Rayleigh Town Centre Area Action Plan - Issues and Options

A. OVERVIEW

The preparation of an Area Action Plan for Rayleigh Town Centre is welcomed and supported. The Plan should enable a clear strategy to emerge that will maintain and enhance the role and status of the town centre in a sustainable manner that contributes positively to the needs of the local community. Generally the Issues and Options document presents a clear analysis of the issues that Rayleigh town centre faces. Detailed comments on aspects of the analysis are set out elsewhere in this response.

The County Council would welcome further discussion with the District Council at the earliest opportunity as the Plan moves forward to the Preferred Options stage. On the basis of the Issues and Options document there are two areas in particular where early discussion would be beneficial,

the operational requirements of County Council service departments within Rayleigh Town Centre, for example, the Issues and Options document (page 46) suggests the relocation of the library;
the technical feasibility of any highways and transport proposals, having regard to their impact on the functioning and safety of the highway network and the cost and deliverability of highway and transportation requirements (see also response on Options below).

Also, as the Area Action Plan evolves it should,

establish a clearer relationship between its intended outcomes and those of the Rayleigh Conservation Area and Management Plan and the Design Guidelines for Conservation Areas (SPD6).
include consideration of the accessibility needs of all sectors of the population to the town centre. Key words, such as 'inclusive' and 'accessibility', are absent from the Issues and Options document (see also response on Detailed Comments below). An Equality Impact Assessment of the town centre would help ensure that the town centre is capable of satisfactorily meeting the needs of all members of the community in respect of the services and facilities it will provide, and how the Plan should promote and influence accessible design.

B. VISION AND OBJECTIVES

The Vision and Objectives proposed for the Plan are generally supported but could be enhanced by,

In the Vision by,

amending the text in lines five and six to read, '....creating a vibrant, attractive, accessible, inclusive and welcoming centre for all....', to emphasise the intent that the town centre should serve the needs of all sectors of the community;
including 'residential' in the listed mix of uses, to reflect the highlighting of new town centre residential development in Objective 3 and the encouragement throughout the Issues and Options document for inclusion of residential accommodation in town centre schemes.

In the Objectives by,

making reference to 'sustainable development' within Objective 3, to clarify that any development proposals should accord with sustainable principles;
retitling Objective 4 to read 'Improve inclusive and sustainable access to the town centre', to clarify that any transport proposals should accord with sustainable principles;
adding a bullet to Objective 4 to read 'ensure accessible and inclusive provision of town centre services and facilities for all sectors of the community' in support of the inclusion of 'accessible' and 'inclusive' in the Vision.

C. OPTIONS

To a significant degree the Options choices for Rayleigh town centre are likely to hinge on financial considerations, in respect of both private and public sector investment. The County Council prefers not to comment on the individual options that are presented in the Issues and Options document. Rather, the County Council has reviewed the suggested options and sets out comments below on considerations that will need to be taken into account in moving towards the Preferred Option. The County Council would welcome early discussion during the preparation of the Preferred Option of any matters which would impact on its own operational requirements and service delivery within Rayleigh town centre.

A key matter informing preparation of the Preferred Option will be the circulation and management of traffic within the town centre. The County Council would agree with the proposition of Question 15 in the Issues and Options document that there is merit in maintaining the current direction of flow of traffic through the town centre. From the information available within the Issues and Options document it appears that the disbenefits of pedestrianisation of the high Street outweigh the benefits. It is unlikely that traffic currently using the High Street can be accommodated satisfactorily elsewhere on the local network. Alternative routes to relieve congestion on Websters Way are problematic and 'rat running' down residential streets would have to be avoided.

In addition, particular matters that require further study and examination during the remaining stages of the Area Action Plan should include consideration of,

provision of good alternative means of travel to the centre of Rayleigh for local people before the provision of additional town centre parking in an already congested area. For instance, how would the provision of extra car parking on Websters Way affect the desire to relieve congestion along that route? Whilst car parking may promote economic growth in the town centre, it could well increase congestion and traffic in the town centre which will have a negative effect on access to the centre for car drivers. Additionally, conditions for pedestrians, cyclists and bus users as well as the quality of the public realm will be adversely affected by increased volumes of traffic. These in turn could reduce the attractiveness of the centre and discourage economic growth;
the necessary transport assessments and programming of delivery of impact mitigation for any proposed changes to junction operation and layouts. In particular, the removal of highway guard railing should only be undertaken after the necessary public risk and safety assessments have confirmed its practicality at appropriate locations;
how cyclists would use, and could be better accommodated by the local network, including improved provision for cycle access and parking within the High Street;
how the Area Action Plan may assist enhancement of walking and cycling routes and links through the town centre to other parts of the town. The Issues and Options document (page 50) considers the need to improve routes between the town centre and the railway station. However, the town centre also includes routes used by pupils on their way to and from school. Proposals for the town centre should analyse and incorporate cross town routes to the two secondary schools, which with improved pedestrian priority, especially at key junctions, could reduce school-run traffic and town centre congestion without the need for major infrastructure schemes;
the implications of any proposals to provide a more attractive series of spaces through provision of shared surfaces within the High Street for,
the location of bus stops in regard to accommodating high kerbs that assist access to low floor buses by the disabled and the elderly;
the requirements for accessible Blue Badge disabled people's parking spaces;
provision of clearly delineated routes to assist accessibility by, for example, the visually impaired and those using mobility aids, to minimise the risk of accident/collision in congested areas or adjacent to pavement cafes;
the role of the town centre taxi rank in providing accessibility to the centre. Taxi ranks are an important form of public transport and improve accessibility for disabled and elderly people and those without access to a car. They are also an important support to any desire to provide more evening leisure facilities in the town centre;
any relocation of the market would need careful consideration in relation to transportation issues in the town centre, in particular the operation of bus services;
the potential survival of extensive urban archaeological deposits, particularly in the area of Rayleigh Mount and Mill, and at potential development sites in the town centre (including the Police Station/Somerfield, Rayleigh Mount and Mill, Rayleigh Lanes and Websters Way sites) and the impacts that any future development will have upon this resource.
the measures necessary to ensure that high quality design is evident throughout and that accessible routes to and within the town centre, together with inclusive access points to premises, are addressed sufficiently.

D. DETAILED COMMENTS

1. Accessibility and Inclusion

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.2.7 - the second sentence should be amended to read, 'Direct, safe, accessible and well-signed routes should be considered.'
Paragraph 2.3.5 bullet 4 - should refer to provision of Blue Badge disabled people's parking;
Paragraph 2.3.11 - should refer to the area being as accessible and inclusive as possible while seeking to preserve the historic value of the town centre;
Paragraph 2.5.6 - should refer to 'accessibility' in line with the requirement within the same RSS Policy ENV7 (paragraph 2, bullet5) to 'have regard to the needs and well being of all sectors of the community'.
Paragraph 2.5.13 - should also refer to the need for Lifetime homes.
Paragraphs 2.7.8 to 2.7.12 (Parking) - do not address the requirements for Blue Badge disabled people's parking spaces.
Paragraph 2.8.1(5) - pavement parking causes obstruction and danger to certain sectors of the community, for example, the visually impaired, and, as a known and current issue, should be addressed through other available enforcement measures. Other examples of obstruction can arise through the use of shared space in town centres (see following two bullets) and the further preparation of the Area Action Plan should include measures to secure the safety of all visitors to the town centre.
Page 39, Issue 1 (High Option) - suggests a 'shared space scheme along High Street' which could be a concern, particularly to the visually impaired, in the current absence of national best practice guidance. If implemented it would be necessary for clear delineated routes to be provided.
Pages 42 and 49 - are illustrated with photographs of pavement cafés with no guard rails around seated customers and/or in congested areas. Both situations increase the risk of accident/collision for the visually impaired and those using mobility aids. This well illustrates the amount of detailed thought required within the Area Action Plan to ensure that the town centre becomes accessible for, and inclusive of, all sectors of the community.

2. Highways and Transportation

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.7.23 - the approach to cycling is very prescriptive in the Issues section of the document and, if carried forward, could limit future cycle improvements in the town, especially those funded by developers. Paragraph 2.7.23 should be deleted and replaced by, 'The approach to cycling in the town will be to manage traffic speeds and focus on the provision of improved facilities for cyclists including appropriate signage, routes and of cycle parking in the town and at the station.'

Question 1 - cycling and pubic transport are discussed as key issues in Section 2 of the document but they do not appear in the summaries at the end of the Issues section. This gives the perception that these two topics are less important than those highlighted in the Summary of Issues. It is suggested that reference could be made to cycling and public transport within the pedestrian and public realm part of the Summary of Issues, although mention in a new separate paragraph would be more appropriate.

Question 11 - in respect of 'Opportunities between the High Street and Mount' Option 2, bullet 2 should also refer to facilities for cyclists and so should be amended to read '... with formalised pedestrian and cycling routes....'

Para 4.2.22, bullet 1 - it should be noted that delivery of other improvements could be delayed by procedures to formalise routes involving third-party land, such as through pub gardens etc.

Para 4.3.4 - the word 'appropriate' should be inserted into the last sentence as follows, 'Similarly, the appropriate removal of guard railing...'. Increased permeability and legibility of the town centre is supported but it must be balanced with pedestrian safety. The removal of highway guard railing should only be undertaken after necessary public risk and safety assessments have confirmed its practicality at appropriate locations.

3. Urban Design

Where appropriate, the subsequent Area Action Plan should ensure inclusion of guidance on the form and character of future developments. Such guidance should include schematic layouts and perspectives, in separate Design Briefs where appropriate. It would be an important element in achieving acceptable forms of development and helping to ensure that the aims of the Area Action Plan are achieved.

In addition, the following detailed comments on the text of the Issues and Options should inform further progress of the Area Action Plan,

Table 1, Urban design principles, Legibility - within the option statements the application of the principle/objective of 'Legibility' application to Rayleigh seems to cover 'access' rather than 'legibility'. Legibility in urban design terms is more to do with finding one's way around, assisted by landmarks, clear views, clear routes and gateways.

Paragraph 3.2.3 - refers to the Urban Place Supplement 'being adopted by most district and borough councils in Essex' but it would be more appropriate to clearly state Rochford District Council's position on the Supplement.

Figure 35, Rayleigh Town Centre Concept Plan - it is not clear how the content of this Figure fits into the complete structure of the document or the preparation of the options for the town centre. For instance, it shows green links between The Mount and King Georges Field but these are not listed or mentioned in the objectives. Also, the 'gateways' identified in Figure 35 do not correlate with the Nodes/Gateways identified elsewhere in the document, for example, Figure 30.

Figure 22, Broad structuring plan - the purpose of this figure, and its relationship to the remainder of the document, is not clear; especially given that the same features are illustrated more elegantly elsewhere in the document.

General - The document's use of aspirational illustrations from other town centres is welcomed but it is questionable whether all are applicable to, or present appropriate images for Rayleigh.

4. Historic Environment

The inclusion of a section on 'Heritage and Conservation' in the Issues and Options document is welcomed. However, the section principally relates to issues regarding the conservation area and the built environment with little reference to the significant archaeological resource surviving as below ground deposits within the historic medieval core of Rayleigh. It is essential that the Area Action Plan includes reference to these important deposits as they form an essential part of the history of the town and its development. Consideration of the 'Heritage and Conservation' should be broadened to explicitly address the archaeological element of the Historic Environment. Suggested wording to cover this concern is,

'The Historic Environment lends significant character to settlements such as Rayleigh and can provide a positive template for new development. It can also play a key role in creating a 'sense of place' and identities as existing towns/settlements are enhanced. It is important the protection, promotion and enhancement of the historic character and extensive surviving archaeological deposits associated with the development of historic Rayleigh are fully considered so that the adverse impacts of future development can be minimised. Any developments within the town centre and its immediate hinterland will need to fully consider the cultural assets and the high potential for the survival of significant archaeological remains.'

In addition, to ensure that the historic environment is appropriately considered the following amendments to the existing text are suggested,

Paragraph 1.3.3 - amend the final sentence to read 'Holy Trinity Church, Rayleigh Mount and the windmill are distinctive local landmarks.'

Paragraph 2.3.2 - add to the end of the paragraph 'and the Rochford District Historic Environment Characterisation Project'

Paragraph 2.3.3
Amend the first sentence to read, 'Rayleigh is an attractive medieval market town with a strong cultural heritage and a number of attractive and important listed buildings.'
Delete the final sentence of the paragraph and replace with, 'The Rayleigh Historic Town Assessment and the Rochford District Historic Environment Characterisation Project both highlight the extent and character of the heritage/cultural assets within historic Rayleigh. The medieval street pattern including the remains of the market place close to the church, the wide High Street and the castle survive well. Archaeological investigations within the castle and historic town have uncovered a high potential for wide ranging deposits dating from the early medieval period onwards. Both the surviving medieval town morphology and the buried archaeological deposits are particularly sensitive to change.'

Paragraph 2.3.4 - amend the paragraph (noting that the term 'scheduled ancient monuments' has been officially replaced by the term 'scheduled monuments') to read,

'The Rayleigh Conservation Area (designated in 1969 and extended in 2009 - see Figure 9) covers the historic centre of the town and also takes in Rayleigh Mount (the site of the Motte and Bailey Castle), a scheduled monument, on a spur to the north west of the High Street. The conservation area was designated partly in response to rapid development taking place in the High Street. The Rayleigh Conservation Area identifies some of the key features in Rayleigh, including:
24 listed buildings in the historic town area of Rayleigh, all of which are Grade II listed except Holy Trinity Church which is Grade II*.
The most notable of the listed buildings are the Holy Trinity Church, the Windmill (19th century), Kingsleigh House (18th century red brick building on the High Street which has been converted into offices) and Francis House (now Lloyds Bank on the High Street)
The core elements of the original medieval street pattern/morphology of the town and its association to the castle still remains legible today
Rayleigh has an exceptionally wide High Street (a feature of its development as a market town in the medieval period), presided over at one end by Holy Trinity Church and the remains of the market place.
Rayleigh Mount, the site of a Norman castle, given to the National Trust in 1923 and designated a scheduled monument. Rayleigh Mount is a site of national importance because it survives as one of the earliest Motte and Bailey Castles in England. Built between 1066 and 1086 it is one of the very few castles mentioned in Domesday. The castle lost its importance in the 13th century, was used as a stone quarry for the construction of Hadleigh Castle, a Royal Stud and latterly a farmyard. It is now a key area of open space and is a popular venue for recreational purposes.
A High Street which consists largely of 20th century buildings but also includes significant buildings from the late medieval and post medieval periods ( 16th-18th centuries) which represent an important historic, archaeological and architectural resource, which continue to contribute to the town's historic character and sense of place.
Attractive views looking up and down the High Street (in contrast to the unattractive ones looking up and down Websters Way).
Attractive views over the surrounding countryside from the top of London Hill.

Paragraph 2.4.1 - amend the second sentence to read, 'The Y shaped High Street, incorporating a fossilised market place at its northern end, remains intact...'

A. OVERVIEW

The preparation of an Area Action Plan for Rayleigh Town Centre is welcomed and supported. The Plan should enable a clear strategy to emerge that will maintain and enhance the role and status of the town centre in a sustainable manner that contributes positively to the needs of the local community. Generally the Issues and Options document presents a clear analysis of the issues that Rayleigh town centre faces. Detailed comments on aspects of the analysis are set out elsewhere in this response.

The County Council would welcome further discussion with the District Council at the earliest opportunity as the Plan moves forward to the Preferred Options stage. On the basis of the Issues and Options document there are two areas in particular where early discussion would be beneficial,

the operational requirements of County Council service departments within Rayleigh Town Centre, for example, the Issues and Options document (page 46) suggests the relocation of the library;
the technical feasibility of any highways and transport proposals, having regard to their impact on the functioning and safety of the highway network and the cost and deliverability of highway and transportation requirements (see also response on Options below).

Also, as the Area Action Plan evolves it should,

establish a clearer relationship between its intended outcomes and those of the Rayleigh Conservation Area and Management Plan and the Design Guidelines for Conservation Areas (SPD6).
include consideration of the accessibility needs of all sectors of the population to the town centre. Key words, such as 'inclusive' and 'accessibility', are absent from the Issues and Options document (see also response on Detailed Comments below). An Equality Impact Assessment of the town centre would help ensure that the town centre is capable of satisfactorily meeting the needs of all members of the community in respect of the services and facilities it will provide, and how the Plan should promote and influence accessible design.

B. VISION AND OBJECTIVES

The Vision and Objectives proposed for the Plan are generally supported but could be enhanced by,

In the Vision by,

amending the text in lines five and six to read, '....creating a vibrant, attractive, accessible, inclusive and welcoming centre for all....', to emphasise the intent that the town centre should serve the needs of all sectors of the community;
including 'residential' in the listed mix of uses, to reflect the highlighting of new town centre residential development in Objective 3 and the encouragement throughout the Issues and Options document for inclusion of residential accommodation in town centre schemes.

In the Objectives by,

making reference to 'sustainable development' within Objective 3, to clarify that any development proposals should accord with sustainable principles;
retitling Objective 4 to read 'Improve inclusive and sustainable access to the town centre', to clarify that any transport proposals should accord with sustainable principles;
adding a bullet to Objective 4 to read 'ensure accessible and inclusive provision of town centre services and facilities for all sectors of the community' in support of the inclusion of 'accessible' and 'inclusive' in the Vision.

C. OPTIONS

To a significant degree the Options choices for Rayleigh town centre are likely to hinge on financial considerations, in respect of both private and public sector investment. The County Council prefers not to comment on the individual options that are presented in the Issues and Options document. Rather, the County Council has reviewed the suggested options and sets out comments below on considerations that will need to be taken into account in moving towards the Preferred Option. The County Council would welcome early discussion during the preparation of the Preferred Option of any matters which would impact on its own operational requirements and service delivery within Rayleigh town centre.

A key matter informing preparation of the Preferred Option will be the circulation and management of traffic within the town centre. The County Council would agree with the proposition of Question 15 in the Issues and Options document that there is merit in maintaining the current direction of flow of traffic through the town centre. From the information available within the Issues and Options document it appears that the disbenefits of pedestrianisation of the high Street outweigh the benefits. It is unlikely that traffic currently using the High Street can be accommodated satisfactorily elsewhere on the local network. Alternative routes to relieve congestion on Websters Way are problematic and 'rat running' down residential streets would have to be avoided.

