Core Strategy Submission Document

Thank you for inviting the Highways Agency (HA) to comment on the Rochford Core Strategy (CS) Submission Document and Rochford Area Action plan (AAP) prepared by Rochford District Council

As you are aware the HA is an executive agency of the Department for Transport (DfT). We are responsible for operating, maintaining and improving England's motorway and all-purpose trunk road network, collectively known as the Strategic Road Network (SRN), on behalf of the Secretary of State for Transport.

In spatial planning and development control terms, we have a duty to safeguard the operation of the motorway and trunk road network as set out in the Department for Transport Circular: 02/2007: Planning and the Strategic Road Network. http://www.dft.gov.uk/pgr/regional/strategy/policy/circular207planningandstrategic. The circular encourages the HA to work co-operatively with Local Planning Authorities within the framework of the Government's policies for planning, growth areas, regeneration, integrated transport and sustainability. We look to your Council's Local Development Framework to promote strategies, policies and land allocations which would support alternatives to the private car.

In the case of Rochford there are no trunk roads within the District although there are two strategic corridors namely the A13 and A127/A1159 which connect into the M25 motorway network at Junctions 30 and 29 respectively. Sections of these areas are currently heavily congested, particularly during peak periods, and operate under considerable levels of network stress. Therefore it is important to the HA that the impact of major development proposals in the Rochford area is considered within the context of future impact on the M25 and the A13 Trunk Road.

Please see below some general comments regarding the soundness of the CS and SSA from a transport perspective, referring to specific proposed submission policies as necessary. This response has been completed with reference to paragraph 4.52 of PPS12 (2008) PPS12, paragraph 4.52 - To be 'sound' a core strategy should be JUSTIFIED, EFFECTIVE and consistent with NATIONAL POLICY.

CORE STRATEGY

Policy GB1 - Green Belt Protection

The HA acknowledges that only the minimum amount of Green Belt land will be allocated to meet the District's housing and employment needs as necessary. However, the HA is concerned that any proposed redevelopment of greenbelt sites could result in development in areas with limited access to sustainable transport modes therefore resulting in higher levels of car usage and subsequent impact on the SRN. Although the HA recognizes that new public transport hubs that would facilitate the use of non-car modes could be developed over time, this process is likely to require very substantial investment.

It is therefore important that an appropriate assessment of infrastructure requirements is performed for development sites on Green Belt land. Funding towards the necessary public transport infrastructure improvements must be sought and secured prior to occupation of any new development on greenbelt land. Furthermore, the occupation of such developments should be phased in line with necessary transport infrastructure. This will help the CS meet the PPS12 requirement that a sound DPD should be 'justified' and 'effective' and hence deliverable.

Policy T1 - Highways

Policy T1 highlights the need to reduce reliance on the private car but also observes that 'some impact on the highway network is inevitable'. In a District with such high levels of private car ownership and a limited public transport network, as stated in paragraph 10.2, it will be important to assess the potential impacts to the highway network and ensure that mitigation measures are proposed and implemented where necessary.

An emphasis should be placed on the provision and improvement of sustainable transport infrastructure, particularly where high trip-generating developments such as offices are proposed. In line with the DfT's Guidance on Transport Assessment (2007) - DfT GTA, paragraph 4.51 - 'The key issue is the need to ensure that development proposals strive to achieve nil detriment ('no worse off') to the strategic network, for the opening year and appropriate horizon year'. This emphasis will assist in mitigating potential increases in private vehicle trips and hence help ensure that there is a nil-detriment effect on the SRN.

