPF highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities. Paragraph 95 states that local planning authorities should take a proactive,
positive and collaborative approach to meeting this requirement, and to development that will widen
choice in education. Local planning authorities should give great weight to the need to create schools
through the preparation of plans. In light of the above, there is a compelling case for the delivery of a Secondary school and SEND provision in this area.
The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary
and SEND education facilities in this locality and also can contribute towards green and blue infrastructure delivery including the extension of Friars Park.
In summary the key benefits of allocating the subject site include -
• Delivery of up to 525 homes which will make a positive contribution towards the Council’s housing
needs in the short term;
• Ensure a diverse range of tenures (market and affordable) and range of house types;
• Provision of the land to deliver a Secondary School along with scope for a SEND facility;
• Enhance connections and green links through the site improving green and blue infrastructure and extending Friars Park;
• Deliver a robust landscaping strategy which achieves biodiversity net gain;
• Enhancement of Public Rights of Way through the site;
• Support local highway improvements from the site and encourage sustainable transport behaviours.

INTRODUCTION
1.1 These representations have been prepared by Iceni Projects Ltd (“Iceni”) on behalf of Stolkin and Clements (Southend) LLP in respect of the Tithe Park, Poynters Lane, Great Wakering. Our clients
are the freehold owners of this site and are committed to working with the Council and key
stakeholders to deliver a sustainable residential scheme and facilitate the provision of community
infrastructure in this location.
1.2 For reference, enclosed with these representations is a Design Document prepared by Turner Architects which sets out the vision, key features and development potential of the site.
1.3 The preparation of a new Local Plan for Rochford provides an important opportunity in which to deliver positive growth for Rochford and the existing community, along with delivering new homes and infrastructure. This proposal at Poynters Lane is complementary to the Vision for Great Wakering
as set out in the Consultation and will assist the Council in meeting their strategic objectives including the delivery of a Secondary School.
1.4 The Rochford District Council (RDC) evidence base confirms that the site is deliverable; has no issues in terms of flood risk; has a medium to high capacity to accommodate development in landscape terms; will have no impact on any ecological designations; has no Impacts in terms of air quality; is not sensitive from a heritage perspective; it is not restricted in terms of site conditions or topography; and it is in an area of deprivation. The only considerations that the Local Plan evidence base raised in respect of this site relates to green belt; mineral safeguarding and agricultural land
classification and that the site is removed from a secondary school. These matters are considered in
further detail in these representations where it is demonstrated that there are no impediments to this
site in coming forward.
1.5 These representations in relation to Tithe Park are structured as follows:
• Section 2 provides an overview of the site location and context, along with the accessibility of the site to public transport and local services;
• Section 3 summarises the relevant national planning policy framework in so far as it relates to the subject site and proposals;
• Section 4 details housing and education needs in Rochford District;
• Section 5 sets out the evidence base prepared by the Council to date in relation to this site and also the technical reports prepared by our client which demonstrates the suitability of this site for development;
• Section 6 sets out the case for the allocation of the subject site at Tithe Park; &
• Section 7 contains the Conclusion and provides a response to the Questions contained in the Consultation.
SITE CONTEXT
Site Description
2.1 The site comprises a large, rectangular, open parcel of land to the south of Poynters Lane, with an area of 33 hectares, to the north-west of North Shoebury, within the administrative boundary of Rochford District Council. The site is located further south of Great Wakering High Street. The site wraps around a collection of farm buildings at Tithe Farm, and the properties at Tithe Cottages. The southern boundary of the site adjoins the borough of Southend-on-Sea.
2.2 The landholding is bound to the north by Poynters Lane and bordered to the west and south by postwar housing, and open space at Friars Park. To the east, lies an area of unmanaged scrub and grassland and a pocket of commercial development located at the junction of Poynters Lane and Wakering Road. North of this, on the opposite side of Poynters Lane is further residential and
commercial development at Crouchmans Cottages and Crouchmans Farm.
2.3 To the north of the site is an area of arable farmland, beyond which the settlement at Great Wakering
lies. The historic core of Great Wakering lies within the eastern part of the settlement. The village has grown in the latter part of the 20th Century, with housing estates extending the settlement to the north and south of the High Street. New development is currently ongoing at the southwestern edge of the village. Recent development has also occurred off Alexander Road, forming a cluster of housing, which extends someway south of the main part of the village.
2.4 The site is not covered by any statutory or non-statutory designations. The nearest listed building is
the Grade II North Shoebury House, which is located on Poynters Lane to the north-west of the Site. Foulness Ramsar site, Special Protection Area (‘SPA’) and Site of Special Scientific Interest (‘SSSI’) is situated to the east of the site.
2.5 There are a number of local services and amenities located within North Shoebury and Great Wakering including areas of open space, schools, shops, businesses and places of worship. A public footpath crosses the eastern part of the Site, linking Poynters Lane to Friars Park. A second public footpath follows the western boundary of the Site.
2.6 Views towards the site from the surrounding area are limited, due to its proximity to surrounding urban development. In terms of landscape character, the site is closely associated with the surrounding urban land uses, and it has an urban edge character. The site is assessed as being of medium to low landscape quality, value and sensitivity.
The site is exceptionally well located in terms of access to local bus services. The bus routes serving the subject site are detailed in the table below which illustrates that there are bus stops within 100 metres and 460 metres of the site providing a high frequency of services.
Table 2.1 Local Bus Services
Route Bus Stop Distance from Site boundary
Route 1 (The Renown to Rayleigh via Southend Bus
Station and Hadleigh (A13))
Shoebury
Renown
460m
Route 7 (Rayleigh to Great Wakering via Southend Bus
Station and Hawkwell)
Star Lane 100m
Route 8 ( (Rayleigh to Great Wakering via Southend
Bus Station and Ashingdon)
Star Lane 100m
Route 9 (Rayleigh to Shoeburyness East Beach via
Southend Bus Station and Eastwood).
Shoebury
Renown
460m
2.8 In addition, these services stop at Southend Central Bus Station which is a major public transport hub providing routes across Essex, including routes to Southend and Stansted Airports. An extract
of the local bus routes is shown in Figure 2.1.
[SEE DOCUMENT FOR IMAGE]

