Rochford District Core Strategy Regulation 26 Draft

Thank you for consulting the historic environment management team on the Rochford Core Strategy Preferred Options.

Within the core strategy document heritage sites and the historic environment are mentioned under sections 2.2, 2.5, 2.19, 2.21 and 2.29. Rochford have already commissioned a Historic Environment Characterisation Project which clearly identifies the importance of all three strands of the historic environment comprising the historic landscape, built heritage and the archaeological deposits.

Although the Historic Environment is mentioned throughout the document there is a lack of bullet points or policies under section 4.10 (Character of Place and the Historic Environment). Most of the sub sections in 4.10 relate to the built environment and there is little which relates to both Rochford's important historic landscape and surviving archaeological deposits. It is recommended that an additional bullet point be added on the important historic landscape and archaeological deposits of the District. A suggested wording is:

The district has a diverse historic landscape and extensive surviving archaeological deposits. There is the potential to protect and enhance the historic environment assets and their surroundings both within development areas, and in rural and coastal landscape and as a first step the council has commissioned a Historic Environment Characterisation Project.

Also it would be appropriate to add a further bullet point in the highlighted section stating:

The council will provide policies to both protect and enhance the historic environment protecting the Districts Sense of Place.

Thank you for consulting the historic environment management team on the Rochford Core Strategy Preferred Options.

Within the core strategy document heritage sites and the historic environment are mentioned under sections 2.2, 2.5, 2.19, 2.21 and 2.29. Rochford have already commissioned a Historic Environment Characterisation Project which clearly identifies the importance of all three strands of the historic environment comprising the historic landscape, built heritage and the archaeological deposits.

Although the Historic Environment is mentioned throughout the document there is a lack of bullet points or policies under section 4.10 (Character of Place and the Historic Environment). Most of the sub sections in 4.10 relate to the built environment and there is little which relates to both Rochford's important historic landscape and surviving archaeological deposits. It is recommended that an additional bullet point be added on the important historic landscape and archaeological deposits of the District. A suggested wording is:

The district has a diverse historic landscape and extensive surviving archaeological deposits. There is the potential to protect and enhance the historic environment assets and their surroundings both within development areas, and in rural and coastal landscape and as a first step the council has commissioned a Historic Environment Characterisation Project.

Also it would be appropriate to add a further bullet point in the highlighted section stating:

The council will provide policies to both protect and enhance the historic environment protecting the Districts Sense of Place.

Policy Content

The main comments concerning the content of the published consultation document are as follows:

1. To satisfy government guidance, the Core Strategy Preferred Options stage should have moved significantly on from the previous Issues and Options stage in terms of scope, content, and process as outlined below.

2. The evidence base should be substantially expanded and rolled forward to ultimately justify the selection of the Preferred Option. In particular, further evidence involving urban capacity, strategic housing market assessment, strategic housing land availability, town centres & retailing, employment land review, and transport studies is required. The whole evidence base should also be extended and rolled-forward well beyond 2021 so as to comply with PPS3 Housing guidance (namely that adopted DPDs should look forward at least 15 years' ahead at the date of their adoption).

3. Rochford district has significant functional economic relationships with Southend, Basildon, and other parts of Essex Thames Gateway, as well as parts of Greater London. The evolving Core Strategy should consider how these relationships might change and develop up to 2021, and what the practical implications might be for job/home alignment, commuting patterns, transport, and patterns of development provision.

4. The urban capacity study needs urgent updating before the broad direction of any Preferred Options can be confirmed. It also needs to be linked into a strategic housing market assessment and strategic housing land availability assessment in accordance with PPS3. In this way, the re-use of previously-developed land (PDL) and the consequential need for any greenfield site releases in the district can be properly clarified. At present there is inadequate information about this issue to inform discussion of Preferred Options.

5. The Preferred Options stage should also investigate the spatial planning implications of the RSS jobs figure. It should identify where the net jobs increase will come from within different economic sectors, and what the corresponding land-use implications might be for B1 employment uses, office development, retail and services, tourism, and the public sector (such as education and health). The District Council should undertake an employment land review to assess the extent to which existing employment areas will remain suitable and which new or existing locations would best support the future economic strategy of the district. This should then feed into the consideration of the future accessibility of employment sites to housing locations.

6. The Preferred Options should contain policy guidance regarding the preferred strategy for the district's town centres. This should include discussion of strategic options and choices for the amount and location of retail provision and other town centre uses. The policy approach towards out-of-centre development should also be explored and clarified.

7. The range of alternative options for the development strategy should be explained much more explicitly. This includes identifying and quantifying how much new housing should to be provided on PDL and greenfield sites, respectively; and the development provision required for employment, offices, town centre and retail uses, and other major development. Having established the broad quantum of new development required in the district, the Preferred Options stage should set out the reasonable alternatives for the location of new development in terms of its spatial pattern. This includes both the numeric distribution between individual key settlements and the broad locations for any major development. The latter would include identifying the geographical sectors on the edge of major settlements. The reasoned justification for any preferred option(s) should also be set out explicitly by drawing on the results of technical studies, SEA and sustainability appraisal, transport studies, and the results of public consultation at previous stages.

8. The practicality and desirability of designating 'buffers' in policy terms within the Metropolitan Green Belt (MGB) is unclear. The stated purposes of the MGB already include preventing the coalescence of existing settlements plan situated within the MGB, so the proposed use of 'buffers' represents a duplication of existing policy. Alternatively, if the proposed 'buffers' are to perform a different policy role this is not adequately explained. Since greenfield land releases may be required in the district up to 2021 and beyond, it is unclear whether the proposed use of 'buffers' would be incompatible with such an approach or not.

9. The approach towards the provision of new affordable housing is based upon specific local size thresholds in terms of site size. However, the proposed local thresholds are different from those set out in PPS3 Housing. The use of local thresholds departing from national guidance requires special justification, but this is not provided. It is also unclear whether the proposed affordable housing could be delivered in the absence of clear mechanisms for its delivery.

10. The Preferred Options should set out much greater consideration of the elements of a sustainable transport strategy to support the 5, 10 and 15 year visions. The County Council would be willing to assist Rochford District Council in preparing this material to support its Core Strategy DPD submission.

11. The Core Strategy will require more consideration of implementation and monitoring in accordance with government guidance. In particular, the actions necessary for delivery, any absolute dependencies on infrastructure, and the timescale should be identified. The recent White Paper (Planning for a Sustainable Future, May 2007) is proposing that detailed implementation plans should be prepared alongside Core Strategy DPD preparation.


Future Process

In view of the above comments, Rochford District Council is recommended to:

a) Commission additional technical studies to support and supplement the evidence base, and extend the base well beyond 2021;

b) Give more explicit guidance about the range of future development options in the district for different types of new development, including a more fuller reasoned justification at arriving at any preferred option(s);

c) Carry out further public consultation on (a) and (b) before proceeding to the preparation of a Core Strategy DPD for submission to the Secretary of State.


2. MORE DETAILED COMMENTS

Spatial Portrait
Para 1.9 The sentence "Within the district road infrastructure is poor" should be deleted, as there is no evidence that Rochford's roads are particularly poor.

Para 1.9 The sentence "There are no designated Heavy Lorry Routes in the District and many routes are unfit for their current level of use" should be amended to "The district's road network is under pressure from increasing private car and commercial traffic."

Spatial Vision

Para 2.6 After second sentence add, "The larger new development sites will have been designed with priority access to public transport, pedestrians and cyclists in mind".

Para 2.14 Add "The South Essex Rapid Transit (SERT) project, enhancing the use and attractiveness of public transport in the Thames Gateway area, will have entered the District."
Para 2.24 Amend "Public transport is well used and has been enhanced by the completion of the South Essex Rapid Transit (SERT), which serves most of the population of the district." to "Public Transport is well used and has been enhanced by further South Essex Rapid Transit services."

Para 2.27 The phrase "Despite travel times to and from the airport increasing " should either be explained or deleted.

Green Belt

Para 4.2.7 The expansion of King Edmund School would require extra land in the Green Belt. Therefore, it may be helpful to include community facilities in the consideration of relaxation of policy.

General development locations

Para 4.6.2 The Rochford Core Strategy should have regard to the existing Brickearth Consultation Area when identifying new locations for development.

Para 4.6.1 Add at end: "embodying priority access by sustainable transportation modes consistent with Local Transport Plan policies as far as practicable where appropriate. Development will also be progressed with regard to highway development control policies to be defined in detail within the Development Control policies set of documents outlined in paragraph 3.9."

Para 4.6.3 While schools are included in the 'good range of facilities' alluded to, these settlements are only 'capable of sustaining some expansion' if the number of school places is increased. The document needs to be clear that there are insufficient surplus places to accommodate 3,900 additional homes.

Para 4.6.10 Significant additional schools capacity will be needed as set out below. In addition, Early Years and Childcare facilities will need to be provided in each case. Financial and land contributions from developers will be needed to deliver this infrastructure. The allocation of 300 more units than proposed to Hockley and 300 less to Rayleigh would provide a better fit in terms of maximising the use of current schools' capacity. Rochford/Ashingdon:- 1,000 UnitsThe capacity of Doggetts Primary can potentially be expanded to meet the needs of up to 1,000 new homes. If the sites are poorly located for this school, a new single form entry primary school would be needed (site area required 1.1 hectares). At secondary, King Edmund is already accommodating significantly more pupils than is recommended by the DfES for their site area. The school is forecast to remain oversubscribed. To expand, the school will need to obtain additional land. Land to the north and east of the school is open. The school has access difficulties with significant vehicle / pedestrian conflict and congestion at the start and end of the day. Incorporation of land to the north into the school site would allow the school to expand to serve new housing while at the same time providing improved access via Brat's Lane. The plan should allocate a minimum of 2.7 hectares of land for this purpose based on 1,000 new homes. RDC will need to consult with the School as to the precise piece of land needed. Hockley/Hawkwell: - 400 UnitsDemand for both primary and secondary places in the area is forecast to fall, which should allow this number of new dwellings to be accommodated without the need for significant additional capacity. Rayleigh: - 1,800 UnitsThis quantum of new development is likely to require an additional two forms of entry to be added to permanent capacity across the town at both primary and secondary levels. Half of this requirement at primary level can be met by expanding existing schools. The allocation of a single housing site of around 700 units would be needed to deliver a new single form entry primary school (1.1 hectares) to make up the anticipated shortfall. Limited expansion of Fitzwimarc and/or Sweyne Park can probably be achieved with careful planning/ negotiation with the schools. Smaller settlements: - 500 UnitsThe allocation of units to smaller settlements could help sustain rural primary schools within the District but would impose long term school transport costs upon the County Council that should be mitigated through developer contributions. Specific locations will require careful consideration.