In addition, particular matters that require further study and examination during the remaining stages of the Area Action Plan should include consideration of,

provision of good alternative means of travel to the centre of Rayleigh for local people before the provision of additional town centre parking in an already congested area. For instance, how would the provision of extra car parking on Websters Way affect the desire to relieve congestion along that route? Whilst car parking may promote economic growth in the town centre, it could well increase congestion and traffic in the town centre which will have a negative effect on access to the centre for car drivers. Additionally, conditions for pedestrians, cyclists and bus users as well as the quality of the public realm will be adversely affected by increased volumes of traffic. These in turn could reduce the attractiveness of the centre and discourage economic growth;
the necessary transport assessments and programming of delivery of impact mitigation for any proposed changes to junction operation and layouts. In particular, the removal of highway guard railing should only be undertaken after the necessary public risk and safety assessments have confirmed its practicality at appropriate locations;
how cyclists would use, and could be better accommodated by the local network, including improved provision for cycle access and parking within the High Street;
how the Area Action Plan may assist enhancement of walking and cycling routes and links through the town centre to other parts of the town. The Issues and Options document (page 50) considers the need to improve routes between the town centre and the railway station. However, the town centre also includes routes used by pupils on their way to and from school. Proposals for the town centre should analyse and incorporate cross town routes to the two secondary schools, which with improved pedestrian priority, especially at key junctions, could reduce school-run traffic and town centre congestion without the need for major infrastructure schemes;
the implications of any proposals to provide a more attractive series of spaces through provision of shared surfaces within the High Street for,
the location of bus stops in regard to accommodating high kerbs that assist access to low floor buses by the disabled and the elderly;
the requirements for accessible Blue Badge disabled people's parking spaces;
provision of clearly delineated routes to assist accessibility by, for example, the visually impaired and those using mobility aids, to minimise the risk of accident/collision in congested areas or adjacent to pavement cafes;
the role of the town centre taxi rank in providing accessibility to the centre. Taxi ranks are an important form of public transport and improve accessibility for disabled and elderly people and those without access to a car. They are also an important support to any desire to provide more evening leisure facilities in the town centre;
any relocation of the market would need careful consideration in relation to transportation issues in the town centre, in particular the operation of bus services;
the potential survival of extensive urban archaeological deposits, particularly in the area of Rayleigh Mount and Mill, and at potential development sites in the town centre (including the Police Station/Somerfield, Rayleigh Mount and Mill, Rayleigh Lanes and Websters Way sites) and the impacts that any future development will have upon this resource.
the measures necessary to ensure that high quality design is evident throughout and that accessible routes to and within the town centre, together with inclusive access points to premises, are addressed sufficiently.

D. DETAILED COMMENTS

1. Accessibility and Inclusion

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.2.7 - the second sentence should be amended to read, 'Direct, safe, accessible and well-signed routes should be considered.'
Paragraph 2.3.5 bullet 4 - should refer to provision of Blue Badge disabled people's parking;
Paragraph 2.3.11 - should refer to the area being as accessible and inclusive as possible while seeking to preserve the historic value of the town centre;
Paragraph 2.5.6 - should refer to 'accessibility' in line with the requirement within the same RSS Policy ENV7 (paragraph 2, bullet5) to 'have regard to the needs and well being of all sectors of the community'.
Paragraph 2.5.13 - should also refer to the need for Lifetime homes.
Paragraphs 2.7.8 to 2.7.12 (Parking) - do not address the requirements for Blue Badge disabled people's parking spaces.
Paragraph 2.8.1(5) - pavement parking causes obstruction and danger to certain sectors of the community, for example, the visually impaired, and, as a known and current issue, should be addressed through other available enforcement measures. Other examples of obstruction can arise through the use of shared space in town centres (see following two bullets) and the further preparation of the Area Action Plan should include measures to secure the safety of all visitors to the town centre.
Page 39, Issue 1 (High Option) - suggests a 'shared space scheme along High Street' which could be a concern, particularly to the visually impaired, in the current absence of national best practice guidance. If implemented it would be necessary for clear delineated routes to be provided.
Pages 42 and 49 - are illustrated with photographs of pavement cafés with no guard rails around seated customers and/or in congested areas. Both situations increase the risk of accident/collision for the visually impaired and those using mobility aids. This well illustrates the amount of detailed thought required within the Area Action Plan to ensure that the town centre becomes accessible for, and inclusive of, all sectors of the community.

2. Highways and Transportation

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.7.23 - the approach to cycling is very prescriptive in the Issues section of the document and, if carried forward, could limit future cycle improvements in the town, especially those funded by developers. Paragraph 2.7.23 should be deleted and replaced by, 'The approach to cycling in the town will be to manage traffic speeds and focus on the provision of improved facilities for cyclists including appropriate signage, routes and of cycle parking in the town and at the station.'

Question 1 - cycling and pubic transport are discussed as key issues in Section 2 of the document but they do not appear in the summaries at the end of the Issues section. This gives the perception that these two topics are less important than those highlighted in the Summary of Issues. It is suggested that reference could be made to cycling and public transport within the pedestrian and public realm part of the Summary of Issues, although mention in a new separate paragraph would be more appropriate.

Question 11 - in respect of 'Opportunities between the High Street and Mount' Option 2, bullet 2 should also refer to facilities for cyclists and so should be amended to read '... with formalised pedestrian and cycling routes....'

Para 4.2.22, bullet 1 - it should be noted that delivery of other improvements could be delayed by procedures to formalise routes involving third-party land, such as through pub gardens etc.

Para 4.3.4 - the word 'appropriate' should be inserted into the last sentence as follows, 'Similarly, the appropriate removal of guard railing...'. Increased permeability and legibility of the town centre is supported but it must be balanced with pedestrian safety. The removal of highway guard railing should only be undertaken after necessary public risk and safety assessments have confirmed its practicality at appropriate locations.

3. Urban Design

Where appropriate, the subsequent Area Action Plan should ensure inclusion of guidance on the form and character of future developments. Such guidance should include schematic layouts and perspectives, in separate Design Briefs where appropriate. It would be an important element in achieving acceptable forms of development and helping to ensure that the aims of the Area Action Plan are achieved.

In addition, the following detailed comments on the text of the Issues and Options should inform further progress of the Area Action Plan,

Table 1, Urban design principles, Legibility - within the option statements the application of the principle/objective of 'Legibility' application to Rayleigh seems to cover 'access' rather than 'legibility'. Legibility in urban design terms is more to do with finding one's way around, assisted by landmarks, clear views, clear routes and gateways.

Paragraph 3.2.3 - refers to the Urban Place Supplement 'being adopted by most district and borough councils in Essex' but it would be more appropriate to clearly state Rochford District Council's position on the Supplement.

Figure 35, Rayleigh Town Centre Concept Plan - it is not clear how the content of this Figure fits into the complete structure of the document or the preparation of the options for the town centre. For instance, it shows green links between The Mount and King Georges Field but these are not listed or mentioned in the objectives. Also, the 'gateways' identified in Figure 35 do not correlate with the Nodes/Gateways identified elsewhere in the document, for example, Figure 30.

Figure 22, Broad structuring plan - the purpose of this figure, and its relationship to the remainder of the document, is not clear; especially given that the same features are illustrated more elegantly elsewhere in the document.

General - The document's use of aspirational illustrations from other town centres is welcomed but it is questionable whether all are applicable to, or present appropriate images for Rayleigh.

4. Historic Environment

The inclusion of a section on 'Heritage and Conservation' in the Issues and Options document is welcomed. However, the section principally relates to issues regarding the conservation area and the built environment with little reference to the significant archaeological resource surviving as below ground deposits within the historic medieval core of Rayleigh. It is essential that the Area Action Plan includes reference to these important deposits as they form an essential part of the history of the town and its development. Consideration of the 'Heritage and Conservation' should be broadened to explicitly address the archaeological element of the Historic Environment. Suggested wording to cover this concern is,

'The Historic Environment lends significant character to settlements such as Rayleigh and can provide a positive template for new development. It can also play a key role in creating a 'sense of place' and identities as existing towns/settlements are enhanced. It is important the protection, promotion and enhancement of the historic character and extensive surviving archaeological deposits associated with the development of historic Rayleigh are fully considered so that the adverse impacts of future development can be minimised. Any developments within the town centre and its immediate hinterland will need to fully consider the cultural assets and the high potential for the survival of significant archaeological remains.'

In addition, to ensure that the historic environment is appropriately considered the following amendments to the existing text are suggested,

Paragraph 1.3.3 - amend the final sentence to read 'Holy Trinity Church, Rayleigh Mount and the windmill are distinctive local landmarks.'

Paragraph 2.3.2 - add to the end of the paragraph 'and the Rochford District Historic Environment Characterisation Project'

Paragraph 2.3.3
Amend the first sentence to read, 'Rayleigh is an attractive medieval market town with a strong cultural heritage and a number of attractive and important listed buildings.'
Delete the final sentence of the paragraph and replace with, 'The Rayleigh Historic Town Assessment and the Rochford District Historic Environment Characterisation Project both highlight the extent and character of the heritage/cultural assets within historic Rayleigh. The medieval street pattern including the remains of the market place close to the church, the wide High Street and the castle survive well. Archaeological investigations within the castle and historic town have uncovered a high potential for wide ranging deposits dating from the early medieval period onwards. Both the surviving medieval town morphology and the buried archaeological deposits are particularly sensitive to change.'

Paragraph 2.3.4 - amend the paragraph (noting that the term 'scheduled ancient monuments' has been officially replaced by the term 'scheduled monuments') to read,

'The Rayleigh Conservation Area (designated in 1969 and extended in 2009 - see Figure 9) covers the historic centre of the town and also takes in Rayleigh Mount (the site of the Motte and Bailey Castle), a scheduled monument, on a spur to the north west of the High Street. The conservation area was designated partly in response to rapid development taking place in the High Street. The Rayleigh Conservation Area identifies some of the key features in Rayleigh, including:
24 listed buildings in the historic town area of Rayleigh, all of which are Grade II listed except Holy Trinity Church which is Grade II*.
The most notable of the listed buildings are the Holy Trinity Church, the Windmill (19th century), Kingsleigh House (18th century red brick building on the High Street which has been converted into offices) and Francis House (now Lloyds Bank on the High Street)
The core elements of the original medieval street pattern/morphology of the town and its association to the castle still remains legible today
Rayleigh has an exceptionally wide High Street (a feature of its development as a market town in the medieval period), presided over at one end by Holy Trinity Church and the remains of the market place.
Rayleigh Mount, the site of a Norman castle, given to the National Trust in 1923 and designated a scheduled monument. Rayleigh Mount is a site of national importance because it survives as one of the earliest Motte and Bailey Castles in England. Built between 1066 and 1086 it is one of the very few castles mentioned in Domesday. The castle lost its importance in the 13th century, was used as a stone quarry for the construction of Hadleigh Castle, a Royal Stud and latterly a farmyard. It is now a key area of open space and is a popular venue for recreational purposes.
A High Street which consists largely of 20th century buildings but also includes significant buildings from the late medieval and post medieval periods ( 16th-18th centuries) which represent an important historic, archaeological and architectural resource, which continue to contribute to the town's historic character and sense of place.
Attractive views looking up and down the High Street (in contrast to the unattractive ones looking up and down Websters Way).
Attractive views over the surrounding countryside from the top of London Hill.

Paragraph 2.4.1 - amend the second sentence to read, 'The Y shaped High Street, incorporating a fossilised market place at its northern end, remains intact...'

A. OVERVIEW

The preparation of an Area Action Plan for Rayleigh Town Centre is welcomed and supported. The Plan should enable a clear strategy to emerge that will maintain and enhance the role and status of the town centre in a sustainable manner that contributes positively to the needs of the local community. Generally the Issues and Options document presents a clear analysis of the issues that Rayleigh town centre faces. Detailed comments on aspects of the analysis are set out elsewhere in this response.

The County Council would welcome further discussion with the District Council at the earliest opportunity as the Plan moves forward to the Preferred Options stage. On the basis of the Issues and Options document there are two areas in particular where early discussion would be beneficial,

the operational requirements of County Council service departments within Rayleigh Town Centre, for example, the Issues and Options document (page 46) suggests the relocation of the library;
the technical feasibility of any highways and transport proposals, having regard to their impact on the functioning and safety of the highway network and the cost and deliverability of highway and transportation requirements (see also response on Options below).

Also, as the Area Action Plan evolves it should,

establish a clearer relationship between its intended outcomes and those of the Rayleigh Conservation Area and Management Plan and the Design Guidelines for Conservation Areas (SPD6).
include consideration of the accessibility needs of all sectors of the population to the town centre. Key words, such as 'inclusive' and 'accessibility', are absent from the Issues and Options document (see also response on Detailed Comments below). An Equality Impact Assessment of the town centre would help ensure that the town centre is capable of satisfactorily meeting the needs of all members of the community in respect of the services and facilities it will provide, and how the Plan should promote and influence accessible design.

B. VISION AND OBJECTIVES

The Vision and Objectives proposed for the Plan are generally supported but could be enhanced by,

In the Vision by,

amending the text in lines five and six to read, '....creating a vibrant, attractive, accessible, inclusive and welcoming centre for all....', to emphasise the intent that the town centre should serve the needs of all sectors of the community;
including 'residential' in the listed mix of uses, to reflect the highlighting of new town centre residential development in Objective 3 and the encouragement throughout the Issues and Options document for inclusion of residential accommodation in town centre schemes.

In the Objectives by,

making reference to 'sustainable development' within Objective 3, to clarify that any development proposals should accord with sustainable principles;
retitling Objective 4 to read 'Improve inclusive and sustainable access to the town centre', to clarify that any transport proposals should accord with sustainable principles;
adding a bullet to Objective 4 to read 'ensure accessible and inclusive provision of town centre services and facilities for all sectors of the community' in support of the inclusion of 'accessible' and 'inclusive' in the Vision.

C. OPTIONS

To a significant degree the Options choices for Rayleigh town centre are likely to hinge on financial considerations, in respect of both private and public sector investment. The County Council prefers not to comment on the individual options that are presented in the Issues and Options document. Rather, the County Council has reviewed the suggested options and sets out comments below on considerations that will need to be taken into account in moving towards the Preferred Option. The County Council would welcome early discussion during the preparation of the Preferred Option of any matters which would impact on its own operational requirements and service delivery within Rayleigh town centre.

A key matter informing preparation of the Preferred Option will be the circulation and management of traffic within the town centre. The County Council would agree with the proposition of Question 15 in the Issues and Options document that there is merit in maintaining the current direction of flow of traffic through the town centre. From the information available within the Issues and Options document it appears that the disbenefits of pedestrianisation of the high Street outweigh the benefits. It is unlikely that traffic currently using the High Street can be accommodated satisfactorily elsewhere on the local network. Alternative routes to relieve congestion on Websters Way are problematic and 'rat running' down residential streets would have to be avoided.

In addition, particular matters that require further study and examination during the remaining stages of the Area Action Plan should include consideration of,

provision of good alternative means of travel to the centre of Rayleigh for local people before the provision of additional town centre parking in an already congested area. For instance, how would the provision of extra car parking on Websters Way affect the desire to relieve congestion along that route? Whilst car parking may promote economic growth in the town centre, it could well increase congestion and traffic in the town centre which will have a negative effect on access to the centre for car drivers. Additionally, conditions for pedestrians, cyclists and bus users as well as the quality of the public realm will be adversely affected by increased volumes of traffic. These in turn could reduce the attractiveness of the centre and discourage economic growth;
the necessary transport assessments and programming of delivery of impact mitigation for any proposed changes to junction operation and layouts. In particular, the removal of highway guard railing should only be undertaken after the necessary public risk and safety assessments have confirmed its practicality at appropriate locations;
how cyclists would use, and could be better accommodated by the local network, including improved provision for cycle access and parking within the High Street;
how the Area Action Plan may assist enhancement of walking and cycling routes and links through the town centre to other parts of the town. The Issues and Options document (page 50) considers the need to improve routes between the town centre and the railway station. However, the town centre also includes routes used by pupils on their way to and from school. Proposals for the town centre should analyse and incorporate cross town routes to the two secondary schools, which with improved pedestrian priority, especially at key junctions, could reduce school-run traffic and town centre congestion without the need for major infrastructure schemes;
the implications of any proposals to provide a more attractive series of spaces through provision of shared surfaces within the High Street for,
the location of bus stops in regard to accommodating high kerbs that assist access to low floor buses by the disabled and the elderly;
the requirements for accessible Blue Badge disabled people's parking spaces;
provision of clearly delineated routes to assist accessibility by, for example, the visually impaired and those using mobility aids, to minimise the risk of accident/collision in congested areas or adjacent to pavement cafes;
the role of the town centre taxi rank in providing accessibility to the centre. Taxi ranks are an important form of public transport and improve accessibility for disabled and elderly people and those without access to a car. They are also an important support to any desire to provide more evening leisure facilities in the town centre;
any relocation of the market would need careful consideration in relation to transportation issues in the town centre, in particular the operation of bus services;
the potential survival of extensive urban archaeological deposits, particularly in the area of Rayleigh Mount and Mill, and at potential development sites in the town centre (including the Police Station/Somerfield, Rayleigh Mount and Mill, Rayleigh Lanes and Websters Way sites) and the impacts that any future development will have upon this resource.
the measures necessary to ensure that high quality design is evident throughout and that accessible routes to and within the town centre, together with inclusive access points to premises, are addressed sufficiently.

D. DETAILED COMMENTS

1. Accessibility and Inclusion

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.2.7 - the second sentence should be amended to read, 'Direct, safe, accessible and well-signed routes should be considered.'
Paragraph 2.3.5 bullet 4 - should refer to provision of Blue Badge disabled people's parking;
Paragraph 2.3.11 - should refer to the area being as accessible and inclusive as possible while seeking to preserve the historic value of the town centre;
Paragraph 2.5.6 - should refer to 'accessibility' in line with the requirement within the same RSS Policy ENV7 (paragraph 2, bullet5) to 'have regard to the needs and well being of all sectors of the community'.
Paragraph 2.5.13 - should also refer to the need for Lifetime homes.
Paragraphs 2.7.8 to 2.7.12 (Parking) - do not address the requirements for Blue Badge disabled people's parking spaces.
Paragraph 2.8.1(5) - pavement parking causes obstruction and danger to certain sectors of the community, for example, the visually impaired, and, as a known and current issue, should be addressed through other available enforcement measures. Other examples of obstruction can arise through the use of shared space in town centres (see following two bullets) and the further preparation of the Area Action Plan should include measures to secure the safety of all visitors to the town centre.
Page 39, Issue 1 (High Option) - suggests a 'shared space scheme along High Street' which could be a concern, particularly to the visually impaired, in the current absence of national best practice guidance. If implemented it would be necessary for clear delineated routes to be provided.
Pages 42 and 49 - are illustrated with photographs of pavement cafés with no guard rails around seated customers and/or in congested areas. Both situations increase the risk of accident/collision for the visually impaired and those using mobility aids. This well illustrates the amount of detailed thought required within the Area Action Plan to ensure that the town centre becomes accessible for, and inclusive of, all sectors of the community.