Both Routes 7 and 8 can be accessed from Poynters Lane, providing one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at the Renown on Constable Way with both routes each providing five buses per hour in the AM peak.
There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
2.10 The site is also well placed with a large number of local facilities with 1km of the site. These facilities include:
• Asda Superstore;
• Asda Pharmacy;
• Friars Park;
• Friars Primary School;
• St George’s Catholic School
• Convenience Store;
• North Shoeburyness Surgery;
• Eagle Way Surgery; and
• Parsons Barn Public House.
2.11 These local facilities, alongside the local bus services, highlight that the site is well located and
alternatives to car use are practical.

NATIONAL PLANNING POLICY FRAMEWORK
3.1 The National Planning Policy Framework was recently updated in July 2021. The purpose of this section of the representations is to highlight the key policy matters of relevance to the subject site.
Plan Led Approach
3.2 The National Planning Policy Framework (referred to herein as “the Framework”) states that the planning system should be genuinely plan-led. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that all plans should promote a sustainable pattern of development that seeks to:
• meet the development needs of their area;
• align growth and infrastructure;
• improve the environment;
• mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects.
3.3 Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, infrastructure, community facilities and conservation and
enhancement of the natural, built and historic environment. These policies should provide a clear
strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development. This should include planning for and allocating sufficient sites to deliver the strategic priorities of the area.
Green Belt Release
3.4 Para 141 of the Framework requires that before concluding exceptional circumstances exist to justify
changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This includes maximising potential of brownfield land, optimising density within urban areas and discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.
3.5 Section 13 ‘Protecting Green Belt land’ identifies that Green Belt boundaries can be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. The required process is for strategic policies to establish the need for any changes to Green Belt boundaries and subsequently detailed amendments to those boundaries may be made through non-strategic policies. The Spatial Consultation and supporting evidence base recognises that RDC
are unlikely to have sufficient urban and brownfield sites to meet the need for housing, employment or community facilities, and neighbouring authorities have advised they are unlikely to be able to accommodate any of Rochford’s needs themselves. Given this context it is considered that there are exceptional circumstances in which to release land from the Green Belt in Rochford.
3.6 The Framework requires at Para 142 that “Where it has been concluded that it is necessary to release
Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport.” The subject site benefits from a high frequency bus service which connects this site to the key local centres, and also provides connections to major rail stations in the locality. In this respect the Framework requires that sites such as Tithe Park should be given first consideration for release from the Green Belt.
30 Year Vision
3.7 The Framework requires for large scale developments such as significant extensions to existing
villages and towns ‘policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. The Framework does not define what constitutes a significant extension and thus it is not clear whether the development of the subject site would require a 30-year vision. Given the scale of the proposal and the timescales for delivery, it is
considered that this policy is not applicable in this instance, nonetheless further clarity is expected
from the Government on this policy in due course.
Planning for Education
3.8 The cornerstone of the Framework is the pursuit of sustainable development. The most recent
revision includes reference to UK’s commitment to pursuing the 17 Global Goals for Sustainable
Development in the period to 2030. Goal 4 relates to quality education and ensuring inclusive and
equitable quality education and promotion of lifelong learning opportunities for all.
3.9 In this vein, the Framework highlights the importance of ensuring a sufficient choice of school places is available to meet the needs of existing and new communities in the promotion of healthy and safe
communities. Paragraph 95 states that Local planning authorities should take a proactive, positive
