Allocations DPD Discussion and Consultation Document

Background

Countryside Properties have control of some 98 ha of land to the north of London Road, Rayleigh, which it is seeking to bring forward to meet the development proposals set out in the emerging Rochford Core Strategy (alongside adjoining owners, as appropriate).

Notwithstanding the matters of detail raised in these submissions, Countryside Properties are committed to working with the District Council towards the successful delivery of these proposals.

Over-Arching Representations (All Site Options)

The Site Allocations DPD sets out 5 potential land parcels on the western side of Rayleigh north of London Road, ranging from 23ha to 29ha, as possible locations for accommodating the 550 houses, primary school, youth/community facilities and play space proposed in the current draft of the Core Strategy. We assume the proposed Public Park would be accommodated on land outside the identified parcels, but with some open space accommodated within the allocated area (as implied by the notation used to describe each area in the published document).

In common with the representations made by Countryside Properties to the Core Strategy, there are we consider some important points to bear in mind in respect of all of the options being put forward, being:

(1) Flexibility - The need for flexibility in the area to be allocated, to cater for lack of delivery elsewhere and to reflect the fact that the proposed allocation is a "minimum";
(2) Site Area - Delivering even the minimum level of development as currently set out in the Core Strategy will require a greater land allocation that the Site Allocations options imply; and
(3) Long-term Green Belt boundary - In allocating new development land and amending the Green Belt boundary, the Site Allocations document will be setting a new, long term defensible Green Belt boundary, and under the terms of PPG2, this will require consideration of both potential development needs in the post-Plan period, and consideration of the most appropriate Green Belt boundary.

Before turning to consider site specific matters, we set out our comments on the above points more fully below.

(1) The need for flexibility

Countryside Properties have highlighted in their representations to the Core Strategy the requirement in PPS12 for Development Plan documents to have flexibility, in order to respond to changing circumstances. Also highlighted was the fact that the RSS housing requirement is a "minimum", and that all strategic site allocations need likewise to be considered as a minimum if the requirements of the RSS in this respect are to be enacted at the local level.

The definition of the specific land allocation at the Site Allocations stage needs to have regard to that strategic context. It needs to ensure that there is sufficient flexibility within the allocated area to respond to potential changes in development requirements over the Plan period, including the possibility that additional land for housing (or indeed other development needs) may need to be delivered.

(2) Site Area

Even without the requirement for flexibility, we do not consider that the Options put forward have fully considered the land-take required for the scale of development envisaged.

Within the allocated area, there will be a requirement not only to provide the number of homes specified, but also to deliver the highway infrastructure necessary to serve the residential use, to deliver the appropriate social and community infrastructure necessary to support the housing proposed, the associated open space and strategic landscaping, and the drainage infrastructure and sustainable drainage systems necessary to create the quality of residential environment that both Countryside Properties and residents will expect to see.

We also note the requirement in the Core Strategy to provide additional employment land to the West of Rayleigh. For the reasons set out in our representations to the Core Strategy, and set out in our response to the site options presented in the Site Allocations DPD, the additional employment land proposed should be located north of London Road as part of a comprehensive mixed-use scheme.

In our experience of creating successful new residential and mixed-use communities, it is essential not to under-estimate the land required to deliver a quality scheme. In particular for and edge-of-settlement location, integrating a structural landscape framework to 'green' the environment and achieve a successful transition between town and country is essential.

The land west of Rayleigh is relatively free of physical or environmental constraints, but that does not mean that any Masterplan for the site can ignore such features as do exist - there is a public sewer, some specific areas identified as being at flood risk, the potential for existing sports pitches to be retained, the potential need for a buffer to the existing Rayleigh Industrial Estate (assuming it does not relocate), a nearby Listed Building, and existing trees and hedgerows. Any Masterplan will need to be sensitive to these existing features, even if they do not pose significant constraints, and this will inevitably have an impact on the disposition of development and therefore land-take.

At net residential densities of between 30 and 35 dwellings per hectare, 550 residential units would require around 16-18 ha. Allowing a ratio of 60% built area to 40% landscaping, formal open space, incidental open space, children's play space, and green routes (cycleways/pedestrian ways), would produce a gross housing area of 27-30 ha.

The provision of a primary school and other youth/community facilities could equate to around a further 2.0 ha (including parking and servicing etc). We note the site specific requirements for the primary school set out on page 110 of the document, and clearly these could impact on the extent of land required in practice.

Strategic road infrastructure (including bus priority measures) alongside appropriate surface water drainage would equate to around a further 2 ha (a spine road providing bus access at Rawreth Road and linking to London Road could have a distance, avoiding a straight route, or around 1.4km).

Even if no employment land is provided north of London Road, and even assuming no more than 550 residential units, the minimum land-take for the proposed development would in our view be in the order of 30ha, but more likely in the order of 35ha.

(3) Long Term Green Belt Boundary

The Site Allocations DPD provides the mechanism not just by which a specific land allocation will be made to meet the immediate development requirement set out in the Core Strategy, but also by which the long-term, defensible Green Belt boundary will be re-set. PPG2 provides the relevant guidance, and paragraphs 2.8, 2.12 and Annex B are particularly relevant.

Paragraph 2.8 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

There is currently no reference in the Site Allocations DPD to the issue of the revised Green Belt boundary, but under the provisions of PPG2, the immediate land release and the long-term Green Belt boundary are not one and the same issue.

There are exceptional circumstances arising from the RSS development requirement to review the inner Green Belt boundary, but this should be a one-off review that re-establishes a permanent Green Belt for the future, which is capable of accommodating development requirements beyond the Plan period without needing to change. Irrespective therefore of whether or not the Core Strategy identifies a need for more than 550 units at West Rayleigh now, the revised Green Belt boundary should be capable of accommodating more than 550 units, should a need for additional units come forward either within the lifetime of this Plan, or beyond this Plan, to provide the permanence that PPG2 requires.

We feel the Site Allocations DPD needs to address the revised Green Belt boundary explicitly, and set out a proper consideration of the alternative options, having specific regard to the requirements of PPG2, including the need for safeguarded land.


Site Specific Representations (All Site Options)

It follows from the matters raised above that we do not wholly agree with any of the 5 options put forward in the Site Allocations DPD.

We agree that all of the 5 sites have potential for development, but given our comments above regarding likely land-take, we consider that a combination of the sites put forward, together potentially with additional neighbouring land, is likely to provide the right solution at the detailed master-planning stage.

In terms of some specific observations, we would offer the following:

* We do not disagree with the Council regarding the potential desirability of achieving a 'through' public transport route between Rawreth Road and London Road;

* There is a reference under several of the options presented to the need to avoid development in land at risk of flooding. Clearly we agree with the need for development to avoid flood risk areas, which in reality affects only a very small proportion of the site, and a sensible approach to Masterplanning will ensure that flood risk does not impose a constraint on the new development, and that there is no risk to existing development. The need to address flood risk and sustainable drainage within the scheme does however add weight to our argument that the size of the site allocation does require some flexibility, if the Masterplan is to be able to respond positively to existing site features (including but not exclusively flood risk);

* We do not consider that the existing pylon line forms a logical boundary to the development area. As we have set out in submissions elsewhere, these pylons can be re-laid underground (in whole or part, or take a new alignment) and therefore should not be regarded as a determining factor, either on site selection or Masterplanning;

* We do consider that the Core Strategy proposals for additional employment land west of Rayleigh should be accommodated to the north of London Road, as part of a comprehensive mixed-use scheme - we address this matter further in our representations on the employment land options;

* Finally, we note the reference to using a "Public Park" to provide a buffer between any future built development and the A1245. Countryside Properties agree that any development will need to provide appropriate open space, and that there may well be opportunities for greater public access and a Park between the built development and the A1245. This is a substantial area of land, and we do have some concerns that the reference to "park" may imply a substantially landscaped and formal area of open space. We are also unclear as to the extent of land which the Council might be considering for inclusion in the "park". In our experience, access to the countryside is an important source of informal leisure activity, and therefore retaining part at least of this land in agricultural use (perhaps with improved access) may provide both a better 'green' buffer and a greater recreational resource than an (underused) formal "park".

