Core Strategy Submission Document

Policy H2 of the Core Strategy is not "sound". Policy H2 pre-allocates residential development "North" of London Road, Rayleigh.
My clients accepted that residential development is to take place in the Green Belt, and that this should be to the West of Rayleigh, but there is no justification why the area to the north of London Road has been selected, as opposed to any other area to the West of the town. This lack of justification pre-judges the forthcoming "call for sites" DPD to be produced by the council and is unsound.

Allocation of the area North of the London Road fails to take account of a number of the criteria of para 4.19 of the Core Strategy document, and would, amongst others; availability of existing infrastructure and the requirement to provide additional infrastructure; Potential to reduce car trips and dependency; Impact on the existing highway network; and encourages the coalescence of Rayleigh and Rawreth. This further emphasises that the strategic decision has not been properly made.

Para 4.5 of the PPS confirms that core strategies should make clear spatial choices about where development should go in broad terms. It does not say that sites should be allocated, which in effect is what policy H2 does.
The policy also refers to appendix H1 which sets out details of local infrastructure. Again this fails to comply with PPS12. Para 4.9 of the PPS requires infrastructure needs and costs to be identified. This has not been completed or published. There is no evidence to support the infrastructure requirements, or who will provide it, or when.

The document therefore fails to comply with PPS12 and is not sound. The reference to north of London Road Rayleigh should be replaced by a general strategic requirement of West of Rayleigh and the technical analysis should be fully considered in the DPD "Site allocations" document.

The site allocation should be general at this stage in order to allow proper consultation of the alternatives. This has not previously be consulted on in the previous options documents.
There are alternative sites to the west of Rayleigh town centre that do not require such a substantial investment to the highway network, that are closer to major transport junctions and interchanges than sites north of the London Road. These considerations do not appear to have been fully taken into account in making the strategic assessment and allocation of sites to the north. Other sites have better highway links and are thus more sustainable, but no assessment has been considered in public. The site allocation in this document flies in the face of national guidance in PPG13. The authority appear to have selected their preferred option from the previous consultation document, but gone one stage further in this publication, refining the defined area further without proper consultation. No Credible alternative sites to the West of the town centre appear to have been considered.

The site allocation should be general at this stage in order to allow proper consultation of the alternatives. This has not previously be consulted on in the previous options documents.

Proposed Change

We request that the policy be changed from "North of London Road, Rayleigh" to refer to "West of Rayleigh", pending further consideration of alternative sites.
We reserve the right to expand on these grounds in more detailed evidence to follow should the Inspector request.

Site location plan received, see Council ref AE30

Policy Appendix H1 of the Core Strategy is not "sound". The appendix H1 is unjustified and this not sound.

Para 4.9 of PPS12 requires infrastructure needs and costs to be identified. This has not been completed or published. There is no evidence to support the infrastructure requirements, or who will provide it, or when.

The list of infrastructure projects is not justified in accordance with the PPS. The list of infrastructure required, whilst potentially accepted appears to be based on a development brief that we are not aware of and has not been published. The site allocation should be general at this stage in order to allow proper consultation of the alternatives. This has not previously be consulted on in the previous options documents.

Proposed Change

We request that the wording be changed from "North of London Road, Rayleigh" to refer to "West of Rayleigh", to allow further consideration of alternative sites.

We reserve the right to expand on these grounds in more detailed evidence to follow should the Inspector request.

Site location plan received, see Council ref AE30

Policy ED4 is not sound as it is not precisely worded.

The main text of point 1 of policy ED4 confirms that land to the South of London Road, west of Rayleigh will be used for the relocation of displacement of Rawreth Industrial Estate industrial uses and for additional office development. The bullet points then state that industrial development will be acceptable.
The first para of point 1 should be clear and confirm that additional industrial development in addition to that displaced from Rawreth Industrial estate will be acceptable.

Proposed Change

We request the following amendment to point 1 of policy ED4:

The Council will allocate land to the south of London Road, Rayleigh to accommodate a new employment park capable of accommodating businesses displaced by the redevelopment of Rawreth Industrial Estate as well as additional office space B1 - B8 uses. It will have the following characteristics:

Site location plan received, see Council ref AE30