and collaborative approach to meeting this requirement, and to development that will widen choice in education. Local planning authorities should give great weight to the need to create schools through the preparation of plans
HOUSING & EDUCATION NEEDS ANALYSIS
Housing Needs
4.1 In Rochford District, the housing crisis is stark. Rochford is one of the least affordable regions in
England and house prices are continuing to increase at an unprecedented rate. Many people who want to own a home in Rochford simply cannot afford to do so. The exorbitant increase in house prices and also rents indicates an imbalance between supply and demand. In addition, a growing population, including a largely elderly population, will place significant pressure on the demand for different types of housing and services over the next 20 years.
4.2 The ratio of local house prices to earnings is far in excess of historic levels and above the national average, creating real difficulties for local people to afford a local home, particularly for first time buyers. On this basis it is evident that the current status quo to housing delivery is not working and a bolder approach to housing is required, urgently.
4.3 Government Local Housing Need Standard Method identifies that a minimum 360 houses are needed annually, 7,200 new homes by 2040. To meet minimum local housing needs there needs to be an uplift of +60% on historic delivery rates. The RDC Spatial Options considers a further growth scenario comprising the Standard Method + 50% Buffer which would result in 10,800 new homes by 2040, which the Council states could help to drive local economic growth or address unmet need from elsewhere. Moreover, the SHMA highlights the need for 238 affordable homes a year. Only 1 in every 9 households on the housing register are likely to ever be rehoused based on current projections.
4.4 The Council is under a Duty to Cooperate, requiring plan makers to consider issues which affect not just Rochford but other neighbouring authorities. The Duty to Cooperate is a legal requirement. Southend-on-Sea Borough Council have published their Local Plan Consultation ‘Refining the Plan Options’ which confirms that they are unable to meet their full housing needs with an arising shortfall of 3,550 – 4,300 homes over the period to 2040. Given the close relationships between Rochford and Southend, with people moving home, commuting and travel to access education and services
between the two authorities, RDC needs to consider and test the degree to which it can contribute to meeting unmet needs from Southend in preparing the Local Plan.
4.5 Local Plans get independently examined before the Council can adopt them and must meet relevant legal and ‘soundness’ tests. A failure to effectively address these issues is the major reason why local plans are unable to progress or are found unsound at the Examination stage.
Set against this, the Council’s Housing and Employment Land Availability Assessment considers the potential supply of land based on the application of current planning policies. It identifies potential land which is capable of accommodating 4,5001 dwellings over the plan period on sites which are currently deliverable or developable or through windfall development. This includes sites which have been allocated for development in previous plans, sites with planning permission and other sites identified within existing settlements in the District. This falls substantially short of the District’s
housing needs, meaning that the Plan must consider the potential review of Green Belt boundaries.
4.7 The table below illustrates that RDC will have a shortfall in the range of 2,700 – 6,300 homes. The
Council is duty bound to test whether there can accommodate this level of development, particularly
in view of Southend-on-Sea’s ability to meet their housing needs.
[SEE DOCUMENT FOR TABLE]
Education Needs
4.8 Iceni Projects has undertaken an assessment of the educational needs provision in Rochford and
Southend-on-Sea.
4.9 Figure 4.2 provides an overview in terms of the geographical spread of the secondary school
provision across the two authorities. As it can be seen, the majority of schools are concentrated to the west and centre of the two authorities, with no schools within 2km of the site and one within 5km.
4.10 There are currently no secondary schools in the southeastern parts of Rochford District to directly
serve settlements in these areas such as Barling, Great Wakering and Little Wakering, indicating that children from these areas would need to travel to facilities in other parts of Rochford or Southend/Shoeburyness. The closest secondary establishment in the southeastern areas is the Shoeburyness High School.
[SEE DOCUMENT FOR IMAGE]