Para 4.6.18 Reference to public transport should be added, as Rayleigh has excellent access by rail both towards London and Southend.

Employment

Para 4.8.8 Regional Employment Strategy should be amended to Regional Economic Strategy.

Good design & design statements

Para 4.9.9 Architects and developers should be required to design their new developments with the use of recycled and alternative materials in mind, as efforts to increase recycling will only be worthwhile if there is a local market for recycled products.

Character of place & the historic environment

Para 4.10.8 The policy bullet points should include reference to historic heritage (e.g. historic landscape and archaeology), not just identity and buildings.

Energy & water conservation & renewable energy

Section 4.12 It is considered the Core Strategy for Rochford should provide the basis of policy guidance for accommodating waste management facilities within the District in order to be consistent with the RSS and PPS10. Policies should address the following:

- Resource reduction, re-use and recycling during construction of new developments as a way of driving waste up the waste hierarchy. This should be a primary objective.

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

- Appropriate layout and design of buildings, external spaces and roads to allow for waste storage and collection and to facilitate waste separation and recycling. PPS10 contains guidance with regard to what facilities should be incorporated into non-waste related development.

- The recommendations on pages 91 - 94 of The Essex Design Guide Urban Place Supplement, which is being adopted by Rochford District Council as a Supplementary Planning Document.

4.12.11 The first bullet point relates to much wider issues than the energy conservation heading under which it appears. It should be a core policy in its own right, and include aspects such as safe routes to schools.

Compulsory purchase & planning obligations

4.13.7 Add education to list of justifications for compulsory purchase. As stated above, The King Edmund School needs to secure additional land.

Policy Content

The main comments concerning the content of the published consultation document are as follows:

1. To satisfy government guidance, the Core Strategy Preferred Options stage should have moved significantly on from the previous Issues and Options stage in terms of scope, content, and process as outlined below.

2. The evidence base should be substantially expanded and rolled forward to ultimately justify the selection of the Preferred Option. In particular, further evidence involving urban capacity, strategic housing market assessment, strategic housing land availability, town centres & retailing, employment land review, and transport studies is required. The whole evidence base should also be extended and rolled-forward well beyond 2021 so as to comply with PPS3 Housing guidance (namely that adopted DPDs should look forward at least 15 years' ahead at the date of their adoption).

3. Rochford district has significant functional economic relationships with Southend, Basildon, and other parts of Essex Thames Gateway, as well as parts of Greater London. The evolving Core Strategy should consider how these relationships might change and develop up to 2021, and what the practical implications might be for job/home alignment, commuting patterns, transport, and patterns of development provision.

4. The urban capacity study needs urgent updating before the broad direction of any Preferred Options can be confirmed. It also needs to be linked into a strategic housing market assessment and strategic housing land availability assessment in accordance with PPS3. In this way, the re-use of previously-developed land (PDL) and the consequential need for any greenfield site releases in the district can be properly clarified. At present there is inadequate information about this issue to inform discussion of Preferred Options.

5. The Preferred Options stage should also investigate the spatial planning implications of the RSS jobs figure. It should identify where the net jobs increase will come from within different economic sectors, and what the corresponding land-use implications might be for B1 employment uses, office development, retail and services, tourism, and the public sector (such as education and health). The District Council should undertake an employment land review to assess the extent to which existing employment areas will remain suitable and which new or existing locations would best support the future economic strategy of the district. This should then feed into the consideration of the future accessibility of employment sites to housing locations.

6. The Preferred Options should contain policy guidance regarding the preferred strategy for the district's town centres. This should include discussion of strategic options and choices for the amount and location of retail provision and other town centre uses. The policy approach towards out-of-centre development should also be explored and clarified.

7. The range of alternative options for the development strategy should be explained much more explicitly. This includes identifying and quantifying how much new housing should to be provided on PDL and greenfield sites, respectively; and the development provision required for employment, offices, town centre and retail uses, and other major development. Having established the broad quantum of new development required in the district, the Preferred Options stage should set out the reasonable alternatives for the location of new development in terms of its spatial pattern. This includes both the numeric distribution between individual key settlements and the broad locations for any major development. The latter would include identifying the geographical sectors on the edge of major settlements. The reasoned justification for any preferred option(s) should also be set out explicitly by drawing on the results of technical studies, SEA and sustainability appraisal, transport studies, and the results of public consultation at previous stages.

8. The practicality and desirability of designating 'buffers' in policy terms within the Metropolitan Green Belt (MGB) is unclear. The stated purposes of the MGB already include preventing the coalescence of existing settlements plan situated within the MGB, so the proposed use of 'buffers' represents a duplication of existing policy. Alternatively, if the proposed 'buffers' are to perform a different policy role this is not adequately explained. Since greenfield land releases may be required in the district up to 2021 and beyond, it is unclear whether the proposed use of 'buffers' would be incompatible with such an approach or not.

9. The approach towards the provision of new affordable housing is based upon specific local size thresholds in terms of site size. However, the proposed local thresholds are different from those set out in PPS3 Housing. The use of local thresholds departing from national guidance requires special justification, but this is not provided. It is also unclear whether the proposed affordable housing could be delivered in the absence of clear mechanisms for its delivery.

10. The Preferred Options should set out much greater consideration of the elements of a sustainable transport strategy to support the 5, 10 and 15 year visions. The County Council would be willing to assist Rochford District Council in preparing this material to support its Core Strategy DPD submission.

11. The Core Strategy will require more consideration of implementation and monitoring in accordance with government guidance. In particular, the actions necessary for delivery, any absolute dependencies on infrastructure, and the timescale should be identified. The recent White Paper (Planning for a Sustainable Future, May 2007) is proposing that detailed implementation plans should be prepared alongside Core Strategy DPD preparation.


Future Process

In view of the above comments, Rochford District Council is recommended to:

a) Commission additional technical studies to support and supplement the evidence base, and extend the base well beyond 2021;

b) Give more explicit guidance about the range of future development options in the district for different types of new development, including a more fuller reasoned justification at arriving at any preferred option(s);

c) Carry out further public consultation on (a) and (b) before proceeding to the preparation of a Core Strategy DPD for submission to the Secretary of State.


2. MORE DETAILED COMMENTS

Spatial Portrait
Para 1.9 The sentence "Within the district road infrastructure is poor" should be deleted, as there is no evidence that Rochford's roads are particularly poor.

Para 1.9 The sentence "There are no designated Heavy Lorry Routes in the District and many routes are unfit for their current level of use" should be amended to "The district's road network is under pressure from increasing private car and commercial traffic."

Spatial Vision

Para 2.6 After second sentence add, "The larger new development sites will have been designed with priority access to public transport, pedestrians and cyclists in mind".

Para 2.14 Add "The South Essex Rapid Transit (SERT) project, enhancing the use and attractiveness of public transport in the Thames Gateway area, will have entered the District."
Para 2.24 Amend "Public transport is well used and has been enhanced by the completion of the South Essex Rapid Transit (SERT), which serves most of the population of the district." to "Public Transport is well used and has been enhanced by further South Essex Rapid Transit services."

Para 2.27 The phrase "Despite travel times to and from the airport increasing " should either be explained or deleted.

Green Belt

Para 4.2.7 The expansion of King Edmund School would require extra land in the Green Belt. Therefore, it may be helpful to include community facilities in the consideration of relaxation of policy.

General development locations

Para 4.6.2 The Rochford Core Strategy should have regard to the existing Brickearth Consultation Area when identifying new locations for development.

Para 4.6.1 Add at end: "embodying priority access by sustainable transportation modes consistent with Local Transport Plan policies as far as practicable where appropriate. Development will also be progressed with regard to highway development control policies to be defined in detail within the Development Control policies set of documents outlined in paragraph 3.9."

Para 4.6.3 While schools are included in the 'good range of facilities' alluded to, these settlements are only 'capable of sustaining some expansion' if the number of school places is increased. The document needs to be clear that there are insufficient surplus places to accommodate 3,900 additional homes.

Para 4.6.10 Significant additional schools capacity will be needed as set out below. In addition, Early Years and Childcare facilities will need to be provided in each case. Financial and land contributions from developers will be needed to deliver this infrastructure. The allocation of 300 more units than proposed to Hockley and 300 less to Rayleigh would provide a better fit in terms of maximising the use of current schools' capacity. Rochford/Ashingdon:- 1,000 UnitsThe capacity of Doggetts Primary can potentially be expanded to meet the needs of up to 1,000 new homes. If the sites are poorly located for this school, a new single form entry primary school would be needed (site area required 1.1 hectares). At secondary, King Edmund is already accommodating significantly more pupils than is recommended by the DfES for their site area. The school is forecast to remain oversubscribed. To expand, the school will need to obtain additional land. Land to the north and east of the school is open. The school has access difficulties with significant vehicle / pedestrian conflict and congestion at the start and end of the day. Incorporation of land to the north into the school site would allow the school to expand to serve new housing while at the same time providing improved access via Brat's Lane. The plan should allocate a minimum of 2.7 hectares of land for this purpose based on 1,000 new homes. RDC will need to consult with the School as to the precise piece of land needed. Hockley/Hawkwell: - 400 UnitsDemand for both primary and secondary places in the area is forecast to fall, which should allow this number of new dwellings to be accommodated without the need for significant additional capacity. Rayleigh: - 1,800 UnitsThis quantum of new development is likely to require an additional two forms of entry to be added to permanent capacity across the town at both primary and secondary levels. Half of this requirement at primary level can be met by expanding existing schools. The allocation of a single housing site of around 700 units would be needed to deliver a new single form entry primary school (1.1 hectares) to make up the anticipated shortfall. Limited expansion of Fitzwimarc and/or Sweyne Park can probably be achieved with careful planning/ negotiation with the schools. Smaller settlements: - 500 UnitsThe allocation of units to smaller settlements could help sustain rural primary schools within the District but would impose long term school transport costs upon the County Council that should be mitigated through developer contributions. Specific locations will require careful consideration.

