Core Strategy Submission Document

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This submission is made on behalf of the West Rochford Action Group and its members. Further details sent under separate cover: email and by hand.
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H1 Efficient use of land for housing.

Only 4 brownfield sites have been identified in this policy for redevelopment Star Lane Industrial estate, Stambridge Mills, Eldon Way Industrial Estates and Rawreth Lane Industrial estate, Rayleigh. However there are others which have not been included despite the statement that the Council will prioritise the use of previously developed land. The Brickfields site off Cherry Orchard Way is not mentioned and would provide an additional site and be more appropriate in land use terms. On the Rochford Town Centre Plan further sites are being considered namely the Rose and Crown Car Park and adjoining shops, Whittinghams garage. There are further sites which were previously being considered by the Council in 2007 which are not mentioned - these should all be assessed and utilised in preference to green belt sites.

PPG3 on housing requires Local authorities to promote more sustainable patterns of development and make better use of previously developed land the focus for additional housing should be existing towns and cities. PPG3 requires LAs to build in ways which exploit and deliver accessibility by public transport to jobs education and health facilities shopping and local services.

The Core Strategy does not provide for a proper annual monitoring and review of brownfield sites or a policy which states that as brownfield sites come forward the proposed green belt sites will be abandoned. There is no reason why such a policy should not be adopted.

See supporting document, Council ref AE28

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This submission is made on behalf of the West Rochford Action Group and its members. Further details sent under separate cover: email and by hand.
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H2 Extensions to residential envelopes and phasing.

1. Loss of Green Belt
West Rochford has been identified as bearing the largest extension to the current residential envelope with the proposed loss of greenbelt land to accommodate a total of 600 homes by 2021. This cannot be said to be a balanced strategy (para 4.18) when considering the population statistics (para 2.21) which places the settlement tier of Rochford/Ashingdon 3rd in terms of size behind Rayleigh and Hawkwell/Hockley.

The proposal to reallocate Green Belt land for housing on such a large scale (more than 50% of the housing proposed to be on land currently Green Belt) cannot be viewed as having a minimal impact. The Town and Country Planning (Green Belt) Directive 2005 final regulatory impact statement when considering the size of development that would be potentially harmful to the green belt and should require referral to the Secretary of State states (para 21) that a site which roughly equates to ten new, average-size dwellings broadly represents the scale of development around which there is the potential for significant impact on the openness of the Green Belt.

PPG2 provides the Governments policy on Green Belts and the intentions of the policy are set out in para 1.4:-
The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the most important attribute of Green Belts is their openness. Green Belts can shape patterns of urban development at sub-regional and regional scale, and help to ensure that development occurs in locations allocated in development plans. They help to protect the countryside, be it in agricultural, forestry or other use.

The purpose of including land in Green Belts is set out at 1.5 :-
* to check the unrestricted sprawl of large built-up areas;
* to prevent neighbouring towns from merging into one another;
* to assist in safeguarding the countryside from encroachment;
* to preserve the setting and special character of historic towns; and
* to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

PPG2 para1.6 states:-
Once Green Belts have been defined, the use of land in them has a positive role to play in fulfilling the following objectives:
— to provide opportunities for access to the open countryside for the urban population;
— to provide opportunities for outdoor sport and outdoor recreation near urban areas;
— to retain attractive landscapes, and enhance landscapes, near to where people live;
— to improve damaged and derelict land around towns;
— to secure nature conservation interest; and
— to retain land in agricultural, forestry and related uses.

The proposals in the Core Strategy in relation to Green Belt land do not comply with these objectives and will lead to urban sprawl particularly in the area of West Rochford.

Although not site specific the Key Diagram attached to the Core Strategy shows a triangle of land immediately west of Oak Road as proposed for development and further research has demonstrated this to be the case.

This area has a particular character which will clearly be lost if large scale development is permitted. PPG2 states at para 2.6 that once the general extent of a Green Belt has been approved it should be altered only in exceptional circumstances. If such an alteration is proposed the Secretary of State will wish to be satisfied that the authority has considered opportunities for development within the urban areas contained by and beyond the Green Belt. Similarly, detailed Green Belt boundaries defined in adopted local plans or earlier approved development plans should be altered only exceptionally. Detailed boundaries should not be altered or development allowed merely because the land has become derelict.