The spatial coverage of the various Rochford secondary establishments indicates that settlements located in the south east of the District (e.g. Great Wakering and Little Wakering), are currently situated on the edge of King Edmund School’s catchment area. This could lead to potential difficulties for residents of these areas and their children to access secondary school facilities. In addition, the site falls within the Shoeburyness High School catchment area.
4.2 The Department for Education provides the latest school performance tables through the Find and
compare Schools Tool.
In Rochford, the King Edmund School, which is closest to the Site has a rating of Well below average (-0.79). The performance of the school in terms of Grade 5 or above in English & maths GCSEs is lower than national averages. There is thus a qualitative issue regarding
the choice of good quality schools for residents living in the Rochford and the south-eastern part of Rochford District.
4.3 Moreover, in Southend-on-Sea the Shoeburyness High School ranks at below average; as does the
Southchurch High School. The school’s performance in terms of Grade 5 or above in English & Maths GCSEs is lower than Southend-on-Sea and national averages.
4.4 There are currently no specific Special Education Needs & Disability (SEND) facilities within
Rochford, with some of the mainstream schools in Rochford offering special education needs settings
for limited number of pupils. While there are limited facilities in Southend the school performance of
SEND schools is poor when compared to authority and national averages. There is thus a qualitative
issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District
EVIDENCE BASE & TECHNICAL ASSESSMENTS
5.1 The purpose of this section is to consider both the evidence prepared by RDC to date in so far as it
relates to the subject site and also to consider the technical reports prepared by our client in order to
inform the plan making process and assist the Council.
5.2 In this section we provide an overview of the Rochford Site Appraisals Paper, along with the Green
Belt and Landscape assessments undertaken by RDC.
5.3 Our client has undertaken the following technical reports in respect of the site –
• Green Belt & Landscape Assessment
• Flood Risk Assessment
• Agricultural Land Assessment
• Minerals Assessment
• Ecological Assessment
• Highways, Public Transport & Connectivity Analysis
• Community Infrastructure Audit
• Education Needs Assessment
5.4 In the interests of ensuring these representations are as concise as possible it is not intended to submit these technical reports with the submission, with the exception of the Green Belt and landscape assessment prepared by CSA, rather we will provide an overview of the key findings. We would be pleased to share these reports with the Planning Authority at the appropriate juncture.
RDC Site Appraisals Paper
5.5 The Site Appraisals Paper (SAP) forms an assessment of land being promoted for development in
the District, providing a technical understanding of the sustainability of different sites to inform future
decisions about development as part of the Council’s emerging Local Plan. The Council have stated that it is not the purpose of the SAP to arrive at a list of preferred sites, nor ‘select’ a list of final sites for allocation. The site selection process could logically follow as a next stage.
5.6 The assessment has not flagged any significant issues to hinder the development of Tithe Park (minus being a GB site). Using this assessment potential concerns from the Council regarding development on this site could include the site being Grade 1-3 agricultural land and a minerals safeguarding area. Our client has commissioned technical assessments in relation to these issues which are summarised further below.
5.7 A key issue that needs to be clarified is that the RDC analysis is incorrect in relation to bus frequency which states “The Site is between 400m and 800m from a bus stop however, no bus services received at stops within 400m”. This is an error and needs to be clarified to ensure the site benefits from the correct scoring when assessed against other sites. As detailed above at section 2, the site is within 100 metres of bus stops served by Routes 7 and 8 which provide one and two buses per hour in the AM peak respectively. Route 1 and Route 9 can be accessed to the south of the site at
The Renown on Constable Way, 460 metres from the site, with both routes each providing five buses per hour in the AM peak. There are in the order of 13 buses per hour available to residents at the site and provide access to local train stations and major employment hubs.
5.8 The sustainability of the locality is raised due to the lack of access to major facilities such as a secondary school. However, it is recognised the scale of the site is capable of delivering services such as a school which the subject site could facilitate.
5.9 No notable constraints in terms of site conditions have been identified, there is also a lack biodiversity
and ecology features on the site. Also, the sites close proximity to the strategic road network and suitable vehicular access being possible from a private road are considerations in favour of development on this site.
[SEE DOCUMENT FOR TABLE]

