Core Strategy Preferred Options (Revised October 2008)

INTRODUCTION

We act on behalf of Crowstone Properties Ltd and are instructed to submit Representations on their behalf as part of the Consultation on the emerging Core Strategy.

Whilst we fully appreciate that the current stage is principally concerned with strategic and district-wide issues rather than site-specific aspects, we note that Policy H2 General Locations and Phasing Preferred Option contains a schedule of areas which are indicated on the Key Diagram. We also note that two of the areas, namely West Hockley and West Great Wakering, have capacities of only 50 units. Our clients Representations submitted at an earlier consultation stage on the Core Strategy Preferred Options, (ie July 2007) included a Land Bid relating to developable land on the western side of Ashingdon which extends to approximately 2.5 hectares and would therefore provide an estimated minimum capacity in excess of 50 units. It is therefore of sufficient size to be regarded as "strategic" in terms of the Core Strategy and Policy H2.

Our Representations are in three parts:-

Part A: General Representations
Part B: Strategic Site Representations
Part C: Schedule of Amendments

At various points, however, we will cross-reference to our proposed strategic site, a plan of which can be found at the end of Part B. As noted, the area edged red extends to 2.5 hectares of which 0.5 hectares would be used to provide peripheral landscaping, and if required, a car park to serve the open space to the west and south. Immediately to the north, edged in blue, a woodland area extending to approximately 1.5 hectares would be dedicated for public open space. The strategic 4.0 hectare site would therefore constitute a mixed use comprising housing, a public car park and public open space and amenity land.

It would be of great assistance if future documents have their various sections numbered and each paragraph given a discreet paragraph number. The absence of any form of numbering system poses difficulty in identifying particular quotes from the document which makes the task of the reader and writer more laborious.

PART A: GENERAL REPRESENTATIONS

Listening to your views:

We found the summary of public opinion set out in "Listening To Your Views" to be both interesting and valuable as a basis for formulating the Core Strategy.

Clearly, one of the key points of public concern relates to the question of whether some Green Belt land should be used for future development. Much depends on how the question is put; if one asks: should Green Belt land be developed? - it is to be expected that most people's first reaction is that it should not. It is widely recognised and appreciated that undeveloped land in Rochford District performs many functions - it provides the setting for the settlements, gaps which prevent the coalescence of settlements, areas for informal and formal recreation, and pleasant countryside. Any encroachment of the Green Belt must be at a cost and should be avoided if humanly possible. If, however, the question is put another way, namely - should we safeguard the Green Belt rather than make provision for the various types of housing to meet the needs of our existing and future residents? - then a different response might be forthcoming. The prospect of housing shortages, with house shortages, with house prices driven up by scarcity value, and younger sections of the population finding it even more difficult to reach the first rung on the housing ladder, might be sufficiently unattractive a proposition to lead people to support a justified and carefully controlled release of parts of the Green Belt. We therefore welcome the fact that after many years of assiduous protection of Green Belt land, the Council has "grasped the nettle" and has clearly identified sound reasons why it is a Preferred Option to identify some Green Belt land for development.

Characteristics, Issue and Opportunities

We also found the section headed "Characteristics, Issues and Opportunities" to be a useful summary which painted an accurate picture of the current character and contemporary issues in Rochford District.

Economy

We do not consider the document sufficiently recognises the need to adopt a strategy which seeks to make the District more self-contained and hence more sustainable. We note the paragraph which states "A high proportion of the Rochford workforce commutes out of the District. 30% travel to work in Southend, 14% to London, 9% to Basildon and about 15% travel elsewhere outside the District." In other words, 68% of the working population commute out of the District and only 32% work within the District. Even allowing for the high proportion that commute the relatively short distance to Southend, this represents a very heavy reliance on employment beyond the District's boundaries. The District is therefore highly unsustainable in this particular respect.

We note the references to Thames Gateway South Essex and to initiatives at Southend Airport, but consider that such employment growth will needs to be supplemented by a myriad of smaller and localized initiatives which are more likely to reduce the lengths of journey to work. At the same time, if well located, small business parks and enterprise areas would help counterbalance the lack of local employment which makes the District so heavily reliant on other areas. It would also reinforce the District's track record for thriving small businesses.

Settlements

We broadly support the four tiers of settlement with the first tier comprising Rayleigh, Rochford and Hockley as set out on page 20. We note, however, in "General Locations" on page 26, the first tier settlements are listed as Rayleigh; Rochford/Ashingdon; Hockley/Hawkwell. We have no difficulty with this but consider there should be consistency as to how settlements are addressed. For the avoidance of doubt, we prefer the approach adopted on page 26.

