Allocations DPD Discussion and Consultation Document

LOCAL DEVELOPMENT FRAMEWORK
Allocations DPD consultation
West Rochford Action Group Response
Proposed Allocation WR 1-4

Green Belt

It is inappropriate to allocate any of these sites as all are within the Metropolitan Green Belt. The Government attaches great importance to the protection of the Green Belt as detailed in PPG2. In para 1.4 it states that the fundamental aim of Green Belt Policy is to prevent urban sprawl by keeping land permanently open and the most important attribute of Green Belts is their openness. They help to protect the countryside and Green Belts can shape patterns of urban development at sub-regional and regional scale and help to ensure that development occurs in locations allocated in development plans. PPG 2 also states the other central purposes of including land in the Green Belt (paragraph 1.5):

- To prevent neighbouring towns from merging into one another;
- To assist in safeguarding the countryside from encroachment;
- To preserve the setting and special character of historic towns; and

PPG 2 explains that the purposes of including land in Green Belts are of paramount importance to their continued protection and that development within Green Belts is strictly controlled by National Green Belt policy under PPG 2 to ensure that the purposes of Green Belts are not undermined and in para 1.6 states that once Green Belts have been defined the use of land in them has a positive role to play in fulfilling the specified objectives including the provision of opportunities for access to the open countryside for the urban population and to retain attractive landscapes and enhance landscapes near to where people live and to retain land in agricultural forestry and related areas

The proposals to allocate one of these sites for residential development would undoubtedly cause harm to the Green Belt for the reasons set out below:-

"The sprawl of a large built up area"

The proposal to allocate one of these sites for 600 dwellings and a primary school would result in the spreading outwards of this built up area since additional and significant residential development would be directly linked to the surrounding existing settlement. Such would result in a marked sprawl of the urban area.

Impact on the character and appearance of the Green Belt including "the loss of an open, attractive landscape close to where people live


(a) Loss of an open landscape

As stated in PPG 2, the most important attribute of Green Belts is their openness. Whilst some land designated as Green Belt may not be entirely open in nature as buildings or uses that reduce openness may occupy a site, this is certainly not the case at any of these sites where the existing landscape is exceptional.

All 4 sites are entirely open in nature, contain no built structures, and are not made subject to any use which might compromise openness. The Town and Country Planning (Green Belt) Directive 2005 final regulatory impact statement when considering the size of development that would be potentially harmful to the green belt and should require referral to the Secretary of State states that that a site which roughly equate to ten new, average-size dwellings broadly represents the scale of development around which there is the potential for significant impact on the openness of the Green Belt

The sizeable proposed development of 600 dwellings and a primary school would create substantial built form on land which is currently entirely open in nature which would result in significant harm as a result of a considerable loss of openness.

In addition there is no evidence provided in the Allocations DPD that the Council have undertaken a landscape impact assessment prior to proposing this site be allocated for residential development.

(b) Loss of an attractive landscape close to where people live

Sites WR1 and WR4 adjoin the western edge of the built up residential settlement of Rochford and is therefore located close to where people live.

All 4 of the Sites are natural in appearance, consisting of an actively toiled agricultural field.

The visual attractiveness of all of the 4 sites arises as a consequence of both the natural appearance of the land alongside the fact that the land is actively toiled and provides a traditional land use typical of, and pleasant to observe in, the countryside. The allocation of this land for development will be contrary to the provisions of PPG2.

( c) Impact on character

The proposed development would also dramatically change the character of the Site. The Site is currently peaceful and free from general activity. The only activity which can presently be gauged is that characterised by an extremely modest level of vehicular activity (comprising the infrequent use of farm machinery) and a low-level pedestrian flow arising from those who may use the existing public right of way when traversing the Site for recreational and/or scenic purposes.