Green Belt & Landscape Assessment
5.10 The Council’s Green Belt assessment considered that release of the site from the Green Belt would result in a high level of harm to the Green Belt purposes. The study noted its potential role in maintaining separation between Great Wakering and Southend-on-Sea, and in preventing sprawl and countryside encroachment. The assessment did however acknowledge that the parcel was contained by development on two sides and that Poynters Lane would be a stronger Green Belt
boundary than the current one. Moreover, the Council’s evidence base identified that the majority of site falls within medium-high capacity area to accommodate development.
5.11 CSA Environmental have undertaken their own independent review of the site’s contribution to the
green belt, attached at Appendix 2 of these representations, and found that “development of the Site could provide a logical planned extension, which would effectively infill an area of land at the north eastern edge of Shoebury. It would be extremely well related to surrounding urban land uses, and would be contained by the route of Poynters Lane, which would form a robust
and consistent boundary to the redefined Green Belt. There would be some reduction in the
separation between Southend-on-Sea and the smaller settlement at Great Wakering, however a clear visual and physical break would remain”.
5.12 This area is assessed generally as being of medium to low landscape quality, value and sensitivity. The is consistent with the Council’s published Landscape Character, Sensitivity and Capacity Study.
5.13 Views towards the Site from the surrounding area are limited, due to its proximity to surrounding
urban development. There are filtered views from the rear of properties which lie adjacent to the Site, and from the open space at Friars Park. There are also views from Poynters Lane, and from the footpaths which cross the farmland at the edge of Great Wakering.
5.14 The site’s performance against the first four Green Belt purposes is summarised in the table below.
Table 5.2 Assessment of the Site against the four Green Belt purposes
[SEE DOCUMENT FOR TABLE]
In light of the above, it is considered that the Council should assess the green belt contribution of
this site independent of the wider area, and thus will reach similiar conclusions as the CSA Environmental analysis.

Education Needs Assessment
5.16 An Education Need Assessment has been prepared by Iceni Projects with the key findings –
• The demographic analysis shows an expected notable increase in the population of secondary school age over the next 6 years to 2027;
• By 2027, the school age population is expected to increase by 2,200 – 2,600 pupils in Rochford and Southend;
• Estimated there is a residual shortfall of approximately 880 to 1,280 places for both Rochford
and Southend when considering school age population increase and planned provision;
• Moreover, the closest schools to these areas (in both Southend and Rochford) are currently
performing poorly, with below average performance when compared to local authority and national averages;
• Lack of good quality secondary school provision in the area for residents to easily access;
• Beyond 2027, the demographic analysis indicates that additional need could be generated as
family housing is delivered and attracts enhanced in-migration to Southend and Rochford. A total population of secondary school age children (relative to the 2020 baseline) of between 2,000 –
3,000. This implies an additional need of up to 400 pupils relative to that to 2027.
5.17 There is currently capacity deficit in the Special Education Needs and Disability (SEND) facilities
closest to the Site. Moreover, the school performance of SEND schools within both Southend-onSea and Essex is poor when compared to authority and national averages. There is thus a qualitative issue regarding the choice of good quality SEND schools for residents living in the Rochford and the south-eastern part of Rochford District.
Community Infrastructure Audit
5.18 A Community Infrastructure Audit was also prepared by Iceni Projects, which presents an overview of current community facilities and services in the area where the Site is located. This assessment came to the conclusion the Local Impact Area where the site is located is considered to have a good range of community facilities. There is capacity in most existing facilities including sport and openspace, health care facilities and community facilities. However, it is likely that local education facilities
to experience some deficits if additional population is introduced into the area. The Report also identifies there is a shortage of allotments and young people’s provision in the District, therefore development on this site could address this need.