Policy T3 - Public Transport

The recent Planning Inspectorate 'LDF - Learning from Experience' document (September 2009) suggests that a Core Strategy should identify a clear source of funding for infrastructure for at least the first 5 years of the plan - The Planning Inspectorate, LDF: Examining DPDs: Learning from experience, September 2009, Paragraph 22 - 'For at least the first 5 years of the plan it should be clear what infrastructure is required, who is going to fund and provide it and how it is to relate to the rate of development'.. Paragraph 10.15 of the CS highlights the importance of public transport links for new developments and implies that developers may be required to contribute towards public transport provision. However, it is noted that developer contributions cannot be expected to pay for all transport improvements and as such, in line with the recent Planning Inspectorate document outlined above additional sources of funding should be identified. It is recommended that alternative sources of funding for public transport improvements are clearly outlined within the CS to ensure that adequate infrastructure provision is made.

Policy T4 - South Essex Rapid Transit

As mentioned in our response to the Core Strategy Issues and options consultation the HA is supportive of this policy and the need to progress the route through South Essex. This has the potential to reduce the impact on the SRN (A13).

Policy T5 - Travel Plans

The HA welcomes the requirement for a travel plan for developments involving both destination and origin trips. However it is noted that no threshold for employment sites have been specified. Essex County Council requires the production of a workplace travel plan for developments with over 50 employees or where there will be a significant impact on the local road network. To avoid ambiguity for developers, the HA recommends that the Rochford District Core Strategy specifies a similar threshold within Policy T5. This will ensure the Core Strategy is in line with PPG13 paragraph 87 - PPG13 - 'Local authorities are expected to consider setting local targets for the adoption of travel plans by local businesses and other organizations..'

Policy ED2 - London Southend Airport

The HA previously responded to the London Southend and Environs Joint Area Action Plan Preferred Options Document (March 2009). As such, we have not repeated our comments here but instead refer you to our consultation response dated 31 March 2009.

Thank you for inviting the Highways Agency (HA) to comment on the Rochford Core Strategy (CS) Submission Document and Rochford Area Action plan (AAP) prepared by Rochford District Council

As you are aware the HA is an executive agency of the Department for Transport (DfT). We are responsible for operating, maintaining and improving England's motorway and all-purpose trunk road network, collectively known as the Strategic Road Network (SRN), on behalf of the Secretary of State for Transport.

In spatial planning and development control terms, we have a duty to safeguard the operation of the motorway and trunk road network as set out in the Department for Transport Circular: 02/2007: Planning and the Strategic Road Network. http://www.dft.gov.uk/pgr/regional/strategy/policy/circular207planningandstrategic. The circular encourages the HA to work co-operatively with Local Planning Authorities within the framework of the Government's policies for planning, growth areas, regeneration, integrated transport and sustainability. We look to your Council's Local Development Framework to promote strategies, policies and land allocations which would support alternatives to the private car.

In the case of Rochford there are no trunk roads within the District although there are two strategic corridors namely the A13 and A127/A1159 which connect into the M25 motorway network at Junctions 30 and 29 respectively. Sections of these areas are currently heavily congested, particularly during peak periods, and operate under considerable levels of network stress. Therefore it is important to the HA that the impact of major development proposals in the Rochford area is considered within the context of future impact on the M25 and the A13 Trunk Road.

Please see below some general comments regarding the soundness of the CS and SSA from a transport perspective, referring to specific proposed submission policies as necessary. This response has been completed with reference to paragraph 4.52 of PPS12 (2008) PPS12, paragraph 4.52 - To be 'sound' a core strategy should be JUSTIFIED, EFFECTIVE and consistent with NATIONAL POLICY.

CORE STRATEGY

Policy GB1 - Green Belt Protection

The HA acknowledges that only the minimum amount of Green Belt land will be allocated to meet the District's housing and employment needs as necessary. However, the HA is concerned that any proposed redevelopment of greenbelt sites could result in development in areas with limited access to sustainable transport modes therefore resulting in higher levels of car usage and subsequent impact on the SRN. Although the HA recognizes that new public transport hubs that would facilitate the use of non-car modes could be developed over time, this process is likely to require very substantial investment.