Vision

Again we register our support for the overarching vision and the key planning objectives. Without detracting from the high ideals expressed here, we would perhaps hope to see a much fuller explanation of how the vision is to be realised. Some reference to the types of measures or policy and proposals that will be introduced to implement the key planning objectives might be appropriate at this stage.

Housing

We consider the remaining balance of 2,489 units for the period 2001-2021 together with the further 1,000 units for the period 2021-2025 represents a substantial commitment requiring careful decisions in relation to its future distribution. We fully acknowledge the concern that can arise from town cramming and the difficulty posed by the rapidly dwindling supply of other brownfield land. We consider the Council can be justifiably proud of its record in directing a high proportion of recent growth to brownfield sites. However, this is a finite resource and it was inevitable that at some point it would be necessary to increase the Greenfield contribution. In the Council's view, that point has now been reached, and we agree with that. We note that the 30% of development that will still be targeted to brownfield sites is only half that advised in the East of England Plan, but that this lower level is probably realistic and hence deliverable. In any event, it is also important not to rely on regular reviews of the Green Belt boundary and this points to the need for long term land reserves needed for development being taken out of the Green Belt as part of the Core Strategy.

In moving towards the Preferred Distribution, we note the following on page 26.

"The preferred distribution is based not simply on which areas are the most sustainable at present, but also on how residential development can contribute to, and marry with, other strategies - particularly in relation to town centre vitality, environmental issues and employment - to ensure long term sustainable development within the District."

We believe that is exactly the right approach but at this stage we have not seen the evidence to support this important claim. Indeed, the Preferred Options move rapidly into the topic of "Housing" without any clear demonstration of a comprehensive and holistic approach in terms of the distribution of the wider development needs of the District. In other words, we would expect to see a coherent strategy which closely and geographically associates housing needs, employment and community facilities based on sound sustainability principles. We do not believe that general locations for new housing, for example, can be selected in isolation but that such decisions must reflect a pre-agreed framework of sustainability principles taking account of existing and all forms of new development requirements.

In turning to H2 General Locations and Phasing - Preferred Option, it is unclear what process of selection was undertaken to alight on this particular choice of area. No doubt each of the areas identified have their own particular merits and advantages, and some may be highly sustainable and other less so. It is difficult to pass judgement without any pre-stated basis for the inclusion of these particular areas. By the same token, the reasoning behind the split before and after 2015 is equally unclear. We do not oppose the principle of staging development - indeed we support it if this assists in ensuring land allocations are more evenly spread and hence available throughout the plan period. Again, however, we expect to see the reasoning for this split and this does not seem to be apparent. We raise these points because they are fundamental and there needs to be a clearly understood basis for the choice of general locations and for phasing. We have given careful consideration to the general locations set out in H2 and the alternative options set out giving reasons why these further locations were not preferred. Having regard to the earlier representations submitted on behalf of Crowstone Development Ltd relating to an area on the western side of Ashingdon, we can find no reference to this as a possible option.

Turning to H3 General Location Post-2021 Preferred Option, we consider there is a similar duty to justify the general locations and capacity for the areas identified. Whilst we note that: "The detailed location and development will be articulated within the Allocations Development Plan document and, where appropriate, Area Action Plans," this in no way reduces the need to ensure that the location itself is sustainable and can be justified as a Preferred Option. The information and analysis to support the general locations both pre and post 2015 and post 2021 is lacking and we consider this must go to the soundness of the Plan.

Affordable Housing

We take the view that much greater emphasis must be given in future to the delivery of affordable units, especially having regard to the high house values which preclude so many entering the housing market. We recognise that Exceptions Policies are necessary but deliver very little in terms of numbers. We also recognise that it is the larger sites that have the viability which enables a significant proportion of affordable units to be provided or cross-subsidised by free market housing. A judgement is needed as to the level of affordable provision that should be required from new sites. On balance we consider the suggestion that at least 35% of dwellings on all developments of 15 or more units, or on sites greater than 0.5 ha, should be affordable - gets the balance about right. We therefore support the wording of H4 Affordable Housing - Preferred Option in this respect and favour this to the Alternative Options in H4.

With regard, however, to the requirement to spread (pepper-pot) affordable dwellings throughout larger developments, we express certain concerns. We agree that large blocs of affordable housing should be avoided if possible but pepper-potting can give rise to design and management problems. As usual, these matters can normally be overcome through compromise having regard to the circumstances relating to each particular site. We would therefore prefer to see a more general reference to the need to avoid large blocs of affordable housing and the need to integrate affordable and free market housing in a harmonious way.