In terms of the individual options, our preliminary comments would be as follows:

* NLR1 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints, is suitable for residential development, and is deliverable. In isolation, it is not of sufficient size, nor does it have the benefit of a frontage to London Road, which it is assumed at this stage will be the primary point of access;

* NLR2 - This site is constrained by flood risk, and in isolation has no suitable access. It is not a realistic option for development, except as part of a wider scheme.

* NLR3 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints (assuming the pylons are laid underground or diverted), and it is likely that the principle point of access to London Road will lie on this part of the frontage to London Road. The site is not of sufficient size on its own, and also would not provide for a public transport link to Rawreth Lane, and therefore we assume this site would need to form part of a more comprehensive allocation.

* NLR4 - Our comments in relation to this land are largely the same as for NLR1 - a minimum of physical/environmental constraint (small area of flood risk), but a developable and deliverable site. It is not large enough in isolation, and does not have a frontage to London Road where we assume the primary access will be taken. It appears as if the western boundary is based on the line of the pylons, but as stated elsewhere in our representations, we do not consider the pylons to form a logical boundary to the development area.

* NLR5 - Our comments in relation to this land are largely the same as for NLR4 - although this option does have a frontage to London Road, it would necessitate disruption to the existing playing fields, and we feel that there are better options for accessing London Road. Again, the site is not large enough in isolation.

Background

Countryside Properties have control of some 98 ha of land to the north of London Road, Rayleigh, which it is seeking to bring forward to meet the development proposals set out in the emerging Rochford Core Strategy (alongside adjoining owners, as appropriate).

Notwithstanding the matters of detail raised in these submissions, Countryside Properties are committed to working with the District Council towards the successful delivery of these proposals.

Over-Arching Representations (All Site Options)

The Site Allocations DPD sets out 5 potential land parcels on the western side of Rayleigh north of London Road, ranging from 23ha to 29ha, as possible locations for accommodating the 550 houses, primary school, youth/community facilities and play space proposed in the current draft of the Core Strategy. We assume the proposed Public Park would be accommodated on land outside the identified parcels, but with some open space accommodated within the allocated area (as implied by the notation used to describe each area in the published document).

In common with the representations made by Countryside Properties to the Core Strategy, there are we consider some important points to bear in mind in respect of all of the options being put forward, being:

(1) Flexibility - The need for flexibility in the area to be allocated, to cater for lack of delivery elsewhere and to reflect the fact that the proposed allocation is a "minimum";
(2) Site Area - Delivering even the minimum level of development as currently set out in the Core Strategy will require a greater land allocation that the Site Allocations options imply; and
(3) Long-term Green Belt boundary - In allocating new development land and amending the Green Belt boundary, the Site Allocations document will be setting a new, long term defensible Green Belt boundary, and under the terms of PPG2, this will require consideration of both potential development needs in the post-Plan period, and consideration of the most appropriate Green Belt boundary.

Before turning to consider site specific matters, we set out our comments on the above points more fully below.

(1) The need for flexibility

Countryside Properties have highlighted in their representations to the Core Strategy the requirement in PPS12 for Development Plan documents to have flexibility, in order to respond to changing circumstances. Also highlighted was the fact that the RSS housing requirement is a "minimum", and that all strategic site allocations need likewise to be considered as a minimum if the requirements of the RSS in this respect are to be enacted at the local level.

The definition of the specific land allocation at the Site Allocations stage needs to have regard to that strategic context. It needs to ensure that there is sufficient flexibility within the allocated area to respond to potential changes in development requirements over the Plan period, including the possibility that additional land for housing (or indeed other development needs) may need to be delivered.

(2) Site Area

Even without the requirement for flexibility, we do not consider that the Options put forward have fully considered the land-take required for the scale of development envisaged.

Within the allocated area, there will be a requirement not only to provide the number of homes specified, but also to deliver the highway infrastructure necessary to serve the residential use, to deliver the appropriate social and community infrastructure necessary to support the housing proposed, the associated open space and strategic landscaping, and the drainage infrastructure and sustainable drainage systems necessary to create the quality of residential environment that both Countryside Properties and residents will expect to see.

We also note the requirement in the Core Strategy to provide additional employment land to the West of Rayleigh. For the reasons set out in our representations to the Core Strategy, and set out in our response to the site options presented in the Site Allocations DPD, the additional employment land proposed should be located north of London Road as part of a comprehensive mixed-use scheme.

In our experience of creating successful new residential and mixed-use communities, it is essential not to under-estimate the land required to deliver a quality scheme. In particular for and edge-of-settlement location, integrating a structural landscape framework to 'green' the environment and achieve a successful transition between town and country is essential.

The land west of Rayleigh is relatively free of physical or environmental constraints, but that does not mean that any Masterplan for the site can ignore such features as do exist - there is a public sewer, some specific areas identified as being at flood risk, the potential for existing sports pitches to be retained, the potential need for a buffer to the existing Rayleigh Industrial Estate (assuming it does not relocate), a nearby Listed Building, and existing trees and hedgerows. Any Masterplan will need to be sensitive to these existing features, even if they do not pose significant constraints, and this will inevitably have an impact on the disposition of development and therefore land-take.

At net residential densities of between 30 and 35 dwellings per hectare, 550 residential units would require around 16-18 ha. Allowing a ratio of 60% built area to 40% landscaping, formal open space, incidental open space, children's play space, and green routes (cycleways/pedestrian ways), would produce a gross housing area of 27-30 ha.

The provision of a primary school and other youth/community facilities could equate to around a further 2.0 ha (including parking and servicing etc). We note the site specific requirements for the primary school set out on page 110 of the document, and clearly these could impact on the extent of land required in practice.

Strategic road infrastructure (including bus priority measures) alongside appropriate surface water drainage would equate to around a further 2 ha (a spine road providing bus access at Rawreth Road and linking to London Road could have a distance, avoiding a straight route, or around 1.4km).

Even if no employment land is provided north of London Road, and even assuming no more than 550 residential units, the minimum land-take for the proposed development would in our view be in the order of 30ha, but more likely in the order of 35ha.

(3) Long Term Green Belt Boundary

The Site Allocations DPD provides the mechanism not just by which a specific land allocation will be made to meet the immediate development requirement set out in the Core Strategy, but also by which the long-term, defensible Green Belt boundary will be re-set. PPG2 provides the relevant guidance, and paragraphs 2.8, 2.12 and Annex B are particularly relevant.

Paragraph 2.8 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

There is currently no reference in the Site Allocations DPD to the issue of the revised Green Belt boundary, but under the provisions of PPG2, the immediate land release and the long-term Green Belt boundary are not one and the same issue.

There are exceptional circumstances arising from the RSS development requirement to review the inner Green Belt boundary, but this should be a one-off review that re-establishes a permanent Green Belt for the future, which is capable of accommodating development requirements beyond the Plan period without needing to change. Irrespective therefore of whether or not the Core Strategy identifies a need for more than 550 units at West Rayleigh now, the revised Green Belt boundary should be capable of accommodating more than 550 units, should a need for additional units come forward either within the lifetime of this Plan, or beyond this Plan, to provide the permanence that PPG2 requires.