A need for such a large number of homes has not been demonstrated and in April 2001 there were 761 empty dwellings in Rochford and the trend has shown an increase in vacant dwellings as by April 2006 there were 996 empty homes which indicates that demand has plateaued. Furthermore two developments designed and built especially for the elderly in Rochford prior to the economic problems still have units unsold.

2. Agricultural Land
In so far as any development proposals include agricultural land the need has to be observed of the future requirements of feeding the country in view of the serious concerns for world food shortages and the estimated large increase in the population of the world and particularly this country. It will not be environmentally acceptable to pursue a policy of importing food which could be grown in this country. Sent under separate cover (email), is an article from the business edition of the Daily Telegraph dated 13th October 2009 and stressed in that article is the second paragraph which refers to the shortage of quality farmland as the global population expands. The agricultural land on the north side of Hall Road is top quality (Grade one) and is a prime example of land which will be needed in the future.

3. Social Housing
The Housing Waiting list statistics shown at para 2.38 of the consultation document shows 44.4% of the demand for social housing to be located in Rayleigh against 29% for Rochford. There is therefore a greater need for social housing in Rayleigh and the Core Strategy does not indicate that a greater proportion of social housing will be provided in Rayleigh. Furthermore no statistics have been provided in respect of the Housing Waiting List so it is unclear as to the exact extent of the need for social housing in the district

PPG2 para 3.2 states:-
Inappropriate development is, by definition, harmful to the Green Belt. It is for the applicant to show why permission should be granted. Very special circumstances to justify inappropriate development will not exist unless the harm by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. In view of the presumption against inappropriate development, the Secretary of State will attach substantial weight to the harm to the Green Belt when considering any planning application or appeal concerning such development.
3.4 The construction of new buildings inside a Green Belt is inappropriate unless it is for the following purposes:
— agriculture and forestry (unless permitted development rights have been withdrawn;
— essential facilities for outdoor sport and outdoor recreation, for cemeteries, and for other uses of land which preserve the openness of the Green Belt and which do not conflict with
the purposes of including land in it;
— limited extension, alteration or replacement of existing dwellings;
— limited infilling in existing villages, and limited affordable housing for local community needs under development plan policies according with PPG3,
— limited infilling or redevelopment of major existing developed sites identified in adopted local plans, which meets the criteria in paragraph C3 or C4 of Annex C1.
As land proposed to be developed is in the Green Belt these policies should apply to the proposals for reallocation.

4.Roads and Transport
Traffic congestion in Hall Road and on the outskirts of Rochford town is a frequent occurrence particularly at peak times. Additional development in west Rochford on the scale proposed will force additional traffic on to both Hall Road and Cherry Orchard Way and thence on to the A127 or via Warners Bridge towards Southend Town Centre - both routes are regularly congested. The junction improvements proposed will not solve the issue because it was acknowledged in the East of England Plan paras 4.57 and 4.58 that in the morning peak period traffic flows on the A127 already exceed capacity in the westbound direction which is expected to become worse by 2031. It is also acknowledged that traffic flows already exceed capacity on several sections of the A13 and are forecast to increase further. There is currently no bus service serving Hall Road or Cherry Orchard Way. It was also acknowledged in the Core Strategy document that 84% of households have cars.

If the employment proposals north of Aviation Way which have been included as part of the airport expansion and development scheme proceed the traffic impact would be even worse. Furthermore the pedestrian access under the bridge at Rochford station already poses dangers to pedestrians particularly for those in wheelchairs and prams with no potential for access improvements. The increased traffic flow generated by development proposals will exacerbate the dangers.

Emergency services must be able to gain access to incidents and a significant further increase in traffic flows that will result from these proposals will jeopardise their effective operation.

A full transport assessment is required to ensure the provisions of PPG13 para 23 can be met before reallocating green belt land and ensure achievement of the key planning objective set out in para 19 of PPG13 to ensure that developments are accessible by public transport walking and cycling to promote social inclusion particularly for those who do not have regular use of a car. The emphasis in the Core Strategy on social housing provision makes this requirement particularly important. Para 40 of PPG13 requires that this same policy should be applied in rural areas where public transport is less available.

5.Water supply
Para 4.70 of the East of England Plan showed a deficit of -50 -20 mega litres per day and further acknowledges that unless the supply of water and related infrastructure is improved it will be a barrier to development from 2015. Any reallocation of sites should therefore be contingent upon the necessary infrastructure provision being secured. There are serious doubts as to whether this development can responsibly be pursued.

See supporting document, Council ref AE28