The Green Belt

As indicated above, we support the conclusion that the time has now come when the current boundaries of the Green Belt need to be reviewed to enable development required to be provided in Rochford District by the East of England Plan can be met in an environmentally acceptable way. Given the long-term nature of the plan period, the opportunity arises to adjust the Green Belt boundaries to facilitate growth over a long period and this should avoid the need for repetitive short term reviews which could undermine the confidence in the Green Belt. We note the wording of GB1 Green Belt Protection - Preferred Option and in particular the commitment to prioritise the protection of Green Belt land based on how well the land helps achieve the purposes of the Green Belt. Whilst this seems entirely clear and logical, we would expect this exercise to be conducted to inform the general locations identified in H2 and H3. Further uncertainty arises from the reference to "strategic buffers that are particularly worthy of mention" which appear not to be mentioned or featured on the Key Diagram. We consider any reference to "strategic buffers" should be deleted from the text as this function will continue to be achieved by means of the Green Belt.

The approach being adopted towards the release of Green Belt land for development may be sound as a general principle but we would expect to see clear evidence to support the general locations for growth in terms of their relative impact on the purposes of the Green Belt. There would appear to be a lack of joined up thinking between the Preferred Options in H1 and H2 and that in GB1.

Dwelling Types

Whilst we support the wish to ensure a mix of dwelling types to reflect a wide spectrum of housing needs and budgets, much will depend of the size of the particular development, the character of the area, and any other local constraints or factors. We therefore have certain reservations about a blanket policy requiring a housing mix. Such a mix may in any event be triggered by the requirement to provide affordable housing over and above the thresholds in H4. Our reservations might be overcome quite simply by inserting the words "Where appropriate," at the beginning of the text H5.

Rural Diversification, Green Tourism and Recreational Uses

We support the Council's aims to promote and secure a vibrant and prosperous countryside and one that encourages recreational uses. In fringe urban areas and particularly where development abuts the Green Belt boundary, opportunities should be explored to supplement formal and informal recreational provision as part and parcel of mixed use development sites. The opportunities for such provision should be one of the determining factors in the selection of locations for growth and subsequently at the Site Allocations DPD stage.

Future Employment Allocations

We generally welcome the initiatives set out to deliver increased employment provision to meet the needs of the District and its growing population over the plan period. We nevertheless have similar reservations to those expressed in relation to housing in terms of the proposals put forward. It is vital that housing and employment are considered jointly to ensure the best possible "fit" which would encourage new and more accessible employment opportunities. We would like to see evidence of the co-ordinated provision for housing and employment promoted through the growth locations put forward as Preferred Options. Again, this potentially calls into question the soundness of the plan.

Environmental Issues

We support the continuing protection of the District's natural landscape and habitats and hence we endorse the Preferred Options in ENV1 and ENV2. We consider some of the protective notations are sufficiently important to be denoted on the Key Diagram.

Flood Risk

Clearly the avoidance of areas prone to or at risk of flooding will be a key consideration in the choice of growth locations and later individual sites at the Site Allocations DPD stage. We mention in passing that the inclusion of the western side of Ashingdon as a General Location would not pose any problems associated with flood risk as it lies entirely outside any area so defined by the Environment Agency (see Part C).

Transport

We fully endorse the Preferred Options in T1 Highways and T2 Public Transport. With regard to the Preferred Option T5 Cycling and Walking, we draw attention to the particular opportunities in this respect associated with the inclusion of the western side of Ashingdon (see Part C).

Community Infrastructure, Leisure and Tourism

With regard to CLT5 Open Space - Preferred Option, we have already indicated we see opportunities for providing Open Space for both formal and informal recreation in association with General Locations especially on the edge or within the Green Belt. There are particular opportunities on the western side of Ashingdon which we refer to in Part C.

CONCLUSION

Whilst it will be seen that we have identified much to support within the text of the consultation document, we have expressed concerns in relation to the justification of many of the Preferred Options - particularly where these have Lane Use implications. Whilst not necessarily opposing any particular proposal, we have been unable to establish a paper trail which would convince us that such proposals are indeed justified in themselves or sufficiently tested. In some respects, the danger is that unless there is a clear testing of options against agreed criteria leading through a sieving process to establish the most appropriate locations for growth, then the process is not very different from the old style Local Plan system. It is this introduction of "better assessment" which is critical in terms of determining 'soundness'. An example of this crucial defect is the identification of General Locations requiring the loss of Green Belt land without any reference to the evaluation of the relative effects of that encroachment in relation to the purposes of the Green Belt. We believe these fundamental concerns need to be addressed in order to achieve reasonable confidence in the Core Strategy.