Highways, Public Transport & Connectivity
5.19 Iceni Projects undertook an initial Transport Assessment on the Site. The Assessment investigated
a number of potential options for the Poynter Lane / Star Lane Priority Junction to ensure sufficient capacity at this junction when the site is developed. The transport study demonstrates that there are a range of options in order to enhance Poynter Lane / Star Lane Priority Junction which include a new roundabout or a signalised junction.
5.20 There are currently no pedestrian frontages along Poynters Lane, but there are number of other
Public Rights of Way (PRoW) in the vicinity of the Site, including a pedestrian link to Great Wakering.
Local roads are commonly used by recreational cyclists albeit there are no formal cycle routes in the vicinity of the Site. There may also be an opportunity to improve recreational footpaths along the site boundaries to provide purpose-built routes to nearby local amenities.
5.21 As detailed above, the Site is also located in proximity to a number of bus routes in the vicinity of the
Site, serving routes across Essex including Southend and Stansted Airport. The nearest bus stops are located on Poynters Lane and Constable Way and there are up to 13 buses per hour available to residents at the Site which provide access to local train stations and major employment hubs.
Given its proximity to a number of local amenities combined with good connectivity to the public transport network, sustainable transport modes are considered feasible in this location.
Agricultural Land Assessment
5.22 An Agricultural Land Classification and Soil Resources Assessment has been prepared by Reading
Agricultural Consultants. This report set out the findings from an assessment of the Agricultural Land
Classification (ALC) and soil resources by means of a detailed survey of site and soil characteristics.
5.23 15.7 hectares (46%) of the site was identified as Grade 2 soil quality ‘Grade 2 is very good quality
agricultural land, with minor limitations which affect crop yield, cultivations or harvesting. The level of yield is generally high but may be lower or more variable than Grade 1’.
5.24 18.5 hectares (54%) was identified as Grade 3a ‘land has moderate limitations which affect the choice of crops, timing and type of cultivation, harvesting or the level of yield, it is subdivided into Subgrade 3a, which is land is capable of consistently producing moderate to high yields of a narrow range of arable crops or moderate yields of a wide range of crops’.
5.25 The majority of the district comprises Best and Most Versatile Agricultural Land. It is clear that there will be a loss of BMV as part of RDC meeting their local housing needs. On this site, there is no Grade 1 and the majority of the land is Grade 3a. The benefits of the proposed development outweigh any minor harm as a result of the loss in this respect.

Ecological Assessment
5.26 An Extended Phase 1 Habitat Survey was undertaken by Derek Finnie Associates in July 2021. The
Site was found to comprise a single arable field under a bean crop. On the northern, eastern and southern boundaries, outgrown, semi-mature hedgerows are present. There are no ecological constraints to developing the Site, with ample potential in any future landscape design to provide a net biodiversity benefit.
Minerals Assessment
5.27 A Minerals Assessment of the site was undertaken by Tetra Tech Environment Planning Transport Limited, this assessment concluded the majority of the site has previously been worked for minerals.
5.28 The report identifies that a small proportion of the site, approximately 5 hectares, are potentially still
suitable for mineral extraction, however it is not possible to state with any great level of certainty that mineral extraction could take place. Having found that the majority of the site has already been worked it is not considered that, in the case that any underlying economically viable minerals are proven, that this should be of any detriment to the site’s ability to be developed.
5.29 The site is of such a size that it would be possible to phase the development to incorporate the recovery of any minerals, sand or gravel in a timely manner. It is considered that the recovery of any sand and gravel could have sustainability benefits for the site. Depending on the quality of any resource that was proven, the sand and gravel could be used within the site’s construction.
Flood Risk Assessment
5.30 A Flood Risk and Drainage Note was prepared by Waterman to appraise the flood risk and drainage
opportunities and constraints at the Site. The key conclusions from this assessment are set out as, the EA Flood Map for Planning shows that the majority of the Site is located within Flood Zone 1, indicating a low risk of flooding from tidal and fluvial sources (less than 1 in 1,000 annual probability of river or sea flooding). Based on the proximity to the sea, it is understood that any flood risk to the Site would originate from tidal sources. The Map also indicates the majority of the Site is at ‘very low’
risk from flooding from surface water. There have been no recorded groundwater flooding incidents at or within the vicinity of the Site. The risk of flooding from artificial sources and sewers has also been assessed and is considered to be low.