We feel the Site Allocations DPD needs to address the revised Green Belt boundary explicitly, and set out a proper consideration of the alternative options, having specific regard to the requirements of PPG2, including the need for safeguarded land.


Site Specific Representations (All Site Options)

It follows from the matters raised above that we do not wholly agree with any of the 5 options put forward in the Site Allocations DPD.

We agree that all of the 5 sites have potential for development, but given our comments above regarding likely land-take, we consider that a combination of the sites put forward, together potentially with additional neighbouring land, is likely to provide the right solution at the detailed master-planning stage.

In terms of some specific observations, we would offer the following:

* We do not disagree with the Council regarding the potential desirability of achieving a 'through' public transport route between Rawreth Road and London Road;

* There is a reference under several of the options presented to the need to avoid development in land at risk of flooding. Clearly we agree with the need for development to avoid flood risk areas, which in reality affects only a very small proportion of the site, and a sensible approach to Masterplanning will ensure that flood risk does not impose a constraint on the new development, and that there is no risk to existing development. The need to address flood risk and sustainable drainage within the scheme does however add weight to our argument that the size of the site allocation does require some flexibility, if the Masterplan is to be able to respond positively to existing site features (including but not exclusively flood risk);

* We do not consider that the existing pylon line forms a logical boundary to the development area. As we have set out in submissions elsewhere, these pylons can be re-laid underground (in whole or part, or take a new alignment) and therefore should not be regarded as a determining factor, either on site selection or Masterplanning;

* We do consider that the Core Strategy proposals for additional employment land west of Rayleigh should be accommodated to the north of London Road, as part of a comprehensive mixed-use scheme - we address this matter further in our representations on the employment land options;

* Finally, we note the reference to using a "Public Park" to provide a buffer between any future built development and the A1245. Countryside Properties agree that any development will need to provide appropriate open space, and that there may well be opportunities for greater public access and a Park between the built development and the A1245. This is a substantial area of land, and we do have some concerns that the reference to "park" may imply a substantially landscaped and formal area of open space. We are also unclear as to the extent of land which the Council might be considering for inclusion in the "park". In our experience, access to the countryside is an important source of informal leisure activity, and therefore retaining part at least of this land in agricultural use (perhaps with improved access) may provide both a better 'green' buffer and a greater recreational resource than an (underused) formal "park".

In terms of the individual options, our preliminary comments would be as follows:

* NLR1 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints, is suitable for residential development, and is deliverable. In isolation, it is not of sufficient size, nor does it have the benefit of a frontage to London Road, which it is assumed at this stage will be the primary point of access;

* NLR2 - This site is constrained by flood risk, and in isolation has no suitable access. It is not a realistic option for development, except as part of a wider scheme.

* NLR3 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints (assuming the pylons are laid underground or diverted), and it is likely that the principle point of access to London Road will lie on this part of the frontage to London Road. The site is not of sufficient size on its own, and also would not provide for a public transport link to Rawreth Lane, and therefore we assume this site would need to form part of a more comprehensive allocation.

* NLR4 - Our comments in relation to this land are largely the same as for NLR1 - a minimum of physical/environmental constraint (small area of flood risk), but a developable and deliverable site. It is not large enough in isolation, and does not have a frontage to London Road where we assume the primary access will be taken. It appears as if the western boundary is based on the line of the pylons, but as stated elsewhere in our representations, we do not consider the pylons to form a logical boundary to the development area.

* NLR5 - Our comments in relation to this land are largely the same as for NLR4 - although this option does have a frontage to London Road, it would necessitate disruption to the existing playing fields, and we feel that there are better options for accessing London Road. Again, the site is not large enough in isolation.

Background

Countryside Properties have control of some 98 ha of land to the north of London Road, Rayleigh, which it is seeking to bring forward to meet the development proposals set out in the emerging Rochford Core Strategy (alongside adjoining owners, as appropriate).

Notwithstanding the matters of detail raised in these submissions, Countryside Properties are committed to working with the District Council towards the successful delivery of these proposals.

Over-Arching Representations (All Site Options)

The Site Allocations DPD sets out 5 potential land parcels on the western side of Rayleigh north of London Road, ranging from 23ha to 29ha, as possible locations for accommodating the 550 houses, primary school, youth/community facilities and play space proposed in the current draft of the Core Strategy. We assume the proposed Public Park would be accommodated on land outside the identified parcels, but with some open space accommodated within the allocated area (as implied by the notation used to describe each area in the published document).

In common with the representations made by Countryside Properties to the Core Strategy, there are we consider some important points to bear in mind in respect of all of the options being put forward, being:

(1) Flexibility - The need for flexibility in the area to be allocated, to cater for lack of delivery elsewhere and to reflect the fact that the proposed allocation is a "minimum";
(2) Site Area - Delivering even the minimum level of development as currently set out in the Core Strategy will require a greater land allocation that the Site Allocations options imply; and
(3) Long-term Green Belt boundary - In allocating new development land and amending the Green Belt boundary, the Site Allocations document will be setting a new, long term defensible Green Belt boundary, and under the terms of PPG2, this will require consideration of both potential development needs in the post-Plan period, and consideration of the most appropriate Green Belt boundary.

Before turning to consider site specific matters, we set out our comments on the above points more fully below.

(1) The need for flexibility

Countryside Properties have highlighted in their representations to the Core Strategy the requirement in PPS12 for Development Plan documents to have flexibility, in order to respond to changing circumstances. Also highlighted was the fact that the RSS housing requirement is a "minimum", and that all strategic site allocations need likewise to be considered as a minimum if the requirements of the RSS in this respect are to be enacted at the local level.

The definition of the specific land allocation at the Site Allocations stage needs to have regard to that strategic context. It needs to ensure that there is sufficient flexibility within the allocated area to respond to potential changes in development requirements over the Plan period, including the possibility that additional land for housing (or indeed other development needs) may need to be delivered.

(2) Site Area

Even without the requirement for flexibility, we do not consider that the Options put forward have fully considered the land-take required for the scale of development envisaged.

Within the allocated area, there will be a requirement not only to provide the number of homes specified, but also to deliver the highway infrastructure necessary to serve the residential use, to deliver the appropriate social and community infrastructure necessary to support the housing proposed, the associated open space and strategic landscaping, and the drainage infrastructure and sustainable drainage systems necessary to create the quality of residential environment that both Countryside Properties and residents will expect to see.

We also note the requirement in the Core Strategy to provide additional employment land to the West of Rayleigh. For the reasons set out in our representations to the Core Strategy, and set out in our response to the site options presented in the Site Allocations DPD, the additional employment land proposed should be located north of London Road as part of a comprehensive mixed-use scheme.

In our experience of creating successful new residential and mixed-use communities, it is essential not to under-estimate the land required to deliver a quality scheme. In particular for and edge-of-settlement location, integrating a structural landscape framework to 'green' the environment and achieve a successful transition between town and country is essential.

The land west of Rayleigh is relatively free of physical or environmental constraints, but that does not mean that any Masterplan for the site can ignore such features as do exist - there is a public sewer, some specific areas identified as being at flood risk, the potential for existing sports pitches to be retained, the potential need for a buffer to the existing Rayleigh Industrial Estate (assuming it does not relocate), a nearby Listed Building, and existing trees and hedgerows. Any Masterplan will need to be sensitive to these existing features, even if they do not pose significant constraints, and this will inevitably have an impact on the disposition of development and therefore land-take.