PART B: STRATEGIC SITE REPRESENTATIONS

In the above submission, we indicated that we considered the Land Bid put forward at an earlier stage in relation to Land on the Western Side of Ashingdon qualifies as a General Location because of its capacity to deliver more than 50 units - the lowest capacity threshold in H2. A plan identifying theland in question is found at the end of this section. As noted in the introduction, the site extends to 4.0 hectares of which 1.5 hectares is existing woodland. The remaining 2.5 hectares re envisaged to provide 2.0 hectares of housing and 0.5 hectares for landscaping and a public car park serving the Open Space to the west. Based on minimum densities required in PPS3: Housing, it is therefore envisaged that the location would provide a minimum of 60 units.

The main justification for the inclusion of the western side of Ashingdon as a General Location is as follows.

The location directly abuts established development off Rectory Avenue with estate road access up to its boundary along Hogarth Way. It therefore forms a natural adjunct to the existing built up area.
The location has very clearly demarcated and defensible boundaries in the form of a boundary with a flood park to the south, a footpath/cycleway to the west, and mature woodland and bridleway to the north.
There are important opportunities to contribute to the recreational use and potential of the land to the west as well as to upgrade the woodland for public access.
There are additional opportunities to provide a landscaped recreational car park for use by ramblers and dog walkers on the western side of the development served via Hogarth Way.
The interface between the development and open land to the west can be provided with a landscape buffer to help integrate the General Location into its landscape setting.
The site lies outside any Flood Risk zone identified by the Environment Agency (see plan at end of this section).

It is considered that a General Location identified on the western side of Ashingdon compares well with other locations on the edge of Rochford/Ashingdon in terms of its sustainability, its effect on the Green Belt, and on the setting of the settlement. As noted in Part A, this general location is not included in the list of General Locations or in the alternatives that have been considered and rejected.

We have advanced the view in Part A that particular regard should be had to the contribution General Locations might make to recreational facilities and amenities. We attach sufficient importance to this by suggesting that it could be a determining factor in the choice of General Locations. The associated Open Space and woodland management that would be achieved as part of the development of this proposed General Location would be very substantial indeed and would reinforce the existing neighbouring Open Space provision which is heavily used by both the local resident population and by visitors. There are no Rights of Way across this General Location at present. However, we envisage that there would be new footpath and cycleway routes through the development area to link with the existing Rights of Way.

Having regard to the above, we put forward land on the western side of Ashingdon as a General Location that should be included in H2 as a Preferred Option.

PART C: SCHEDULE OF AMENDMENTS

We set out below the main amendments we are seeking and suggesting to the Core Strategy Preferred Options some of which we believe to be necessary in order to make the document 'sound'.

1. Insert text which recognises the need to adopt a strategy which seeks to make the District more self-contained and hence more sustainable.

2. Supplement the main employment growth proposals with complementary proposals relating to smaller and localised employment initiatives likely to reduce the lengths of journey to work.

3. Refer consistently to Rochford/Ashingdon and Hockley/Hawkwell rather than just Rochford and Hockley.

4. Provide a fuller explanation of how the 'Vision' is to be realised through the implementation of the key planning objectives.

5. Provide evidence to support the claim that "The preferred distribution is based not simply on which areas are the most sustainable at present, but also on how residential development can contribute to, and marry with, other strategies - particularly in relation to town centre vitality, environmental issues and employment - to ensure long term sustainable development within the District".

6. Set out a coherent strategy which closely and geographically associates housing needs, employment and community facilities based on sound sustainability principles.

7. Demonstrate how the coherent strategy referred to in (6) above has informed the General Locations for new housing and other forms of development.

8. Provide supporting evidence to justify the locations and capacity for the release of land pre- and post-2015 and post 2021.

9. Amend text to delete reference to pepper-potting affordable housing and refer instead to the need to avoid large blocks of affordable housing and the need to integrate affordable and free-market housing in a harmonious way.

10. Explain the relative effects of the General Locations identified in H2 and H3 on the Green Belt.

11. Delete reference to "strategic buffers" as their purpose will continue to be achieved by the Green Belt.

12. Insert the words "Where appropriate," at the beginning of H5.

13. Make explicit that opportunities should be explored for the provision of recreational and amenity land within or adjoining General Locations.

14. Provide clearer evidence to show a coordinated approach to the provision for housing and employment in order to meet the tests of soundness.