THE ALLOCATION OF TITHE PARK FOR HOUSING & COMMUNITY
INFRASTRUCTURE
Spatial Strategy
6.1 RDC propose to take a positive approach to growth locally, helping to create a more inclusive housing
market, avoiding the emergence of housing-related issues including homelessness and concealed
households. A number of strategy options have been identified in the Local Plan Consultation that could form the basis of the plan’s approach to housing growth over the next 20 years and beyond.
6.2 These representations support growth in the Great Wakering area and more generally to the east of
Rochford. In terms of spatial options, Option 2 seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns or villages. The development of the subject site would accord with Option 2b: Urban extensions dispersed to settlements based on hierarchy. Essentially our client’s preference is Option 4: Balanced
Combination, which proposes growth in terms of urban intensification, urban extensions and concentrated growth. It is considered that this is the only way that the Council will be able to meet their housing needs in the future through a range of growth options which deliver homes and infrastructure in tandem.
6.3 The subject site is available, suitable and achievable to deliver residential development in the short term, along with facilitating the delivery of community infrastructure. This site performs exceptionally well against housing market indicators which is evidenced by the strong interest from a multitude of housebuilders to build on this site. Consequently, this site will make a positive contribution to housing delivery in the early years of the Local Plan.
6.4 The Consultation indicates that the subject site is covered by the ‘Proposed Regional Park’. Our client supports the delivery of the South Essex Estuary Park. However, it is considered that if this site is brought forward for a combination of uses namely new homes, education and open space it will make a positive contribution towards housing needs; address the current deficit in Secondary and SEND education facilities in this locality and also can also perform a role in the delivery of green and blue infrastructure.
Delivery of Homes & Community Infrastructure
6.5 The Consultation states that new development can also deliver community infrastructure stating that “It is therefore important that new growth is not simply seen as creating additional demand for community infrastructure but also as one of the most effective tools at creating additional supply”. The proposal at Tithe Park will deliver up to 525 homes, and also facilitate the provision of a
secondary school including scope for SEND and enhance connections between Southend and the
River Roach.
6.6 The Rochford Consultation is clear that while the Wakerings and Barling has a good range of core
facilities, these only serve local residents and ‘most town-scale facilities, such as a secondary school and large-scale job opportunities, are absent’. The Consultation further notes that ‘The population of the Wakerings and Barling skews slightly younger than the District average which may generate additional demand for housing and jobs in coming years’.
6.7 The proposed development comprising of new homes, provision of land for the delivery of a
secondary school and scope for SEND and open space is designed to be locally-responsive and aimed at meeting the ongoing needs of local residents. The nature of the development and the site location will ensure that the development of this site does not impact on the character of the existing settlements.
Design Principles
6.8 The proposal provides for landscape lead scheme which seeks to strengthen and enhance the
character of the area. The key design principles include :
• Residential development to be focused on the western and central parts of the Site, in close proximity to existing residential land uses.
• New pedestrian / cycle connections to connect into the adjacent residential areas and to Friars Park to integrate the proposals with the existing urban area at Shoebury;
• New planting and open space alongside the northern boundary with Poynters Lane to soften views of the new homes from the north and to provide a robust edge to the redefined Green Belt;
• Potential secondary school and SEND site and associated playing fields to be located to the east; and
• Existing rights of way to be retained and enhanced within green routeways.

CONCLUSION & RESPONSE TO QUESTIONS
7.1 In conclusion, and to summarise the main issues pertaining to these representations, a response to
the relevant questions relating to this site are set out below -
Q33. Do you agree that the central woodlands arc and island wetlands, shown on Figure 32 are the most appropriate areas for new regional parklands? Are there any other areas that should be considered or preferred? [Please state reasoning]
7.2 Our client fully supports the delivery of the South Essex Estuary Park, however the current location
and extent of the park needs to be reconsidered. At present, the entirety of the subject site is indicated as a Regional Park. If this position were to be maintained the site will not deliver any new homes or education facilities. It also would not provide publicly accessible open space as the site would remain in private ownership. Therefore, it is considered that to facilitate the delivery of the
parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach, this site should be allocated for housing and community infrastructure. Our client welcomes the opportunity to engage with the Council and their consultant team to ensure the design of the proposals maximises the potential of the Park and ensures it is deliverable.
Q59b. With reference to Figure 47 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of the Wakerings and Barling?
i) Housing [market, affordable, specialist, traveller, other]
ii) Commercial [offices, industrial, retail, other]
iii) Community infrastructure [open space, education, healthcare, allotments, other]
iv) Other
7.3 As detailed in these representations, it is considered that the subject site should be allocated for
housing and community infrastructure comprising a secondary school. In addition the development
of this site will enhancement green and blue infrastructure including an extension to Friars Park.
7.4 The Consultation details a vision for the Wakerings and Barling which highlights that more services
need to be developed to reduce its reliance on neighbouring towns and ensure villages should have
become more self-sufficient when it comes to homes, jobs and community facilities, including education.
7.5 The Educational Needs Assessment clearly demonstrates that there is a serious shortfall in
Secondary School and SEND provision in the vicinity of Great Wakering and the local area.
Furthermore, the limited provision that does exist in the area is poor performing. This proposal will enable the delivery of a new school which will meet existing and future needs of the locality. This would be of major benefit to the local community. The allocation of this site will also facilitate the delivery of the parkland and key green connections from the south of the district / Southend -on- Sea up to the River Roach.
Conclusion
7.6 Our client fully supports the Council in the preparation of a new Local Plan for Rochford in order to meet local needs and address current deficiencies in the District. The allocation of this site in a highly sustainable location, on land which has a limited contribution in landscape and Green Belt terms will assist the Council in meeting their strategic priorities. This site has the potential to deliver up to 525 homes, facilitate the provision of a Secondary School including scope for SEND provision and
contribute towards the delivery of blue and green infrastructure.
7.7 We welcome the opportunity to discuss the emerging Local Plan preparation and the Council’s proposals for this site in further detail.