It is therefore important that an appropriate assessment of infrastructure requirements is performed for development sites on Green Belt land. Funding towards the necessary public transport infrastructure improvements must be sought and secured prior to occupation of any new development on greenbelt land. Furthermore, the occupation of such developments should be phased in line with necessary transport infrastructure. This will help the CS meet the PPS12 requirement that a sound DPD should be 'justified' and 'effective' and hence deliverable.

Policy T1 - Highways

Policy T1 highlights the need to reduce reliance on the private car but also observes that 'some impact on the highway network is inevitable'. In a District with such high levels of private car ownership and a limited public transport network, as stated in paragraph 10.2, it will be important to assess the potential impacts to the highway network and ensure that mitigation measures are proposed and implemented where necessary.

An emphasis should be placed on the provision and improvement of sustainable transport infrastructure, particularly where high trip-generating developments such as offices are proposed. In line with the DfT's Guidance on Transport Assessment (2007) - DfT GTA, paragraph 4.51 - 'The key issue is the need to ensure that development proposals strive to achieve nil detriment ('no worse off') to the strategic network, for the opening year and appropriate horizon year'. This emphasis will assist in mitigating potential increases in private vehicle trips and hence help ensure that there is a nil-detriment effect on the SRN.

Policy T3 - Public Transport

The recent Planning Inspectorate 'LDF - Learning from Experience' document (September 2009) suggests that a Core Strategy should identify a clear source of funding for infrastructure for at least the first 5 years of the plan - The Planning Inspectorate, LDF: Examining DPDs: Learning from experience, September 2009, Paragraph 22 - 'For at least the first 5 years of the plan it should be clear what infrastructure is required, who is going to fund and provide it and how it is to relate to the rate of development'.. Paragraph 10.15 of the CS highlights the importance of public transport links for new developments and implies that developers may be required to contribute towards public transport provision. However, it is noted that developer contributions cannot be expected to pay for all transport improvements and as such, in line with the recent Planning Inspectorate document outlined above additional sources of funding should be identified. It is recommended that alternative sources of funding for public transport improvements are clearly outlined within the CS to ensure that adequate infrastructure provision is made.

Policy T4 - South Essex Rapid Transit

As mentioned in our response to the Core Strategy Issues and options consultation the HA is supportive of this policy and the need to progress the route through South Essex. This has the potential to reduce the impact on the SRN (A13).

Policy T5 - Travel Plans

The HA welcomes the requirement for a travel plan for developments involving both destination and origin trips. However it is noted that no threshold for employment sites have been specified. Essex County Council requires the production of a workplace travel plan for developments with over 50 employees or where there will be a significant impact on the local road network. To avoid ambiguity for developers, the HA recommends that the Rochford District Core Strategy specifies a similar threshold within Policy T5. This will ensure the Core Strategy is in line with PPG13 paragraph 87 - PPG13 - 'Local authorities are expected to consider setting local targets for the adoption of travel plans by local businesses and other organizations..'

Policy ED2 - London Southend Airport

The HA previously responded to the London Southend and Environs Joint Area Action Plan Preferred Options Document (March 2009). As such, we have not repeated our comments here but instead refer you to our consultation response dated 31 March 2009.

Thank you for inviting the Highways Agency (HA) to comment on the Rochford Core Strategy (CS) Submission Document and Rochford Area Action plan (AAP) prepared by Rochford District Council

As you are aware the HA is an executive agency of the Department for Transport (DfT). We are responsible for operating, maintaining and improving England's motorway and all-purpose trunk road network, collectively known as the Strategic Road Network (SRN), on behalf of the Secretary of State for Transport.

In spatial planning and development control terms, we have a duty to safeguard the operation of the motorway and trunk road network as set out in the Department for Transport Circular: 02/2007: Planning and the Strategic Road Network. http://www.dft.gov.uk/pgr/regional/strategy/policy/circular207planningandstrategic. The circular encourages the HA to work co-operatively with Local Planning Authorities within the framework of the Government's policies for planning, growth areas, regeneration, integrated transport and sustainability. We look to your Council's Local Development Framework to promote strategies, policies and land allocations which would support alternatives to the private car.