At net residential densities of between 30 and 35 dwellings per hectare, 550 residential units would require around 16-18 ha. Allowing a ratio of 60% built area to 40% landscaping, formal open space, incidental open space, children's play space, and green routes (cycleways/pedestrian ways), would produce a gross housing area of 27-30 ha.

The provision of a primary school and other youth/community facilities could equate to around a further 2.0 ha (including parking and servicing etc). We note the site specific requirements for the primary school set out on page 110 of the document, and clearly these could impact on the extent of land required in practice.

Strategic road infrastructure (including bus priority measures) alongside appropriate surface water drainage would equate to around a further 2 ha (a spine road providing bus access at Rawreth Road and linking to London Road could have a distance, avoiding a straight route, or around 1.4km).

Even if no employment land is provided north of London Road, and even assuming no more than 550 residential units, the minimum land-take for the proposed development would in our view be in the order of 30ha, but more likely in the order of 35ha.

(3) Long Term Green Belt Boundary

The Site Allocations DPD provides the mechanism not just by which a specific land allocation will be made to meet the immediate development requirement set out in the Core Strategy, but also by which the long-term, defensible Green Belt boundary will be re-set. PPG2 provides the relevant guidance, and paragraphs 2.8, 2.12 and Annex B are particularly relevant.

Paragraph 2.8 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

There is currently no reference in the Site Allocations DPD to the issue of the revised Green Belt boundary, but under the provisions of PPG2, the immediate land release and the long-term Green Belt boundary are not one and the same issue.

There are exceptional circumstances arising from the RSS development requirement to review the inner Green Belt boundary, but this should be a one-off review that re-establishes a permanent Green Belt for the future, which is capable of accommodating development requirements beyond the Plan period without needing to change. Irrespective therefore of whether or not the Core Strategy identifies a need for more than 550 units at West Rayleigh now, the revised Green Belt boundary should be capable of accommodating more than 550 units, should a need for additional units come forward either within the lifetime of this Plan, or beyond this Plan, to provide the permanence that PPG2 requires.

We feel the Site Allocations DPD needs to address the revised Green Belt boundary explicitly, and set out a proper consideration of the alternative options, having specific regard to the requirements of PPG2, including the need for safeguarded land.


Site Specific Representations (All Site Options)

It follows from the matters raised above that we do not wholly agree with any of the 5 options put forward in the Site Allocations DPD.

We agree that all of the 5 sites have potential for development, but given our comments above regarding likely land-take, we consider that a combination of the sites put forward, together potentially with additional neighbouring land, is likely to provide the right solution at the detailed master-planning stage.

In terms of some specific observations, we would offer the following:

* We do not disagree with the Council regarding the potential desirability of achieving a 'through' public transport route between Rawreth Road and London Road;

* There is a reference under several of the options presented to the need to avoid development in land at risk of flooding. Clearly we agree with the need for development to avoid flood risk areas, which in reality affects only a very small proportion of the site, and a sensible approach to Masterplanning will ensure that flood risk does not impose a constraint on the new development, and that there is no risk to existing development. The need to address flood risk and sustainable drainage within the scheme does however add weight to our argument that the size of the site allocation does require some flexibility, if the Masterplan is to be able to respond positively to existing site features (including but not exclusively flood risk);

* We do not consider that the existing pylon line forms a logical boundary to the development area. As we have set out in submissions elsewhere, these pylons can be re-laid underground (in whole or part, or take a new alignment) and therefore should not be regarded as a determining factor, either on site selection or Masterplanning;

* We do consider that the Core Strategy proposals for additional employment land west of Rayleigh should be accommodated to the north of London Road, as part of a comprehensive mixed-use scheme - we address this matter further in our representations on the employment land options;

* Finally, we note the reference to using a "Public Park" to provide a buffer between any future built development and the A1245. Countryside Properties agree that any development will need to provide appropriate open space, and that there may well be opportunities for greater public access and a Park between the built development and the A1245. This is a substantial area of land, and we do have some concerns that the reference to "park" may imply a substantially landscaped and formal area of open space. We are also unclear as to the extent of land which the Council might be considering for inclusion in the "park". In our experience, access to the countryside is an important source of informal leisure activity, and therefore retaining part at least of this land in agricultural use (perhaps with improved access) may provide both a better 'green' buffer and a greater recreational resource than an (underused) formal "park".

In terms of the individual options, our preliminary comments would be as follows:

* NLR1 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints, is suitable for residential development, and is deliverable. In isolation, it is not of sufficient size, nor does it have the benefit of a frontage to London Road, which it is assumed at this stage will be the primary point of access;

* NLR2 - This site is constrained by flood risk, and in isolation has no suitable access. It is not a realistic option for development, except as part of a wider scheme.

* NLR3 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints (assuming the pylons are laid underground or diverted), and it is likely that the principle point of access to London Road will lie on this part of the frontage to London Road. The site is not of sufficient size on its own, and also would not provide for a public transport link to Rawreth Lane, and therefore we assume this site would need to form part of a more comprehensive allocation.

* NLR4 - Our comments in relation to this land are largely the same as for NLR1 - a minimum of physical/environmental constraint (small area of flood risk), but a developable and deliverable site. It is not large enough in isolation, and does not have a frontage to London Road where we assume the primary access will be taken. It appears as if the western boundary is based on the line of the pylons, but as stated elsewhere in our representations, we do not consider the pylons to form a logical boundary to the development area.

* NLR5 - Our comments in relation to this land are largely the same as for NLR4 - although this option does have a frontage to London Road, it would necessitate disruption to the existing playing fields, and we feel that there are better options for accessing London Road. Again, the site is not large enough in isolation.

Background

Countryside Properties have control of some 98 ha of land to the north of London Road, Rayleigh, which it is seeking to bring forward to meet the development proposals set out in the emerging Rochford Core Strategy (alongside adjoining owners, as appropriate).

Notwithstanding the matters of detail raised in these submissions, Countryside Properties are committed to working with the District Council towards the successful delivery of these proposals.

Over-Arching Representations (All Site Options)

The Site Allocations DPD sets out 5 potential land parcels on the western side of Rayleigh north of London Road, ranging from 23ha to 29ha, as possible locations for accommodating the 550 houses, primary school, youth/community facilities and play space proposed in the current draft of the Core Strategy. We assume the proposed Public Park would be accommodated on land outside the identified parcels, but with some open space accommodated within the allocated area (as implied by the notation used to describe each area in the published document).

In common with the representations made by Countryside Properties to the Core Strategy, there are we consider some important points to bear in mind in respect of all of the options being put forward, being:

(1) Flexibility - The need for flexibility in the area to be allocated, to cater for lack of delivery elsewhere and to reflect the fact that the proposed allocation is a "minimum";
(2) Site Area - Delivering even the minimum level of development as currently set out in the Core Strategy will require a greater land allocation that the Site Allocations options imply; and
(3) Long-term Green Belt boundary - In allocating new development land and amending the Green Belt boundary, the Site Allocations document will be setting a new, long term defensible Green Belt boundary, and under the terms of PPG2, this will require consideration of both potential development needs in the post-Plan period, and consideration of the most appropriate Green Belt boundary.

Before turning to consider site specific matters, we set out our comments on the above points more fully below.

(1) The need for flexibility

Countryside Properties have highlighted in their representations to the Core Strategy the requirement in PPS12 for Development Plan documents to have flexibility, in order to respond to changing circumstances. Also highlighted was the fact that the RSS housing requirement is a "minimum", and that all strategic site allocations need likewise to be considered as a minimum if the requirements of the RSS in this respect are to be enacted at the local level.