2. Highways and Transportation

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.7.23 - the approach to cycling is very prescriptive in the Issues section of the document and, if carried forward, could limit future cycle improvements in the town, especially those funded by developers. Paragraph 2.7.23 should be deleted and replaced by, 'The approach to cycling in the town will be to manage traffic speeds and focus on the provision of improved facilities for cyclists including appropriate signage, routes and of cycle parking in the town and at the station.'

Question 1 - cycling and pubic transport are discussed as key issues in Section 2 of the document but they do not appear in the summaries at the end of the Issues section. This gives the perception that these two topics are less important than those highlighted in the Summary of Issues. It is suggested that reference could be made to cycling and public transport within the pedestrian and public realm part of the Summary of Issues, although mention in a new separate paragraph would be more appropriate.

Question 11 - in respect of 'Opportunities between the High Street and Mount' Option 2, bullet 2 should also refer to facilities for cyclists and so should be amended to read '... with formalised pedestrian and cycling routes....'

Para 4.2.22, bullet 1 - it should be noted that delivery of other improvements could be delayed by procedures to formalise routes involving third-party land, such as through pub gardens etc.

Para 4.3.4 - the word 'appropriate' should be inserted into the last sentence as follows, 'Similarly, the appropriate removal of guard railing...'. Increased permeability and legibility of the town centre is supported but it must be balanced with pedestrian safety. The removal of highway guard railing should only be undertaken after necessary public risk and safety assessments have confirmed its practicality at appropriate locations.

3. Urban Design

Where appropriate, the subsequent Area Action Plan should ensure inclusion of guidance on the form and character of future developments. Such guidance should include schematic layouts and perspectives, in separate Design Briefs where appropriate. It would be an important element in achieving acceptable forms of development and helping to ensure that the aims of the Area Action Plan are achieved.

In addition, the following detailed comments on the text of the Issues and Options should inform further progress of the Area Action Plan,

Table 1, Urban design principles, Legibility - within the option statements the application of the principle/objective of 'Legibility' application to Rayleigh seems to cover 'access' rather than 'legibility'. Legibility in urban design terms is more to do with finding one's way around, assisted by landmarks, clear views, clear routes and gateways.

Paragraph 3.2.3 - refers to the Urban Place Supplement 'being adopted by most district and borough councils in Essex' but it would be more appropriate to clearly state Rochford District Council's position on the Supplement.

Figure 35, Rayleigh Town Centre Concept Plan - it is not clear how the content of this Figure fits into the complete structure of the document or the preparation of the options for the town centre. For instance, it shows green links between The Mount and King Georges Field but these are not listed or mentioned in the objectives. Also, the 'gateways' identified in Figure 35 do not correlate with the Nodes/Gateways identified elsewhere in the document, for example, Figure 30.

Figure 22, Broad structuring plan - the purpose of this figure, and its relationship to the remainder of the document, is not clear; especially given that the same features are illustrated more elegantly elsewhere in the document.

General - The document's use of aspirational illustrations from other town centres is welcomed but it is questionable whether all are applicable to, or present appropriate images for Rayleigh.

4. Historic Environment

The inclusion of a section on 'Heritage and Conservation' in the Issues and Options document is welcomed. However, the section principally relates to issues regarding the conservation area and the built environment with little reference to the significant archaeological resource surviving as below ground deposits within the historic medieval core of Rayleigh. It is essential that the Area Action Plan includes reference to these important deposits as they form an essential part of the history of the town and its development. Consideration of the 'Heritage and Conservation' should be broadened to explicitly address the archaeological element of the Historic Environment. Suggested wording to cover this concern is,

'The Historic Environment lends significant character to settlements such as Rayleigh and can provide a positive template for new development. It can also play a key role in creating a 'sense of place' and identities as existing towns/settlements are enhanced. It is important the protection, promotion and enhancement of the historic character and extensive surviving archaeological deposits associated with the development of historic Rayleigh are fully considered so that the adverse impacts of future development can be minimised. Any developments within the town centre and its immediate hinterland will need to fully consider the cultural assets and the high potential for the survival of significant archaeological remains.'

In addition, to ensure that the historic environment is appropriately considered the following amendments to the existing text are suggested,

Paragraph 1.3.3 - amend the final sentence to read 'Holy Trinity Church, Rayleigh Mount and the windmill are distinctive local landmarks.'

Paragraph 2.3.2 - add to the end of the paragraph 'and the Rochford District Historic Environment Characterisation Project'

Paragraph 2.3.3
Amend the first sentence to read, 'Rayleigh is an attractive medieval market town with a strong cultural heritage and a number of attractive and important listed buildings.'
Delete the final sentence of the paragraph and replace with, 'The Rayleigh Historic Town Assessment and the Rochford District Historic Environment Characterisation Project both highlight the extent and character of the heritage/cultural assets within historic Rayleigh. The medieval street pattern including the remains of the market place close to the church, the wide High Street and the castle survive well. Archaeological investigations within the castle and historic town have uncovered a high potential for wide ranging deposits dating from the early medieval period onwards. Both the surviving medieval town morphology and the buried archaeological deposits are particularly sensitive to change.'

Paragraph 2.3.4 - amend the paragraph (noting that the term 'scheduled ancient monuments' has been officially replaced by the term 'scheduled monuments') to read,

'The Rayleigh Conservation Area (designated in 1969 and extended in 2009 - see Figure 9) covers the historic centre of the town and also takes in Rayleigh Mount (the site of the Motte and Bailey Castle), a scheduled monument, on a spur to the north west of the High Street. The conservation area was designated partly in response to rapid development taking place in the High Street. The Rayleigh Conservation Area identifies some of the key features in Rayleigh, including:
24 listed buildings in the historic town area of Rayleigh, all of which are Grade II listed except Holy Trinity Church which is Grade II*.
The most notable of the listed buildings are the Holy Trinity Church, the Windmill (19th century), Kingsleigh House (18th century red brick building on the High Street which has been converted into offices) and Francis House (now Lloyds Bank on the High Street)
The core elements of the original medieval street pattern/morphology of the town and its association to the castle still remains legible today
Rayleigh has an exceptionally wide High Street (a feature of its development as a market town in the medieval period), presided over at one end by Holy Trinity Church and the remains of the market place.
Rayleigh Mount, the site of a Norman castle, given to the National Trust in 1923 and designated a scheduled monument. Rayleigh Mount is a site of national importance because it survives as one of the earliest Motte and Bailey Castles in England. Built between 1066 and 1086 it is one of the very few castles mentioned in Domesday. The castle lost its importance in the 13th century, was used as a stone quarry for the construction of Hadleigh Castle, a Royal Stud and latterly a farmyard. It is now a key area of open space and is a popular venue for recreational purposes.
A High Street which consists largely of 20th century buildings but also includes significant buildings from the late medieval and post medieval periods ( 16th-18th centuries) which represent an important historic, archaeological and architectural resource, which continue to contribute to the town's historic character and sense of place.
Attractive views looking up and down the High Street (in contrast to the unattractive ones looking up and down Websters Way).
Attractive views over the surrounding countryside from the top of London Hill.

Paragraph 2.4.1 - amend the second sentence to read, 'The Y shaped High Street, incorporating a fossilised market place at its northern end, remains intact...'

A. OVERVIEW

The preparation of an Area Action Plan for Rayleigh Town Centre is welcomed and supported. The Plan should enable a clear strategy to emerge that will maintain and enhance the role and status of the town centre in a sustainable manner that contributes positively to the needs of the local community. Generally the Issues and Options document presents a clear analysis of the issues that Rayleigh town centre faces. Detailed comments on aspects of the analysis are set out elsewhere in this response.

The County Council would welcome further discussion with the District Council at the earliest opportunity as the Plan moves forward to the Preferred Options stage. On the basis of the Issues and Options document there are two areas in particular where early discussion would be beneficial,

the operational requirements of County Council service departments within Rayleigh Town Centre, for example, the Issues and Options document (page 46) suggests the relocation of the library;
the technical feasibility of any highways and transport proposals, having regard to their impact on the functioning and safety of the highway network and the cost and deliverability of highway and transportation requirements (see also response on Options below).

Also, as the Area Action Plan evolves it should,

establish a clearer relationship between its intended outcomes and those of the Rayleigh Conservation Area and Management Plan and the Design Guidelines for Conservation Areas (SPD6).
include consideration of the accessibility needs of all sectors of the population to the town centre. Key words, such as 'inclusive' and 'accessibility', are absent from the Issues and Options document (see also response on Detailed Comments below). An Equality Impact Assessment of the town centre would help ensure that the town centre is capable of satisfactorily meeting the needs of all members of the community in respect of the services and facilities it will provide, and how the Plan should promote and influence accessible design.

B. VISION AND OBJECTIVES

The Vision and Objectives proposed for the Plan are generally supported but could be enhanced by,

In the Vision by,

amending the text in lines five and six to read, '....creating a vibrant, attractive, accessible, inclusive and welcoming centre for all....', to emphasise the intent that the town centre should serve the needs of all sectors of the community;
including 'residential' in the listed mix of uses, to reflect the highlighting of new town centre residential development in Objective 3 and the encouragement throughout the Issues and Options document for inclusion of residential accommodation in town centre schemes.

In the Objectives by,

making reference to 'sustainable development' within Objective 3, to clarify that any development proposals should accord with sustainable principles;
retitling Objective 4 to read 'Improve inclusive and sustainable access to the town centre', to clarify that any transport proposals should accord with sustainable principles;
adding a bullet to Objective 4 to read 'ensure accessible and inclusive provision of town centre services and facilities for all sectors of the community' in support of the inclusion of 'accessible' and 'inclusive' in the Vision.

C. OPTIONS

To a significant degree the Options choices for Rayleigh town centre are likely to hinge on financial considerations, in respect of both private and public sector investment. The County Council prefers not to comment on the individual options that are presented in the Issues and Options document. Rather, the County Council has reviewed the suggested options and sets out comments below on considerations that will need to be taken into account in moving towards the Preferred Option. The County Council would welcome early discussion during the preparation of the Preferred Option of any matters which would impact on its own operational requirements and service delivery within Rayleigh town centre.

A key matter informing preparation of the Preferred Option will be the circulation and management of traffic within the town centre. The County Council would agree with the proposition of Question 15 in the Issues and Options document that there is merit in maintaining the current direction of flow of traffic through the town centre. From the information available within the Issues and Options document it appears that the disbenefits of pedestrianisation of the high Street outweigh the benefits. It is unlikely that traffic currently using the High Street can be accommodated satisfactorily elsewhere on the local network. Alternative routes to relieve congestion on Websters Way are problematic and 'rat running' down residential streets would have to be avoided.

In addition, particular matters that require further study and examination during the remaining stages of the Area Action Plan should include consideration of,

provision of good alternative means of travel to the centre of Rayleigh for local people before the provision of additional town centre parking in an already congested area. For instance, how would the provision of extra car parking on Websters Way affect the desire to relieve congestion along that route? Whilst car parking may promote economic growth in the town centre, it could well increase congestion and traffic in the town centre which will have a negative effect on access to the centre for car drivers. Additionally, conditions for pedestrians, cyclists and bus users as well as the quality of the public realm will be adversely affected by increased volumes of traffic. These in turn could reduce the attractiveness of the centre and discourage economic growth;
the necessary transport assessments and programming of delivery of impact mitigation for any proposed changes to junction operation and layouts. In particular, the removal of highway guard railing should only be undertaken after the necessary public risk and safety assessments have confirmed its practicality at appropriate locations;
how cyclists would use, and could be better accommodated by the local network, including improved provision for cycle access and parking within the High Street;
how the Area Action Plan may assist enhancement of walking and cycling routes and links through the town centre to other parts of the town. The Issues and Options document (page 50) considers the need to improve routes between the town centre and the railway station. However, the town centre also includes routes used by pupils on their way to and from school. Proposals for the town centre should analyse and incorporate cross town routes to the two secondary schools, which with improved pedestrian priority, especially at key junctions, could reduce school-run traffic and town centre congestion without the need for major infrastructure schemes;
the implications of any proposals to provide a more attractive series of spaces through provision of shared surfaces within the High Street for,
the location of bus stops in regard to accommodating high kerbs that assist access to low floor buses by the disabled and the elderly;
the requirements for accessible Blue Badge disabled people's parking spaces;
provision of clearly delineated routes to assist accessibility by, for example, the visually impaired and those using mobility aids, to minimise the risk of accident/collision in congested areas or adjacent to pavement cafes;
the role of the town centre taxi rank in providing accessibility to the centre. Taxi ranks are an important form of public transport and improve accessibility for disabled and elderly people and those without access to a car. They are also an important support to any desire to provide more evening leisure facilities in the town centre;
any relocation of the market would need careful consideration in relation to transportation issues in the town centre, in particular the operation of bus services;
the potential survival of extensive urban archaeological deposits, particularly in the area of Rayleigh Mount and Mill, and at potential development sites in the town centre (including the Police Station/Somerfield, Rayleigh Mount and Mill, Rayleigh Lanes and Websters Way sites) and the impacts that any future development will have upon this resource.
the measures necessary to ensure that high quality design is evident throughout and that accessible routes to and within the town centre, together with inclusive access points to premises, are addressed sufficiently.

D. DETAILED COMMENTS

1. Accessibility and Inclusion

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.2.7 - the second sentence should be amended to read, 'Direct, safe, accessible and well-signed routes should be considered.'
Paragraph 2.3.5 bullet 4 - should refer to provision of Blue Badge disabled people's parking;
Paragraph 2.3.11 - should refer to the area being as accessible and inclusive as possible while seeking to preserve the historic value of the town centre;
Paragraph 2.5.6 - should refer to 'accessibility' in line with the requirement within the same RSS Policy ENV7 (paragraph 2, bullet5) to 'have regard to the needs and well being of all sectors of the community'.
Paragraph 2.5.13 - should also refer to the need for Lifetime homes.
Paragraphs 2.7.8 to 2.7.12 (Parking) - do not address the requirements for Blue Badge disabled people's parking spaces.
Paragraph 2.8.1(5) - pavement parking causes obstruction and danger to certain sectors of the community, for example, the visually impaired, and, as a known and current issue, should be addressed through other available enforcement measures. Other examples of obstruction can arise through the use of shared space in town centres (see following two bullets) and the further preparation of the Area Action Plan should include measures to secure the safety of all visitors to the town centre.
Page 39, Issue 1 (High Option) - suggests a 'shared space scheme along High Street' which could be a concern, particularly to the visually impaired, in the current absence of national best practice guidance. If implemented it would be necessary for clear delineated routes to be provided.
Pages 42 and 49 - are illustrated with photographs of pavement cafés with no guard rails around seated customers and/or in congested areas. Both situations increase the risk of accident/collision for the visually impaired and those using mobility aids. This well illustrates the amount of detailed thought required within the Area Action Plan to ensure that the town centre becomes accessible for, and inclusive of, all sectors of the community.

2. Highways and Transportation

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.7.23 - the approach to cycling is very prescriptive in the Issues section of the document and, if carried forward, could limit future cycle improvements in the town, especially those funded by developers. Paragraph 2.7.23 should be deleted and replaced by, 'The approach to cycling in the town will be to manage traffic speeds and focus on the provision of improved facilities for cyclists including appropriate signage, routes and of cycle parking in the town and at the station.'

Question 1 - cycling and pubic transport are discussed as key issues in Section 2 of the document but they do not appear in the summaries at the end of the Issues section. This gives the perception that these two topics are less important than those highlighted in the Summary of Issues. It is suggested that reference could be made to cycling and public transport within the pedestrian and public realm part of the Summary of Issues, although mention in a new separate paragraph would be more appropriate.

Question 11 - in respect of 'Opportunities between the High Street and Mount' Option 2, bullet 2 should also refer to facilities for cyclists and so should be amended to read '... with formalised pedestrian and cycling routes....'

Para 4.2.22, bullet 1 - it should be noted that delivery of other improvements could be delayed by procedures to formalise routes involving third-party land, such as through pub gardens etc.

Para 4.3.4 - the word 'appropriate' should be inserted into the last sentence as follows, 'Similarly, the appropriate removal of guard railing...'. Increased permeability and legibility of the town centre is supported but it must be balanced with pedestrian safety. The removal of highway guard railing should only be undertaken after necessary public risk and safety assessments have confirmed its practicality at appropriate locations.

3. Urban Design

Where appropriate, the subsequent Area Action Plan should ensure inclusion of guidance on the form and character of future developments. Such guidance should include schematic layouts and perspectives, in separate Design Briefs where appropriate. It would be an important element in achieving acceptable forms of development and helping to ensure that the aims of the Area Action Plan are achieved.

In addition, the following detailed comments on the text of the Issues and Options should inform further progress of the Area Action Plan,

Table 1, Urban design principles, Legibility - within the option statements the application of the principle/objective of 'Legibility' application to Rayleigh seems to cover 'access' rather than 'legibility'. Legibility in urban design terms is more to do with finding one's way around, assisted by landmarks, clear views, clear routes and gateways.

Paragraph 3.2.3 - refers to the Urban Place Supplement 'being adopted by most district and borough councils in Essex' but it would be more appropriate to clearly state Rochford District Council's position on the Supplement.

Figure 35, Rayleigh Town Centre Concept Plan - it is not clear how the content of this Figure fits into the complete structure of the document or the preparation of the options for the town centre. For instance, it shows green links between The Mount and King Georges Field but these are not listed or mentioned in the objectives. Also, the 'gateways' identified in Figure 35 do not correlate with the Nodes/Gateways identified elsewhere in the document, for example, Figure 30.

Figure 22, Broad structuring plan - the purpose of this figure, and its relationship to the remainder of the document, is not clear; especially given that the same features are illustrated more elegantly elsewhere in the document.

General - The document's use of aspirational illustrations from other town centres is welcomed but it is questionable whether all are applicable to, or present appropriate images for Rayleigh.