In the case of Rochford there are no trunk roads within the District although there are two strategic corridors namely the A13 and A127/A1159 which connect into the M25 motorway network at Junctions 30 and 29 respectively. Sections of these areas are currently heavily congested, particularly during peak periods, and operate under considerable levels of network stress. Therefore it is important to the HA that the impact of major development proposals in the Rochford area is considered within the context of future impact on the M25 and the A13 Trunk Road.

Please see below some general comments regarding the soundness of the CS and SSA from a transport perspective, referring to specific proposed submission policies as necessary. This response has been completed with reference to paragraph 4.52 of PPS12 (2008) PPS12, paragraph 4.52 - To be 'sound' a core strategy should be JUSTIFIED, EFFECTIVE and consistent with NATIONAL POLICY.

CORE STRATEGY

Policy GB1 - Green Belt Protection

The HA acknowledges that only the minimum amount of Green Belt land will be allocated to meet the District's housing and employment needs as necessary. However, the HA is concerned that any proposed redevelopment of greenbelt sites could result in development in areas with limited access to sustainable transport modes therefore resulting in higher levels of car usage and subsequent impact on the SRN. Although the HA recognizes that new public transport hubs that would facilitate the use of non-car modes could be developed over time, this process is likely to require very substantial investment.

It is therefore important that an appropriate assessment of infrastructure requirements is performed for development sites on Green Belt land. Funding towards the necessary public transport infrastructure improvements must be sought and secured prior to occupation of any new development on greenbelt land. Furthermore, the occupation of such developments should be phased in line with necessary transport infrastructure. This will help the CS meet the PPS12 requirement that a sound DPD should be 'justified' and 'effective' and hence deliverable.

Policy T1 - Highways

Policy T1 highlights the need to reduce reliance on the private car but also observes that 'some impact on the highway network is inevitable'. In a District with such high levels of private car ownership and a limited public transport network, as stated in paragraph 10.2, it will be important to assess the potential impacts to the highway network and ensure that mitigation measures are proposed and implemented where necessary.

An emphasis should be placed on the provision and improvement of sustainable transport infrastructure, particularly where high trip-generating developments such as offices are proposed. In line with the DfT's Guidance on Transport Assessment (2007) - DfT GTA, paragraph 4.51 - 'The key issue is the need to ensure that development proposals strive to achieve nil detriment ('no worse off') to the strategic network, for the opening year and appropriate horizon year'. This emphasis will assist in mitigating potential increases in private vehicle trips and hence help ensure that there is a nil-detriment effect on the SRN.

Policy T3 - Public Transport

The recent Planning Inspectorate 'LDF - Learning from Experience' document (September 2009) suggests that a Core Strategy should identify a clear source of funding for infrastructure for at least the first 5 years of the plan - The Planning Inspectorate, LDF: Examining DPDs: Learning from experience, September 2009, Paragraph 22 - 'For at least the first 5 years of the plan it should be clear what infrastructure is required, who is going to fund and provide it and how it is to relate to the rate of development'.. Paragraph 10.15 of the CS highlights the importance of public transport links for new developments and implies that developers may be required to contribute towards public transport provision. However, it is noted that developer contributions cannot be expected to pay for all transport improvements and as such, in line with the recent Planning Inspectorate document outlined above additional sources of funding should be identified. It is recommended that alternative sources of funding for public transport improvements are clearly outlined within the CS to ensure that adequate infrastructure provision is made.

Policy T4 - South Essex Rapid Transit

As mentioned in our response to the Core Strategy Issues and options consultation the HA is supportive of this policy and the need to progress the route through South Essex. This has the potential to reduce the impact on the SRN (A13).