The definition of the specific land allocation at the Site Allocations stage needs to have regard to that strategic context. It needs to ensure that there is sufficient flexibility within the allocated area to respond to potential changes in development requirements over the Plan period, including the possibility that additional land for housing (or indeed other development needs) may need to be delivered.

(2) Site Area

Even without the requirement for flexibility, we do not consider that the Options put forward have fully considered the land-take required for the scale of development envisaged.

Within the allocated area, there will be a requirement not only to provide the number of homes specified, but also to deliver the highway infrastructure necessary to serve the residential use, to deliver the appropriate social and community infrastructure necessary to support the housing proposed, the associated open space and strategic landscaping, and the drainage infrastructure and sustainable drainage systems necessary to create the quality of residential environment that both Countryside Properties and residents will expect to see.

We also note the requirement in the Core Strategy to provide additional employment land to the West of Rayleigh. For the reasons set out in our representations to the Core Strategy, and set out in our response to the site options presented in the Site Allocations DPD, the additional employment land proposed should be located north of London Road as part of a comprehensive mixed-use scheme.

In our experience of creating successful new residential and mixed-use communities, it is essential not to under-estimate the land required to deliver a quality scheme. In particular for and edge-of-settlement location, integrating a structural landscape framework to 'green' the environment and achieve a successful transition between town and country is essential.

The land west of Rayleigh is relatively free of physical or environmental constraints, but that does not mean that any Masterplan for the site can ignore such features as do exist - there is a public sewer, some specific areas identified as being at flood risk, the potential for existing sports pitches to be retained, the potential need for a buffer to the existing Rayleigh Industrial Estate (assuming it does not relocate), a nearby Listed Building, and existing trees and hedgerows. Any Masterplan will need to be sensitive to these existing features, even if they do not pose significant constraints, and this will inevitably have an impact on the disposition of development and therefore land-take.

At net residential densities of between 30 and 35 dwellings per hectare, 550 residential units would require around 16-18 ha. Allowing a ratio of 60% built area to 40% landscaping, formal open space, incidental open space, children's play space, and green routes (cycleways/pedestrian ways), would produce a gross housing area of 27-30 ha.

The provision of a primary school and other youth/community facilities could equate to around a further 2.0 ha (including parking and servicing etc). We note the site specific requirements for the primary school set out on page 110 of the document, and clearly these could impact on the extent of land required in practice.

Strategic road infrastructure (including bus priority measures) alongside appropriate surface water drainage would equate to around a further 2 ha (a spine road providing bus access at Rawreth Road and linking to London Road could have a distance, avoiding a straight route, or around 1.4km).

Even if no employment land is provided north of London Road, and even assuming no more than 550 residential units, the minimum land-take for the proposed development would in our view be in the order of 30ha, but more likely in the order of 35ha.

(3) Long Term Green Belt Boundary

The Site Allocations DPD provides the mechanism not just by which a specific land allocation will be made to meet the immediate development requirement set out in the Core Strategy, but also by which the long-term, defensible Green Belt boundary will be re-set. PPG2 provides the relevant guidance, and paragraphs 2.8, 2.12 and Annex B are particularly relevant.

Paragraph 2.8 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

There is currently no reference in the Site Allocations DPD to the issue of the revised Green Belt boundary, but under the provisions of PPG2, the immediate land release and the long-term Green Belt boundary are not one and the same issue.

There are exceptional circumstances arising from the RSS development requirement to review the inner Green Belt boundary, but this should be a one-off review that re-establishes a permanent Green Belt for the future, which is capable of accommodating development requirements beyond the Plan period without needing to change. Irrespective therefore of whether or not the Core Strategy identifies a need for more than 550 units at West Rayleigh now, the revised Green Belt boundary should be capable of accommodating more than 550 units, should a need for additional units come forward either within the lifetime of this Plan, or beyond this Plan, to provide the permanence that PPG2 requires.

We feel the Site Allocations DPD needs to address the revised Green Belt boundary explicitly, and set out a proper consideration of the alternative options, having specific regard to the requirements of PPG2, including the need for safeguarded land.


Site Specific Representations (All Site Options)

It follows from the matters raised above that we do not wholly agree with any of the 5 options put forward in the Site Allocations DPD.

We agree that all of the 5 sites have potential for development, but given our comments above regarding likely land-take, we consider that a combination of the sites put forward, together potentially with additional neighbouring land, is likely to provide the right solution at the detailed master-planning stage.

In terms of some specific observations, we would offer the following:

* We do not disagree with the Council regarding the potential desirability of achieving a 'through' public transport route between Rawreth Road and London Road;

* There is a reference under several of the options presented to the need to avoid development in land at risk of flooding. Clearly we agree with the need for development to avoid flood risk areas, which in reality affects only a very small proportion of the site, and a sensible approach to Masterplanning will ensure that flood risk does not impose a constraint on the new development, and that there is no risk to existing development. The need to address flood risk and sustainable drainage within the scheme does however add weight to our argument that the size of the site allocation does require some flexibility, if the Masterplan is to be able to respond positively to existing site features (including but not exclusively flood risk);

* We do not consider that the existing pylon line forms a logical boundary to the development area. As we have set out in submissions elsewhere, these pylons can be re-laid underground (in whole or part, or take a new alignment) and therefore should not be regarded as a determining factor, either on site selection or Masterplanning;

* We do consider that the Core Strategy proposals for additional employment land west of Rayleigh should be accommodated to the north of London Road, as part of a comprehensive mixed-use scheme - we address this matter further in our representations on the employment land options;

* Finally, we note the reference to using a "Public Park" to provide a buffer between any future built development and the A1245. Countryside Properties agree that any development will need to provide appropriate open space, and that there may well be opportunities for greater public access and a Park between the built development and the A1245. This is a substantial area of land, and we do have some concerns that the reference to "park" may imply a substantially landscaped and formal area of open space. We are also unclear as to the extent of land which the Council might be considering for inclusion in the "park". In our experience, access to the countryside is an important source of informal leisure activity, and therefore retaining part at least of this land in agricultural use (perhaps with improved access) may provide both a better 'green' buffer and a greater recreational resource than an (underused) formal "park".

In terms of the individual options, our preliminary comments would be as follows:

* NLR1 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints, is suitable for residential development, and is deliverable. In isolation, it is not of sufficient size, nor does it have the benefit of a frontage to London Road, which it is assumed at this stage will be the primary point of access;

* NLR2 - This site is constrained by flood risk, and in isolation has no suitable access. It is not a realistic option for development, except as part of a wider scheme.

* NLR3 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints (assuming the pylons are laid underground or diverted), and it is likely that the principle point of access to London Road will lie on this part of the frontage to London Road. The site is not of sufficient size on its own, and also would not provide for a public transport link to Rawreth Lane, and therefore we assume this site would need to form part of a more comprehensive allocation.

* NLR4 - Our comments in relation to this land are largely the same as for NLR1 - a minimum of physical/environmental constraint (small area of flood risk), but a developable and deliverable site. It is not large enough in isolation, and does not have a frontage to London Road where we assume the primary access will be taken. It appears as if the western boundary is based on the line of the pylons, but as stated elsewhere in our representations, we do not consider the pylons to form a logical boundary to the development area.

* NLR5 - Our comments in relation to this land are largely the same as for NLR4 - although this option does have a frontage to London Road, it would necessitate disruption to the existing playing fields, and we feel that there are better options for accessing London Road. Again, the site is not large enough in isolation.