Para 4.6.18 Reference to public transport should be added, as Rayleigh has excellent access by rail both towards London and Southend.

Employment

Para 4.8.8 Regional Employment Strategy should be amended to Regional Economic Strategy.

Good design & design statements

Para 4.9.9 Architects and developers should be required to design their new developments with the use of recycled and alternative materials in mind, as efforts to increase recycling will only be worthwhile if there is a local market for recycled products.

Character of place & the historic environment

Para 4.10.8 The policy bullet points should include reference to historic heritage (e.g. historic landscape and archaeology), not just identity and buildings.

Energy & water conservation & renewable energy

Section 4.12 It is considered the Core Strategy for Rochford should provide the basis of policy guidance for accommodating waste management facilities within the District in order to be consistent with the RSS and PPS10. Policies should address the following:

- Resource reduction, re-use and recycling during construction of new developments as a way of driving waste up the waste hierarchy. This should be a primary objective.

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

- Appropriate layout and design of buildings, external spaces and roads to allow for waste storage and collection and to facilitate waste separation and recycling. PPS10 contains guidance with regard to what facilities should be incorporated into non-waste related development.

- The recommendations on pages 91 - 94 of The Essex Design Guide Urban Place Supplement, which is being adopted by Rochford District Council as a Supplementary Planning Document.

4.12.11 The first bullet point relates to much wider issues than the energy conservation heading under which it appears. It should be a core policy in its own right, and include aspects such as safe routes to schools.

Compulsory purchase & planning obligations

4.13.7 Add education to list of justifications for compulsory purchase. As stated above, The King Edmund School needs to secure additional land.

Policy Content

The main comments concerning the content of the published consultation document are as follows:

1. To satisfy government guidance, the Core Strategy Preferred Options stage should have moved significantly on from the previous Issues and Options stage in terms of scope, content, and process as outlined below.

2. The evidence base should be substantially expanded and rolled forward to ultimately justify the selection of the Preferred Option. In particular, further evidence involving urban capacity, strategic housing market assessment, strategic housing land availability, town centres & retailing, employment land review, and transport studies is required. The whole evidence base should also be extended and rolled-forward well beyond 2021 so as to comply with PPS3 Housing guidance (namely that adopted DPDs should look forward at least 15 years' ahead at the date of their adoption).

3. Rochford district has significant functional economic relationships with Southend, Basildon, and other parts of Essex Thames Gateway, as well as parts of Greater London. The evolving Core Strategy should consider how these relationships might change and develop up to 2021, and what the practical implications might be for job/home alignment, commuting patterns, transport, and patterns of development provision.

4. The urban capacity study needs urgent updating before the broad direction of any Preferred Options can be confirmed. It also needs to be linked into a strategic housing market assessment and strategic housing land availability assessment in accordance with PPS3. In this way, the re-use of previously-developed land (PDL) and the consequential need for any greenfield site releases in the district can be properly clarified. At present there is inadequate information about this issue to inform discussion of Preferred Options.

5. The Preferred Options stage should also investigate the spatial planning implications of the RSS jobs figure. It should identify where the net jobs increase will come from within different economic sectors, and what the corresponding land-use implications might be for B1 employment uses, office development, retail and services, tourism, and the public sector (such as education and health). The District Council should undertake an employment land review to assess the extent to which existing employment areas will remain suitable and which new or existing locations would best support the future economic strategy of the district. This should then feed into the consideration of the future accessibility of employment sites to housing locations.

6. The Preferred Options should contain policy guidance regarding the preferred strategy for the district's town centres. This should include discussion of strategic options and choices for the amount and location of retail provision and other town centre uses. The policy approach towards out-of-centre development should also be explored and clarified.

7. The range of alternative options for the development strategy should be explained much more explicitly. This includes identifying and quantifying how much new housing should to be provided on PDL and greenfield sites, respectively; and the development provision required for employment, offices, town centre and retail uses, and other major development. Having established the broad quantum of new development required in the district, the Preferred Options stage should set out the reasonable alternatives for the location of new development in terms of its spatial pattern. This includes both the numeric distribution between individual key settlements and the broad locations for any major development. The latter would include identifying the geographical sectors on the edge of major settlements. The reasoned justification for any preferred option(s) should also be set out explicitly by drawing on the results of technical studies, SEA and sustainability appraisal, transport studies, and the results of public consultation at previous stages.

8. The practicality and desirability of designating 'buffers' in policy terms within the Metropolitan Green Belt (MGB) is unclear. The stated purposes of the MGB already include preventing the coalescence of existing settlements plan situated within the MGB, so the proposed use of 'buffers' represents a duplication of existing policy. Alternatively, if the proposed 'buffers' are to perform a different policy role this is not adequately explained. Since greenfield land releases may be required in the district up to 2021 and beyond, it is unclear whether the proposed use of 'buffers' would be incompatible with such an approach or not.

9. The approach towards the provision of new affordable housing is based upon specific local size thresholds in terms of site size. However, the proposed local thresholds are different from those set out in PPS3 Housing. The use of local thresholds departing from national guidance requires special justification, but this is not provided. It is also unclear whether the proposed affordable housing could be delivered in the absence of clear mechanisms for its delivery.

10. The Preferred Options should set out much greater consideration of the elements of a sustainable transport strategy to support the 5, 10 and 15 year visions. The County Council would be willing to assist Rochford District Council in preparing this material to support its Core Strategy DPD submission.

11. The Core Strategy will require more consideration of implementation and monitoring in accordance with government guidance. In particular, the actions necessary for delivery, any absolute dependencies on infrastructure, and the timescale should be identified. The recent White Paper (Planning for a Sustainable Future, May 2007) is proposing that detailed implementation plans should be prepared alongside Core Strategy DPD preparation.


Future Process

In view of the above comments, Rochford District Council is recommended to:

a) Commission additional technical studies to support and supplement the evidence base, and extend the base well beyond 2021;

b) Give more explicit guidance about the range of future development options in the district for different types of new development, including a more fuller reasoned justification at arriving at any preferred option(s);

c) Carry out further public consultation on (a) and (b) before proceeding to the preparation of a Core Strategy DPD for submission to the Secretary of State.


2. MORE DETAILED COMMENTS

Spatial Portrait
Para 1.9 The sentence "Within the district road infrastructure is poor" should be deleted, as there is no evidence that Rochford's roads are particularly poor.

Para 1.9 The sentence "There are no designated Heavy Lorry Routes in the District and many routes are unfit for their current level of use" should be amended to "The district's road network is under pressure from increasing private car and commercial traffic."

Spatial Vision

Para 2.6 After second sentence add, "The larger new development sites will have been designed with priority access to public transport, pedestrians and cyclists in mind".

Para 2.14 Add "The South Essex Rapid Transit (SERT) project, enhancing the use and attractiveness of public transport in the Thames Gateway area, will have entered the District."
Para 2.24 Amend "Public transport is well used and has been enhanced by the completion of the South Essex Rapid Transit (SERT), which serves most of the population of the district." to "Public Transport is well used and has been enhanced by further South Essex Rapid Transit services."

Para 2.27 The phrase "Despite travel times to and from the airport increasing " should either be explained or deleted.

Green Belt

Para 4.2.7 The expansion of King Edmund School would require extra land in the Green Belt. Therefore, it may be helpful to include community facilities in the consideration of relaxation of policy.

General development locations

Para 4.6.2 The Rochford Core Strategy should have regard to the existing Brickearth Consultation Area when identifying new locations for development.

Para 4.6.1 Add at end: "embodying priority access by sustainable transportation modes consistent with Local Transport Plan policies as far as practicable where appropriate. Development will also be progressed with regard to highway development control policies to be defined in detail within the Development Control policies set of documents outlined in paragraph 3.9."

Para 4.6.3 While schools are included in the 'good range of facilities' alluded to, these settlements are only 'capable of sustaining some expansion' if the number of school places is increased. The document needs to be clear that there are insufficient surplus places to accommodate 3,900 additional homes.

Para 4.6.10 Significant additional schools capacity will be needed as set out below. In addition, Early Years and Childcare facilities will need to be provided in each case. Financial and land contributions from developers will be needed to deliver this infrastructure. The allocation of 300 more units than proposed to Hockley and 300 less to Rayleigh would provide a better fit in terms of maximising the use of current schools' capacity. Rochford/Ashingdon:- 1,000 UnitsThe capacity of Doggetts Primary can potentially be expanded to meet the needs of up to 1,000 new homes. If the sites are poorly located for this school, a new single form entry primary school would be needed (site area required 1.1 hectares). At secondary, King Edmund is already accommodating significantly more pupils than is recommended by the DfES for their site area. The school is forecast to remain oversubscribed. To expand, the school will need to obtain additional land. Land to the north and east of the school is open. The school has access difficulties with significant vehicle / pedestrian conflict and congestion at the start and end of the day. Incorporation of land to the north into the school site would allow the school to expand to serve new housing while at the same time providing improved access via Brat's Lane. The plan should allocate a minimum of 2.7 hectares of land for this purpose based on 1,000 new homes. RDC will need to consult with the School as to the precise piece of land needed. Hockley/Hawkwell: - 400 UnitsDemand for both primary and secondary places in the area is forecast to fall, which should allow this number of new dwellings to be accommodated without the need for significant additional capacity. Rayleigh: - 1,800 UnitsThis quantum of new development is likely to require an additional two forms of entry to be added to permanent capacity across the town at both primary and secondary levels. Half of this requirement at primary level can be met by expanding existing schools. The allocation of a single housing site of around 700 units would be needed to deliver a new single form entry primary school (1.1 hectares) to make up the anticipated shortfall. Limited expansion of Fitzwimarc and/or Sweyne Park can probably be achieved with careful planning/ negotiation with the schools. Smaller settlements: - 500 UnitsThe allocation of units to smaller settlements could help sustain rural primary schools within the District but would impose long term school transport costs upon the County Council that should be mitigated through developer contributions. Specific locations will require careful consideration.

Para 4.6.18 Reference to public transport should be added, as Rayleigh has excellent access by rail both towards London and Southend.