Policy T5 - Travel Plans

The HA welcomes the requirement for a travel plan for developments involving both destination and origin trips. However it is noted that no threshold for employment sites have been specified. Essex County Council requires the production of a workplace travel plan for developments with over 50 employees or where there will be a significant impact on the local road network. To avoid ambiguity for developers, the HA recommends that the Rochford District Core Strategy specifies a similar threshold within Policy T5. This will ensure the Core Strategy is in line with PPG13 paragraph 87 - PPG13 - 'Local authorities are expected to consider setting local targets for the adoption of travel plans by local businesses and other organizations..'

Policy ED2 - London Southend Airport

The HA previously responded to the London Southend and Environs Joint Area Action Plan Preferred Options Document (March 2009). As such, we have not repeated our comments here but instead refer you to our consultation response dated 31 March 2009.

Thank you for inviting the Highways Agency (HA) to comment on the Rochford Core Strategy (CS) Submission Document and Rochford Area Action plan (AAP) prepared by Rochford District Council

As you are aware the HA is an executive agency of the Department for Transport (DfT). We are responsible for operating, maintaining and improving England's motorway and all-purpose trunk road network, collectively known as the Strategic Road Network (SRN), on behalf of the Secretary of State for Transport.

In spatial planning and development control terms, we have a duty to safeguard the operation of the motorway and trunk road network as set out in the Department for Transport Circular: 02/2007: Planning and the Strategic Road Network. http://www.dft.gov.uk/pgr/regional/strategy/policy/circular207planningandstrategic. The circular encourages the HA to work co-operatively with Local Planning Authorities within the framework of the Government's policies for planning, growth areas, regeneration, integrated transport and sustainability. We look to your Council's Local Development Framework to promote strategies, policies and land allocations which would support alternatives to the private car.

In the case of Rochford there are no trunk roads within the District although there are two strategic corridors namely the A13 and A127/A1159 which connect into the M25 motorway network at Junctions 30 and 29 respectively. Sections of these areas are currently heavily congested, particularly during peak periods, and operate under considerable levels of network stress. Therefore it is important to the HA that the impact of major development proposals in the Rochford area is considered within the context of future impact on the M25 and the A13 Trunk Road.

Please see below some general comments regarding the soundness of the CS and SSA from a transport perspective, referring to specific proposed submission policies as necessary. This response has been completed with reference to paragraph 4.52 of PPS12 (2008) PPS12, paragraph 4.52 - To be 'sound' a core strategy should be JUSTIFIED, EFFECTIVE and consistent with NATIONAL POLICY.

CORE STRATEGY

Policy GB1 - Green Belt Protection

The HA acknowledges that only the minimum amount of Green Belt land will be allocated to meet the District's housing and employment needs as necessary. However, the HA is concerned that any proposed redevelopment of greenbelt sites could result in development in areas with limited access to sustainable transport modes therefore resulting in higher levels of car usage and subsequent impact on the SRN. Although the HA recognizes that new public transport hubs that would facilitate the use of non-car modes could be developed over time, this process is likely to require very substantial investment.

It is therefore important that an appropriate assessment of infrastructure requirements is performed for development sites on Green Belt land. Funding towards the necessary public transport infrastructure improvements must be sought and secured prior to occupation of any new development on greenbelt land. Furthermore, the occupation of such developments should be phased in line with necessary transport infrastructure. This will help the CS meet the PPS12 requirement that a sound DPD should be 'justified' and 'effective' and hence deliverable.

Policy T1 - Highways

Policy T1 highlights the need to reduce reliance on the private car but also observes that 'some impact on the highway network is inevitable'. In a District with such high levels of private car ownership and a limited public transport network, as stated in paragraph 10.2, it will be important to assess the potential impacts to the highway network and ensure that mitigation measures are proposed and implemented where necessary.