Spatial Options Consultation The Wakerings & Barling
Having viewed the online Spatial Options Consultation I am writing to make my feelings and opinions known to you.

We are all aware that there is a housing shortage in this country and that there is an urgent need for affordable housing around the entire country. However, seeing the quotas which the Westminster government are insisting be shouldered by this area and the rest of Essex, there is no question we are being expected to shoulder an unfair and unreasonable share of the burden, due to our convenient proximity to London. Since the government have committed to ‘Levelling Up’ the country I consider this most hypocritical. The South East is already far too congested, our infrastructure in terms of roads, schools and hospitals is at bursting point and there is no doubt that expanding infrastructure in the area will not keep pace with the proposed expansion.

Your Vision Statement for Wakering:
In 2050, the Wakerings and Barling should have retained their rural village character and sense of relative tranquillity. More services should have developed locally to reduce its reliance on neighbouring towns, whilst any new services introduced should be located so that those located on the edges of the settlement are able to access them sustainably. The villages should have become more self-sufficient when it comes to homes, jobs and community facilities, including education. Development that takes place should be locally-responsive and aimed at meeting the ongoing housing and employment needs of local residents.

It is obvious that it is impossible to live up to this statement and at the same time press forward with the level of development proposed in the Rochford area.

At the moment Wakering and Barling are beautiful rural villages. However if an area so close to Southend and London has not been developed more in the past, we can assume there are solid reasons and that the land here does not offer a friendly environment for too much housing. We are on the Creek, close to marshland and with rainfall predicted to rise due to climate change it is imperative the water table is maintained to prevent serious flooding. This means leaving open land for adequate drainage not only for proposed developments but for the residents already in situ. The current roads are single lane and many of the residents have to park street side because older houses do not have off road parking. This reduces traffic flow still further for most of the time (Little Wakering Rd is particularly susceptible to this.)

Much of the proposed building would be on currently agricultural land. It may well be that the encumbant farmers are tempted to sell up and retire on the proceeds but whereas this may suit them individually it would be criminally negligent of the authorities to allow this land to switch use because once it has done so, it will never return to the original purpose. We are living in times of global upheaval. Brexit means the UK will have to consider producing far more of our own food if we are to maintain present standards of living at minimal cost. Furthermore, combatting climate change (already officially recognised as affecting Britain) means we need to be sourcing food locally as possible and paying far more attention to ecology and our wildlife. Destroying the agricultural benefits of Wakering would be cutting off our noses to spite our faces.

I will finish by pointing out that one of the main ways to access Wakering is via Shopland, which feeds into Sutton Rd and thus into Ashingdon Rd. It is no secret that the traffic flow in these areas is close to gridlock for a lot of the time and further traffic feeding in from the Wakering area would be unworkable.

I am aware that Basildon and Southend councils are lodging objections and resisting the pressures from government to overdevelop their respective areas. It is obvious if they are successful the onus will simply be slope shouldered and further pressure put on surrounding councils like Rochford. Please, stand up for our area and join them in resisting these directives. The greenbelt was conceived for a reason and I can think of no time when we have needed to commit to this principle more!

Be loyal to Rochford, not to party politics.

I wish to express concern at the suggested development in the above area with particular reference to Sites Refs: CFS004 and CFS071.

Any large scale development is bound to impact negatively on the much-prized rural character of this area.

Even beyond the development sites, road usage would markedly increase resulting in further disruption and potential further loss of green space. Traffic safety is another consideration.

There is already a potentially dangerous traffic situation affecting Barling School. The building of x26 houses on the adjoining site would exacerbate this. A more appropriate use of this land would be to provide school parking/school facilities.

Heavy traffic due to construction vehicles and, later, increased population, would create further dangers throughout the villages and noise pollution.

Further, I would challenge the desire for more self-sufficiency. I would suggest that having to travel out of the area for some services, especially commercial, is a price worth paying for the preservation of this rural setting.