Background

Countryside Properties have control of some 98 ha of land to the north of London Road, Rayleigh, which it is seeking to bring forward to meet the development proposals set out in the emerging Rochford Core Strategy (alongside adjoining owners, as appropriate).

Notwithstanding the matters of detail raised in these submissions, Countryside Properties are committed to working with the District Council towards the successful delivery of these proposals.

Over-Arching Representations (All Site Options)

The Site Allocations DPD sets out 5 potential land parcels on the western side of Rayleigh north of London Road, ranging from 23ha to 29ha, as possible locations for accommodating the 550 houses, primary school, youth/community facilities and play space proposed in the current draft of the Core Strategy. We assume the proposed Public Park would be accommodated on land outside the identified parcels, but with some open space accommodated within the allocated area (as implied by the notation used to describe each area in the published document).

In common with the representations made by Countryside Properties to the Core Strategy, there are we consider some important points to bear in mind in respect of all of the options being put forward, being:

(1) Flexibility - The need for flexibility in the area to be allocated, to cater for lack of delivery elsewhere and to reflect the fact that the proposed allocation is a "minimum";
(2) Site Area - Delivering even the minimum level of development as currently set out in the Core Strategy will require a greater land allocation that the Site Allocations options imply; and
(3) Long-term Green Belt boundary - In allocating new development land and amending the Green Belt boundary, the Site Allocations document will be setting a new, long term defensible Green Belt boundary, and under the terms of PPG2, this will require consideration of both potential development needs in the post-Plan period, and consideration of the most appropriate Green Belt boundary.

Before turning to consider site specific matters, we set out our comments on the above points more fully below.

(1) The need for flexibility

Countryside Properties have highlighted in their representations to the Core Strategy the requirement in PPS12 for Development Plan documents to have flexibility, in order to respond to changing circumstances. Also highlighted was the fact that the RSS housing requirement is a "minimum", and that all strategic site allocations need likewise to be considered as a minimum if the requirements of the RSS in this respect are to be enacted at the local level.

The definition of the specific land allocation at the Site Allocations stage needs to have regard to that strategic context. It needs to ensure that there is sufficient flexibility within the allocated area to respond to potential changes in development requirements over the Plan period, including the possibility that additional land for housing (or indeed other development needs) may need to be delivered.

(2) Site Area

Even without the requirement for flexibility, we do not consider that the Options put forward have fully considered the land-take required for the scale of development envisaged.

Within the allocated area, there will be a requirement not only to provide the number of homes specified, but also to deliver the highway infrastructure necessary to serve the residential use, to deliver the appropriate social and community infrastructure necessary to support the housing proposed, the associated open space and strategic landscaping, and the drainage infrastructure and sustainable drainage systems necessary to create the quality of residential environment that both Countryside Properties and residents will expect to see.

We also note the requirement in the Core Strategy to provide additional employment land to the West of Rayleigh. For the reasons set out in our representations to the Core Strategy, and set out in our response to the site options presented in the Site Allocations DPD, the additional employment land proposed should be located north of London Road as part of a comprehensive mixed-use scheme.

In our experience of creating successful new residential and mixed-use communities, it is essential not to under-estimate the land required to deliver a quality scheme. In particular for and edge-of-settlement location, integrating a structural landscape framework to 'green' the environment and achieve a successful transition between town and country is essential.

The land west of Rayleigh is relatively free of physical or environmental constraints, but that does not mean that any Masterplan for the site can ignore such features as do exist - there is a public sewer, some specific areas identified as being at flood risk, the potential for existing sports pitches to be retained, the potential need for a buffer to the existing Rayleigh Industrial Estate (assuming it does not relocate), a nearby Listed Building, and existing trees and hedgerows. Any Masterplan will need to be sensitive to these existing features, even if they do not pose significant constraints, and this will inevitably have an impact on the disposition of development and therefore land-take.

At net residential densities of between 30 and 35 dwellings per hectare, 550 residential units would require around 16-18 ha. Allowing a ratio of 60% built area to 40% landscaping, formal open space, incidental open space, children's play space, and green routes (cycleways/pedestrian ways), would produce a gross housing area of 27-30 ha.

The provision of a primary school and other youth/community facilities could equate to around a further 2.0 ha (including parking and servicing etc). We note the site specific requirements for the primary school set out on page 110 of the document, and clearly these could impact on the extent of land required in practice.

Strategic road infrastructure (including bus priority measures) alongside appropriate surface water drainage would equate to around a further 2 ha (a spine road providing bus access at Rawreth Road and linking to London Road could have a distance, avoiding a straight route, or around 1.4km).

Even if no employment land is provided north of London Road, and even assuming no more than 550 residential units, the minimum land-take for the proposed development would in our view be in the order of 30ha, but more likely in the order of 35ha.

(3) Long Term Green Belt Boundary

The Site Allocations DPD provides the mechanism not just by which a specific land allocation will be made to meet the immediate development requirement set out in the Core Strategy, but also by which the long-term, defensible Green Belt boundary will be re-set. PPG2 provides the relevant guidance, and paragraphs 2.8, 2.12 and Annex B are particularly relevant.

Paragraph 2.8 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

There is currently no reference in the Site Allocations DPD to the issue of the revised Green Belt boundary, but under the provisions of PPG2, the immediate land release and the long-term Green Belt boundary are not one and the same issue.

There are exceptional circumstances arising from the RSS development requirement to review the inner Green Belt boundary, but this should be a one-off review that re-establishes a permanent Green Belt for the future, which is capable of accommodating development requirements beyond the Plan period without needing to change. Irrespective therefore of whether or not the Core Strategy identifies a need for more than 550 units at West Rayleigh now, the revised Green Belt boundary should be capable of accommodating more than 550 units, should a need for additional units come forward either within the lifetime of this Plan, or beyond this Plan, to provide the permanence that PPG2 requires.

We feel the Site Allocations DPD needs to address the revised Green Belt boundary explicitly, and set out a proper consideration of the alternative options, having specific regard to the requirements of PPG2, including the need for safeguarded land.


Site Specific Representations (All Site Options)

It follows from the matters raised above that we do not wholly agree with any of the 5 options put forward in the Site Allocations DPD.

We agree that all of the 5 sites have potential for development, but given our comments above regarding likely land-take, we consider that a combination of the sites put forward, together potentially with additional neighbouring land, is likely to provide the right solution at the detailed master-planning stage.

In terms of some specific observations, we would offer the following:

* We do not disagree with the Council regarding the potential desirability of achieving a 'through' public transport route between Rawreth Road and London Road;

* There is a reference under several of the options presented to the need to avoid development in land at risk of flooding. Clearly we agree with the need for development to avoid flood risk areas, which in reality affects only a very small proportion of the site, and a sensible approach to Masterplanning will ensure that flood risk does not impose a constraint on the new development, and that there is no risk to existing development. The need to address flood risk and sustainable drainage within the scheme does however add weight to our argument that the size of the site allocation does require some flexibility, if the Masterplan is to be able to respond positively to existing site features (including but not exclusively flood risk);

* We do not consider that the existing pylon line forms a logical boundary to the development area. As we have set out in submissions elsewhere, these pylons can be re-laid underground (in whole or part, or take a new alignment) and therefore should not be regarded as a determining factor, either on site selection or Masterplanning;

* We do consider that the Core Strategy proposals for additional employment land west of Rayleigh should be accommodated to the north of London Road, as part of a comprehensive mixed-use scheme - we address this matter further in our representations on the employment land options;

* Finally, we note the reference to using a "Public Park" to provide a buffer between any future built development and the A1245. Countryside Properties agree that any development will need to provide appropriate open space, and that there may well be opportunities for greater public access and a Park between the built development and the A1245. This is a substantial area of land, and we do have some concerns that the reference to "park" may imply a substantially landscaped and formal area of open space. We are also unclear as to the extent of land which the Council might be considering for inclusion in the "park". In our experience, access to the countryside is an important source of informal leisure activity, and therefore retaining part at least of this land in agricultural use (perhaps with improved access) may provide both a better 'green' buffer and a greater recreational resource than an (underused) formal "park".