15. Consider including the more important rural and natural resource notations on the Key Diagram.

16. Include Land on the western side of Ashingdon (Part B of this submission) as a General Location in H2.

INTRODUCTION

We act on behalf of Crowstone Properties Ltd and are instructed to submit Representations on their behalf as part of the Consultation on the emerging Core Strategy.

Whilst we fully appreciate that the current stage is principally concerned with strategic and district-wide issues rather than site-specific aspects, we note that Policy H2 General Locations and Phasing Preferred Option contains a schedule of areas which are indicated on the Key Diagram. We also note that two of the areas, namely West Hockley and West Great Wakering, have capacities of only 50 units. Our clients Representations submitted at an earlier consultation stage on the Core Strategy Preferred Options, (ie July 2007) included a Land Bid relating to developable land on the western side of Ashingdon which extends to approximately 2.5 hectares and would therefore provide an estimated minimum capacity in excess of 50 units. It is therefore of sufficient size to be regarded as "strategic" in terms of the Core Strategy and Policy H2.

Our Representations are in three parts:-

Part A: General Representations
Part B: Strategic Site Representations
Part C: Schedule of Amendments

At various points, however, we will cross-reference to our proposed strategic site, a plan of which can be found at the end of Part B. As noted, the area edged red extends to 2.5 hectares of which 0.5 hectares would be used to provide peripheral landscaping, and if required, a car park to serve the open space to the west and south. Immediately to the north, edged in blue, a woodland area extending to approximately 1.5 hectares would be dedicated for public open space. The strategic 4.0 hectare site would therefore constitute a mixed use comprising housing, a public car park and public open space and amenity land.

It would be of great assistance if future documents have their various sections numbered and each paragraph given a discreet paragraph number. The absence of any form of numbering system poses difficulty in identifying particular quotes from the document which makes the task of the reader and writer more laborious.

PART A: GENERAL REPRESENTATIONS

Listening to your views:

We found the summary of public opinion set out in "Listening To Your Views" to be both interesting and valuable as a basis for formulating the Core Strategy.

Clearly, one of the key points of public concern relates to the question of whether some Green Belt land should be used for future development. Much depends on how the question is put; if one asks: should Green Belt land be developed? - it is to be expected that most people's first reaction is that it should not. It is widely recognised and appreciated that undeveloped land in Rochford District performs many functions - it provides the setting for the settlements, gaps which prevent the coalescence of settlements, areas for informal and formal recreation, and pleasant countryside. Any encroachment of the Green Belt must be at a cost and should be avoided if humanly possible. If, however, the question is put another way, namely - should we safeguard the Green Belt rather than make provision for the various types of housing to meet the needs of our existing and future residents? - then a different response might be forthcoming. The prospect of housing shortages, with house shortages, with house prices driven up by scarcity value, and younger sections of the population finding it even more difficult to reach the first rung on the housing ladder, might be sufficiently unattractive a proposition to lead people to support a justified and carefully controlled release of parts of the Green Belt. We therefore welcome the fact that after many years of assiduous protection of Green Belt land, the Council has "grasped the nettle" and has clearly identified sound reasons why it is a Preferred Option to identify some Green Belt land for development.

Characteristics, Issue and Opportunities

We also found the section headed "Characteristics, Issues and Opportunities" to be a useful summary which painted an accurate picture of the current character and contemporary issues in Rochford District.

Economy

We do not consider the document sufficiently recognises the need to adopt a strategy which seeks to make the District more self-contained and hence more sustainable. We note the paragraph which states "A high proportion of the Rochford workforce commutes out of the District. 30% travel to work in Southend, 14% to London, 9% to Basildon and about 15% travel elsewhere outside the District." In other words, 68% of the working population commute out of the District and only 32% work within the District. Even allowing for the high proportion that commute the relatively short distance to Southend, this represents a very heavy reliance on employment beyond the District's boundaries. The District is therefore highly unsustainable in this particular respect.

We note the references to Thames Gateway South Essex and to initiatives at Southend Airport, but consider that such employment growth will needs to be supplemented by a myriad of smaller and localized initiatives which are more likely to reduce the lengths of journey to work. At the same time, if well located, small business parks and enterprise areas would help counterbalance the lack of local employment which makes the District so heavily reliant on other areas. It would also reinforce the District's track record for thriving small businesses.

Settlements

We broadly support the four tiers of settlement with the first tier comprising Rayleigh, Rochford and Hockley as set out on page 20. We note, however, in "General Locations" on page 26, the first tier settlements are listed as Rayleigh; Rochford/Ashingdon; Hockley/Hawkwell. We have no difficulty with this but consider there should be consistency as to how settlements are addressed. For the avoidance of doubt, we prefer the approach adopted on page 26.