Employment

Para 4.8.8 Regional Employment Strategy should be amended to Regional Economic Strategy.

Good design & design statements

Para 4.9.9 Architects and developers should be required to design their new developments with the use of recycled and alternative materials in mind, as efforts to increase recycling will only be worthwhile if there is a local market for recycled products.

Character of place & the historic environment

Para 4.10.8 The policy bullet points should include reference to historic heritage (e.g. historic landscape and archaeology), not just identity and buildings.

Energy & water conservation & renewable energy

Section 4.12 It is considered the Core Strategy for Rochford should provide the basis of policy guidance for accommodating waste management facilities within the District in order to be consistent with the RSS and PPS10. Policies should address the following:

- Resource reduction, re-use and recycling during construction of new developments as a way of driving waste up the waste hierarchy. This should be a primary objective.

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

- Appropriate layout and design of buildings, external spaces and roads to allow for waste storage and collection and to facilitate waste separation and recycling. PPS10 contains guidance with regard to what facilities should be incorporated into non-waste related development.

- The recommendations on pages 91 - 94 of The Essex Design Guide Urban Place Supplement, which is being adopted by Rochford District Council as a Supplementary Planning Document.

4.12.11 The first bullet point relates to much wider issues than the energy conservation heading under which it appears. It should be a core policy in its own right, and include aspects such as safe routes to schools.

Compulsory purchase & planning obligations

4.13.7 Add education to list of justifications for compulsory purchase. As stated above, The King Edmund School needs to secure additional land.

Policy Content

The main comments concerning the content of the published consultation document are as follows:

1. To satisfy government guidance, the Core Strategy Preferred Options stage should have moved significantly on from the previous Issues and Options stage in terms of scope, content, and process as outlined below.

2. The evidence base should be substantially expanded and rolled forward to ultimately justify the selection of the Preferred Option. In particular, further evidence involving urban capacity, strategic housing market assessment, strategic housing land availability, town centres & retailing, employment land review, and transport studies is required. The whole evidence base should also be extended and rolled-forward well beyond 2021 so as to comply with PPS3 Housing guidance (namely that adopted DPDs should look forward at least 15 years' ahead at the date of their adoption).

3. Rochford district has significant functional economic relationships with Southend, Basildon, and other parts of Essex Thames Gateway, as well as parts of Greater London. The evolving Core Strategy should consider how these relationships might change and develop up to 2021, and what the practical implications might be for job/home alignment, commuting patterns, transport, and patterns of development provision.

4. The urban capacity study needs urgent updating before the broad direction of any Preferred Options can be confirmed. It also needs to be linked into a strategic housing market assessment and strategic housing land availability assessment in accordance with PPS3. In this way, the re-use of previously-developed land (PDL) and the consequential need for any greenfield site releases in the district can be properly clarified. At present there is inadequate information about this issue to inform discussion of Preferred Options.

5. The Preferred Options stage should also investigate the spatial planning implications of the RSS jobs figure. It should identify where the net jobs increase will come from within different economic sectors, and what the corresponding land-use implications might be for B1 employment uses, office development, retail and services, tourism, and the public sector (such as education and health). The District Council should undertake an employment land review to assess the extent to which existing employment areas will remain suitable and which new or existing locations would best support the future economic strategy of the district. This should then feed into the consideration of the future accessibility of employment sites to housing locations.

6. The Preferred Options should contain policy guidance regarding the preferred strategy for the district's town centres. This should include discussion of strategic options and choices for the amount and location of retail provision and other town centre uses. The policy approach towards out-of-centre development should also be explored and clarified.

7. The range of alternative options for the development strategy should be explained much more explicitly. This includes identifying and quantifying how much new housing should to be provided on PDL and greenfield sites, respectively; and the development provision required for employment, offices, town centre and retail uses, and other major development. Having established the broad quantum of new development required in the district, the Preferred Options stage should set out the reasonable alternatives for the location of new development in terms of its spatial pattern. This includes both the numeric distribution between individual key settlements and the broad locations for any major development. The latter would include identifying the geographical sectors on the edge of major settlements. The reasoned justification for any preferred option(s) should also be set out explicitly by drawing on the results of technical studies, SEA and sustainability appraisal, transport studies, and the results of public consultation at previous stages.

8. The practicality and desirability of designating 'buffers' in policy terms within the Metropolitan Green Belt (MGB) is unclear. The stated purposes of the MGB already include preventing the coalescence of existing settlements plan situated within the MGB, so the proposed use of 'buffers' represents a duplication of existing policy. Alternatively, if the proposed 'buffers' are to perform a different policy role this is not adequately explained. Since greenfield land releases may be required in the district up to 2021 and beyond, it is unclear whether the proposed use of 'buffers' would be incompatible with such an approach or not.

9. The approach towards the provision of new affordable housing is based upon specific local size thresholds in terms of site size. However, the proposed local thresholds are different from those set out in PPS3 Housing. The use of local thresholds departing from national guidance requires special justification, but this is not provided. It is also unclear whether the proposed affordable housing could be delivered in the absence of clear mechanisms for its delivery.

10. The Preferred Options should set out much greater consideration of the elements of a sustainable transport strategy to support the 5, 10 and 15 year visions. The County Council would be willing to assist Rochford District Council in preparing this material to support its Core Strategy DPD submission.

11. The Core Strategy will require more consideration of implementation and monitoring in accordance with government guidance. In particular, the actions necessary for delivery, any absolute dependencies on infrastructure, and the timescale should be identified. The recent White Paper (Planning for a Sustainable Future, May 2007) is proposing that detailed implementation plans should be prepared alongside Core Strategy DPD preparation.


Future Process

In view of the above comments, Rochford District Council is recommended to:

a) Commission additional technical studies to support and supplement the evidence base, and extend the base well beyond 2021;

b) Give more explicit guidance about the range of future development options in the district for different types of new development, including a more fuller reasoned justification at arriving at any preferred option(s);

c) Carry out further public consultation on (a) and (b) before proceeding to the preparation of a Core Strategy DPD for submission to the Secretary of State.


2. MORE DETAILED COMMENTS

Spatial Portrait
Para 1.9 The sentence "Within the district road infrastructure is poor" should be deleted, as there is no evidence that Rochford's roads are particularly poor.

Para 1.9 The sentence "There are no designated Heavy Lorry Routes in the District and many routes are unfit for their current level of use" should be amended to "The district's road network is under pressure from increasing private car and commercial traffic."

Spatial Vision

Para 2.6 After second sentence add, "The larger new development sites will have been designed with priority access to public transport, pedestrians and cyclists in mind".

Para 2.14 Add "The South Essex Rapid Transit (SERT) project, enhancing the use and attractiveness of public transport in the Thames Gateway area, will have entered the District."
Para 2.24 Amend "Public transport is well used and has been enhanced by the completion of the South Essex Rapid Transit (SERT), which serves most of the population of the district." to "Public Transport is well used and has been enhanced by further South Essex Rapid Transit services."

Para 2.27 The phrase "Despite travel times to and from the airport increasing " should either be explained or deleted.

Green Belt

Para 4.2.7 The expansion of King Edmund School would require extra land in the Green Belt. Therefore, it may be helpful to include community facilities in the consideration of relaxation of policy.

General development locations

Para 4.6.2 The Rochford Core Strategy should have regard to the existing Brickearth Consultation Area when identifying new locations for development.

Para 4.6.1 Add at end: "embodying priority access by sustainable transportation modes consistent with Local Transport Plan policies as far as practicable where appropriate. Development will also be progressed with regard to highway development control policies to be defined in detail within the Development Control policies set of documents outlined in paragraph 3.9."

Para 4.6.3 While schools are included in the 'good range of facilities' alluded to, these settlements are only 'capable of sustaining some expansion' if the number of school places is increased. The document needs to be clear that there are insufficient surplus places to accommodate 3,900 additional homes.

Para 4.6.10 Significant additional schools capacity will be needed as set out below. In addition, Early Years and Childcare facilities will need to be provided in each case. Financial and land contributions from developers will be needed to deliver this infrastructure. The allocation of 300 more units than proposed to Hockley and 300 less to Rayleigh would provide a better fit in terms of maximising the use of current schools' capacity. Rochford/Ashingdon:- 1,000 UnitsThe capacity of Doggetts Primary can potentially be expanded to meet the needs of up to 1,000 new homes. If the sites are poorly located for this school, a new single form entry primary school would be needed (site area required 1.1 hectares). At secondary, King Edmund is already accommodating significantly more pupils than is recommended by the DfES for their site area. The school is forecast to remain oversubscribed. To expand, the school will need to obtain additional land. Land to the north and east of the school is open. The school has access difficulties with significant vehicle / pedestrian conflict and congestion at the start and end of the day. Incorporation of land to the north into the school site would allow the school to expand to serve new housing while at the same time providing improved access via Brat's Lane. The plan should allocate a minimum of 2.7 hectares of land for this purpose based on 1,000 new homes. RDC will need to consult with the School as to the precise piece of land needed. Hockley/Hawkwell: - 400 UnitsDemand for both primary and secondary places in the area is forecast to fall, which should allow this number of new dwellings to be accommodated without the need for significant additional capacity. Rayleigh: - 1,800 UnitsThis quantum of new development is likely to require an additional two forms of entry to be added to permanent capacity across the town at both primary and secondary levels. Half of this requirement at primary level can be met by expanding existing schools. The allocation of a single housing site of around 700 units would be needed to deliver a new single form entry primary school (1.1 hectares) to make up the anticipated shortfall. Limited expansion of Fitzwimarc and/or Sweyne Park can probably be achieved with careful planning/ negotiation with the schools. Smaller settlements: - 500 UnitsThe allocation of units to smaller settlements could help sustain rural primary schools within the District but would impose long term school transport costs upon the County Council that should be mitigated through developer contributions. Specific locations will require careful consideration.

Para 4.6.18 Reference to public transport should be added, as Rayleigh has excellent access by rail both towards London and Southend.

Employment

Para 4.8.8 Regional Employment Strategy should be amended to Regional Economic Strategy.

Good design & design statements

Para 4.9.9 Architects and developers should be required to design their new developments with the use of recycled and alternative materials in mind, as efforts to increase recycling will only be worthwhile if there is a local market for recycled products.