The proposed development would significantly increase the level of general activity, noise and disturbance at the Site. Such would be wholly incongruous to the Site. This would derive from a significant increase in pedestrian and vehicular activity which would result from the creation of up to 600 residential dwellings and a primary school.

The appearance of the land alongside the fact that the land is actively toiled provides a traditional land use typical of, and pleasant to observe in, the countryside.

This particular area of West Rochford although technically on the edge of the town is unique in character. The railway line on the eastern side forms a boundary which has the effect of separating the town from the Hall Road giving the effect of a separate settlement. This area contains a small amount of low density housing Part of the area on the south side contains Rochford Hall a Grade1 listed building which is part of the conservation area. The remainder is an attractive expanse of well kept open fields trees and hedgerows . The unique character of the area was recognised by Rochford District Council in May 2007 in its document entitled" LDF - Evidence Base- Rochford Conservation Area and Management Plan.

The area analysis begins by describing Hall Road as follows:

Until the first half of the 20th century, Hall Road was undeveloped. It still has a rural feel to it, to which the trees along it make a significant contribution, and forms an attractive approach to the town and conservation area. The large houses which have been built along Hall Road since the Second World War begin on the south side outside the conservation area and stop at Rochford Hall where the conservation area begins. The Hall and the conservation area have formed an obstacle to development on this side of the road, but the houses resume on the north side outside the conservation area boundary which is drawn along the north side of the road. It is essential to the preservation of this approach to the town, and of the setting of Rochford Hall, that further suburbanisation of the road is avoided. In particular, boundary walls in unsympathetic materials can have an effect quite disproportionate to their size or the appearance of the road (Fig. 15). Hedges are much more appropriate in this context.

The current proposals for WR 1-4 are completely at odds with the Council's own statements in this context in that it proposes large scale development with a massive quantity of visible brick

In relation to WR1 one of the reasons stated to justify this site being the Council's preferred option is that it provides a defensible Green Belt boundary. However the existing boundary with Oak Road is fully defensible if the normal criteria of PPG2 are applied

.2. Agricultural Land

The proposal to release prime agricultural land ignores the need to fulfil the future requirements of feeding the country in view of the serious concerns for world food shortages and the estimated large increase in the population of the world and particularly this country. It will not be environmentally acceptable to pursue a policy of importing food which could be grown in this country

The land in Hall Road falls into the category of Best and Most Versatile land (BMV) and is identified at para 8.16 of the present Local Development Plan as being a national resource and should be protected from permanent loss. This is confirmed by national statistics as TIN049 from Natural England states that Grade 1 and2 together form around 21% of all farmland in England. The need for such land to be protected is further stated in PPS7 paras 28 and 29. This states that where significant development of agricultural land is unavoidable Local Planning Authorities should seek to use area of poorer quality land (grade 3b 4 & 5)in preference. Para 29 requires that development land should include policies which identify any major areas of agricultural land that are planned for development and where it is proposed to develop BMV land this should be done having carefully weighed the options in the light of competent advice. The CSCD and Allocations DPD do not include policies specifically identify agricultural land in this way. Furthermore no evidence has been provided that the local Planning Authority have taken competent advice as required by para 29.

3.Roads and transport -

Traffic congestion in Hall Road and on the outskirts of Rochford town is a frequent occurrence particularly at peak times. Additional development in West Rochford on the scale proposed will force additional traffic on to both Hall Road and Cherry Orchard Way and thence on to the A127 or via Warners Bridge towards Southend Town Centre - both routes are regularly congested. The junction improvement proposed will not solve the issue because it was acknowledged in the East of England Plan paras 4.57 and 4.58 that in the morning peak period traffic flows on the A127 already exceed capacity in the westbound direction which it is expected to become worse by 2031. It was also acknowledged that traffic flows already exceed capacity on several sections of the A13 and are forecast to increase further . If the employment proposals north of Aviation Way which have been included as part of the airport expansion and development scheme proceed the traffic impact would be even worse. Furthermore the pedestrian access under the bridge at Rochford station already poses dangers to pedestrians particularly for those in wheelchairs and prams with no potential for access improvements. The increased traffic flow generated by development proposals will exacerbate the dangers.