Vision

Again we register our support for the overarching vision and the key planning objectives. Without detracting from the high ideals expressed here, we would perhaps hope to see a much fuller explanation of how the vision is to be realised. Some reference to the types of measures or policy and proposals that will be introduced to implement the key planning objectives might be appropriate at this stage.

Housing

We consider the remaining balance of 2,489 units for the period 2001-2021 together with the further 1,000 units for the period 2021-2025 represents a substantial commitment requiring careful decisions in relation to its future distribution. We fully acknowledge the concern that can arise from town cramming and the difficulty posed by the rapidly dwindling supply of other brownfield land. We consider the Council can be justifiably proud of its record in directing a high proportion of recent growth to brownfield sites. However, this is a finite resource and it was inevitable that at some point it would be necessary to increase the Greenfield contribution. In the Council's view, that point has now been reached, and we agree with that. We note that the 30% of development that will still be targeted to brownfield sites is only half that advised in the East of England Plan, but that this lower level is probably realistic and hence deliverable. In any event, it is also important not to rely on regular reviews of the Green Belt boundary and this points to the need for long term land reserves needed for development being taken out of the Green Belt as part of the Core Strategy.

In moving towards the Preferred Distribution, we note the following on page 26.

"The preferred distribution is based not simply on which areas are the most sustainable at present, but also on how residential development can contribute to, and marry with, other strategies - particularly in relation to town centre vitality, environmental issues and employment - to ensure long term sustainable development within the District."

We believe that is exactly the right approach but at this stage we have not seen the evidence to support this important claim. Indeed, the Preferred Options move rapidly into the topic of "Housing" without any clear demonstration of a comprehensive and holistic approach in terms of the distribution of the wider development needs of the District. In other words, we would expect to see a coherent strategy which closely and geographically associates housing needs, employment and community facilities based on sound sustainability principles. We do not believe that general locations for new housing, for example, can be selected in isolation but that such decisions must reflect a pre-agreed framework of sustainability principles taking account of existing and all forms of new development requirements.

In turning to H2 General Locations and Phasing - Preferred Option, it is unclear what process of selection was undertaken to alight on this particular choice of area. No doubt each of the areas identified have their own particular merits and advantages, and some may be highly sustainable and other less so. It is difficult to pass judgement without any pre-stated basis for the inclusion of these particular areas. By the same token, the reasoning behind the split before and after 2015 is equally unclear. We do not oppose the principle of staging development - indeed we support it if this assists in ensuring land allocations are more evenly spread and hence available throughout the plan period. Again, however, we expect to see the reasoning for this split and this does not seem to be apparent. We raise these points because they are fundamental and there needs to be a clearly understood basis for the choice of general locations and for phasing. We have given careful consideration to the general locations set out in H2 and the alternative options set out giving reasons why these further locations were not preferred. Having regard to the earlier representations submitted on behalf of Crowstone Development Ltd relating to an area on the western side of Ashingdon, we can find no reference to this as a possible option.

Turning to H3 General Location Post-2021 Preferred Option, we consider there is a similar duty to justify the general locations and capacity for the areas identified. Whilst we note that: "The detailed location and development will be articulated within the Allocations Development Plan document and, where appropriate, Area Action Plans," this in no way reduces the need to ensure that the location itself is sustainable and can be justified as a Preferred Option. The information and analysis to support the general locations both pre and post 2015 and post 2021 is lacking and we consider this must go to the soundness of the Plan.

Affordable Housing

We take the view that much greater emphasis must be given in future to the delivery of affordable units, especially having regard to the high house values which preclude so many entering the housing market. We recognise that Exceptions Policies are necessary but deliver very little in terms of numbers. We also recognise that it is the larger sites that have the viability which enables a significant proportion of affordable units to be provided or cross-subsidised by free market housing. A judgement is needed as to the level of affordable provision that should be required from new sites. On balance we consider the suggestion that at least 35% of dwellings on all developments of 15 or more units, or on sites greater than 0.5 ha, should be affordable - gets the balance about right. We therefore support the wording of H4 Affordable Housing - Preferred Option in this respect and favour this to the Alternative Options in H4.

With regard, however, to the requirement to spread (pepper-pot) affordable dwellings throughout larger developments, we express certain concerns. We agree that large blocs of affordable housing should be avoided if possible but pepper-potting can give rise to design and management problems. As usual, these matters can normally be overcome through compromise having regard to the circumstances relating to each particular site. We would therefore prefer to see a more general reference to the need to avoid large blocs of affordable housing and the need to integrate affordable and free market housing in a harmonious way.