Character of place & the historic environment

Para 4.10.8 The policy bullet points should include reference to historic heritage (e.g. historic landscape and archaeology), not just identity and buildings.

Energy & water conservation & renewable energy

Section 4.12 It is considered the Core Strategy for Rochford should provide the basis of policy guidance for accommodating waste management facilities within the District in order to be consistent with the RSS and PPS10. Policies should address the following:

- Resource reduction, re-use and recycling during construction of new developments as a way of driving waste up the waste hierarchy. This should be a primary objective.

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

- Appropriate layout and design of buildings, external spaces and roads to allow for waste storage and collection and to facilitate waste separation and recycling. PPS10 contains guidance with regard to what facilities should be incorporated into non-waste related development.

- The recommendations on pages 91 - 94 of The Essex Design Guide Urban Place Supplement, which is being adopted by Rochford District Council as a Supplementary Planning Document.

4.12.11 The first bullet point relates to much wider issues than the energy conservation heading under which it appears. It should be a core policy in its own right, and include aspects such as safe routes to schools.

Compulsory purchase & planning obligations

4.13.7 Add education to list of justifications for compulsory purchase. As stated above, The King Edmund School needs to secure additional land.

Policy Content

The main comments concerning the content of the published consultation document are as follows:

1. To satisfy government guidance, the Core Strategy Preferred Options stage should have moved significantly on from the previous Issues and Options stage in terms of scope, content, and process as outlined below.

2. The evidence base should be substantially expanded and rolled forward to ultimately justify the selection of the Preferred Option. In particular, further evidence involving urban capacity, strategic housing market assessment, strategic housing land availability, town centres & retailing, employment land review, and transport studies is required. The whole evidence base should also be extended and rolled-forward well beyond 2021 so as to comply with PPS3 Housing guidance (namely that adopted DPDs should look forward at least 15 years' ahead at the date of their adoption).

3. Rochford district has significant functional economic relationships with Southend, Basildon, and other parts of Essex Thames Gateway, as well as parts of Greater London. The evolving Core Strategy should consider how these relationships might change and develop up to 2021, and what the practical implications might be for job/home alignment, commuting patterns, transport, and patterns of development provision.

4. The urban capacity study needs urgent updating before the broad direction of any Preferred Options can be confirmed. It also needs to be linked into a strategic housing market assessment and strategic housing land availability assessment in accordance with PPS3. In this way, the re-use of previously-developed land (PDL) and the consequential need for any greenfield site releases in the district can be properly clarified. At present there is inadequate information about this issue to inform discussion of Preferred Options.

5. The Preferred Options stage should also investigate the spatial planning implications of the RSS jobs figure. It should identify where the net jobs increase will come from within different economic sectors, and what the corresponding land-use implications might be for B1 employment uses, office development, retail and services, tourism, and the public sector (such as education and health). The District Council should undertake an employment land review to assess the extent to which existing employment areas will remain suitable and which new or existing locations would best support the future economic strategy of the district. This should then feed into the consideration of the future accessibility of employment sites to housing locations.

6. The Preferred Options should contain policy guidance regarding the preferred strategy for the district's town centres. This should include discussion of strategic options and choices for the amount and location of retail provision and other town centre uses. The policy approach towards out-of-centre development should also be explored and clarified.

7. The range of alternative options for the development strategy should be explained much more explicitly. This includes identifying and quantifying how much new housing should to be provided on PDL and greenfield sites, respectively; and the development provision required for employment, offices, town centre and retail uses, and other major development. Having established the broad quantum of new development required in the district, the Preferred Options stage should set out the reasonable alternatives for the location of new development in terms of its spatial pattern. This includes both the numeric distribution between individual key settlements and the broad locations for any major development. The latter would include identifying the geographical sectors on the edge of major settlements. The reasoned justification for any preferred option(s) should also be set out explicitly by drawing on the results of technical studies, SEA and sustainability appraisal, transport studies, and the results of public consultation at previous stages.

8. The practicality and desirability of designating 'buffers' in policy terms within the Metropolitan Green Belt (MGB) is unclear. The stated purposes of the MGB already include preventing the coalescence of existing settlements plan situated within the MGB, so the proposed use of 'buffers' represents a duplication of existing policy. Alternatively, if the proposed 'buffers' are to perform a different policy role this is not adequately explained. Since greenfield land releases may be required in the district up to 2021 and beyond, it is unclear whether the proposed use of 'buffers' would be incompatible with such an approach or not.

9. The approach towards the provision of new affordable housing is based upon specific local size thresholds in terms of site size. However, the proposed local thresholds are different from those set out in PPS3 Housing. The use of local thresholds departing from national guidance requires special justification, but this is not provided. It is also unclear whether the proposed affordable housing could be delivered in the absence of clear mechanisms for its delivery.

10. The Preferred Options should set out much greater consideration of the elements of a sustainable transport strategy to support the 5, 10 and 15 year visions. The County Council would be willing to assist Rochford District Council in preparing this material to support its Core Strategy DPD submission.

11. The Core Strategy will require more consideration of implementation and monitoring in accordance with government guidance. In particular, the actions necessary for delivery, any absolute dependencies on infrastructure, and the timescale should be identified. The recent White Paper (Planning for a Sustainable Future, May 2007) is proposing that detailed implementation plans should be prepared alongside Core Strategy DPD preparation.


Future Process

In view of the above comments, Rochford District Council is recommended to:

a) Commission additional technical studies to support and supplement the evidence base, and extend the base well beyond 2021;

b) Give more explicit guidance about the range of future development options in the district for different types of new development, including a more fuller reasoned justification at arriving at any preferred option(s);

c) Carry out further public consultation on (a) and (b) before proceeding to the preparation of a Core Strategy DPD for submission to the Secretary of State.


2. MORE DETAILED COMMENTS

Spatial Portrait
Para 1.9 The sentence "Within the district road infrastructure is poor" should be deleted, as there is no evidence that Rochford's roads are particularly poor.

Para 1.9 The sentence "There are no designated Heavy Lorry Routes in the District and many routes are unfit for their current level of use" should be amended to "The district's road network is under pressure from increasing private car and commercial traffic."

Spatial Vision

Para 2.6 After second sentence add, "The larger new development sites will have been designed with priority access to public transport, pedestrians and cyclists in mind".

Para 2.14 Add "The South Essex Rapid Transit (SERT) project, enhancing the use and attractiveness of public transport in the Thames Gateway area, will have entered the District."
Para 2.24 Amend "Public transport is well used and has been enhanced by the completion of the South Essex Rapid Transit (SERT), which serves most of the population of the district." to "Public Transport is well used and has been enhanced by further South Essex Rapid Transit services."

Para 2.27 The phrase "Despite travel times to and from the airport increasing " should either be explained or deleted.

Green Belt

Para 4.2.7 The expansion of King Edmund School would require extra land in the Green Belt. Therefore, it may be helpful to include community facilities in the consideration of relaxation of policy.

General development locations

Para 4.6.2 The Rochford Core Strategy should have regard to the existing Brickearth Consultation Area when identifying new locations for development.

Para 4.6.1 Add at end: "embodying priority access by sustainable transportation modes consistent with Local Transport Plan policies as far as practicable where appropriate. Development will also be progressed with regard to highway development control policies to be defined in detail within the Development Control policies set of documents outlined in paragraph 3.9."

Para 4.6.3 While schools are included in the 'good range of facilities' alluded to, these settlements are only 'capable of sustaining some expansion' if the number of school places is increased. The document needs to be clear that there are insufficient surplus places to accommodate 3,900 additional homes.

Para 4.6.10 Significant additional schools capacity will be needed as set out below. In addition, Early Years and Childcare facilities will need to be provided in each case. Financial and land contributions from developers will be needed to deliver this infrastructure. The allocation of 300 more units than proposed to Hockley and 300 less to Rayleigh would provide a better fit in terms of maximising the use of current schools' capacity. Rochford/Ashingdon:- 1,000 UnitsThe capacity of Doggetts Primary can potentially be expanded to meet the needs of up to 1,000 new homes. If the sites are poorly located for this school, a new single form entry primary school would be needed (site area required 1.1 hectares). At secondary, King Edmund is already accommodating significantly more pupils than is recommended by the DfES for their site area. The school is forecast to remain oversubscribed. To expand, the school will need to obtain additional land. Land to the north and east of the school is open. The school has access difficulties with significant vehicle / pedestrian conflict and congestion at the start and end of the day. Incorporation of land to the north into the school site would allow the school to expand to serve new housing while at the same time providing improved access via Brat's Lane. The plan should allocate a minimum of 2.7 hectares of land for this purpose based on 1,000 new homes. RDC will need to consult with the School as to the precise piece of land needed. Hockley/Hawkwell: - 400 UnitsDemand for both primary and secondary places in the area is forecast to fall, which should allow this number of new dwellings to be accommodated without the need for significant additional capacity. Rayleigh: - 1,800 UnitsThis quantum of new development is likely to require an additional two forms of entry to be added to permanent capacity across the town at both primary and secondary levels. Half of this requirement at primary level can be met by expanding existing schools. The allocation of a single housing site of around 700 units would be needed to deliver a new single form entry primary school (1.1 hectares) to make up the anticipated shortfall. Limited expansion of Fitzwimarc and/or Sweyne Park can probably be achieved with careful planning/ negotiation with the schools. Smaller settlements: - 500 UnitsThe allocation of units to smaller settlements could help sustain rural primary schools within the District but would impose long term school transport costs upon the County Council that should be mitigated through developer contributions. Specific locations will require careful consideration.

Para 4.6.18 Reference to public transport should be added, as Rayleigh has excellent access by rail both towards London and Southend.

Employment

Para 4.8.8 Regional Employment Strategy should be amended to Regional Economic Strategy.

Good design & design statements

Para 4.9.9 Architects and developers should be required to design their new developments with the use of recycled and alternative materials in mind, as efforts to increase recycling will only be worthwhile if there is a local market for recycled products.

Character of place & the historic environment

Para 4.10.8 The policy bullet points should include reference to historic heritage (e.g. historic landscape and archaeology), not just identity and buildings.