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

It is stated that all 4 sites are within walking distance of Rochford Railway station and bus routes. Any development at the western end of WR1 and WR4 or on any part of WR2 and WR3 will entail a considerable walk in excess of 30 minutes to either the train station bus routes or Town Centre There is currently no bus service serving Hall Road or Cherry Orchard Way. The distance from the western end of site WR1 is approximately 0.5 miles to the train station and from the north western point of the site approx 0.7 miles to the train station with a further walk to the town centre.

The nearest bus stop for westward travel is by the train station and for eastward travel either in Dalys Road or East Street The practical result of these proposals is that residents in this area will rely on the motor car contrary to the objective of the Core Strategy and not in line with PPG13. The proposal to include a primary school in this location will exacerbate the traffic situation still further with additional cars parking in the early morning and mid afternoon. This scenario already exists in relation to Rochford Primary school where the lack of parking facilities results in parents cars being parked in St Andrews Road and the access road in Church Lane in the early morning and mid afternoon. It was also acknowledged in the Core Strategy document that 84% of households have cars.

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

WRAG response to Allocations DPD
Community Facilities page 110.

We have already objected to the residential development in WR1-4 which it is proposed to include a primary school. A new primary school in this location is unsuitable as it does not meet the criteria set out on page 111.

In particular Hall Road provides a direct route for emergency services and traffic calming measures would therefore be inappropriate in this location. Hall Road is a direct route into the town centre from the west and already carries considerable traffic which will be exacerbated by further residential and primary school development.

A new primary school would cause considerable parking problems in the area as is already the case early in the mornings and late afternoon when St Andrews Road in particular is utilised as a car park for parents of children at Rochford Primary School following the development of the schools car park several years ago.

As has already been stated under objections to WR1-4 there are no buses in this location

LOCAL DEVELOPMENT FRAMEWORK
Allocations DPD consultation
West Rochford Action Group Response
Proposed Allocation WR 1-4

Green Belt

It is inappropriate to allocate any of these sites as all are within the Metropolitan Green Belt. The Government attaches great importance to the protection of the Green Belt as detailed in PPG2. In para 1.4 it states that the fundamental aim of Green Belt Policy is to prevent urban sprawl by keeping land permanently open and the most important attribute of Green Belts is their openness. They help to protect the countryside and Green Belts can shape patterns of urban development at sub-regional and regional scale and help to ensure that development occurs in locations allocated in development plans. PPG 2 also states the other central purposes of including land in the Green Belt (paragraph 1.5):

- To prevent neighbouring towns from merging into one another;
- To assist in safeguarding the countryside from encroachment;
- To preserve the setting and special character of historic towns; and

PPG 2 explains that the purposes of including land in Green Belts are of paramount importance to their continued protection and that development within Green Belts is strictly controlled by National Green Belt policy under PPG 2 to ensure that the purposes of Green Belts are not undermined and in para 1.6 states that once Green Belts have been defined the use of land in them has a positive role to play in fulfilling the specified objectives including the provision of opportunities for access to the open countryside for the urban population and to retain attractive landscapes and enhance landscapes near to where people live and to retain land in agricultural forestry and related areas

The proposals to allocate one of these sites for residential development would undoubtedly cause harm to the Green Belt for the reasons set out below:-

"The sprawl of a large built up area"

The proposal to allocate one of these sites for 600 dwellings and a primary school would result in the spreading outwards of this built up area since additional and significant residential development would be directly linked to the surrounding existing settlement. Such would result in a marked sprawl of the urban area.