The Green Belt

As indicated above, we support the conclusion that the time has now come when the current boundaries of the Green Belt need to be reviewed to enable development required to be provided in Rochford District by the East of England Plan can be met in an environmentally acceptable way. Given the long-term nature of the plan period, the opportunity arises to adjust the Green Belt boundaries to facilitate growth over a long period and this should avoid the need for repetitive short term reviews which could undermine the confidence in the Green Belt. We note the wording of GB1 Green Belt Protection - Preferred Option and in particular the commitment to prioritise the protection of Green Belt land based on how well the land helps achieve the purposes of the Green Belt. Whilst this seems entirely clear and logical, we would expect this exercise to be conducted to inform the general locations identified in H2 and H3. Further uncertainty arises from the reference to "strategic buffers that are particularly worthy of mention" which appear not to be mentioned or featured on the Key Diagram. We consider any reference to "strategic buffers" should be deleted from the text as this function will continue to be achieved by means of the Green Belt.

The approach being adopted towards the release of Green Belt land for development may be sound as a general principle but we would expect to see clear evidence to support the general locations for growth in terms of their relative impact on the purposes of the Green Belt. There would appear to be a lack of joined up thinking between the Preferred Options in H1 and H2 and that in GB1.

Dwelling Types

Whilst we support the wish to ensure a mix of dwelling types to reflect a wide spectrum of housing needs and budgets, much will depend of the size of the particular development, the character of the area, and any other local constraints or factors. We therefore have certain reservations about a blanket policy requiring a housing mix. Such a mix may in any event be triggered by the requirement to provide affordable housing over and above the thresholds in H4. Our reservations might be overcome quite simply by inserting the words "Where appropriate," at the beginning of the text H5.

Rural Diversification, Green Tourism and Recreational Uses

We support the Council's aims to promote and secure a vibrant and prosperous countryside and one that encourages recreational uses. In fringe urban areas and particularly where development abuts the Green Belt boundary, opportunities should be explored to supplement formal and informal recreational provision as part and parcel of mixed use development sites. The opportunities for such provision should be one of the determining factors in the selection of locations for growth and subsequently at the Site Allocations DPD stage.

Future Employment Allocations

We generally welcome the initiatives set out to deliver increased employment provision to meet the needs of the District and its growing population over the plan period. We nevertheless have similar reservations to those expressed in relation to housing in terms of the proposals put forward. It is vital that housing and employment are considered jointly to ensure the best possible "fit" which would encourage new and more accessible employment opportunities. We would like to see evidence of the co-ordinated provision for housing and employment promoted through the growth locations put forward as Preferred Options. Again, this potentially calls into question the soundness of the plan.

Environmental Issues

We support the continuing protection of the District's natural landscape and habitats and hence we endorse the Preferred Options in ENV1 and ENV2. We consider some of the protective notations are sufficiently important to be denoted on the Key Diagram.

Flood Risk

Clearly the avoidance of areas prone to or at risk of flooding will be a key consideration in the choice of growth locations and later individual sites at the Site Allocations DPD stage. We mention in passing that the inclusion of the western side of Ashingdon as a General Location would not pose any problems associated with flood risk as it lies entirely outside any area so defined by the Environment Agency (see Part C).

Transport

We fully endorse the Preferred Options in T1 Highways and T2 Public Transport. With regard to the Preferred Option T5 Cycling and Walking, we draw attention to the particular opportunities in this respect associated with the inclusion of the western side of Ashingdon (see Part C).

Community Infrastructure, Leisure and Tourism

With regard to CLT5 Open Space - Preferred Option, we have already indicated we see opportunities for providing Open Space for both formal and informal recreation in association with General Locations especially on the edge or within the Green Belt. There are particular opportunities on the western side of Ashingdon which we refer to in Part C.

CONCLUSION

Whilst it will be seen that we have identified much to support within the text of the consultation document, we have expressed concerns in relation to the justification of many of the Preferred Options - particularly where these have Lane Use implications. Whilst not necessarily opposing any particular proposal, we have been unable to establish a paper trail which would convince us that such proposals are indeed justified in themselves or sufficiently tested. In some respects, the danger is that unless there is a clear testing of options against agreed criteria leading through a sieving process to establish the most appropriate locations for growth, then the process is not very different from the old style Local Plan system. It is this introduction of "better assessment" which is critical in terms of determining 'soundness'. An example of this crucial defect is the identification of General Locations requiring the loss of Green Belt land without any reference to the evaluation of the relative effects of that encroachment in relation to the purposes of the Green Belt. We believe these fundamental concerns need to be addressed in order to achieve reasonable confidence in the Core Strategy.