In terms of the individual options, our preliminary comments would be as follows:

* NLR1 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints, is suitable for residential development, and is deliverable. In isolation, it is not of sufficient size, nor does it have the benefit of a frontage to London Road, which it is assumed at this stage will be the primary point of access;

* NLR2 - This site is constrained by flood risk, and in isolation has no suitable access. It is not a realistic option for development, except as part of a wider scheme.

* NLR3 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints (assuming the pylons are laid underground or diverted), and it is likely that the principle point of access to London Road will lie on this part of the frontage to London Road. The site is not of sufficient size on its own, and also would not provide for a public transport link to Rawreth Lane, and therefore we assume this site would need to form part of a more comprehensive allocation.

* NLR4 - Our comments in relation to this land are largely the same as for NLR1 - a minimum of physical/environmental constraint (small area of flood risk), but a developable and deliverable site. It is not large enough in isolation, and does not have a frontage to London Road where we assume the primary access will be taken. It appears as if the western boundary is based on the line of the pylons, but as stated elsewhere in our representations, we do not consider the pylons to form a logical boundary to the development area.

* NLR5 - Our comments in relation to this land are largely the same as for NLR4 - although this option does have a frontage to London Road, it would necessitate disruption to the existing playing fields, and we feel that there are better options for accessing London Road. Again, the site is not large enough in isolation.

Background

Countryside Properties have control of some 98 ha of land to the north of London Road, Rayleigh, which it is seeking to bring forward to meet the development proposals set out in the emerging Rochford Core Strategy (alongside adjoining owners, as appropriate).

Notwithstanding the matters of detail raised in these submissions, Countryside Properties are committed to working with the District Council towards the successful delivery of these proposals.

Over-Arching Representations (All Site Options)

The Site Allocations DPD sets out 5 potential land parcels on the western side of Rayleigh north of London Road, ranging from 23ha to 29ha, as possible locations for accommodating the 550 houses, primary school, youth/community facilities and play space proposed in the current draft of the Core Strategy. We assume the proposed Public Park would be accommodated on land outside the identified parcels, but with some open space accommodated within the allocated area (as implied by the notation used to describe each area in the published document).

In common with the representations made by Countryside Properties to the Core Strategy, there are we consider some important points to bear in mind in respect of all of the options being put forward, being:

(1) Flexibility - The need for flexibility in the area to be allocated, to cater for lack of delivery elsewhere and to reflect the fact that the proposed allocation is a "minimum";
(2) Site Area - Delivering even the minimum level of development as currently set out in the Core Strategy will require a greater land allocation that the Site Allocations options imply; and
(3) Long-term Green Belt boundary - In allocating new development land and amending the Green Belt boundary, the Site Allocations document will be setting a new, long term defensible Green Belt boundary, and under the terms of PPG2, this will require consideration of both potential development needs in the post-Plan period, and consideration of the most appropriate Green Belt boundary.

Before turning to consider site specific matters, we set out our comments on the above points more fully below.

(1) The need for flexibility

Countryside Properties have highlighted in their representations to the Core Strategy the requirement in PPS12 for Development Plan documents to have flexibility, in order to respond to changing circumstances. Also highlighted was the fact that the RSS housing requirement is a "minimum", and that all strategic site allocations need likewise to be considered as a minimum if the requirements of the RSS in this respect are to be enacted at the local level.

The definition of the specific land allocation at the Site Allocations stage needs to have regard to that strategic context. It needs to ensure that there is sufficient flexibility within the allocated area to respond to potential changes in development requirements over the Plan period, including the possibility that additional land for housing (or indeed other development needs) may need to be delivered.

(2) Site Area

Even without the requirement for flexibility, we do not consider that the Options put forward have fully considered the land-take required for the scale of development envisaged.

Within the allocated area, there will be a requirement not only to provide the number of homes specified, but also to deliver the highway infrastructure necessary to serve the residential use, to deliver the appropriate social and community infrastructure necessary to support the housing proposed, the associated open space and strategic landscaping, and the drainage infrastructure and sustainable drainage systems necessary to create the quality of residential environment that both Countryside Properties and residents will expect to see.

We also note the requirement in the Core Strategy to provide additional employment land to the West of Rayleigh. For the reasons set out in our representations to the Core Strategy, and set out in our response to the site options presented in the Site Allocations DPD, the additional employment land proposed should be located north of London Road as part of a comprehensive mixed-use scheme.

In our experience of creating successful new residential and mixed-use communities, it is essential not to under-estimate the land required to deliver a quality scheme. In particular for and edge-of-settlement location, integrating a structural landscape framework to 'green' the environment and achieve a successful transition between town and country is essential.

The land west of Rayleigh is relatively free of physical or environmental constraints, but that does not mean that any Masterplan for the site can ignore such features as do exist - there is a public sewer, some specific areas identified as being at flood risk, the potential for existing sports pitches to be retained, the potential need for a buffer to the existing Rayleigh Industrial Estate (assuming it does not relocate), a nearby Listed Building, and existing trees and hedgerows. Any Masterplan will need to be sensitive to these existing features, even if they do not pose significant constraints, and this will inevitably have an impact on the disposition of development and therefore land-take.

At net residential densities of between 30 and 35 dwellings per hectare, 550 residential units would require around 16-18 ha. Allowing a ratio of 60% built area to 40% landscaping, formal open space, incidental open space, children's play space, and green routes (cycleways/pedestrian ways), would produce a gross housing area of 27-30 ha.

The provision of a primary school and other youth/community facilities could equate to around a further 2.0 ha (including parking and servicing etc). We note the site specific requirements for the primary school set out on page 110 of the document, and clearly these could impact on the extent of land required in practice.

Strategic road infrastructure (including bus priority measures) alongside appropriate surface water drainage would equate to around a further 2 ha (a spine road providing bus access at Rawreth Road and linking to London Road could have a distance, avoiding a straight route, or around 1.4km).

Even if no employment land is provided north of London Road, and even assuming no more than 550 residential units, the minimum land-take for the proposed development would in our view be in the order of 30ha, but more likely in the order of 35ha.

(3) Long Term Green Belt Boundary

The Site Allocations DPD provides the mechanism not just by which a specific land allocation will be made to meet the immediate development requirement set out in the Core Strategy, but also by which the long-term, defensible Green Belt boundary will be re-set. PPG2 provides the relevant guidance, and paragraphs 2.8, 2.12 and Annex B are particularly relevant.

Paragraph 2.8 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

There is currently no reference in the Site Allocations DPD to the issue of the revised Green Belt boundary, but under the provisions of PPG2, the immediate land release and the long-term Green Belt boundary are not one and the same issue.

There are exceptional circumstances arising from the RSS development requirement to review the inner Green Belt boundary, but this should be a one-off review that re-establishes a permanent Green Belt for the future, which is capable of accommodating development requirements beyond the Plan period without needing to change. Irrespective therefore of whether or not the Core Strategy identifies a need for more than 550 units at West Rayleigh now, the revised Green Belt boundary should be capable of accommodating more than 550 units, should a need for additional units come forward either within the lifetime of this Plan, or beyond this Plan, to provide the permanence that PPG2 requires.