Impact on the character and appearance of the Green Belt including "the loss of an open, attractive landscape close to where people live


(a) Loss of an open landscape

As stated in PPG 2, the most important attribute of Green Belts is their openness. Whilst some land designated as Green Belt may not be entirely open in nature as buildings or uses that reduce openness may occupy a site, this is certainly not the case at any of these sites where the existing landscape is exceptional.

All 4 sites are entirely open in nature, contain no built structures, and are not made subject to any use which might compromise openness. The Town and Country Planning (Green Belt) Directive 2005 final regulatory impact statement when considering the size of development that would be potentially harmful to the green belt and should require referral to the Secretary of State states that that a site which roughly equate to ten new, average-size dwellings broadly represents the scale of development around which there is the potential for significant impact on the openness of the Green Belt

The sizeable proposed development of 600 dwellings and a primary school would create substantial built form on land which is currently entirely open in nature which would result in significant harm as a result of a considerable loss of openness.

In addition there is no evidence provided in the Allocations DPD that the Council have undertaken a landscape impact assessment prior to proposing this site be allocated for residential development.

(b) Loss of an attractive landscape close to where people live

Sites WR1 and WR4 adjoin the western edge of the built up residential settlement of Rochford and is therefore located close to where people live.

All 4 of the Sites are natural in appearance, consisting of an actively toiled agricultural field.

The visual attractiveness of all of the 4 sites arises as a consequence of both the natural appearance of the land alongside the fact that the land is actively toiled and provides a traditional land use typical of, and pleasant to observe in, the countryside. The allocation of this land for development will be contrary to the provisions of PPG2.

( c) Impact on character

The proposed development would also dramatically change the character of the Site. The Site is currently peaceful and free from general activity. The only activity which can presently be gauged is that characterised by an extremely modest level of vehicular activity (comprising the infrequent use of farm machinery) and a low-level pedestrian flow arising from those who may use the existing public right of way when traversing the Site for recreational and/or scenic purposes.

The proposed development would significantly increase the level of general activity, noise and disturbance at the Site. Such would be wholly incongruous to the Site. This would derive from a significant increase in pedestrian and vehicular activity which would result from the creation of up to 600 residential dwellings and a primary school.

The appearance of the land alongside the fact that the land is actively toiled provides a traditional land use typical of, and pleasant to observe in, the countryside.

This particular area of West Rochford although technically on the edge of the town is unique in character. The railway line on the eastern side forms a boundary which has the effect of separating the town from the Hall Road giving the effect of a separate settlement. This area contains a small amount of low density housing Part of the area on the south side contains Rochford Hall a Grade1 listed building which is part of the conservation area. The remainder is an attractive expanse of well kept open fields trees and hedgerows . The unique character of the area was recognised by Rochford District Council in May 2007 in its document entitled" LDF - Evidence Base- Rochford Conservation Area and Management Plan.

The area analysis begins by describing Hall Road as follows:

Until the first half of the 20th century, Hall Road was undeveloped. It still has a rural feel to it, to which the trees along it make a significant contribution, and forms an attractive approach to the town and conservation area. The large houses which have been built along Hall Road since the Second World War begin on the south side outside the conservation area and stop at Rochford Hall where the conservation area begins. The Hall and the conservation area have formed an obstacle to development on this side of the road, but the houses resume on the north side outside the conservation area boundary which is drawn along the north side of the road. It is essential to the preservation of this approach to the town, and of the setting of Rochford Hall, that further suburbanisation of the road is avoided. In particular, boundary walls in unsympathetic materials can have an effect quite disproportionate to their size or the appearance of the road (Fig. 15). Hedges are much more appropriate in this context.