4. Historic Environment

The inclusion of a section on 'Heritage and Conservation' in the Issues and Options document is welcomed. However, the section principally relates to issues regarding the conservation area and the built environment with little reference to the significant archaeological resource surviving as below ground deposits within the historic medieval core of Rayleigh. It is essential that the Area Action Plan includes reference to these important deposits as they form an essential part of the history of the town and its development. Consideration of the 'Heritage and Conservation' should be broadened to explicitly address the archaeological element of the Historic Environment. Suggested wording to cover this concern is,

'The Historic Environment lends significant character to settlements such as Rayleigh and can provide a positive template for new development. It can also play a key role in creating a 'sense of place' and identities as existing towns/settlements are enhanced. It is important the protection, promotion and enhancement of the historic character and extensive surviving archaeological deposits associated with the development of historic Rayleigh are fully considered so that the adverse impacts of future development can be minimised. Any developments within the town centre and its immediate hinterland will need to fully consider the cultural assets and the high potential for the survival of significant archaeological remains.'

In addition, to ensure that the historic environment is appropriately considered the following amendments to the existing text are suggested,

Paragraph 1.3.3 - amend the final sentence to read 'Holy Trinity Church, Rayleigh Mount and the windmill are distinctive local landmarks.'

Paragraph 2.3.2 - add to the end of the paragraph 'and the Rochford District Historic Environment Characterisation Project'

Paragraph 2.3.3
Amend the first sentence to read, 'Rayleigh is an attractive medieval market town with a strong cultural heritage and a number of attractive and important listed buildings.'
Delete the final sentence of the paragraph and replace with, 'The Rayleigh Historic Town Assessment and the Rochford District Historic Environment Characterisation Project both highlight the extent and character of the heritage/cultural assets within historic Rayleigh. The medieval street pattern including the remains of the market place close to the church, the wide High Street and the castle survive well. Archaeological investigations within the castle and historic town have uncovered a high potential for wide ranging deposits dating from the early medieval period onwards. Both the surviving medieval town morphology and the buried archaeological deposits are particularly sensitive to change.'

Paragraph 2.3.4 - amend the paragraph (noting that the term 'scheduled ancient monuments' has been officially replaced by the term 'scheduled monuments') to read,

'The Rayleigh Conservation Area (designated in 1969 and extended in 2009 - see Figure 9) covers the historic centre of the town and also takes in Rayleigh Mount (the site of the Motte and Bailey Castle), a scheduled monument, on a spur to the north west of the High Street. The conservation area was designated partly in response to rapid development taking place in the High Street. The Rayleigh Conservation Area identifies some of the key features in Rayleigh, including:
24 listed buildings in the historic town area of Rayleigh, all of which are Grade II listed except Holy Trinity Church which is Grade II*.
The most notable of the listed buildings are the Holy Trinity Church, the Windmill (19th century), Kingsleigh House (18th century red brick building on the High Street which has been converted into offices) and Francis House (now Lloyds Bank on the High Street)
The core elements of the original medieval street pattern/morphology of the town and its association to the castle still remains legible today
Rayleigh has an exceptionally wide High Street (a feature of its development as a market town in the medieval period), presided over at one end by Holy Trinity Church and the remains of the market place.
Rayleigh Mount, the site of a Norman castle, given to the National Trust in 1923 and designated a scheduled monument. Rayleigh Mount is a site of national importance because it survives as one of the earliest Motte and Bailey Castles in England. Built between 1066 and 1086 it is one of the very few castles mentioned in Domesday. The castle lost its importance in the 13th century, was used as a stone quarry for the construction of Hadleigh Castle, a Royal Stud and latterly a farmyard. It is now a key area of open space and is a popular venue for recreational purposes.
A High Street which consists largely of 20th century buildings but also includes significant buildings from the late medieval and post medieval periods ( 16th-18th centuries) which represent an important historic, archaeological and architectural resource, which continue to contribute to the town's historic character and sense of place.
Attractive views looking up and down the High Street (in contrast to the unattractive ones looking up and down Websters Way).
Attractive views over the surrounding countryside from the top of London Hill.

Paragraph 2.4.1 - amend the second sentence to read, 'The Y shaped High Street, incorporating a fossilised market place at its northern end, remains intact...'

A. OVERVIEW

The preparation of an Area Action Plan for Rayleigh Town Centre is welcomed and supported. The Plan should enable a clear strategy to emerge that will maintain and enhance the role and status of the town centre in a sustainable manner that contributes positively to the needs of the local community. Generally the Issues and Options document presents a clear analysis of the issues that Rayleigh town centre faces. Detailed comments on aspects of the analysis are set out elsewhere in this response.

The County Council would welcome further discussion with the District Council at the earliest opportunity as the Plan moves forward to the Preferred Options stage. On the basis of the Issues and Options document there are two areas in particular where early discussion would be beneficial,

the operational requirements of County Council service departments within Rayleigh Town Centre, for example, the Issues and Options document (page 46) suggests the relocation of the library;
the technical feasibility of any highways and transport proposals, having regard to their impact on the functioning and safety of the highway network and the cost and deliverability of highway and transportation requirements (see also response on Options below).

Also, as the Area Action Plan evolves it should,

establish a clearer relationship between its intended outcomes and those of the Rayleigh Conservation Area and Management Plan and the Design Guidelines for Conservation Areas (SPD6).
include consideration of the accessibility needs of all sectors of the population to the town centre. Key words, such as 'inclusive' and 'accessibility', are absent from the Issues and Options document (see also response on Detailed Comments below). An Equality Impact Assessment of the town centre would help ensure that the town centre is capable of satisfactorily meeting the needs of all members of the community in respect of the services and facilities it will provide, and how the Plan should promote and influence accessible design.

B. VISION AND OBJECTIVES

The Vision and Objectives proposed for the Plan are generally supported but could be enhanced by,

In the Vision by,

amending the text in lines five and six to read, '....creating a vibrant, attractive, accessible, inclusive and welcoming centre for all....', to emphasise the intent that the town centre should serve the needs of all sectors of the community;
including 'residential' in the listed mix of uses, to reflect the highlighting of new town centre residential development in Objective 3 and the encouragement throughout the Issues and Options document for inclusion of residential accommodation in town centre schemes.

In the Objectives by,

making reference to 'sustainable development' within Objective 3, to clarify that any development proposals should accord with sustainable principles;
retitling Objective 4 to read 'Improve inclusive and sustainable access to the town centre', to clarify that any transport proposals should accord with sustainable principles;
adding a bullet to Objective 4 to read 'ensure accessible and inclusive provision of town centre services and facilities for all sectors of the community' in support of the inclusion of 'accessible' and 'inclusive' in the Vision.

C. OPTIONS

To a significant degree the Options choices for Rayleigh town centre are likely to hinge on financial considerations, in respect of both private and public sector investment. The County Council prefers not to comment on the individual options that are presented in the Issues and Options document. Rather, the County Council has reviewed the suggested options and sets out comments below on considerations that will need to be taken into account in moving towards the Preferred Option. The County Council would welcome early discussion during the preparation of the Preferred Option of any matters which would impact on its own operational requirements and service delivery within Rayleigh town centre.

A key matter informing preparation of the Preferred Option will be the circulation and management of traffic within the town centre. The County Council would agree with the proposition of Question 15 in the Issues and Options document that there is merit in maintaining the current direction of flow of traffic through the town centre. From the information available within the Issues and Options document it appears that the disbenefits of pedestrianisation of the high Street outweigh the benefits. It is unlikely that traffic currently using the High Street can be accommodated satisfactorily elsewhere on the local network. Alternative routes to relieve congestion on Websters Way are problematic and 'rat running' down residential streets would have to be avoided.

In addition, particular matters that require further study and examination during the remaining stages of the Area Action Plan should include consideration of,

provision of good alternative means of travel to the centre of Rayleigh for local people before the provision of additional town centre parking in an already congested area. For instance, how would the provision of extra car parking on Websters Way affect the desire to relieve congestion along that route? Whilst car parking may promote economic growth in the town centre, it could well increase congestion and traffic in the town centre which will have a negative effect on access to the centre for car drivers. Additionally, conditions for pedestrians, cyclists and bus users as well as the quality of the public realm will be adversely affected by increased volumes of traffic. These in turn could reduce the attractiveness of the centre and discourage economic growth;
the necessary transport assessments and programming of delivery of impact mitigation for any proposed changes to junction operation and layouts. In particular, the removal of highway guard railing should only be undertaken after the necessary public risk and safety assessments have confirmed its practicality at appropriate locations;
how cyclists would use, and could be better accommodated by the local network, including improved provision for cycle access and parking within the High Street;
how the Area Action Plan may assist enhancement of walking and cycling routes and links through the town centre to other parts of the town. The Issues and Options document (page 50) considers the need to improve routes between the town centre and the railway station. However, the town centre also includes routes used by pupils on their way to and from school. Proposals for the town centre should analyse and incorporate cross town routes to the two secondary schools, which with improved pedestrian priority, especially at key junctions, could reduce school-run traffic and town centre congestion without the need for major infrastructure schemes;
the implications of any proposals to provide a more attractive series of spaces through provision of shared surfaces within the High Street for,
the location of bus stops in regard to accommodating high kerbs that assist access to low floor buses by the disabled and the elderly;
the requirements for accessible Blue Badge disabled people's parking spaces;
provision of clearly delineated routes to assist accessibility by, for example, the visually impaired and those using mobility aids, to minimise the risk of accident/collision in congested areas or adjacent to pavement cafes;
the role of the town centre taxi rank in providing accessibility to the centre. Taxi ranks are an important form of public transport and improve accessibility for disabled and elderly people and those without access to a car. They are also an important support to any desire to provide more evening leisure facilities in the town centre;
any relocation of the market would need careful consideration in relation to transportation issues in the town centre, in particular the operation of bus services;
the potential survival of extensive urban archaeological deposits, particularly in the area of Rayleigh Mount and Mill, and at potential development sites in the town centre (including the Police Station/Somerfield, Rayleigh Mount and Mill, Rayleigh Lanes and Websters Way sites) and the impacts that any future development will have upon this resource.
the measures necessary to ensure that high quality design is evident throughout and that accessible routes to and within the town centre, together with inclusive access points to premises, are addressed sufficiently.

D. DETAILED COMMENTS

1. Accessibility and Inclusion

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.2.7 - the second sentence should be amended to read, 'Direct, safe, accessible and well-signed routes should be considered.'
Paragraph 2.3.5 bullet 4 - should refer to provision of Blue Badge disabled people's parking;
Paragraph 2.3.11 - should refer to the area being as accessible and inclusive as possible while seeking to preserve the historic value of the town centre;
Paragraph 2.5.6 - should refer to 'accessibility' in line with the requirement within the same RSS Policy ENV7 (paragraph 2, bullet5) to 'have regard to the needs and well being of all sectors of the community'.
Paragraph 2.5.13 - should also refer to the need for Lifetime homes.
Paragraphs 2.7.8 to 2.7.12 (Parking) - do not address the requirements for Blue Badge disabled people's parking spaces.
Paragraph 2.8.1(5) - pavement parking causes obstruction and danger to certain sectors of the community, for example, the visually impaired, and, as a known and current issue, should be addressed through other available enforcement measures. Other examples of obstruction can arise through the use of shared space in town centres (see following two bullets) and the further preparation of the Area Action Plan should include measures to secure the safety of all visitors to the town centre.
Page 39, Issue 1 (High Option) - suggests a 'shared space scheme along High Street' which could be a concern, particularly to the visually impaired, in the current absence of national best practice guidance. If implemented it would be necessary for clear delineated routes to be provided.
Pages 42 and 49 - are illustrated with photographs of pavement cafés with no guard rails around seated customers and/or in congested areas. Both situations increase the risk of accident/collision for the visually impaired and those using mobility aids. This well illustrates the amount of detailed thought required within the Area Action Plan to ensure that the town centre becomes accessible for, and inclusive of, all sectors of the community.

2. Highways and Transportation

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.7.23 - the approach to cycling is very prescriptive in the Issues section of the document and, if carried forward, could limit future cycle improvements in the town, especially those funded by developers. Paragraph 2.7.23 should be deleted and replaced by, 'The approach to cycling in the town will be to manage traffic speeds and focus on the provision of improved facilities for cyclists including appropriate signage, routes and of cycle parking in the town and at the station.'

Question 1 - cycling and pubic transport are discussed as key issues in Section 2 of the document but they do not appear in the summaries at the end of the Issues section. This gives the perception that these two topics are less important than those highlighted in the Summary of Issues. It is suggested that reference could be made to cycling and public transport within the pedestrian and public realm part of the Summary of Issues, although mention in a new separate paragraph would be more appropriate.

Question 11 - in respect of 'Opportunities between the High Street and Mount' Option 2, bullet 2 should also refer to facilities for cyclists and so should be amended to read '... with formalised pedestrian and cycling routes....'

Para 4.2.22, bullet 1 - it should be noted that delivery of other improvements could be delayed by procedures to formalise routes involving third-party land, such as through pub gardens etc.

Para 4.3.4 - the word 'appropriate' should be inserted into the last sentence as follows, 'Similarly, the appropriate removal of guard railing...'. Increased permeability and legibility of the town centre is supported but it must be balanced with pedestrian safety. The removal of highway guard railing should only be undertaken after necessary public risk and safety assessments have confirmed its practicality at appropriate locations.

3. Urban Design

Where appropriate, the subsequent Area Action Plan should ensure inclusion of guidance on the form and character of future developments. Such guidance should include schematic layouts and perspectives, in separate Design Briefs where appropriate. It would be an important element in achieving acceptable forms of development and helping to ensure that the aims of the Area Action Plan are achieved.

In addition, the following detailed comments on the text of the Issues and Options should inform further progress of the Area Action Plan,

Table 1, Urban design principles, Legibility - within the option statements the application of the principle/objective of 'Legibility' application to Rayleigh seems to cover 'access' rather than 'legibility'. Legibility in urban design terms is more to do with finding one's way around, assisted by landmarks, clear views, clear routes and gateways.

Paragraph 3.2.3 - refers to the Urban Place Supplement 'being adopted by most district and borough councils in Essex' but it would be more appropriate to clearly state Rochford District Council's position on the Supplement.

Figure 35, Rayleigh Town Centre Concept Plan - it is not clear how the content of this Figure fits into the complete structure of the document or the preparation of the options for the town centre. For instance, it shows green links between The Mount and King Georges Field but these are not listed or mentioned in the objectives. Also, the 'gateways' identified in Figure 35 do not correlate with the Nodes/Gateways identified elsewhere in the document, for example, Figure 30.

Figure 22, Broad structuring plan - the purpose of this figure, and its relationship to the remainder of the document, is not clear; especially given that the same features are illustrated more elegantly elsewhere in the document.

General - The document's use of aspirational illustrations from other town centres is welcomed but it is questionable whether all are applicable to, or present appropriate images for Rayleigh.

4. Historic Environment

The inclusion of a section on 'Heritage and Conservation' in the Issues and Options document is welcomed. However, the section principally relates to issues regarding the conservation area and the built environment with little reference to the significant archaeological resource surviving as below ground deposits within the historic medieval core of Rayleigh. It is essential that the Area Action Plan includes reference to these important deposits as they form an essential part of the history of the town and its development. Consideration of the 'Heritage and Conservation' should be broadened to explicitly address the archaeological element of the Historic Environment. Suggested wording to cover this concern is,

'The Historic Environment lends significant character to settlements such as Rayleigh and can provide a positive template for new development. It can also play a key role in creating a 'sense of place' and identities as existing towns/settlements are enhanced. It is important the protection, promotion and enhancement of the historic character and extensive surviving archaeological deposits associated with the development of historic Rayleigh are fully considered so that the adverse impacts of future development can be minimised. Any developments within the town centre and its immediate hinterland will need to fully consider the cultural assets and the high potential for the survival of significant archaeological remains.'

In addition, to ensure that the historic environment is appropriately considered the following amendments to the existing text are suggested,

Paragraph 1.3.3 - amend the final sentence to read 'Holy Trinity Church, Rayleigh Mount and the windmill are distinctive local landmarks.'

Paragraph 2.3.2 - add to the end of the paragraph 'and the Rochford District Historic Environment Characterisation Project'

Paragraph 2.3.3
Amend the first sentence to read, 'Rayleigh is an attractive medieval market town with a strong cultural heritage and a number of attractive and important listed buildings.'
Delete the final sentence of the paragraph and replace with, 'The Rayleigh Historic Town Assessment and the Rochford District Historic Environment Characterisation Project both highlight the extent and character of the heritage/cultural assets within historic Rayleigh. The medieval street pattern including the remains of the market place close to the church, the wide High Street and the castle survive well. Archaeological investigations within the castle and historic town have uncovered a high potential for wide ranging deposits dating from the early medieval period onwards. Both the surviving medieval town morphology and the buried archaeological deposits are particularly sensitive to change.'

Paragraph 2.3.4 - amend the paragraph (noting that the term 'scheduled ancient monuments' has been officially replaced by the term 'scheduled monuments') to read,

'The Rayleigh Conservation Area (designated in 1969 and extended in 2009 - see Figure 9) covers the historic centre of the town and also takes in Rayleigh Mount (the site of the Motte and Bailey Castle), a scheduled monument, on a spur to the north west of the High Street. The conservation area was designated partly in response to rapid development taking place in the High Street. The Rayleigh Conservation Area identifies some of the key features in Rayleigh, including:
24 listed buildings in the historic town area of Rayleigh, all of which are Grade II listed except Holy Trinity Church which is Grade II*.
The most notable of the listed buildings are the Holy Trinity Church, the Windmill (19th century), Kingsleigh House (18th century red brick building on the High Street which has been converted into offices) and Francis House (now Lloyds Bank on the High Street)
The core elements of the original medieval street pattern/morphology of the town and its association to the castle still remains legible today
Rayleigh has an exceptionally wide High Street (a feature of its development as a market town in the medieval period), presided over at one end by Holy Trinity Church and the remains of the market place.
Rayleigh Mount, the site of a Norman castle, given to the National Trust in 1923 and designated a scheduled monument. Rayleigh Mount is a site of national importance because it survives as one of the earliest Motte and Bailey Castles in England. Built between 1066 and 1086 it is one of the very few castles mentioned in Domesday. The castle lost its importance in the 13th century, was used as a stone quarry for the construction of Hadleigh Castle, a Royal Stud and latterly a farmyard. It is now a key area of open space and is a popular venue for recreational purposes.
A High Street which consists largely of 20th century buildings but also includes significant buildings from the late medieval and post medieval periods ( 16th-18th centuries) which represent an important historic, archaeological and architectural resource, which continue to contribute to the town's historic character and sense of place.
Attractive views looking up and down the High Street (in contrast to the unattractive ones looking up and down Websters Way).
Attractive views over the surrounding countryside from the top of London Hill.

Paragraph 2.4.1 - amend the second sentence to read, 'The Y shaped High Street, incorporating a fossilised market place at its northern end, remains intact...'

