Rochford District Core Strategy Regulation 26 Draft

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.