Energy & water conservation & renewable energy

Section 4.12 It is considered the Core Strategy for Rochford should provide the basis of policy guidance for accommodating waste management facilities within the District in order to be consistent with the RSS and PPS10. Policies should address the following:

- Resource reduction, re-use and recycling during construction of new developments as a way of driving waste up the waste hierarchy. This should be a primary objective.

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

- Appropriate layout and design of buildings, external spaces and roads to allow for waste storage and collection and to facilitate waste separation and recycling. PPS10 contains guidance with regard to what facilities should be incorporated into non-waste related development.

- The recommendations on pages 91 - 94 of The Essex Design Guide Urban Place Supplement, which is being adopted by Rochford District Council as a Supplementary Planning Document.

4.12.11 The first bullet point relates to much wider issues than the energy conservation heading under which it appears. It should be a core policy in its own right, and include aspects such as safe routes to schools.

Compulsory purchase & planning obligations

4.13.7 Add education to list of justifications for compulsory purchase. As stated above, The King Edmund School needs to secure additional land.

Policy Content

The main comments concerning the content of the published consultation document are as follows:

1. To satisfy government guidance, the Core Strategy Preferred Options stage should have moved significantly on from the previous Issues and Options stage in terms of scope, content, and process as outlined below.

2. The evidence base should be substantially expanded and rolled forward to ultimately justify the selection of the Preferred Option. In particular, further evidence involving urban capacity, strategic housing market assessment, strategic housing land availability, town centres & retailing, employment land review, and transport studies is required. The whole evidence base should also be extended and rolled-forward well beyond 2021 so as to comply with PPS3 Housing guidance (namely that adopted DPDs should look forward at least 15 years' ahead at the date of their adoption).

3. Rochford district has significant functional economic relationships with Southend, Basildon, and other parts of Essex Thames Gateway, as well as parts of Greater London. The evolving Core Strategy should consider how these relationships might change and develop up to 2021, and what the practical implications might be for job/home alignment, commuting patterns, transport, and patterns of development provision.

4. The urban capacity study needs urgent updating before the broad direction of any Preferred Options can be confirmed. It also needs to be linked into a strategic housing market assessment and strategic housing land availability assessment in accordance with PPS3. In this way, the re-use of previously-developed land (PDL) and the consequential need for any greenfield site releases in the district can be properly clarified. At present there is inadequate information about this issue to inform discussion of Preferred Options.

5. The Preferred Options stage should also investigate the spatial planning implications of the RSS jobs figure. It should identify where the net jobs increase will come from within different economic sectors, and what the corresponding land-use implications might be for B1 employment uses, office development, retail and services, tourism, and the public sector (such as education and health). The District Council should undertake an employment land review to assess the extent to which existing employment areas will remain suitable and which new or existing locations would best support the future economic strategy of the district. This should then feed into the consideration of the future accessibility of employment sites to housing locations.

6. The Preferred Options should contain policy guidance regarding the preferred strategy for the district's town centres. This should include discussion of strategic options and choices for the amount and location of retail provision and other town centre uses. The policy approach towards out-of-centre development should also be explored and clarified.

7. The range of alternative options for the development strategy should be explained much more explicitly. This includes identifying and quantifying how much new housing should to be provided on PDL and greenfield sites, respectively; and the development provision required for employment, offices, town centre and retail uses, and other major development. Having established the broad quantum of new development required in the district, the Preferred Options stage should set out the reasonable alternatives for the location of new development in terms of its spatial pattern. This includes both the numeric distribution between individual key settlements and the broad locations for any major development. The latter would include identifying the geographical sectors on the edge of major settlements. The reasoned justification for any preferred option(s) should also be set out explicitly by drawing on the results of technical studies, SEA and sustainability appraisal, transport studies, and the results of public consultation at previous stages.

8. The practicality and desirability of designating 'buffers' in policy terms within the Metropolitan Green Belt (MGB) is unclear. The stated purposes of the MGB already include preventing the coalescence of existing settlements plan situated within the MGB, so the proposed use of 'buffers' represents a duplication of existing policy. Alternatively, if the proposed 'buffers' are to perform a different policy role this is not adequately explained. Since greenfield land releases may be required in the district up to 2021 and beyond, it is unclear whether the proposed use of 'buffers' would be incompatible with such an approach or not.

9. The approach towards the provision of new affordable housing is based upon specific local size thresholds in terms of site size. However, the proposed local thresholds are different from those set out in PPS3 Housing. The use of local thresholds departing from national guidance requires special justification, but this is not provided. It is also unclear whether the proposed affordable housing could be delivered in the absence of clear mechanisms for its delivery.

10. The Preferred Options should set out much greater consideration of the elements of a sustainable transport strategy to support the 5, 10 and 15 year visions. The County Council would be willing to assist Rochford District Council in preparing this material to support its Core Strategy DPD submission.

11. The Core Strategy will require more consideration of implementation and monitoring in accordance with government guidance. In particular, the actions necessary for delivery, any absolute dependencies on infrastructure, and the timescale should be identified. The recent White Paper (Planning for a Sustainable Future, May 2007) is proposing that detailed implementation plans should be prepared alongside Core Strategy DPD preparation.


Future Process

In view of the above comments, Rochford District Council is recommended to:

a) Commission additional technical studies to support and supplement the evidence base, and extend the base well beyond 2021;

b) Give more explicit guidance about the range of future development options in the district for different types of new development, including a more fuller reasoned justification at arriving at any preferred option(s);

c) Carry out further public consultation on (a) and (b) before proceeding to the preparation of a Core Strategy DPD for submission to the Secretary of State.


2. MORE DETAILED COMMENTS

Spatial Portrait
Para 1.9 The sentence "Within the district road infrastructure is poor" should be deleted, as there is no evidence that Rochford's roads are particularly poor.

Para 1.9 The sentence "There are no designated Heavy Lorry Routes in the District and many routes are unfit for their current level of use" should be amended to "The district's road network is under pressure from increasing private car and commercial traffic."

Spatial Vision

Para 2.6 After second sentence add, "The larger new development sites will have been designed with priority access to public transport, pedestrians and cyclists in mind".

Para 2.14 Add "The South Essex Rapid Transit (SERT) project, enhancing the use and attractiveness of public transport in the Thames Gateway area, will have entered the District."
Para 2.24 Amend "Public transport is well used and has been enhanced by the completion of the South Essex Rapid Transit (SERT), which serves most of the population of the district." to "Public Transport is well used and has been enhanced by further South Essex Rapid Transit services."

Para 2.27 The phrase "Despite travel times to and from the airport increasing " should either be explained or deleted.

Green Belt

Para 4.2.7 The expansion of King Edmund School would require extra land in the Green Belt. Therefore, it may be helpful to include community facilities in the consideration of relaxation of policy.

General development locations

Para 4.6.2 The Rochford Core Strategy should have regard to the existing Brickearth Consultation Area when identifying new locations for development.

Para 4.6.1 Add at end: "embodying priority access by sustainable transportation modes consistent with Local Transport Plan policies as far as practicable where appropriate. Development will also be progressed with regard to highway development control policies to be defined in detail within the Development Control policies set of documents outlined in paragraph 3.9."

Para 4.6.3 While schools are included in the 'good range of facilities' alluded to, these settlements are only 'capable of sustaining some expansion' if the number of school places is increased. The document needs to be clear that there are insufficient surplus places to accommodate 3,900 additional homes.

Para 4.6.10 Significant additional schools capacity will be needed as set out below. In addition, Early Years and Childcare facilities will need to be provided in each case. Financial and land contributions from developers will be needed to deliver this infrastructure. The allocation of 300 more units than proposed to Hockley and 300 less to Rayleigh would provide a better fit in terms of maximising the use of current schools' capacity. Rochford/Ashingdon:- 1,000 UnitsThe capacity of Doggetts Primary can potentially be expanded to meet the needs of up to 1,000 new homes. If the sites are poorly located for this school, a new single form entry primary school would be needed (site area required 1.1 hectares). At secondary, King Edmund is already accommodating significantly more pupils than is recommended by the DfES for their site area. The school is forecast to remain oversubscribed. To expand, the school will need to obtain additional land. Land to the north and east of the school is open. The school has access difficulties with significant vehicle / pedestrian conflict and congestion at the start and end of the day. Incorporation of land to the north into the school site would allow the school to expand to serve new housing while at the same time providing improved access via Brat's Lane. The plan should allocate a minimum of 2.7 hectares of land for this purpose based on 1,000 new homes. RDC will need to consult with the School as to the precise piece of land needed. Hockley/Hawkwell: - 400 UnitsDemand for both primary and secondary places in the area is forecast to fall, which should allow this number of new dwellings to be accommodated without the need for significant additional capacity. Rayleigh: - 1,800 UnitsThis quantum of new development is likely to require an additional two forms of entry to be added to permanent capacity across the town at both primary and secondary levels. Half of this requirement at primary level can be met by expanding existing schools. The allocation of a single housing site of around 700 units would be needed to deliver a new single form entry primary school (1.1 hectares) to make up the anticipated shortfall. Limited expansion of Fitzwimarc and/or Sweyne Park can probably be achieved with careful planning/ negotiation with the schools. Smaller settlements: - 500 UnitsThe allocation of units to smaller settlements could help sustain rural primary schools within the District but would impose long term school transport costs upon the County Council that should be mitigated through developer contributions. Specific locations will require careful consideration.

Para 4.6.18 Reference to public transport should be added, as Rayleigh has excellent access by rail both towards London and Southend.

Employment

Para 4.8.8 Regional Employment Strategy should be amended to Regional Economic Strategy.

Good design & design statements

Para 4.9.9 Architects and developers should be required to design their new developments with the use of recycled and alternative materials in mind, as efforts to increase recycling will only be worthwhile if there is a local market for recycled products.

Character of place & the historic environment

Para 4.10.8 The policy bullet points should include reference to historic heritage (e.g. historic landscape and archaeology), not just identity and buildings.

Energy & water conservation & renewable energy

Section 4.12 It is considered the Core Strategy for Rochford should provide the basis of policy guidance for accommodating waste management facilities within the District in order to be consistent with the RSS and PPS10. Policies should address the following:

- Resource reduction, re-use and recycling during construction of new developments as a way of driving waste up the waste hierarchy. This should be a primary objective.