A. OVERVIEW

The preparation of an Area Action Plan for Rayleigh Town Centre is welcomed and supported. The Plan should enable a clear strategy to emerge that will maintain and enhance the role and status of the town centre in a sustainable manner that contributes positively to the needs of the local community. Generally the Issues and Options document presents a clear analysis of the issues that Rayleigh town centre faces. Detailed comments on aspects of the analysis are set out elsewhere in this response.

The County Council would welcome further discussion with the District Council at the earliest opportunity as the Plan moves forward to the Preferred Options stage. On the basis of the Issues and Options document there are two areas in particular where early discussion would be beneficial,

the operational requirements of County Council service departments within Rayleigh Town Centre, for example, the Issues and Options document (page 46) suggests the relocation of the library;
the technical feasibility of any highways and transport proposals, having regard to their impact on the functioning and safety of the highway network and the cost and deliverability of highway and transportation requirements (see also response on Options below).

Also, as the Area Action Plan evolves it should,

establish a clearer relationship between its intended outcomes and those of the Rayleigh Conservation Area and Management Plan and the Design Guidelines for Conservation Areas (SPD6).
include consideration of the accessibility needs of all sectors of the population to the town centre. Key words, such as 'inclusive' and 'accessibility', are absent from the Issues and Options document (see also response on Detailed Comments below). An Equality Impact Assessment of the town centre would help ensure that the town centre is capable of satisfactorily meeting the needs of all members of the community in respect of the services and facilities it will provide, and how the Plan should promote and influence accessible design.

B. VISION AND OBJECTIVES

The Vision and Objectives proposed for the Plan are generally supported but could be enhanced by,

In the Vision by,

amending the text in lines five and six to read, '....creating a vibrant, attractive, accessible, inclusive and welcoming centre for all....', to emphasise the intent that the town centre should serve the needs of all sectors of the community;
including 'residential' in the listed mix of uses, to reflect the highlighting of new town centre residential development in Objective 3 and the encouragement throughout the Issues and Options document for inclusion of residential accommodation in town centre schemes.

In the Objectives by,

making reference to 'sustainable development' within Objective 3, to clarify that any development proposals should accord with sustainable principles;
retitling Objective 4 to read 'Improve inclusive and sustainable access to the town centre', to clarify that any transport proposals should accord with sustainable principles;
adding a bullet to Objective 4 to read 'ensure accessible and inclusive provision of town centre services and facilities for all sectors of the community' in support of the inclusion of 'accessible' and 'inclusive' in the Vision.

C. OPTIONS

To a significant degree the Options choices for Rayleigh town centre are likely to hinge on financial considerations, in respect of both private and public sector investment. The County Council prefers not to comment on the individual options that are presented in the Issues and Options document. Rather, the County Council has reviewed the suggested options and sets out comments below on considerations that will need to be taken into account in moving towards the Preferred Option. The County Council would welcome early discussion during the preparation of the Preferred Option of any matters which would impact on its own operational requirements and service delivery within Rayleigh town centre.

A key matter informing preparation of the Preferred Option will be the circulation and management of traffic within the town centre. The County Council would agree with the proposition of Question 15 in the Issues and Options document that there is merit in maintaining the current direction of flow of traffic through the town centre. From the information available within the Issues and Options document it appears that the disbenefits of pedestrianisation of the high Street outweigh the benefits. It is unlikely that traffic currently using the High Street can be accommodated satisfactorily elsewhere on the local network. Alternative routes to relieve congestion on Websters Way are problematic and 'rat running' down residential streets would have to be avoided.

In addition, particular matters that require further study and examination during the remaining stages of the Area Action Plan should include consideration of,

provision of good alternative means of travel to the centre of Rayleigh for local people before the provision of additional town centre parking in an already congested area. For instance, how would the provision of extra car parking on Websters Way affect the desire to relieve congestion along that route? Whilst car parking may promote economic growth in the town centre, it could well increase congestion and traffic in the town centre which will have a negative effect on access to the centre for car drivers. Additionally, conditions for pedestrians, cyclists and bus users as well as the quality of the public realm will be adversely affected by increased volumes of traffic. These in turn could reduce the attractiveness of the centre and discourage economic growth;
the necessary transport assessments and programming of delivery of impact mitigation for any proposed changes to junction operation and layouts. In particular, the removal of highway guard railing should only be undertaken after the necessary public risk and safety assessments have confirmed its practicality at appropriate locations;
how cyclists would use, and could be better accommodated by the local network, including improved provision for cycle access and parking within the High Street;
how the Area Action Plan may assist enhancement of walking and cycling routes and links through the town centre to other parts of the town. The Issues and Options document (page 50) considers the need to improve routes between the town centre and the railway station. However, the town centre also includes routes used by pupils on their way to and from school. Proposals for the town centre should analyse and incorporate cross town routes to the two secondary schools, which with improved pedestrian priority, especially at key junctions, could reduce school-run traffic and town centre congestion without the need for major infrastructure schemes;
the implications of any proposals to provide a more attractive series of spaces through provision of shared surfaces within the High Street for,
the location of bus stops in regard to accommodating high kerbs that assist access to low floor buses by the disabled and the elderly;
the requirements for accessible Blue Badge disabled people's parking spaces;
provision of clearly delineated routes to assist accessibility by, for example, the visually impaired and those using mobility aids, to minimise the risk of accident/collision in congested areas or adjacent to pavement cafes;
the role of the town centre taxi rank in providing accessibility to the centre. Taxi ranks are an important form of public transport and improve accessibility for disabled and elderly people and those without access to a car. They are also an important support to any desire to provide more evening leisure facilities in the town centre;
any relocation of the market would need careful consideration in relation to transportation issues in the town centre, in particular the operation of bus services;
the potential survival of extensive urban archaeological deposits, particularly in the area of Rayleigh Mount and Mill, and at potential development sites in the town centre (including the Police Station/Somerfield, Rayleigh Mount and Mill, Rayleigh Lanes and Websters Way sites) and the impacts that any future development will have upon this resource.
the measures necessary to ensure that high quality design is evident throughout and that accessible routes to and within the town centre, together with inclusive access points to premises, are addressed sufficiently.

D. DETAILED COMMENTS

1. Accessibility and Inclusion

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.2.7 - the second sentence should be amended to read, 'Direct, safe, accessible and well-signed routes should be considered.'
Paragraph 2.3.5 bullet 4 - should refer to provision of Blue Badge disabled people's parking;
Paragraph 2.3.11 - should refer to the area being as accessible and inclusive as possible while seeking to preserve the historic value of the town centre;
Paragraph 2.5.6 - should refer to 'accessibility' in line with the requirement within the same RSS Policy ENV7 (paragraph 2, bullet5) to 'have regard to the needs and well being of all sectors of the community'.
Paragraph 2.5.13 - should also refer to the need for Lifetime homes.
Paragraphs 2.7.8 to 2.7.12 (Parking) - do not address the requirements for Blue Badge disabled people's parking spaces.
Paragraph 2.8.1(5) - pavement parking causes obstruction and danger to certain sectors of the community, for example, the visually impaired, and, as a known and current issue, should be addressed through other available enforcement measures. Other examples of obstruction can arise through the use of shared space in town centres (see following two bullets) and the further preparation of the Area Action Plan should include measures to secure the safety of all visitors to the town centre.
Page 39, Issue 1 (High Option) - suggests a 'shared space scheme along High Street' which could be a concern, particularly to the visually impaired, in the current absence of national best practice guidance. If implemented it would be necessary for clear delineated routes to be provided.
Pages 42 and 49 - are illustrated with photographs of pavement cafés with no guard rails around seated customers and/or in congested areas. Both situations increase the risk of accident/collision for the visually impaired and those using mobility aids. This well illustrates the amount of detailed thought required within the Area Action Plan to ensure that the town centre becomes accessible for, and inclusive of, all sectors of the community.

2. Highways and Transportation

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.7.23 - the approach to cycling is very prescriptive in the Issues section of the document and, if carried forward, could limit future cycle improvements in the town, especially those funded by developers. Paragraph 2.7.23 should be deleted and replaced by, 'The approach to cycling in the town will be to manage traffic speeds and focus on the provision of improved facilities for cyclists including appropriate signage, routes and of cycle parking in the town and at the station.'

Question 1 - cycling and pubic transport are discussed as key issues in Section 2 of the document but they do not appear in the summaries at the end of the Issues section. This gives the perception that these two topics are less important than those highlighted in the Summary of Issues. It is suggested that reference could be made to cycling and public transport within the pedestrian and public realm part of the Summary of Issues, although mention in a new separate paragraph would be more appropriate.

Question 11 - in respect of 'Opportunities between the High Street and Mount' Option 2, bullet 2 should also refer to facilities for cyclists and so should be amended to read '... with formalised pedestrian and cycling routes....'

Para 4.2.22, bullet 1 - it should be noted that delivery of other improvements could be delayed by procedures to formalise routes involving third-party land, such as through pub gardens etc.

Para 4.3.4 - the word 'appropriate' should be inserted into the last sentence as follows, 'Similarly, the appropriate removal of guard railing...'. Increased permeability and legibility of the town centre is supported but it must be balanced with pedestrian safety. The removal of highway guard railing should only be undertaken after necessary public risk and safety assessments have confirmed its practicality at appropriate locations.

3. Urban Design

Where appropriate, the subsequent Area Action Plan should ensure inclusion of guidance on the form and character of future developments. Such guidance should include schematic layouts and perspectives, in separate Design Briefs where appropriate. It would be an important element in achieving acceptable forms of development and helping to ensure that the aims of the Area Action Plan are achieved.

In addition, the following detailed comments on the text of the Issues and Options should inform further progress of the Area Action Plan,

Table 1, Urban design principles, Legibility - within the option statements the application of the principle/objective of 'Legibility' application to Rayleigh seems to cover 'access' rather than 'legibility'. Legibility in urban design terms is more to do with finding one's way around, assisted by landmarks, clear views, clear routes and gateways.

Paragraph 3.2.3 - refers to the Urban Place Supplement 'being adopted by most district and borough councils in Essex' but it would be more appropriate to clearly state Rochford District Council's position on the Supplement.

Figure 35, Rayleigh Town Centre Concept Plan - it is not clear how the content of this Figure fits into the complete structure of the document or the preparation of the options for the town centre. For instance, it shows green links between The Mount and King Georges Field but these are not listed or mentioned in the objectives. Also, the 'gateways' identified in Figure 35 do not correlate with the Nodes/Gateways identified elsewhere in the document, for example, Figure 30.

Figure 22, Broad structuring plan - the purpose of this figure, and its relationship to the remainder of the document, is not clear; especially given that the same features are illustrated more elegantly elsewhere in the document.

General - The document's use of aspirational illustrations from other town centres is welcomed but it is questionable whether all are applicable to, or present appropriate images for Rayleigh.

4. Historic Environment

The inclusion of a section on 'Heritage and Conservation' in the Issues and Options document is welcomed. However, the section principally relates to issues regarding the conservation area and the built environment with little reference to the significant archaeological resource surviving as below ground deposits within the historic medieval core of Rayleigh. It is essential that the Area Action Plan includes reference to these important deposits as they form an essential part of the history of the town and its development. Consideration of the 'Heritage and Conservation' should be broadened to explicitly address the archaeological element of the Historic Environment. Suggested wording to cover this concern is,

'The Historic Environment lends significant character to settlements such as Rayleigh and can provide a positive template for new development. It can also play a key role in creating a 'sense of place' and identities as existing towns/settlements are enhanced. It is important the protection, promotion and enhancement of the historic character and extensive surviving archaeological deposits associated with the development of historic Rayleigh are fully considered so that the adverse impacts of future development can be minimised. Any developments within the town centre and its immediate hinterland will need to fully consider the cultural assets and the high potential for the survival of significant archaeological remains.'

In addition, to ensure that the historic environment is appropriately considered the following amendments to the existing text are suggested,

Paragraph 1.3.3 - amend the final sentence to read 'Holy Trinity Church, Rayleigh Mount and the windmill are distinctive local landmarks.'

Paragraph 2.3.2 - add to the end of the paragraph 'and the Rochford District Historic Environment Characterisation Project'

Paragraph 2.3.3
Amend the first sentence to read, 'Rayleigh is an attractive medieval market town with a strong cultural heritage and a number of attractive and important listed buildings.'
Delete the final sentence of the paragraph and replace with, 'The Rayleigh Historic Town Assessment and the Rochford District Historic Environment Characterisation Project both highlight the extent and character of the heritage/cultural assets within historic Rayleigh. The medieval street pattern including the remains of the market place close to the church, the wide High Street and the castle survive well. Archaeological investigations within the castle and historic town have uncovered a high potential for wide ranging deposits dating from the early medieval period onwards. Both the surviving medieval town morphology and the buried archaeological deposits are particularly sensitive to change.'

Paragraph 2.3.4 - amend the paragraph (noting that the term 'scheduled ancient monuments' has been officially replaced by the term 'scheduled monuments') to read,

'The Rayleigh Conservation Area (designated in 1969 and extended in 2009 - see Figure 9) covers the historic centre of the town and also takes in Rayleigh Mount (the site of the Motte and Bailey Castle), a scheduled monument, on a spur to the north west of the High Street. The conservation area was designated partly in response to rapid development taking place in the High Street. The Rayleigh Conservation Area identifies some of the key features in Rayleigh, including:
24 listed buildings in the historic town area of Rayleigh, all of which are Grade II listed except Holy Trinity Church which is Grade II*.
The most notable of the listed buildings are the Holy Trinity Church, the Windmill (19th century), Kingsleigh House (18th century red brick building on the High Street which has been converted into offices) and Francis House (now Lloyds Bank on the High Street)
The core elements of the original medieval street pattern/morphology of the town and its association to the castle still remains legible today
Rayleigh has an exceptionally wide High Street (a feature of its development as a market town in the medieval period), presided over at one end by Holy Trinity Church and the remains of the market place.
Rayleigh Mount, the site of a Norman castle, given to the National Trust in 1923 and designated a scheduled monument. Rayleigh Mount is a site of national importance because it survives as one of the earliest Motte and Bailey Castles in England. Built between 1066 and 1086 it is one of the very few castles mentioned in Domesday. The castle lost its importance in the 13th century, was used as a stone quarry for the construction of Hadleigh Castle, a Royal Stud and latterly a farmyard. It is now a key area of open space and is a popular venue for recreational purposes.
A High Street which consists largely of 20th century buildings but also includes significant buildings from the late medieval and post medieval periods ( 16th-18th centuries) which represent an important historic, archaeological and architectural resource, which continue to contribute to the town's historic character and sense of place.
Attractive views looking up and down the High Street (in contrast to the unattractive ones looking up and down Websters Way).
Attractive views over the surrounding countryside from the top of London Hill.

Paragraph 2.4.1 - amend the second sentence to read, 'The Y shaped High Street, incorporating a fossilised market place at its northern end, remains intact...'

A. OVERVIEW

The preparation of an Area Action Plan for Rayleigh Town Centre is welcomed and supported. The Plan should enable a clear strategy to emerge that will maintain and enhance the role and status of the town centre in a sustainable manner that contributes positively to the needs of the local community. Generally the Issues and Options document presents a clear analysis of the issues that Rayleigh town centre faces. Detailed comments on aspects of the analysis are set out elsewhere in this response.

The County Council would welcome further discussion with the District Council at the earliest opportunity as the Plan moves forward to the Preferred Options stage. On the basis of the Issues and Options document there are two areas in particular where early discussion would be beneficial,

the operational requirements of County Council service departments within Rayleigh Town Centre, for example, the Issues and Options document (page 46) suggests the relocation of the library;
the technical feasibility of any highways and transport proposals, having regard to their impact on the functioning and safety of the highway network and the cost and deliverability of highway and transportation requirements (see also response on Options below).

Also, as the Area Action Plan evolves it should,

establish a clearer relationship between its intended outcomes and those of the Rayleigh Conservation Area and Management Plan and the Design Guidelines for Conservation Areas (SPD6).
include consideration of the accessibility needs of all sectors of the population to the town centre. Key words, such as 'inclusive' and 'accessibility', are absent from the Issues and Options document (see also response on Detailed Comments below). An Equality Impact Assessment of the town centre would help ensure that the town centre is capable of satisfactorily meeting the needs of all members of the community in respect of the services and facilities it will provide, and how the Plan should promote and influence accessible design.

B. VISION AND OBJECTIVES

The Vision and Objectives proposed for the Plan are generally supported but could be enhanced by,

In the Vision by,

amending the text in lines five and six to read, '....creating a vibrant, attractive, accessible, inclusive and welcoming centre for all....', to emphasise the intent that the town centre should serve the needs of all sectors of the community;
including 'residential' in the listed mix of uses, to reflect the highlighting of new town centre residential development in Objective 3 and the encouragement throughout the Issues and Options document for inclusion of residential accommodation in town centre schemes.

In the Objectives by,

making reference to 'sustainable development' within Objective 3, to clarify that any development proposals should accord with sustainable principles;
retitling Objective 4 to read 'Improve inclusive and sustainable access to the town centre', to clarify that any transport proposals should accord with sustainable principles;
adding a bullet to Objective 4 to read 'ensure accessible and inclusive provision of town centre services and facilities for all sectors of the community' in support of the inclusion of 'accessible' and 'inclusive' in the Vision.

C. OPTIONS

To a significant degree the Options choices for Rayleigh town centre are likely to hinge on financial considerations, in respect of both private and public sector investment. The County Council prefers not to comment on the individual options that are presented in the Issues and Options document. Rather, the County Council has reviewed the suggested options and sets out comments below on considerations that will need to be taken into account in moving towards the Preferred Option. The County Council would welcome early discussion during the preparation of the Preferred Option of any matters which would impact on its own operational requirements and service delivery within Rayleigh town centre.

A key matter informing preparation of the Preferred Option will be the circulation and management of traffic within the town centre. The County Council would agree with the proposition of Question 15 in the Issues and Options document that there is merit in maintaining the current direction of flow of traffic through the town centre. From the information available within the Issues and Options document it appears that the disbenefits of pedestrianisation of the high Street outweigh the benefits. It is unlikely that traffic currently using the High Street can be accommodated satisfactorily elsewhere on the local network. Alternative routes to relieve congestion on Websters Way are problematic and 'rat running' down residential streets would have to be avoided.