An emphasis should be placed on the provision and improvement of sustainable transport infrastructure, particularly where high trip-generating developments such as offices are proposed. In line with the DfT's Guidance on Transport Assessment (2007) - DfT GTA, paragraph 4.51 - 'The key issue is the need to ensure that development proposals strive to achieve nil detriment ('no worse off') to the strategic network, for the opening year and appropriate horizon year'. This emphasis will assist in mitigating potential increases in private vehicle trips and hence help ensure that there is a nil-detriment effect on the SRN.

Policy T3 - Public Transport

The recent Planning Inspectorate 'LDF - Learning from Experience' document (September 2009) suggests that a Core Strategy should identify a clear source of funding for infrastructure for at least the first 5 years of the plan - The Planning Inspectorate, LDF: Examining DPDs: Learning from experience, September 2009, Paragraph 22 - 'For at least the first 5 years of the plan it should be clear what infrastructure is required, who is going to fund and provide it and how it is to relate to the rate of development'.. Paragraph 10.15 of the CS highlights the importance of public transport links for new developments and implies that developers may be required to contribute towards public transport provision. However, it is noted that developer contributions cannot be expected to pay for all transport improvements and as such, in line with the recent Planning Inspectorate document outlined above additional sources of funding should be identified. It is recommended that alternative sources of funding for public transport improvements are clearly outlined within the CS to ensure that adequate infrastructure provision is made.

Policy T4 - South Essex Rapid Transit

As mentioned in our response to the Core Strategy Issues and options consultation the HA is supportive of this policy and the need to progress the route through South Essex. This has the potential to reduce the impact on the SRN (A13).

Policy T5 - Travel Plans

The HA welcomes the requirement for a travel plan for developments involving both destination and origin trips. However it is noted that no threshold for employment sites have been specified. Essex County Council requires the production of a workplace travel plan for developments with over 50 employees or where there will be a significant impact on the local road network. To avoid ambiguity for developers, the HA recommends that the Rochford District Core Strategy specifies a similar threshold within Policy T5. This will ensure the Core Strategy is in line with PPG13 paragraph 87 - PPG13 - 'Local authorities are expected to consider setting local targets for the adoption of travel plans by local businesses and other organizations..'

Policy ED2 - London Southend Airport

The HA previously responded to the London Southend and Environs Joint Area Action Plan Preferred Options Document (March 2009). As such, we have not repeated our comments here but instead refer you to our consultation response dated 31 March 2009.

Thank you for inviting the Highways Agency (HA) to comment on the Rochford Core Strategy (CS) Submission Document and Rochford Area Action plan (AAP) prepared by Rochford District Council

As you are aware the HA is an executive agency of the Department for Transport (DfT). We are responsible for operating, maintaining and improving England's motorway and all-purpose trunk road network, collectively known as the Strategic Road Network (SRN), on behalf of the Secretary of State for Transport.

In spatial planning and development control terms, we have a duty to safeguard the operation of the motorway and trunk road network as set out in the Department for Transport Circular: 02/2007: Planning and the Strategic Road Network. http://www.dft.gov.uk/pgr/regional/strategy/policy/circular207planningandstrategic. The circular encourages the HA to work co-operatively with Local Planning Authorities within the framework of the Government's policies for planning, growth areas, regeneration, integrated transport and sustainability. We look to your Council's Local Development Framework to promote strategies, policies and land allocations which would support alternatives to the private car.

In the case of Rochford there are no trunk roads within the District although there are two strategic corridors namely the A13 and A127/A1159 which connect into the M25 motorway network at Junctions 30 and 29 respectively. Sections of these areas are currently heavily congested, particularly during peak periods, and operate under considerable levels of network stress. Therefore it is important to the HA that the impact of major development proposals in the Rochford area is considered within the context of future impact on the M25 and the A13 Trunk Road.