The current proposals for WR 1-4 are completely at odds with the Council's own statements in this context in that it proposes large scale development with a massive quantity of visible brick

In relation to WR1 one of the reasons stated to justify this site being the Council's preferred option is that it provides a defensible Green Belt boundary. However the existing boundary with Oak Road is fully defensible if the normal criteria of PPG2 are applied

.2. Agricultural Land

The proposal to release prime agricultural land ignores the need to fulfil the future requirements of feeding the country in view of the serious concerns for world food shortages and the estimated large increase in the population of the world and particularly this country. It will not be environmentally acceptable to pursue a policy of importing food which could be grown in this country

The land in Hall Road falls into the category of Best and Most Versatile land (BMV) and is identified at para 8.16 of the present Local Development Plan as being a national resource and should be protected from permanent loss. This is confirmed by national statistics as TIN049 from Natural England states that Grade 1 and2 together form around 21% of all farmland in England. The need for such land to be protected is further stated in PPS7 paras 28 and 29. This states that where significant development of agricultural land is unavoidable Local Planning Authorities should seek to use area of poorer quality land (grade 3b 4 & 5)in preference. Para 29 requires that development land should include policies which identify any major areas of agricultural land that are planned for development and where it is proposed to develop BMV land this should be done having carefully weighed the options in the light of competent advice. The CSCD and Allocations DPD do not include policies specifically identify agricultural land in this way. Furthermore no evidence has been provided that the local Planning Authority have taken competent advice as required by para 29.

3.Roads and transport -

Traffic congestion in Hall Road and on the outskirts of Rochford town is a frequent occurrence particularly at peak times. Additional development in West Rochford on the scale proposed will force additional traffic on to both Hall Road and Cherry Orchard Way and thence on to the A127 or via Warners Bridge towards Southend Town Centre - both routes are regularly congested. The junction improvement proposed will not solve the issue because it was acknowledged in the East of England Plan paras 4.57 and 4.58 that in the morning peak period traffic flows on the A127 already exceed capacity in the westbound direction which it is expected to become worse by 2031. It was also acknowledged that traffic flows already exceed capacity on several sections of the A13 and are forecast to increase further . If the employment proposals north of Aviation Way which have been included as part of the airport expansion and development scheme proceed the traffic impact would be even worse. Furthermore the pedestrian access under the bridge at Rochford station already poses dangers to pedestrians particularly for those in wheelchairs and prams with no potential for access improvements. The increased traffic flow generated by development proposals will exacerbate the dangers.

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

It is stated that all 4 sites are within walking distance of Rochford Railway station and bus routes. Any development at the western end of WR1 and WR4 or on any part of WR2 and WR3 will entail a considerable walk in excess of 30 minutes to either the train station bus routes or Town Centre There is currently no bus service serving Hall Road or Cherry Orchard Way. The distance from the western end of site WR1 is approximately 0.5 miles to the train station and from the north western point of the site approx 0.7 miles to the train station with a further walk to the town centre.

The nearest bus stop for westward travel is by the train station and for eastward travel either in Dalys Road or East Street The practical result of these proposals is that residents in this area will rely on the motor car contrary to the objective of the Core Strategy and not in line with PPG13. The proposal to include a primary school in this location will exacerbate the traffic situation still further with additional cars parking in the early morning and mid afternoon. This scenario already exists in relation to Rochford Primary school where the lack of parking facilities results in parents cars being parked in St Andrews Road and the access road in Church Lane in the early morning and mid afternoon. It was also acknowledged in the Core Strategy document that 84% of households have cars.

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

WRAG response to Allocations DPD
Community Facilities page 110.

We have already objected to the residential development in WR1-4 which it is proposed to include a primary school. A new primary school in this location is unsuitable as it does not meet the criteria set out on page 111.

In particular Hall Road provides a direct route for emergency services and traffic calming measures would therefore be inappropriate in this location. Hall Road is a direct route into the town centre from the west and already carries considerable traffic which will be exacerbated by further residential and primary school development.

A new primary school would cause considerable parking problems in the area as is already the case early in the mornings and late afternoon when St Andrews Road in particular is utilised as a car park for parents of children at Rochford Primary School following the development of the schools car park several years ago.

As has already been stated under objections to WR1-4 there are no buses in this location