In addition, particular matters that require further study and examination during the remaining stages of the Area Action Plan should include consideration of,

provision of good alternative means of travel to the centre of Rayleigh for local people before the provision of additional town centre parking in an already congested area. For instance, how would the provision of extra car parking on Websters Way affect the desire to relieve congestion along that route? Whilst car parking may promote economic growth in the town centre, it could well increase congestion and traffic in the town centre which will have a negative effect on access to the centre for car drivers. Additionally, conditions for pedestrians, cyclists and bus users as well as the quality of the public realm will be adversely affected by increased volumes of traffic. These in turn could reduce the attractiveness of the centre and discourage economic growth;
the necessary transport assessments and programming of delivery of impact mitigation for any proposed changes to junction operation and layouts. In particular, the removal of highway guard railing should only be undertaken after the necessary public risk and safety assessments have confirmed its practicality at appropriate locations;
how cyclists would use, and could be better accommodated by the local network, including improved provision for cycle access and parking within the High Street;
how the Area Action Plan may assist enhancement of walking and cycling routes and links through the town centre to other parts of the town. The Issues and Options document (page 50) considers the need to improve routes between the town centre and the railway station. However, the town centre also includes routes used by pupils on their way to and from school. Proposals for the town centre should analyse and incorporate cross town routes to the two secondary schools, which with improved pedestrian priority, especially at key junctions, could reduce school-run traffic and town centre congestion without the need for major infrastructure schemes;
the implications of any proposals to provide a more attractive series of spaces through provision of shared surfaces within the High Street for,
the location of bus stops in regard to accommodating high kerbs that assist access to low floor buses by the disabled and the elderly;
the requirements for accessible Blue Badge disabled people's parking spaces;
provision of clearly delineated routes to assist accessibility by, for example, the visually impaired and those using mobility aids, to minimise the risk of accident/collision in congested areas or adjacent to pavement cafes;
the role of the town centre taxi rank in providing accessibility to the centre. Taxi ranks are an important form of public transport and improve accessibility for disabled and elderly people and those without access to a car. They are also an important support to any desire to provide more evening leisure facilities in the town centre;
any relocation of the market would need careful consideration in relation to transportation issues in the town centre, in particular the operation of bus services;
the potential survival of extensive urban archaeological deposits, particularly in the area of Rayleigh Mount and Mill, and at potential development sites in the town centre (including the Police Station/Somerfield, Rayleigh Mount and Mill, Rayleigh Lanes and Websters Way sites) and the impacts that any future development will have upon this resource.
the measures necessary to ensure that high quality design is evident throughout and that accessible routes to and within the town centre, together with inclusive access points to premises, are addressed sufficiently.

D. DETAILED COMMENTS

1. Accessibility and Inclusion

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.2.7 - the second sentence should be amended to read, 'Direct, safe, accessible and well-signed routes should be considered.'
Paragraph 2.3.5 bullet 4 - should refer to provision of Blue Badge disabled people's parking;
Paragraph 2.3.11 - should refer to the area being as accessible and inclusive as possible while seeking to preserve the historic value of the town centre;
Paragraph 2.5.6 - should refer to 'accessibility' in line with the requirement within the same RSS Policy ENV7 (paragraph 2, bullet5) to 'have regard to the needs and well being of all sectors of the community'.
Paragraph 2.5.13 - should also refer to the need for Lifetime homes.
Paragraphs 2.7.8 to 2.7.12 (Parking) - do not address the requirements for Blue Badge disabled people's parking spaces.
Paragraph 2.8.1(5) - pavement parking causes obstruction and danger to certain sectors of the community, for example, the visually impaired, and, as a known and current issue, should be addressed through other available enforcement measures. Other examples of obstruction can arise through the use of shared space in town centres (see following two bullets) and the further preparation of the Area Action Plan should include measures to secure the safety of all visitors to the town centre.
Page 39, Issue 1 (High Option) - suggests a 'shared space scheme along High Street' which could be a concern, particularly to the visually impaired, in the current absence of national best practice guidance. If implemented it would be necessary for clear delineated routes to be provided.
Pages 42 and 49 - are illustrated with photographs of pavement cafés with no guard rails around seated customers and/or in congested areas. Both situations increase the risk of accident/collision for the visually impaired and those using mobility aids. This well illustrates the amount of detailed thought required within the Area Action Plan to ensure that the town centre becomes accessible for, and inclusive of, all sectors of the community.

2. Highways and Transportation

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.7.23 - the approach to cycling is very prescriptive in the Issues section of the document and, if carried forward, could limit future cycle improvements in the town, especially those funded by developers. Paragraph 2.7.23 should be deleted and replaced by, 'The approach to cycling in the town will be to manage traffic speeds and focus on the provision of improved facilities for cyclists including appropriate signage, routes and of cycle parking in the town and at the station.'

Question 1 - cycling and pubic transport are discussed as key issues in Section 2 of the document but they do not appear in the summaries at the end of the Issues section. This gives the perception that these two topics are less important than those highlighted in the Summary of Issues. It is suggested that reference could be made to cycling and public transport within the pedestrian and public realm part of the Summary of Issues, although mention in a new separate paragraph would be more appropriate.

Question 11 - in respect of 'Opportunities between the High Street and Mount' Option 2, bullet 2 should also refer to facilities for cyclists and so should be amended to read '... with formalised pedestrian and cycling routes....'

Para 4.2.22, bullet 1 - it should be noted that delivery of other improvements could be delayed by procedures to formalise routes involving third-party land, such as through pub gardens etc.

Para 4.3.4 - the word 'appropriate' should be inserted into the last sentence as follows, 'Similarly, the appropriate removal of guard railing...'. Increased permeability and legibility of the town centre is supported but it must be balanced with pedestrian safety. The removal of highway guard railing should only be undertaken after necessary public risk and safety assessments have confirmed its practicality at appropriate locations.

3. Urban Design

Where appropriate, the subsequent Area Action Plan should ensure inclusion of guidance on the form and character of future developments. Such guidance should include schematic layouts and perspectives, in separate Design Briefs where appropriate. It would be an important element in achieving acceptable forms of development and helping to ensure that the aims of the Area Action Plan are achieved.

In addition, the following detailed comments on the text of the Issues and Options should inform further progress of the Area Action Plan,

Table 1, Urban design principles, Legibility - within the option statements the application of the principle/objective of 'Legibility' application to Rayleigh seems to cover 'access' rather than 'legibility'. Legibility in urban design terms is more to do with finding one's way around, assisted by landmarks, clear views, clear routes and gateways.

Paragraph 3.2.3 - refers to the Urban Place Supplement 'being adopted by most district and borough councils in Essex' but it would be more appropriate to clearly state Rochford District Council's position on the Supplement.

Figure 35, Rayleigh Town Centre Concept Plan - it is not clear how the content of this Figure fits into the complete structure of the document or the preparation of the options for the town centre. For instance, it shows green links between The Mount and King Georges Field but these are not listed or mentioned in the objectives. Also, the 'gateways' identified in Figure 35 do not correlate with the Nodes/Gateways identified elsewhere in the document, for example, Figure 30.

Figure 22, Broad structuring plan - the purpose of this figure, and its relationship to the remainder of the document, is not clear; especially given that the same features are illustrated more elegantly elsewhere in the document.

General - The document's use of aspirational illustrations from other town centres is welcomed but it is questionable whether all are applicable to, or present appropriate images for Rayleigh.

4. Historic Environment

The inclusion of a section on 'Heritage and Conservation' in the Issues and Options document is welcomed. However, the section principally relates to issues regarding the conservation area and the built environment with little reference to the significant archaeological resource surviving as below ground deposits within the historic medieval core of Rayleigh. It is essential that the Area Action Plan includes reference to these important deposits as they form an essential part of the history of the town and its development. Consideration of the 'Heritage and Conservation' should be broadened to explicitly address the archaeological element of the Historic Environment. Suggested wording to cover this concern is,

'The Historic Environment lends significant character to settlements such as Rayleigh and can provide a positive template for new development. It can also play a key role in creating a 'sense of place' and identities as existing towns/settlements are enhanced. It is important the protection, promotion and enhancement of the historic character and extensive surviving archaeological deposits associated with the development of historic Rayleigh are fully considered so that the adverse impacts of future development can be minimised. Any developments within the town centre and its immediate hinterland will need to fully consider the cultural assets and the high potential for the survival of significant archaeological remains.'

In addition, to ensure that the historic environment is appropriately considered the following amendments to the existing text are suggested,

Paragraph 1.3.3 - amend the final sentence to read 'Holy Trinity Church, Rayleigh Mount and the windmill are distinctive local landmarks.'

Paragraph 2.3.2 - add to the end of the paragraph 'and the Rochford District Historic Environment Characterisation Project'

Paragraph 2.3.3
Amend the first sentence to read, 'Rayleigh is an attractive medieval market town with a strong cultural heritage and a number of attractive and important listed buildings.'
Delete the final sentence of the paragraph and replace with, 'The Rayleigh Historic Town Assessment and the Rochford District Historic Environment Characterisation Project both highlight the extent and character of the heritage/cultural assets within historic Rayleigh. The medieval street pattern including the remains of the market place close to the church, the wide High Street and the castle survive well. Archaeological investigations within the castle and historic town have uncovered a high potential for wide ranging deposits dating from the early medieval period onwards. Both the surviving medieval town morphology and the buried archaeological deposits are particularly sensitive to change.'

Paragraph 2.3.4 - amend the paragraph (noting that the term 'scheduled ancient monuments' has been officially replaced by the term 'scheduled monuments') to read,

'The Rayleigh Conservation Area (designated in 1969 and extended in 2009 - see Figure 9) covers the historic centre of the town and also takes in Rayleigh Mount (the site of the Motte and Bailey Castle), a scheduled monument, on a spur to the north west of the High Street. The conservation area was designated partly in response to rapid development taking place in the High Street. The Rayleigh Conservation Area identifies some of the key features in Rayleigh, including:
24 listed buildings in the historic town area of Rayleigh, all of which are Grade II listed except Holy Trinity Church which is Grade II*.
The most notable of the listed buildings are the Holy Trinity Church, the Windmill (19th century), Kingsleigh House (18th century red brick building on the High Street which has been converted into offices) and Francis House (now Lloyds Bank on the High Street)
The core elements of the original medieval street pattern/morphology of the town and its association to the castle still remains legible today
Rayleigh has an exceptionally wide High Street (a feature of its development as a market town in the medieval period), presided over at one end by Holy Trinity Church and the remains of the market place.
Rayleigh Mount, the site of a Norman castle, given to the National Trust in 1923 and designated a scheduled monument. Rayleigh Mount is a site of national importance because it survives as one of the earliest Motte and Bailey Castles in England. Built between 1066 and 1086 it is one of the very few castles mentioned in Domesday. The castle lost its importance in the 13th century, was used as a stone quarry for the construction of Hadleigh Castle, a Royal Stud and latterly a farmyard. It is now a key area of open space and is a popular venue for recreational purposes.
A High Street which consists largely of 20th century buildings but also includes significant buildings from the late medieval and post medieval periods ( 16th-18th centuries) which represent an important historic, archaeological and architectural resource, which continue to contribute to the town's historic character and sense of place.
Attractive views looking up and down the High Street (in contrast to the unattractive ones looking up and down Websters Way).
Attractive views over the surrounding countryside from the top of London Hill.

Paragraph 2.4.1 - amend the second sentence to read, 'The Y shaped High Street, incorporating a fossilised market place at its northern end, remains intact...'

A. OVERVIEW

The preparation of an Area Action Plan for Rayleigh Town Centre is welcomed and supported. The Plan should enable a clear strategy to emerge that will maintain and enhance the role and status of the town centre in a sustainable manner that contributes positively to the needs of the local community. Generally the Issues and Options document presents a clear analysis of the issues that Rayleigh town centre faces. Detailed comments on aspects of the analysis are set out elsewhere in this response.

The County Council would welcome further discussion with the District Council at the earliest opportunity as the Plan moves forward to the Preferred Options stage. On the basis of the Issues and Options document there are two areas in particular where early discussion would be beneficial,

the operational requirements of County Council service departments within Rayleigh Town Centre, for example, the Issues and Options document (page 46) suggests the relocation of the library;
the technical feasibility of any highways and transport proposals, having regard to their impact on the functioning and safety of the highway network and the cost and deliverability of highway and transportation requirements (see also response on Options below).

Also, as the Area Action Plan evolves it should,

establish a clearer relationship between its intended outcomes and those of the Rayleigh Conservation Area and Management Plan and the Design Guidelines for Conservation Areas (SPD6).
include consideration of the accessibility needs of all sectors of the population to the town centre. Key words, such as 'inclusive' and 'accessibility', are absent from the Issues and Options document (see also response on Detailed Comments below). An Equality Impact Assessment of the town centre would help ensure that the town centre is capable of satisfactorily meeting the needs of all members of the community in respect of the services and facilities it will provide, and how the Plan should promote and influence accessible design.

B. VISION AND OBJECTIVES

The Vision and Objectives proposed for the Plan are generally supported but could be enhanced by,

In the Vision by,

amending the text in lines five and six to read, '....creating a vibrant, attractive, accessible, inclusive and welcoming centre for all....', to emphasise the intent that the town centre should serve the needs of all sectors of the community;
including 'residential' in the listed mix of uses, to reflect the highlighting of new town centre residential development in Objective 3 and the encouragement throughout the Issues and Options document for inclusion of residential accommodation in town centre schemes.

In the Objectives by,

making reference to 'sustainable development' within Objective 3, to clarify that any development proposals should accord with sustainable principles;
retitling Objective 4 to read 'Improve inclusive and sustainable access to the town centre', to clarify that any transport proposals should accord with sustainable principles;
adding a bullet to Objective 4 to read 'ensure accessible and inclusive provision of town centre services and facilities for all sectors of the community' in support of the inclusion of 'accessible' and 'inclusive' in the Vision.

C. OPTIONS

To a significant degree the Options choices for Rayleigh town centre are likely to hinge on financial considerations, in respect of both private and public sector investment. The County Council prefers not to comment on the individual options that are presented in the Issues and Options document. Rather, the County Council has reviewed the suggested options and sets out comments below on considerations that will need to be taken into account in moving towards the Preferred Option. The County Council would welcome early discussion during the preparation of the Preferred Option of any matters which would impact on its own operational requirements and service delivery within Rayleigh town centre.

A key matter informing preparation of the Preferred Option will be the circulation and management of traffic within the town centre. The County Council would agree with the proposition of Question 15 in the Issues and Options document that there is merit in maintaining the current direction of flow of traffic through the town centre. From the information available within the Issues and Options document it appears that the disbenefits of pedestrianisation of the high Street outweigh the benefits. It is unlikely that traffic currently using the High Street can be accommodated satisfactorily elsewhere on the local network. Alternative routes to relieve congestion on Websters Way are problematic and 'rat running' down residential streets would have to be avoided.

In addition, particular matters that require further study and examination during the remaining stages of the Area Action Plan should include consideration of,

provision of good alternative means of travel to the centre of Rayleigh for local people before the provision of additional town centre parking in an already congested area. For instance, how would the provision of extra car parking on Websters Way affect the desire to relieve congestion along that route? Whilst car parking may promote economic growth in the town centre, it could well increase congestion and traffic in the town centre which will have a negative effect on access to the centre for car drivers. Additionally, conditions for pedestrians, cyclists and bus users as well as the quality of the public realm will be adversely affected by increased volumes of traffic. These in turn could reduce the attractiveness of the centre and discourage economic growth;
the necessary transport assessments and programming of delivery of impact mitigation for any proposed changes to junction operation and layouts. In particular, the removal of highway guard railing should only be undertaken after the necessary public risk and safety assessments have confirmed its practicality at appropriate locations;
how cyclists would use, and could be better accommodated by the local network, including improved provision for cycle access and parking within the High Street;
how the Area Action Plan may assist enhancement of walking and cycling routes and links through the town centre to other parts of the town. The Issues and Options document (page 50) considers the need to improve routes between the town centre and the railway station. However, the town centre also includes routes used by pupils on their way to and from school. Proposals for the town centre should analyse and incorporate cross town routes to the two secondary schools, which with improved pedestrian priority, especially at key junctions, could reduce school-run traffic and town centre congestion without the need for major infrastructure schemes;
the implications of any proposals to provide a more attractive series of spaces through provision of shared surfaces within the High Street for,
the location of bus stops in regard to accommodating high kerbs that assist access to low floor buses by the disabled and the elderly;
the requirements for accessible Blue Badge disabled people's parking spaces;
provision of clearly delineated routes to assist accessibility by, for example, the visually impaired and those using mobility aids, to minimise the risk of accident/collision in congested areas or adjacent to pavement cafes;
the role of the town centre taxi rank in providing accessibility to the centre. Taxi ranks are an important form of public transport and improve accessibility for disabled and elderly people and those without access to a car. They are also an important support to any desire to provide more evening leisure facilities in the town centre;
any relocation of the market would need careful consideration in relation to transportation issues in the town centre, in particular the operation of bus services;
the potential survival of extensive urban archaeological deposits, particularly in the area of Rayleigh Mount and Mill, and at potential development sites in the town centre (including the Police Station/Somerfield, Rayleigh Mount and Mill, Rayleigh Lanes and Websters Way sites) and the impacts that any future development will have upon this resource.
the measures necessary to ensure that high quality design is evident throughout and that accessible routes to and within the town centre, together with inclusive access points to premises, are addressed sufficiently.

D. DETAILED COMMENTS

1. Accessibility and Inclusion

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.2.7 - the second sentence should be amended to read, 'Direct, safe, accessible and well-signed routes should be considered.'
Paragraph 2.3.5 bullet 4 - should refer to provision of Blue Badge disabled people's parking;
Paragraph 2.3.11 - should refer to the area being as accessible and inclusive as possible while seeking to preserve the historic value of the town centre;
Paragraph 2.5.6 - should refer to 'accessibility' in line with the requirement within the same RSS Policy ENV7 (paragraph 2, bullet5) to 'have regard to the needs and well being of all sectors of the community'.
Paragraph 2.5.13 - should also refer to the need for Lifetime homes.
Paragraphs 2.7.8 to 2.7.12 (Parking) - do not address the requirements for Blue Badge disabled people's parking spaces.
Paragraph 2.8.1(5) - pavement parking causes obstruction and danger to certain sectors of the community, for example, the visually impaired, and, as a known and current issue, should be addressed through other available enforcement measures. Other examples of obstruction can arise through the use of shared space in town centres (see following two bullets) and the further preparation of the Area Action Plan should include measures to secure the safety of all visitors to the town centre.
Page 39, Issue 1 (High Option) - suggests a 'shared space scheme along High Street' which could be a concern, particularly to the visually impaired, in the current absence of national best practice guidance. If implemented it would be necessary for clear delineated routes to be provided.
Pages 42 and 49 - are illustrated with photographs of pavement cafés with no guard rails around seated customers and/or in congested areas. Both situations increase the risk of accident/collision for the visually impaired and those using mobility aids. This well illustrates the amount of detailed thought required within the Area Action Plan to ensure that the town centre becomes accessible for, and inclusive of, all sectors of the community.

