Rochford District Core Strategy Regulation 26 Draft

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.