Please see below some general comments regarding the soundness of the CS and SSA from a transport perspective, referring to specific proposed submission policies as necessary. This response has been completed with reference to paragraph 4.52 of PPS12 (2008) PPS12, paragraph 4.52 - To be 'sound' a core strategy should be JUSTIFIED, EFFECTIVE and consistent with NATIONAL POLICY.

CORE STRATEGY

Policy GB1 - Green Belt Protection

The HA acknowledges that only the minimum amount of Green Belt land will be allocated to meet the District's housing and employment needs as necessary. However, the HA is concerned that any proposed redevelopment of greenbelt sites could result in development in areas with limited access to sustainable transport modes therefore resulting in higher levels of car usage and subsequent impact on the SRN. Although the HA recognizes that new public transport hubs that would facilitate the use of non-car modes could be developed over time, this process is likely to require very substantial investment.

It is therefore important that an appropriate assessment of infrastructure requirements is performed for development sites on Green Belt land. Funding towards the necessary public transport infrastructure improvements must be sought and secured prior to occupation of any new development on greenbelt land. Furthermore, the occupation of such developments should be phased in line with necessary transport infrastructure. This will help the CS meet the PPS12 requirement that a sound DPD should be 'justified' and 'effective' and hence deliverable.

Policy T1 - Highways

Policy T1 highlights the need to reduce reliance on the private car but also observes that 'some impact on the highway network is inevitable'. In a District with such high levels of private car ownership and a limited public transport network, as stated in paragraph 10.2, it will be important to assess the potential impacts to the highway network and ensure that mitigation measures are proposed and implemented where necessary.

An emphasis should be placed on the provision and improvement of sustainable transport infrastructure, particularly where high trip-generating developments such as offices are proposed. In line with the DfT's Guidance on Transport Assessment (2007) - DfT GTA, paragraph 4.51 - 'The key issue is the need to ensure that development proposals strive to achieve nil detriment ('no worse off') to the strategic network, for the opening year and appropriate horizon year'. This emphasis will assist in mitigating potential increases in private vehicle trips and hence help ensure that there is a nil-detriment effect on the SRN.

Policy T3 - Public Transport

The recent Planning Inspectorate 'LDF - Learning from Experience' document (September 2009) suggests that a Core Strategy should identify a clear source of funding for infrastructure for at least the first 5 years of the plan - The Planning Inspectorate, LDF: Examining DPDs: Learning from experience, September 2009, Paragraph 22 - 'For at least the first 5 years of the plan it should be clear what infrastructure is required, who is going to fund and provide it and how it is to relate to the rate of development'.. Paragraph 10.15 of the CS highlights the importance of public transport links for new developments and implies that developers may be required to contribute towards public transport provision. However, it is noted that developer contributions cannot be expected to pay for all transport improvements and as such, in line with the recent Planning Inspectorate document outlined above additional sources of funding should be identified. It is recommended that alternative sources of funding for public transport improvements are clearly outlined within the CS to ensure that adequate infrastructure provision is made.

Policy T4 - South Essex Rapid Transit

As mentioned in our response to the Core Strategy Issues and options consultation the HA is supportive of this policy and the need to progress the route through South Essex. This has the potential to reduce the impact on the SRN (A13).

Policy T5 - Travel Plans

The HA welcomes the requirement for a travel plan for developments involving both destination and origin trips. However it is noted that no threshold for employment sites have been specified. Essex County Council requires the production of a workplace travel plan for developments with over 50 employees or where there will be a significant impact on the local road network. To avoid ambiguity for developers, the HA recommends that the Rochford District Core Strategy specifies a similar threshold within Policy T5. This will ensure the Core Strategy is in line with PPG13 paragraph 87 - PPG13 - 'Local authorities are expected to consider setting local targets for the adoption of travel plans by local businesses and other organizations..'

Policy ED2 - London Southend Airport

The HA previously responded to the London Southend and Environs Joint Area Action Plan Preferred Options Document (March 2009). As such, we have not repeated our comments here but instead refer you to our consultation response dated 31 March 2009.