2. Highways and Transportation

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.7.23 - the approach to cycling is very prescriptive in the Issues section of the document and, if carried forward, could limit future cycle improvements in the town, especially those funded by developers. Paragraph 2.7.23 should be deleted and replaced by, 'The approach to cycling in the town will be to manage traffic speeds and focus on the provision of improved facilities for cyclists including appropriate signage, routes and of cycle parking in the town and at the station.'

Question 1 - cycling and pubic transport are discussed as key issues in Section 2 of the document but they do not appear in the summaries at the end of the Issues section. This gives the perception that these two topics are less important than those highlighted in the Summary of Issues. It is suggested that reference could be made to cycling and public transport within the pedestrian and public realm part of the Summary of Issues, although mention in a new separate paragraph would be more appropriate.

Question 11 - in respect of 'Opportunities between the High Street and Mount' Option 2, bullet 2 should also refer to facilities for cyclists and so should be amended to read '... with formalised pedestrian and cycling routes....'

Para 4.2.22, bullet 1 - it should be noted that delivery of other improvements could be delayed by procedures to formalise routes involving third-party land, such as through pub gardens etc.

Para 4.3.4 - the word 'appropriate' should be inserted into the last sentence as follows, 'Similarly, the appropriate removal of guard railing...'. Increased permeability and legibility of the town centre is supported but it must be balanced with pedestrian safety. The removal of highway guard railing should only be undertaken after necessary public risk and safety assessments have confirmed its practicality at appropriate locations.

3. Urban Design

Where appropriate, the subsequent Area Action Plan should ensure inclusion of guidance on the form and character of future developments. Such guidance should include schematic layouts and perspectives, in separate Design Briefs where appropriate. It would be an important element in achieving acceptable forms of development and helping to ensure that the aims of the Area Action Plan are achieved.

In addition, the following detailed comments on the text of the Issues and Options should inform further progress of the Area Action Plan,

Table 1, Urban design principles, Legibility - within the option statements the application of the principle/objective of 'Legibility' application to Rayleigh seems to cover 'access' rather than 'legibility'. Legibility in urban design terms is more to do with finding one's way around, assisted by landmarks, clear views, clear routes and gateways.

Paragraph 3.2.3 - refers to the Urban Place Supplement 'being adopted by most district and borough councils in Essex' but it would be more appropriate to clearly state Rochford District Council's position on the Supplement.

Figure 35, Rayleigh Town Centre Concept Plan - it is not clear how the content of this Figure fits into the complete structure of the document or the preparation of the options for the town centre. For instance, it shows green links between The Mount and King Georges Field but these are not listed or mentioned in the objectives. Also, the 'gateways' identified in Figure 35 do not correlate with the Nodes/Gateways identified elsewhere in the document, for example, Figure 30.

Figure 22, Broad structuring plan - the purpose of this figure, and its relationship to the remainder of the document, is not clear; especially given that the same features are illustrated more elegantly elsewhere in the document.

General - The document's use of aspirational illustrations from other town centres is welcomed but it is questionable whether all are applicable to, or present appropriate images for Rayleigh.

4. Historic Environment

The inclusion of a section on 'Heritage and Conservation' in the Issues and Options document is welcomed. However, the section principally relates to issues regarding the conservation area and the built environment with little reference to the significant archaeological resource surviving as below ground deposits within the historic medieval core of Rayleigh. It is essential that the Area Action Plan includes reference to these important deposits as they form an essential part of the history of the town and its development. Consideration of the 'Heritage and Conservation' should be broadened to explicitly address the archaeological element of the Historic Environment. Suggested wording to cover this concern is,

'The Historic Environment lends significant character to settlements such as Rayleigh and can provide a positive template for new development. It can also play a key role in creating a 'sense of place' and identities as existing towns/settlements are enhanced. It is important the protection, promotion and enhancement of the historic character and extensive surviving archaeological deposits associated with the development of historic Rayleigh are fully considered so that the adverse impacts of future development can be minimised. Any developments within the town centre and its immediate hinterland will need to fully consider the cultural assets and the high potential for the survival of significant archaeological remains.'

In addition, to ensure that the historic environment is appropriately considered the following amendments to the existing text are suggested,

Paragraph 1.3.3 - amend the final sentence to read 'Holy Trinity Church, Rayleigh Mount and the windmill are distinctive local landmarks.'

Paragraph 2.3.2 - add to the end of the paragraph 'and the Rochford District Historic Environment Characterisation Project'

Paragraph 2.3.3
Amend the first sentence to read, 'Rayleigh is an attractive medieval market town with a strong cultural heritage and a number of attractive and important listed buildings.'
Delete the final sentence of the paragraph and replace with, 'The Rayleigh Historic Town Assessment and the Rochford District Historic Environment Characterisation Project both highlight the extent and character of the heritage/cultural assets within historic Rayleigh. The medieval street pattern including the remains of the market place close to the church, the wide High Street and the castle survive well. Archaeological investigations within the castle and historic town have uncovered a high potential for wide ranging deposits dating from the early medieval period onwards. Both the surviving medieval town morphology and the buried archaeological deposits are particularly sensitive to change.'

Paragraph 2.3.4 - amend the paragraph (noting that the term 'scheduled ancient monuments' has been officially replaced by the term 'scheduled monuments') to read,

'The Rayleigh Conservation Area (designated in 1969 and extended in 2009 - see Figure 9) covers the historic centre of the town and also takes in Rayleigh Mount (the site of the Motte and Bailey Castle), a scheduled monument, on a spur to the north west of the High Street. The conservation area was designated partly in response to rapid development taking place in the High Street. The Rayleigh Conservation Area identifies some of the key features in Rayleigh, including:
24 listed buildings in the historic town area of Rayleigh, all of which are Grade II listed except Holy Trinity Church which is Grade II*.
The most notable of the listed buildings are the Holy Trinity Church, the Windmill (19th century), Kingsleigh House (18th century red brick building on the High Street which has been converted into offices) and Francis House (now Lloyds Bank on the High Street)
The core elements of the original medieval street pattern/morphology of the town and its association to the castle still remains legible today
Rayleigh has an exceptionally wide High Street (a feature of its development as a market town in the medieval period), presided over at one end by Holy Trinity Church and the remains of the market place.
Rayleigh Mount, the site of a Norman castle, given to the National Trust in 1923 and designated a scheduled monument. Rayleigh Mount is a site of national importance because it survives as one of the earliest Motte and Bailey Castles in England. Built between 1066 and 1086 it is one of the very few castles mentioned in Domesday. The castle lost its importance in the 13th century, was used as a stone quarry for the construction of Hadleigh Castle, a Royal Stud and latterly a farmyard. It is now a key area of open space and is a popular venue for recreational purposes.
A High Street which consists largely of 20th century buildings but also includes significant buildings from the late medieval and post medieval periods ( 16th-18th centuries) which represent an important historic, archaeological and architectural resource, which continue to contribute to the town's historic character and sense of place.
Attractive views looking up and down the High Street (in contrast to the unattractive ones looking up and down Websters Way).
Attractive views over the surrounding countryside from the top of London Hill.

Paragraph 2.4.1 - amend the second sentence to read, 'The Y shaped High Street, incorporating a fossilised market place at its northern end, remains intact...'

A. OVERVIEW

The preparation of an Area Action Plan for Rayleigh Town Centre is welcomed and supported. The Plan should enable a clear strategy to emerge that will maintain and enhance the role and status of the town centre in a sustainable manner that contributes positively to the needs of the local community. Generally the Issues and Options document presents a clear analysis of the issues that Rayleigh town centre faces. Detailed comments on aspects of the analysis are set out elsewhere in this response.

The County Council would welcome further discussion with the District Council at the earliest opportunity as the Plan moves forward to the Preferred Options stage. On the basis of the Issues and Options document there are two areas in particular where early discussion would be beneficial,

the operational requirements of County Council service departments within Rayleigh Town Centre, for example, the Issues and Options document (page 46) suggests the relocation of the library;
the technical feasibility of any highways and transport proposals, having regard to their impact on the functioning and safety of the highway network and the cost and deliverability of highway and transportation requirements (see also response on Options below).

Also, as the Area Action Plan evolves it should,

establish a clearer relationship between its intended outcomes and those of the Rayleigh Conservation Area and Management Plan and the Design Guidelines for Conservation Areas (SPD6).
include consideration of the accessibility needs of all sectors of the population to the town centre. Key words, such as 'inclusive' and 'accessibility', are absent from the Issues and Options document (see also response on Detailed Comments below). An Equality Impact Assessment of the town centre would help ensure that the town centre is capable of satisfactorily meeting the needs of all members of the community in respect of the services and facilities it will provide, and how the Plan should promote and influence accessible design.

B. VISION AND OBJECTIVES

The Vision and Objectives proposed for the Plan are generally supported but could be enhanced by,

In the Vision by,

amending the text in lines five and six to read, '....creating a vibrant, attractive, accessible, inclusive and welcoming centre for all....', to emphasise the intent that the town centre should serve the needs of all sectors of the community;
including 'residential' in the listed mix of uses, to reflect the highlighting of new town centre residential development in Objective 3 and the encouragement throughout the Issues and Options document for inclusion of residential accommodation in town centre schemes.

In the Objectives by,

making reference to 'sustainable development' within Objective 3, to clarify that any development proposals should accord with sustainable principles;
retitling Objective 4 to read 'Improve inclusive and sustainable access to the town centre', to clarify that any transport proposals should accord with sustainable principles;
adding a bullet to Objective 4 to read 'ensure accessible and inclusive provision of town centre services and facilities for all sectors of the community' in support of the inclusion of 'accessible' and 'inclusive' in the Vision.

C. OPTIONS

To a significant degree the Options choices for Rayleigh town centre are likely to hinge on financial considerations, in respect of both private and public sector investment. The County Council prefers not to comment on the individual options that are presented in the Issues and Options document. Rather, the County Council has reviewed the suggested options and sets out comments below on considerations that will need to be taken into account in moving towards the Preferred Option. The County Council would welcome early discussion during the preparation of the Preferred Option of any matters which would impact on its own operational requirements and service delivery within Rayleigh town centre.

A key matter informing preparation of the Preferred Option will be the circulation and management of traffic within the town centre. The County Council would agree with the proposition of Question 15 in the Issues and Options document that there is merit in maintaining the current direction of flow of traffic through the town centre. From the information available within the Issues and Options document it appears that the disbenefits of pedestrianisation of the high Street outweigh the benefits. It is unlikely that traffic currently using the High Street can be accommodated satisfactorily elsewhere on the local network. Alternative routes to relieve congestion on Websters Way are problematic and 'rat running' down residential streets would have to be avoided.

In addition, particular matters that require further study and examination during the remaining stages of the Area Action Plan should include consideration of,

provision of good alternative means of travel to the centre of Rayleigh for local people before the provision of additional town centre parking in an already congested area. For instance, how would the provision of extra car parking on Websters Way affect the desire to relieve congestion along that route? Whilst car parking may promote economic growth in the town centre, it could well increase congestion and traffic in the town centre which will have a negative effect on access to the centre for car drivers. Additionally, conditions for pedestrians, cyclists and bus users as well as the quality of the public realm will be adversely affected by increased volumes of traffic. These in turn could reduce the attractiveness of the centre and discourage economic growth;
the necessary transport assessments and programming of delivery of impact mitigation for any proposed changes to junction operation and layouts. In particular, the removal of highway guard railing should only be undertaken after the necessary public risk and safety assessments have confirmed its practicality at appropriate locations;
how cyclists would use, and could be better accommodated by the local network, including improved provision for cycle access and parking within the High Street;
how the Area Action Plan may assist enhancement of walking and cycling routes and links through the town centre to other parts of the town. The Issues and Options document (page 50) considers the need to improve routes between the town centre and the railway station. However, the town centre also includes routes used by pupils on their way to and from school. Proposals for the town centre should analyse and incorporate cross town routes to the two secondary schools, which with improved pedestrian priority, especially at key junctions, could reduce school-run traffic and town centre congestion without the need for major infrastructure schemes;
the implications of any proposals to provide a more attractive series of spaces through provision of shared surfaces within the High Street for,
the location of bus stops in regard to accommodating high kerbs that assist access to low floor buses by the disabled and the elderly;
the requirements for accessible Blue Badge disabled people's parking spaces;
provision of clearly delineated routes to assist accessibility by, for example, the visually impaired and those using mobility aids, to minimise the risk of accident/collision in congested areas or adjacent to pavement cafes;
the role of the town centre taxi rank in providing accessibility to the centre. Taxi ranks are an important form of public transport and improve accessibility for disabled and elderly people and those without access to a car. They are also an important support to any desire to provide more evening leisure facilities in the town centre;
any relocation of the market would need careful consideration in relation to transportation issues in the town centre, in particular the operation of bus services;
the potential survival of extensive urban archaeological deposits, particularly in the area of Rayleigh Mount and Mill, and at potential development sites in the town centre (including the Police Station/Somerfield, Rayleigh Mount and Mill, Rayleigh Lanes and Websters Way sites) and the impacts that any future development will have upon this resource.
the measures necessary to ensure that high quality design is evident throughout and that accessible routes to and within the town centre, together with inclusive access points to premises, are addressed sufficiently.

D. DETAILED COMMENTS

1. Accessibility and Inclusion

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.2.7 - the second sentence should be amended to read, 'Direct, safe, accessible and well-signed routes should be considered.'
Paragraph 2.3.5 bullet 4 - should refer to provision of Blue Badge disabled people's parking;
Paragraph 2.3.11 - should refer to the area being as accessible and inclusive as possible while seeking to preserve the historic value of the town centre;
Paragraph 2.5.6 - should refer to 'accessibility' in line with the requirement within the same RSS Policy ENV7 (paragraph 2, bullet5) to 'have regard to the needs and well being of all sectors of the community'.
Paragraph 2.5.13 - should also refer to the need for Lifetime homes.
Paragraphs 2.7.8 to 2.7.12 (Parking) - do not address the requirements for Blue Badge disabled people's parking spaces.
Paragraph 2.8.1(5) - pavement parking causes obstruction and danger to certain sectors of the community, for example, the visually impaired, and, as a known and current issue, should be addressed through other available enforcement measures. Other examples of obstruction can arise through the use of shared space in town centres (see following two bullets) and the further preparation of the Area Action Plan should include measures to secure the safety of all visitors to the town centre.
Page 39, Issue 1 (High Option) - suggests a 'shared space scheme along High Street' which could be a concern, particularly to the visually impaired, in the current absence of national best practice guidance. If implemented it would be necessary for clear delineated routes to be provided.
Pages 42 and 49 - are illustrated with photographs of pavement cafés with no guard rails around seated customers and/or in congested areas. Both situations increase the risk of accident/collision for the visually impaired and those using mobility aids. This well illustrates the amount of detailed thought required within the Area Action Plan to ensure that the town centre becomes accessible for, and inclusive of, all sectors of the community.

2. Highways and Transportation

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.7.23 - the approach to cycling is very prescriptive in the Issues section of the document and, if carried forward, could limit future cycle improvements in the town, especially those funded by developers. Paragraph 2.7.23 should be deleted and replaced by, 'The approach to cycling in the town will be to manage traffic speeds and focus on the provision of improved facilities for cyclists including appropriate signage, routes and of cycle parking in the town and at the station.'

Question 1 - cycling and pubic transport are discussed as key issues in Section 2 of the document but they do not appear in the summaries at the end of the Issues section. This gives the perception that these two topics are less important than those highlighted in the Summary of Issues. It is suggested that reference could be made to cycling and public transport within the pedestrian and public realm part of the Summary of Issues, although mention in a new separate paragraph would be more appropriate.

Question 11 - in respect of 'Opportunities between the High Street and Mount' Option 2, bullet 2 should also refer to facilities for cyclists and so should be amended to read '... with formalised pedestrian and cycling routes....'

Para 4.2.22, bullet 1 - it should be noted that delivery of other improvements could be delayed by procedures to formalise routes involving third-party land, such as through pub gardens etc.

Para 4.3.4 - the word 'appropriate' should be inserted into the last sentence as follows, 'Similarly, the appropriate removal of guard railing...'. Increased permeability and legibility of the town centre is supported but it must be balanced with pedestrian safety. The removal of highway guard railing should only be undertaken after necessary public risk and safety assessments have confirmed its practicality at appropriate locations.

3. Urban Design

Where appropriate, the subsequent Area Action Plan should ensure inclusion of guidance on the form and character of future developments. Such guidance should include schematic layouts and perspectives, in separate Design Briefs where appropriate. It would be an important element in achieving acceptable forms of development and helping to ensure that the aims of the Area Action Plan are achieved.

In addition, the following detailed comments on the text of the Issues and Options should inform further progress of the Area Action Plan,

Table 1, Urban design principles, Legibility - within the option statements the application of the principle/objective of 'Legibility' application to Rayleigh seems to cover 'access' rather than 'legibility'. Legibility in urban design terms is more to do with finding one's way around, assisted by landmarks, clear views, clear routes and gateways.

Paragraph 3.2.3 - refers to the Urban Place Supplement 'being adopted by most district and borough councils in Essex' but it would be more appropriate to clearly state Rochford District Council's position on the Supplement.

Figure 35, Rayleigh Town Centre Concept Plan - it is not clear how the content of this Figure fits into the complete structure of the document or the preparation of the options for the town centre. For instance, it shows green links between The Mount and King Georges Field but these are not listed or mentioned in the objectives. Also, the 'gateways' identified in Figure 35 do not correlate with the Nodes/Gateways identified elsewhere in the document, for example, Figure 30.

Figure 22, Broad structuring plan - the purpose of this figure, and its relationship to the remainder of the document, is not clear; especially given that the same features are illustrated more elegantly elsewhere in the document.

General - The document's use of aspirational illustrations from other town centres is welcomed but it is questionable whether all are applicable to, or present appropriate images for Rayleigh.