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

- Appropriate layout and design of buildings, external spaces and roads to allow for waste storage and collection and to facilitate waste separation and recycling. PPS10 contains guidance with regard to what facilities should be incorporated into non-waste related development.

- The recommendations on pages 91 - 94 of The Essex Design Guide Urban Place Supplement, which is being adopted by Rochford District Council as a Supplementary Planning Document.

4.12.11 The first bullet point relates to much wider issues than the energy conservation heading under which it appears. It should be a core policy in its own right, and include aspects such as safe routes to schools.

Compulsory purchase & planning obligations

4.13.7 Add education to list of justifications for compulsory purchase. As stated above, The King Edmund School needs to secure additional land.

Policy Content

The main comments concerning the content of the published consultation document are as follows:

1. To satisfy government guidance, the Core Strategy Preferred Options stage should have moved significantly on from the previous Issues and Options stage in terms of scope, content, and process as outlined below.

2. The evidence base should be substantially expanded and rolled forward to ultimately justify the selection of the Preferred Option. In particular, further evidence involving urban capacity, strategic housing market assessment, strategic housing land availability, town centres & retailing, employment land review, and transport studies is required. The whole evidence base should also be extended and rolled-forward well beyond 2021 so as to comply with PPS3 Housing guidance (namely that adopted DPDs should look forward at least 15 years' ahead at the date of their adoption).

3. Rochford district has significant functional economic relationships with Southend, Basildon, and other parts of Essex Thames Gateway, as well as parts of Greater London. The evolving Core Strategy should consider how these relationships might change and develop up to 2021, and what the practical implications might be for job/home alignment, commuting patterns, transport, and patterns of development provision.

4. The urban capacity study needs urgent updating before the broad direction of any Preferred Options can be confirmed. It also needs to be linked into a strategic housing market assessment and strategic housing land availability assessment in accordance with PPS3. In this way, the re-use of previously-developed land (PDL) and the consequential need for any greenfield site releases in the district can be properly clarified. At present there is inadequate information about this issue to inform discussion of Preferred Options.

5. The Preferred Options stage should also investigate the spatial planning implications of the RSS jobs figure. It should identify where the net jobs increase will come from within different economic sectors, and what the corresponding land-use implications might be for B1 employment uses, office development, retail and services, tourism, and the public sector (such as education and health). The District Council should undertake an employment land review to assess the extent to which existing employment areas will remain suitable and which new or existing locations would best support the future economic strategy of the district. This should then feed into the consideration of the future accessibility of employment sites to housing locations.

6. The Preferred Options should contain policy guidance regarding the preferred strategy for the district's town centres. This should include discussion of strategic options and choices for the amount and location of retail provision and other town centre uses. The policy approach towards out-of-centre development should also be explored and clarified.

7. The range of alternative options for the development strategy should be explained much more explicitly. This includes identifying and quantifying how much new housing should to be provided on PDL and greenfield sites, respectively; and the development provision required for employment, offices, town centre and retail uses, and other major development. Having established the broad quantum of new development required in the district, the Preferred Options stage should set out the reasonable alternatives for the location of new development in terms of its spatial pattern. This includes both the numeric distribution between individual key settlements and the broad locations for any major development. The latter would include identifying the geographical sectors on the edge of major settlements. The reasoned justification for any preferred option(s) should also be set out explicitly by drawing on the results of technical studies, SEA and sustainability appraisal, transport studies, and the results of public consultation at previous stages.

8. The practicality and desirability of designating 'buffers' in policy terms within the Metropolitan Green Belt (MGB) is unclear. The stated purposes of the MGB already include preventing the coalescence of existing settlements plan situated within the MGB, so the proposed use of 'buffers' represents a duplication of existing policy. Alternatively, if the proposed 'buffers' are to perform a different policy role this is not adequately explained. Since greenfield land releases may be required in the district up to 2021 and beyond, it is unclear whether the proposed use of 'buffers' would be incompatible with such an approach or not.

9. The approach towards the provision of new affordable housing is based upon specific local size thresholds in terms of site size. However, the proposed local thresholds are different from those set out in PPS3 Housing. The use of local thresholds departing from national guidance requires special justification, but this is not provided. It is also unclear whether the proposed affordable housing could be delivered in the absence of clear mechanisms for its delivery.

10. The Preferred Options should set out much greater consideration of the elements of a sustainable transport strategy to support the 5, 10 and 15 year visions. The County Council would be willing to assist Rochford District Council in preparing this material to support its Core Strategy DPD submission.

11. The Core Strategy will require more consideration of implementation and monitoring in accordance with government guidance. In particular, the actions necessary for delivery, any absolute dependencies on infrastructure, and the timescale should be identified. The recent White Paper (Planning for a Sustainable Future, May 2007) is proposing that detailed implementation plans should be prepared alongside Core Strategy DPD preparation.


Future Process

In view of the above comments, Rochford District Council is recommended to:

a) Commission additional technical studies to support and supplement the evidence base, and extend the base well beyond 2021;

b) Give more explicit guidance about the range of future development options in the district for different types of new development, including a more fuller reasoned justification at arriving at any preferred option(s);

c) Carry out further public consultation on (a) and (b) before proceeding to the preparation of a Core Strategy DPD for submission to the Secretary of State.


2. MORE DETAILED COMMENTS

Spatial Portrait
Para 1.9 The sentence "Within the district road infrastructure is poor" should be deleted, as there is no evidence that Rochford's roads are particularly poor.

Para 1.9 The sentence "There are no designated Heavy Lorry Routes in the District and many routes are unfit for their current level of use" should be amended to "The district's road network is under pressure from increasing private car and commercial traffic."

Spatial Vision

Para 2.6 After second sentence add, "The larger new development sites will have been designed with priority access to public transport, pedestrians and cyclists in mind".

Para 2.14 Add "The South Essex Rapid Transit (SERT) project, enhancing the use and attractiveness of public transport in the Thames Gateway area, will have entered the District."
Para 2.24 Amend "Public transport is well used and has been enhanced by the completion of the South Essex Rapid Transit (SERT), which serves most of the population of the district." to "Public Transport is well used and has been enhanced by further South Essex Rapid Transit services."

Para 2.27 The phrase "Despite travel times to and from the airport increasing " should either be explained or deleted.

Green Belt

Para 4.2.7 The expansion of King Edmund School would require extra land in the Green Belt. Therefore, it may be helpful to include community facilities in the consideration of relaxation of policy.

General development locations

Para 4.6.2 The Rochford Core Strategy should have regard to the existing Brickearth Consultation Area when identifying new locations for development.

Para 4.6.1 Add at end: "embodying priority access by sustainable transportation modes consistent with Local Transport Plan policies as far as practicable where appropriate. Development will also be progressed with regard to highway development control policies to be defined in detail within the Development Control policies set of documents outlined in paragraph 3.9."

Para 4.6.3 While schools are included in the 'good range of facilities' alluded to, these settlements are only 'capable of sustaining some expansion' if the number of school places is increased. The document needs to be clear that there are insufficient surplus places to accommodate 3,900 additional homes.

Para 4.6.10 Significant additional schools capacity will be needed as set out below. In addition, Early Years and Childcare facilities will need to be provided in each case. Financial and land contributions from developers will be needed to deliver this infrastructure. The allocation of 300 more units than proposed to Hockley and 300 less to Rayleigh would provide a better fit in terms of maximising the use of current schools' capacity. Rochford/Ashingdon:- 1,000 UnitsThe capacity of Doggetts Primary can potentially be expanded to meet the needs of up to 1,000 new homes. If the sites are poorly located for this school, a new single form entry primary school would be needed (site area required 1.1 hectares). At secondary, King Edmund is already accommodating significantly more pupils than is recommended by the DfES for their site area. The school is forecast to remain oversubscribed. To expand, the school will need to obtain additional land. Land to the north and east of the school is open. The school has access difficulties with significant vehicle / pedestrian conflict and congestion at the start and end of the day. Incorporation of land to the north into the school site would allow the school to expand to serve new housing while at the same time providing improved access via Brat's Lane. The plan should allocate a minimum of 2.7 hectares of land for this purpose based on 1,000 new homes. RDC will need to consult with the School as to the precise piece of land needed. Hockley/Hawkwell: - 400 UnitsDemand for both primary and secondary places in the area is forecast to fall, which should allow this number of new dwellings to be accommodated without the need for significant additional capacity. Rayleigh: - 1,800 UnitsThis quantum of new development is likely to require an additional two forms of entry to be added to permanent capacity across the town at both primary and secondary levels. Half of this requirement at primary level can be met by expanding existing schools. The allocation of a single housing site of around 700 units would be needed to deliver a new single form entry primary school (1.1 hectares) to make up the anticipated shortfall. Limited expansion of Fitzwimarc and/or Sweyne Park can probably be achieved with careful planning/ negotiation with the schools. Smaller settlements: - 500 UnitsThe allocation of units to smaller settlements could help sustain rural primary schools within the District but would impose long term school transport costs upon the County Council that should be mitigated through developer contributions. Specific locations will require careful consideration.

Para 4.6.18 Reference to public transport should be added, as Rayleigh has excellent access by rail both towards London and Southend.

Employment

Para 4.8.8 Regional Employment Strategy should be amended to Regional Economic Strategy.

Good design & design statements

Para 4.9.9 Architects and developers should be required to design their new developments with the use of recycled and alternative materials in mind, as efforts to increase recycling will only be worthwhile if there is a local market for recycled products.

Character of place & the historic environment

Para 4.10.8 The policy bullet points should include reference to historic heritage (e.g. historic landscape and archaeology), not just identity and buildings.

Energy & water conservation & renewable energy

Section 4.12 It is considered the Core Strategy for Rochford should provide the basis of policy guidance for accommodating waste management facilities within the District in order to be consistent with the RSS and PPS10. Policies should address the following:

- Resource reduction, re-use and recycling during construction of new developments as a way of driving waste up the waste hierarchy. This should be a primary objective.

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

- Appropriate layout and design of buildings, external spaces and roads to allow for waste storage and collection and to facilitate waste separation and recycling. PPS10 contains guidance with regard to what facilities should be incorporated into non-waste related development.

- The recommendations on pages 91 - 94 of The Essex Design Guide Urban Place Supplement, which is being adopted by Rochford District Council as a Supplementary Planning Document.