PART B: STRATEGIC SITE REPRESENTATIONS

In the above submission, we indicated that we considered the Land Bid put forward at an earlier stage in relation to Land on the Western Side of Ashingdon qualifies as a General Location because of its capacity to deliver more than 50 units - the lowest capacity threshold in H2. A plan identifying theland in question is found at the end of this section. As noted in the introduction, the site extends to 4.0 hectares of which 1.5 hectares is existing woodland. The remaining 2.5 hectares re envisaged to provide 2.0 hectares of housing and 0.5 hectares for landscaping and a public car park serving the Open Space to the west. Based on minimum densities required in PPS3: Housing, it is therefore envisaged that the location would provide a minimum of 60 units.

The main justification for the inclusion of the western side of Ashingdon as a General Location is as follows.

The location directly abuts established development off Rectory Avenue with estate road access up to its boundary along Hogarth Way. It therefore forms a natural adjunct to the existing built up area.
The location has very clearly demarcated and defensible boundaries in the form of a boundary with a flood park to the south, a footpath/cycleway to the west, and mature woodland and bridleway to the north.
There are important opportunities to contribute to the recreational use and potential of the land to the west as well as to upgrade the woodland for public access.
There are additional opportunities to provide a landscaped recreational car park for use by ramblers and dog walkers on the western side of the development served via Hogarth Way.
The interface between the development and open land to the west can be provided with a landscape buffer to help integrate the General Location into its landscape setting.
The site lies outside any Flood Risk zone identified by the Environment Agency (see plan at end of this section).

It is considered that a General Location identified on the western side of Ashingdon compares well with other locations on the edge of Rochford/Ashingdon in terms of its sustainability, its effect on the Green Belt, and on the setting of the settlement. As noted in Part A, this general location is not included in the list of General Locations or in the alternatives that have been considered and rejected.

We have advanced the view in Part A that particular regard should be had to the contribution General Locations might make to recreational facilities and amenities. We attach sufficient importance to this by suggesting that it could be a determining factor in the choice of General Locations. The associated Open Space and woodland management that would be achieved as part of the development of this proposed General Location would be very substantial indeed and would reinforce the existing neighbouring Open Space provision which is heavily used by both the local resident population and by visitors. There are no Rights of Way across this General Location at present. However, we envisage that there would be new footpath and cycleway routes through the development area to link with the existing Rights of Way.

Having regard to the above, we put forward land on the western side of Ashingdon as a General Location that should be included in H2 as a Preferred Option.

PART C: SCHEDULE OF AMENDMENTS

We set out below the main amendments we are seeking and suggesting to the Core Strategy Preferred Options some of which we believe to be necessary in order to make the document 'sound'.

1. Insert text which recognises the need to adopt a strategy which seeks to make the District more self-contained and hence more sustainable.

2. Supplement the main employment growth proposals with complementary proposals relating to smaller and localised employment initiatives likely to reduce the lengths of journey to work.

3. Refer consistently to Rochford/Ashingdon and Hockley/Hawkwell rather than just Rochford and Hockley.

4. Provide a fuller explanation of how the 'Vision' is to be realised through the implementation of the key planning objectives.

5. Provide evidence to support the claim that "The preferred distribution is based not simply on which areas are the most sustainable at present, but also on how residential development can contribute to, and marry with, other strategies - particularly in relation to town centre vitality, environmental issues and employment - to ensure long term sustainable development within the District".

6. Set out a coherent strategy which closely and geographically associates housing needs, employment and community facilities based on sound sustainability principles.

7. Demonstrate how the coherent strategy referred to in (6) above has informed the General Locations for new housing and other forms of development.

8. Provide supporting evidence to justify the locations and capacity for the release of land pre- and post-2015 and post 2021.

9. Amend text to delete reference to pepper-potting affordable housing and refer instead to the need to avoid large blocks of affordable housing and the need to integrate affordable and free-market housing in a harmonious way.

10. Explain the relative effects of the General Locations identified in H2 and H3 on the Green Belt.

11. Delete reference to "strategic buffers" as their purpose will continue to be achieved by the Green Belt.

12. Insert the words "Where appropriate," at the beginning of H5.

13. Make explicit that opportunities should be explored for the provision of recreational and amenity land within or adjoining General Locations.

14. Provide clearer evidence to show a coordinated approach to the provision for housing and employment in order to meet the tests of soundness.

15. Consider including the more important rural and natural resource notations on the Key Diagram.

16. Include Land on the western side of Ashingdon (Part B of this submission) as a General Location in H2.