4. Historic Environment

The inclusion of a section on 'Heritage and Conservation' in the Issues and Options document is welcomed. However, the section principally relates to issues regarding the conservation area and the built environment with little reference to the significant archaeological resource surviving as below ground deposits within the historic medieval core of Rayleigh. It is essential that the Area Action Plan includes reference to these important deposits as they form an essential part of the history of the town and its development. Consideration of the 'Heritage and Conservation' should be broadened to explicitly address the archaeological element of the Historic Environment. Suggested wording to cover this concern is,

'The Historic Environment lends significant character to settlements such as Rayleigh and can provide a positive template for new development. It can also play a key role in creating a 'sense of place' and identities as existing towns/settlements are enhanced. It is important the protection, promotion and enhancement of the historic character and extensive surviving archaeological deposits associated with the development of historic Rayleigh are fully considered so that the adverse impacts of future development can be minimised. Any developments within the town centre and its immediate hinterland will need to fully consider the cultural assets and the high potential for the survival of significant archaeological remains.'

In addition, to ensure that the historic environment is appropriately considered the following amendments to the existing text are suggested,

Paragraph 1.3.3 - amend the final sentence to read 'Holy Trinity Church, Rayleigh Mount and the windmill are distinctive local landmarks.'

Paragraph 2.3.2 - add to the end of the paragraph 'and the Rochford District Historic Environment Characterisation Project'

Paragraph 2.3.3
Amend the first sentence to read, 'Rayleigh is an attractive medieval market town with a strong cultural heritage and a number of attractive and important listed buildings.'
Delete the final sentence of the paragraph and replace with, 'The Rayleigh Historic Town Assessment and the Rochford District Historic Environment Characterisation Project both highlight the extent and character of the heritage/cultural assets within historic Rayleigh. The medieval street pattern including the remains of the market place close to the church, the wide High Street and the castle survive well. Archaeological investigations within the castle and historic town have uncovered a high potential for wide ranging deposits dating from the early medieval period onwards. Both the surviving medieval town morphology and the buried archaeological deposits are particularly sensitive to change.'

Paragraph 2.3.4 - amend the paragraph (noting that the term 'scheduled ancient monuments' has been officially replaced by the term 'scheduled monuments') to read,

'The Rayleigh Conservation Area (designated in 1969 and extended in 2009 - see Figure 9) covers the historic centre of the town and also takes in Rayleigh Mount (the site of the Motte and Bailey Castle), a scheduled monument, on a spur to the north west of the High Street. The conservation area was designated partly in response to rapid development taking place in the High Street. The Rayleigh Conservation Area identifies some of the key features in Rayleigh, including:
24 listed buildings in the historic town area of Rayleigh, all of which are Grade II listed except Holy Trinity Church which is Grade II*.
The most notable of the listed buildings are the Holy Trinity Church, the Windmill (19th century), Kingsleigh House (18th century red brick building on the High Street which has been converted into offices) and Francis House (now Lloyds Bank on the High Street)
The core elements of the original medieval street pattern/morphology of the town and its association to the castle still remains legible today
Rayleigh has an exceptionally wide High Street (a feature of its development as a market town in the medieval period), presided over at one end by Holy Trinity Church and the remains of the market place.
Rayleigh Mount, the site of a Norman castle, given to the National Trust in 1923 and designated a scheduled monument. Rayleigh Mount is a site of national importance because it survives as one of the earliest Motte and Bailey Castles in England. Built between 1066 and 1086 it is one of the very few castles mentioned in Domesday. The castle lost its importance in the 13th century, was used as a stone quarry for the construction of Hadleigh Castle, a Royal Stud and latterly a farmyard. It is now a key area of open space and is a popular venue for recreational purposes.
A High Street which consists largely of 20th century buildings but also includes significant buildings from the late medieval and post medieval periods ( 16th-18th centuries) which represent an important historic, archaeological and architectural resource, which continue to contribute to the town's historic character and sense of place.
Attractive views looking up and down the High Street (in contrast to the unattractive ones looking up and down Websters Way).
Attractive views over the surrounding countryside from the top of London Hill.

Paragraph 2.4.1 - amend the second sentence to read, 'The Y shaped High Street, incorporating a fossilised market place at its northern end, remains intact...'

A. OVERVIEW

The preparation of an Area Action Plan for Rayleigh Town Centre is welcomed and supported. The Plan should enable a clear strategy to emerge that will maintain and enhance the role and status of the town centre in a sustainable manner that contributes positively to the needs of the local community. Generally the Issues and Options document presents a clear analysis of the issues that Rayleigh town centre faces. Detailed comments on aspects of the analysis are set out elsewhere in this response.

The County Council would welcome further discussion with the District Council at the earliest opportunity as the Plan moves forward to the Preferred Options stage. On the basis of the Issues and Options document there are two areas in particular where early discussion would be beneficial,

the operational requirements of County Council service departments within Rayleigh Town Centre, for example, the Issues and Options document (page 46) suggests the relocation of the library;
the technical feasibility of any highways and transport proposals, having regard to their impact on the functioning and safety of the highway network and the cost and deliverability of highway and transportation requirements (see also response on Options below).

Also, as the Area Action Plan evolves it should,

establish a clearer relationship between its intended outcomes and those of the Rayleigh Conservation Area and Management Plan and the Design Guidelines for Conservation Areas (SPD6).
include consideration of the accessibility needs of all sectors of the population to the town centre. Key words, such as 'inclusive' and 'accessibility', are absent from the Issues and Options document (see also response on Detailed Comments below). An Equality Impact Assessment of the town centre would help ensure that the town centre is capable of satisfactorily meeting the needs of all members of the community in respect of the services and facilities it will provide, and how the Plan should promote and influence accessible design.

B. VISION AND OBJECTIVES

The Vision and Objectives proposed for the Plan are generally supported but could be enhanced by,

In the Vision by,

amending the text in lines five and six to read, '....creating a vibrant, attractive, accessible, inclusive and welcoming centre for all....', to emphasise the intent that the town centre should serve the needs of all sectors of the community;
including 'residential' in the listed mix of uses, to reflect the highlighting of new town centre residential development in Objective 3 and the encouragement throughout the Issues and Options document for inclusion of residential accommodation in town centre schemes.

In the Objectives by,

making reference to 'sustainable development' within Objective 3, to clarify that any development proposals should accord with sustainable principles;
retitling Objective 4 to read 'Improve inclusive and sustainable access to the town centre', to clarify that any transport proposals should accord with sustainable principles;
adding a bullet to Objective 4 to read 'ensure accessible and inclusive provision of town centre services and facilities for all sectors of the community' in support of the inclusion of 'accessible' and 'inclusive' in the Vision.

C. OPTIONS

To a significant degree the Options choices for Rayleigh town centre are likely to hinge on financial considerations, in respect of both private and public sector investment. The County Council prefers not to comment on the individual options that are presented in the Issues and Options document. Rather, the County Council has reviewed the suggested options and sets out comments below on considerations that will need to be taken into account in moving towards the Preferred Option. The County Council would welcome early discussion during the preparation of the Preferred Option of any matters which would impact on its own operational requirements and service delivery within Rayleigh town centre.

A key matter informing preparation of the Preferred Option will be the circulation and management of traffic within the town centre. The County Council would agree with the proposition of Question 15 in the Issues and Options document that there is merit in maintaining the current direction of flow of traffic through the town centre. From the information available within the Issues and Options document it appears that the disbenefits of pedestrianisation of the high Street outweigh the benefits. It is unlikely that traffic currently using the High Street can be accommodated satisfactorily elsewhere on the local network. Alternative routes to relieve congestion on Websters Way are problematic and 'rat running' down residential streets would have to be avoided.

In addition, particular matters that require further study and examination during the remaining stages of the Area Action Plan should include consideration of,

provision of good alternative means of travel to the centre of Rayleigh for local people before the provision of additional town centre parking in an already congested area. For instance, how would the provision of extra car parking on Websters Way affect the desire to relieve congestion along that route? Whilst car parking may promote economic growth in the town centre, it could well increase congestion and traffic in the town centre which will have a negative effect on access to the centre for car drivers. Additionally, conditions for pedestrians, cyclists and bus users as well as the quality of the public realm will be adversely affected by increased volumes of traffic. These in turn could reduce the attractiveness of the centre and discourage economic growth;
the necessary transport assessments and programming of delivery of impact mitigation for any proposed changes to junction operation and layouts. In particular, the removal of highway guard railing should only be undertaken after the necessary public risk and safety assessments have confirmed its practicality at appropriate locations;
how cyclists would use, and could be better accommodated by the local network, including improved provision for cycle access and parking within the High Street;
how the Area Action Plan may assist enhancement of walking and cycling routes and links through the town centre to other parts of the town. The Issues and Options document (page 50) considers the need to improve routes between the town centre and the railway station. However, the town centre also includes routes used by pupils on their way to and from school. Proposals for the town centre should analyse and incorporate cross town routes to the two secondary schools, which with improved pedestrian priority, especially at key junctions, could reduce school-run traffic and town centre congestion without the need for major infrastructure schemes;
the implications of any proposals to provide a more attractive series of spaces through provision of shared surfaces within the High Street for,
the location of bus stops in regard to accommodating high kerbs that assist access to low floor buses by the disabled and the elderly;
the requirements for accessible Blue Badge disabled people's parking spaces;
provision of clearly delineated routes to assist accessibility by, for example, the visually impaired and those using mobility aids, to minimise the risk of accident/collision in congested areas or adjacent to pavement cafes;
the role of the town centre taxi rank in providing accessibility to the centre. Taxi ranks are an important form of public transport and improve accessibility for disabled and elderly people and those without access to a car. They are also an important support to any desire to provide more evening leisure facilities in the town centre;
any relocation of the market would need careful consideration in relation to transportation issues in the town centre, in particular the operation of bus services;
the potential survival of extensive urban archaeological deposits, particularly in the area of Rayleigh Mount and Mill, and at potential development sites in the town centre (including the Police Station/Somerfield, Rayleigh Mount and Mill, Rayleigh Lanes and Websters Way sites) and the impacts that any future development will have upon this resource.
the measures necessary to ensure that high quality design is evident throughout and that accessible routes to and within the town centre, together with inclusive access points to premises, are addressed sufficiently.

D. DETAILED COMMENTS

1. Accessibility and Inclusion

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.2.7 - the second sentence should be amended to read, 'Direct, safe, accessible and well-signed routes should be considered.'
Paragraph 2.3.5 bullet 4 - should refer to provision of Blue Badge disabled people's parking;
Paragraph 2.3.11 - should refer to the area being as accessible and inclusive as possible while seeking to preserve the historic value of the town centre;
Paragraph 2.5.6 - should refer to 'accessibility' in line with the requirement within the same RSS Policy ENV7 (paragraph 2, bullet5) to 'have regard to the needs and well being of all sectors of the community'.
Paragraph 2.5.13 - should also refer to the need for Lifetime homes.
Paragraphs 2.7.8 to 2.7.12 (Parking) - do not address the requirements for Blue Badge disabled people's parking spaces.
Paragraph 2.8.1(5) - pavement parking causes obstruction and danger to certain sectors of the community, for example, the visually impaired, and, as a known and current issue, should be addressed through other available enforcement measures. Other examples of obstruction can arise through the use of shared space in town centres (see following two bullets) and the further preparation of the Area Action Plan should include measures to secure the safety of all visitors to the town centre.
Page 39, Issue 1 (High Option) - suggests a 'shared space scheme along High Street' which could be a concern, particularly to the visually impaired, in the current absence of national best practice guidance. If implemented it would be necessary for clear delineated routes to be provided.
Pages 42 and 49 - are illustrated with photographs of pavement cafés with no guard rails around seated customers and/or in congested areas. Both situations increase the risk of accident/collision for the visually impaired and those using mobility aids. This well illustrates the amount of detailed thought required within the Area Action Plan to ensure that the town centre becomes accessible for, and inclusive of, all sectors of the community.

2. Highways and Transportation

The following detailed comments on the text of the Issues and Options document should inform further progress of the Area Action Plan,

Paragraph 2.7.23 - the approach to cycling is very prescriptive in the Issues section of the document and, if carried forward, could limit future cycle improvements in the town, especially those funded by developers. Paragraph 2.7.23 should be deleted and replaced by, 'The approach to cycling in the town will be to manage traffic speeds and focus on the provision of improved facilities for cyclists including appropriate signage, routes and of cycle parking in the town and at the station.'

Question 1 - cycling and pubic transport are discussed as key issues in Section 2 of the document but they do not appear in the summaries at the end of the Issues section. This gives the perception that these two topics are less important than those highlighted in the Summary of Issues. It is suggested that reference could be made to cycling and public transport within the pedestrian and public realm part of the Summary of Issues, although mention in a new separate paragraph would be more appropriate.

Question 11 - in respect of 'Opportunities between the High Street and Mount' Option 2, bullet 2 should also refer to facilities for cyclists and so should be amended to read '... with formalised pedestrian and cycling routes....'

Para 4.2.22, bullet 1 - it should be noted that delivery of other improvements could be delayed by procedures to formalise routes involving third-party land, such as through pub gardens etc.

Para 4.3.4 - the word 'appropriate' should be inserted into the last sentence as follows, 'Similarly, the appropriate removal of guard railing...'. Increased permeability and legibility of the town centre is supported but it must be balanced with pedestrian safety. The removal of highway guard railing should only be undertaken after necessary public risk and safety assessments have confirmed its practicality at appropriate locations.

3. Urban Design

Where appropriate, the subsequent Area Action Plan should ensure inclusion of guidance on the form and character of future developments. Such guidance should include schematic layouts and perspectives, in separate Design Briefs where appropriate. It would be an important element in achieving acceptable forms of development and helping to ensure that the aims of the Area Action Plan are achieved.

In addition, the following detailed comments on the text of the Issues and Options should inform further progress of the Area Action Plan,

Table 1, Urban design principles, Legibility - within the option statements the application of the principle/objective of 'Legibility' application to Rayleigh seems to cover 'access' rather than 'legibility'. Legibility in urban design terms is more to do with finding one's way around, assisted by landmarks, clear views, clear routes and gateways.

Paragraph 3.2.3 - refers to the Urban Place Supplement 'being adopted by most district and borough councils in Essex' but it would be more appropriate to clearly state Rochford District Council's position on the Supplement.

Figure 35, Rayleigh Town Centre Concept Plan - it is not clear how the content of this Figure fits into the complete structure of the document or the preparation of the options for the town centre. For instance, it shows green links between The Mount and King Georges Field but these are not listed or mentioned in the objectives. Also, the 'gateways' identified in Figure 35 do not correlate with the Nodes/Gateways identified elsewhere in the document, for example, Figure 30.

Figure 22, Broad structuring plan - the purpose of this figure, and its relationship to the remainder of the document, is not clear; especially given that the same features are illustrated more elegantly elsewhere in the document.

General - The document's use of aspirational illustrations from other town centres is welcomed but it is questionable whether all are applicable to, or present appropriate images for Rayleigh.

4. Historic Environment

The inclusion of a section on 'Heritage and Conservation' in the Issues and Options document is welcomed. However, the section principally relates to issues regarding the conservation area and the built environment with little reference to the significant archaeological resource surviving as below ground deposits within the historic medieval core of Rayleigh. It is essential that the Area Action Plan includes reference to these important deposits as they form an essential part of the history of the town and its development. Consideration of the 'Heritage and Conservation' should be broadened to explicitly address the archaeological element of the Historic Environment. Suggested wording to cover this concern is,

'The Historic Environment lends significant character to settlements such as Rayleigh and can provide a positive template for new development. It can also play a key role in creating a 'sense of place' and identities as existing towns/settlements are enhanced. It is important the protection, promotion and enhancement of the historic character and extensive surviving archaeological deposits associated with the development of historic Rayleigh are fully considered so that the adverse impacts of future development can be minimised. Any developments within the town centre and its immediate hinterland will need to fully consider the cultural assets and the high potential for the survival of significant archaeological remains.'

In addition, to ensure that the historic environment is appropriately considered the following amendments to the existing text are suggested,

Paragraph 1.3.3 - amend the final sentence to read 'Holy Trinity Church, Rayleigh Mount and the windmill are distinctive local landmarks.'

Paragraph 2.3.2 - add to the end of the paragraph 'and the Rochford District Historic Environment Characterisation Project'

Paragraph 2.3.3
Amend the first sentence to read, 'Rayleigh is an attractive medieval market town with a strong cultural heritage and a number of attractive and important listed buildings.'
Delete the final sentence of the paragraph and replace with, 'The Rayleigh Historic Town Assessment and the Rochford District Historic Environment Characterisation Project both highlight the extent and character of the heritage/cultural assets within historic Rayleigh. The medieval street pattern including the remains of the market place close to the church, the wide High Street and the castle survive well. Archaeological investigations within the castle and historic town have uncovered a high potential for wide ranging deposits dating from the early medieval period onwards. Both the surviving medieval town morphology and the buried archaeological deposits are particularly sensitive to change.'

Paragraph 2.3.4 - amend the paragraph (noting that the term 'scheduled ancient monuments' has been officially replaced by the term 'scheduled monuments') to read,

'The Rayleigh Conservation Area (designated in 1969 and extended in 2009 - see Figure 9) covers the historic centre of the town and also takes in Rayleigh Mount (the site of the Motte and Bailey Castle), a scheduled monument, on a spur to the north west of the High Street. The conservation area was designated partly in response to rapid development taking place in the High Street. The Rayleigh Conservation Area identifies some of the key features in Rayleigh, including:
24 listed buildings in the historic town area of Rayleigh, all of which are Grade II listed except Holy Trinity Church which is Grade II*.
The most notable of the listed buildings are the Holy Trinity Church, the Windmill (19th century), Kingsleigh House (18th century red brick building on the High Street which has been converted into offices) and Francis House (now Lloyds Bank on the High Street)
The core elements of the original medieval street pattern/morphology of the town and its association to the castle still remains legible today
Rayleigh has an exceptionally wide High Street (a feature of its development as a market town in the medieval period), presided over at one end by Holy Trinity Church and the remains of the market place.
Rayleigh Mount, the site of a Norman castle, given to the National Trust in 1923 and designated a scheduled monument. Rayleigh Mount is a site of national importance because it survives as one of the earliest Motte and Bailey Castles in England. Built between 1066 and 1086 it is one of the very few castles mentioned in Domesday. The castle lost its importance in the 13th century, was used as a stone quarry for the construction of Hadleigh Castle, a Royal Stud and latterly a farmyard. It is now a key area of open space and is a popular venue for recreational purposes.
A High Street which consists largely of 20th century buildings but also includes significant buildings from the late medieval and post medieval periods ( 16th-18th centuries) which represent an important historic, archaeological and architectural resource, which continue to contribute to the town's historic character and sense of place.
Attractive views looking up and down the High Street (in contrast to the unattractive ones looking up and down Websters Way).
Attractive views over the surrounding countryside from the top of London Hill.

Paragraph 2.4.1 - amend the second sentence to read, 'The Y shaped High Street, incorporating a fossilised market place at its northern end, remains intact...'