4.12.11 The first bullet point relates to much wider issues than the energy conservation heading under which it appears. It should be a core policy in its own right, and include aspects such as safe routes to schools.

Compulsory purchase & planning obligations

4.13.7 Add education to list of justifications for compulsory purchase. As stated above, The King Edmund School needs to secure additional land.

Policy Content

The main comments concerning the content of the published consultation document are as follows:

1. To satisfy government guidance, the Core Strategy Preferred Options stage should have moved significantly on from the previous Issues and Options stage in terms of scope, content, and process as outlined below.

2. The evidence base should be substantially expanded and rolled forward to ultimately justify the selection of the Preferred Option. In particular, further evidence involving urban capacity, strategic housing market assessment, strategic housing land availability, town centres & retailing, employment land review, and transport studies is required. The whole evidence base should also be extended and rolled-forward well beyond 2021 so as to comply with PPS3 Housing guidance (namely that adopted DPDs should look forward at least 15 years' ahead at the date of their adoption).

3. Rochford district has significant functional economic relationships with Southend, Basildon, and other parts of Essex Thames Gateway, as well as parts of Greater London. The evolving Core Strategy should consider how these relationships might change and develop up to 2021, and what the practical implications might be for job/home alignment, commuting patterns, transport, and patterns of development provision.

4. The urban capacity study needs urgent updating before the broad direction of any Preferred Options can be confirmed. It also needs to be linked into a strategic housing market assessment and strategic housing land availability assessment in accordance with PPS3. In this way, the re-use of previously-developed land (PDL) and the consequential need for any greenfield site releases in the district can be properly clarified. At present there is inadequate information about this issue to inform discussion of Preferred Options.

5. The Preferred Options stage should also investigate the spatial planning implications of the RSS jobs figure. It should identify where the net jobs increase will come from within different economic sectors, and what the corresponding land-use implications might be for B1 employment uses, office development, retail and services, tourism, and the public sector (such as education and health). The District Council should undertake an employment land review to assess the extent to which existing employment areas will remain suitable and which new or existing locations would best support the future economic strategy of the district. This should then feed into the consideration of the future accessibility of employment sites to housing locations.

6. The Preferred Options should contain policy guidance regarding the preferred strategy for the district's town centres. This should include discussion of strategic options and choices for the amount and location of retail provision and other town centre uses. The policy approach towards out-of-centre development should also be explored and clarified.

7. The range of alternative options for the development strategy should be explained much more explicitly. This includes identifying and quantifying how much new housing should to be provided on PDL and greenfield sites, respectively; and the development provision required for employment, offices, town centre and retail uses, and other major development. Having established the broad quantum of new development required in the district, the Preferred Options stage should set out the reasonable alternatives for the location of new development in terms of its spatial pattern. This includes both the numeric distribution between individual key settlements and the broad locations for any major development. The latter would include identifying the geographical sectors on the edge of major settlements. The reasoned justification for any preferred option(s) should also be set out explicitly by drawing on the results of technical studies, SEA and sustainability appraisal, transport studies, and the results of public consultation at previous stages.

8. The practicality and desirability of designating 'buffers' in policy terms within the Metropolitan Green Belt (MGB) is unclear. The stated purposes of the MGB already include preventing the coalescence of existing settlements plan situated within the MGB, so the proposed use of 'buffers' represents a duplication of existing policy. Alternatively, if the proposed 'buffers' are to perform a different policy role this is not adequately explained. Since greenfield land releases may be required in the district up to 2021 and beyond, it is unclear whether the proposed use of 'buffers' would be incompatible with such an approach or not.

9. The approach towards the provision of new affordable housing is based upon specific local size thresholds in terms of site size. However, the proposed local thresholds are different from those set out in PPS3 Housing. The use of local thresholds departing from national guidance requires special justification, but this is not provided. It is also unclear whether the proposed affordable housing could be delivered in the absence of clear mechanisms for its delivery.

10. The Preferred Options should set out much greater consideration of the elements of a sustainable transport strategy to support the 5, 10 and 15 year visions. The County Council would be willing to assist Rochford District Council in preparing this material to support its Core Strategy DPD submission.

11. The Core Strategy will require more consideration of implementation and monitoring in accordance with government guidance. In particular, the actions necessary for delivery, any absolute dependencies on infrastructure, and the timescale should be identified. The recent White Paper (Planning for a Sustainable Future, May 2007) is proposing that detailed implementation plans should be prepared alongside Core Strategy DPD preparation.


Future Process

In view of the above comments, Rochford District Council is recommended to:

a) Commission additional technical studies to support and supplement the evidence base, and extend the base well beyond 2021;

b) Give more explicit guidance about the range of future development options in the district for different types of new development, including a more fuller reasoned justification at arriving at any preferred option(s);

c) Carry out further public consultation on (a) and (b) before proceeding to the preparation of a Core Strategy DPD for submission to the Secretary of State.


2. MORE DETAILED COMMENTS

Spatial Portrait
Para 1.9 The sentence "Within the district road infrastructure is poor" should be deleted, as there is no evidence that Rochford's roads are particularly poor.

Para 1.9 The sentence "There are no designated Heavy Lorry Routes in the District and many routes are unfit for their current level of use" should be amended to "The district's road network is under pressure from increasing private car and commercial traffic."

Spatial Vision

Para 2.6 After second sentence add, "The larger new development sites will have been designed with priority access to public transport, pedestrians and cyclists in mind".

Para 2.14 Add "The South Essex Rapid Transit (SERT) project, enhancing the use and attractiveness of public transport in the Thames Gateway area, will have entered the District."
Para 2.24 Amend "Public transport is well used and has been enhanced by the completion of the South Essex Rapid Transit (SERT), which serves most of the population of the district." to "Public Transport is well used and has been enhanced by further South Essex Rapid Transit services."

Para 2.27 The phrase "Despite travel times to and from the airport increasing " should either be explained or deleted.

Green Belt

Para 4.2.7 The expansion of King Edmund School would require extra land in the Green Belt. Therefore, it may be helpful to include community facilities in the consideration of relaxation of policy.

General development locations

Para 4.6.2 The Rochford Core Strategy should have regard to the existing Brickearth Consultation Area when identifying new locations for development.

Para 4.6.1 Add at end: "embodying priority access by sustainable transportation modes consistent with Local Transport Plan policies as far as practicable where appropriate. Development will also be progressed with regard to highway development control policies to be defined in detail within the Development Control policies set of documents outlined in paragraph 3.9."

Para 4.6.3 While schools are included in the 'good range of facilities' alluded to, these settlements are only 'capable of sustaining some expansion' if the number of school places is increased. The document needs to be clear that there are insufficient surplus places to accommodate 3,900 additional homes.

Para 4.6.10 Significant additional schools capacity will be needed as set out below. In addition, Early Years and Childcare facilities will need to be provided in each case. Financial and land contributions from developers will be needed to deliver this infrastructure. The allocation of 300 more units than proposed to Hockley and 300 less to Rayleigh would provide a better fit in terms of maximising the use of current schools' capacity. Rochford/Ashingdon:- 1,000 UnitsThe capacity of Doggetts Primary can potentially be expanded to meet the needs of up to 1,000 new homes. If the sites are poorly located for this school, a new single form entry primary school would be needed (site area required 1.1 hectares). At secondary, King Edmund is already accommodating significantly more pupils than is recommended by the DfES for their site area. The school is forecast to remain oversubscribed. To expand, the school will need to obtain additional land. Land to the north and east of the school is open. The school has access difficulties with significant vehicle / pedestrian conflict and congestion at the start and end of the day. Incorporation of land to the north into the school site would allow the school to expand to serve new housing while at the same time providing improved access via Brat's Lane. The plan should allocate a minimum of 2.7 hectares of land for this purpose based on 1,000 new homes. RDC will need to consult with the School as to the precise piece of land needed. Hockley/Hawkwell: - 400 UnitsDemand for both primary and secondary places in the area is forecast to fall, which should allow this number of new dwellings to be accommodated without the need for significant additional capacity. Rayleigh: - 1,800 UnitsThis quantum of new development is likely to require an additional two forms of entry to be added to permanent capacity across the town at both primary and secondary levels. Half of this requirement at primary level can be met by expanding existing schools. The allocation of a single housing site of around 700 units would be needed to deliver a new single form entry primary school (1.1 hectares) to make up the anticipated shortfall. Limited expansion of Fitzwimarc and/or Sweyne Park can probably be achieved with careful planning/ negotiation with the schools. Smaller settlements: - 500 UnitsThe allocation of units to smaller settlements could help sustain rural primary schools within the District but would impose long term school transport costs upon the County Council that should be mitigated through developer contributions. Specific locations will require careful consideration.

Para 4.6.18 Reference to public transport should be added, as Rayleigh has excellent access by rail both towards London and Southend.

Employment

Para 4.8.8 Regional Employment Strategy should be amended to Regional Economic Strategy.

Good design & design statements

Para 4.9.9 Architects and developers should be required to design their new developments with the use of recycled and alternative materials in mind, as efforts to increase recycling will only be worthwhile if there is a local market for recycled products.

Character of place & the historic environment

Para 4.10.8 The policy bullet points should include reference to historic heritage (e.g. historic landscape and archaeology), not just identity and buildings.

Energy & water conservation & renewable energy

Section 4.12 It is considered the Core Strategy for Rochford should provide the basis of policy guidance for accommodating waste management facilities within the District in order to be consistent with the RSS and PPS10. Policies should address the following:

- Resource reduction, re-use and recycling during construction of new developments as a way of driving waste up the waste hierarchy. This should be a primary objective.

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

- Appropriate layout and design of buildings, external spaces and roads to allow for waste storage and collection and to facilitate waste separation and recycling. PPS10 contains guidance with regard to what facilities should be incorporated into non-waste related development.

- The recommendations on pages 91 - 94 of The Essex Design Guide Urban Place Supplement, which is being adopted by Rochford District Council as a Supplementary Planning Document.

4.12.11 The first bullet point relates to much wider issues than the energy conservation heading under which it appears. It should be a core policy in its own right, and include aspects such as safe routes to schools.

Compulsory purchase & planning obligations

4.13.7 Add education to list of justifications for compulsory purchase. As stated above, The King Edmund School needs to secure additional land.