We feel the Site Allocations DPD needs to address the revised Green Belt boundary explicitly, and set out a proper consideration of the alternative options, having specific regard to the requirements of PPG2, including the need for safeguarded land.


Site Specific Representations (All Site Options)

It follows from the matters raised above that we do not wholly agree with any of the 5 options put forward in the Site Allocations DPD.

We agree that all of the 5 sites have potential for development, but given our comments above regarding likely land-take, we consider that a combination of the sites put forward, together potentially with additional neighbouring land, is likely to provide the right solution at the detailed master-planning stage.

In terms of some specific observations, we would offer the following:

* We do not disagree with the Council regarding the potential desirability of achieving a 'through' public transport route between Rawreth Road and London Road;

* There is a reference under several of the options presented to the need to avoid development in land at risk of flooding. Clearly we agree with the need for development to avoid flood risk areas, which in reality affects only a very small proportion of the site, and a sensible approach to Masterplanning will ensure that flood risk does not impose a constraint on the new development, and that there is no risk to existing development. The need to address flood risk and sustainable drainage within the scheme does however add weight to our argument that the size of the site allocation does require some flexibility, if the Masterplan is to be able to respond positively to existing site features (including but not exclusively flood risk);

* We do not consider that the existing pylon line forms a logical boundary to the development area. As we have set out in submissions elsewhere, these pylons can be re-laid underground (in whole or part, or take a new alignment) and therefore should not be regarded as a determining factor, either on site selection or Masterplanning;

* We do consider that the Core Strategy proposals for additional employment land west of Rayleigh should be accommodated to the north of London Road, as part of a comprehensive mixed-use scheme - we address this matter further in our representations on the employment land options;

* Finally, we note the reference to using a "Public Park" to provide a buffer between any future built development and the A1245. Countryside Properties agree that any development will need to provide appropriate open space, and that there may well be opportunities for greater public access and a Park between the built development and the A1245. This is a substantial area of land, and we do have some concerns that the reference to "park" may imply a substantially landscaped and formal area of open space. We are also unclear as to the extent of land which the Council might be considering for inclusion in the "park". In our experience, access to the countryside is an important source of informal leisure activity, and therefore retaining part at least of this land in agricultural use (perhaps with improved access) may provide both a better 'green' buffer and a greater recreational resource than an (underused) formal "park".

In terms of the individual options, our preliminary comments would be as follows:

* NLR1 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints, is suitable for residential development, and is deliverable. In isolation, it is not of sufficient size, nor does it have the benefit of a frontage to London Road, which it is assumed at this stage will be the primary point of access;

* NLR2 - This site is constrained by flood risk, and in isolation has no suitable access. It is not a realistic option for development, except as part of a wider scheme.

* NLR3 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints (assuming the pylons are laid underground or diverted), and it is likely that the principle point of access to London Road will lie on this part of the frontage to London Road. The site is not of sufficient size on its own, and also would not provide for a public transport link to Rawreth Lane, and therefore we assume this site would need to form part of a more comprehensive allocation.

* NLR4 - Our comments in relation to this land are largely the same as for NLR1 - a minimum of physical/environmental constraint (small area of flood risk), but a developable and deliverable site. It is not large enough in isolation, and does not have a frontage to London Road where we assume the primary access will be taken. It appears as if the western boundary is based on the line of the pylons, but as stated elsewhere in our representations, we do not consider the pylons to form a logical boundary to the development area.

* NLR5 - Our comments in relation to this land are largely the same as for NLR4 - although this option does have a frontage to London Road, it would necessitate disruption to the existing playing fields, and we feel that there are better options for accessing London Road. Again, the site is not large enough in isolation.

Background

Countryside Properties have control of some 98 ha of land to the north of London Road, Rayleigh, which it is seeking to bring forward to meet the development proposals set out in the emerging Rochford Core Strategy (alongside adjoining owners, as appropriate).

Notwithstanding the matters of detail raised in these submissions, Countryside Properties are committed to working with the District Council towards the successful delivery of these proposals.

Over-Arching Representations (All Site Options)

The Site Allocations DPD sets out 5 potential land parcels on the western side of Rayleigh north of London Road, ranging from 23ha to 29ha, as possible locations for accommodating the 550 houses, primary school, youth/community facilities and play space proposed in the current draft of the Core Strategy. We assume the proposed Public Park would be accommodated on land outside the identified parcels, but with some open space accommodated within the allocated area (as implied by the notation used to describe each area in the published document).

In common with the representations made by Countryside Properties to the Core Strategy, there are we consider some important points to bear in mind in respect of all of the options being put forward, being:

(1) Flexibility - The need for flexibility in the area to be allocated, to cater for lack of delivery elsewhere and to reflect the fact that the proposed allocation is a "minimum";
(2) Site Area - Delivering even the minimum level of development as currently set out in the Core Strategy will require a greater land allocation that the Site Allocations options imply; and
(3) Long-term Green Belt boundary - In allocating new development land and amending the Green Belt boundary, the Site Allocations document will be setting a new, long term defensible Green Belt boundary, and under the terms of PPG2, this will require consideration of both potential development needs in the post-Plan period, and consideration of the most appropriate Green Belt boundary.

Before turning to consider site specific matters, we set out our comments on the above points more fully below.

(1) The need for flexibility

Countryside Properties have highlighted in their representations to the Core Strategy the requirement in PPS12 for Development Plan documents to have flexibility, in order to respond to changing circumstances. Also highlighted was the fact that the RSS housing requirement is a "minimum", and that all strategic site allocations need likewise to be considered as a minimum if the requirements of the RSS in this respect are to be enacted at the local level.

The definition of the specific land allocation at the Site Allocations stage needs to have regard to that strategic context. It needs to ensure that there is sufficient flexibility within the allocated area to respond to potential changes in development requirements over the Plan period, including the possibility that additional land for housing (or indeed other development needs) may need to be delivered.

(2) Site Area

Even without the requirement for flexibility, we do not consider that the Options put forward have fully considered the land-take required for the scale of development envisaged.

Within the allocated area, there will be a requirement not only to provide the number of homes specified, but also to deliver the highway infrastructure necessary to serve the residential use, to deliver the appropriate social and community infrastructure necessary to support the housing proposed, the associated open space and strategic landscaping, and the drainage infrastructure and sustainable drainage systems necessary to create the quality of residential environment that both Countryside Properties and residents will expect to see.

We also note the requirement in the Core Strategy to provide additional employment land to the West of Rayleigh. For the reasons set out in our representations to the Core Strategy, and set out in our response to the site options presented in the Site Allocations DPD, the additional employment land proposed should be located north of London Road as part of a comprehensive mixed-use scheme.

In our experience of creating successful new residential and mixed-use communities, it is essential not to under-estimate the land required to deliver a quality scheme. In particular for and edge-of-settlement location, integrating a structural landscape framework to 'green' the environment and achieve a successful transition between town and country is essential.

The land west of Rayleigh is relatively free of physical or environmental constraints, but that does not mean that any Masterplan for the site can ignore such features as do exist - there is a public sewer, some specific areas identified as being at flood risk, the potential for existing sports pitches to be retained, the potential need for a buffer to the existing Rayleigh Industrial Estate (assuming it does not relocate), a nearby Listed Building, and existing trees and hedgerows. Any Masterplan will need to be sensitive to these existing features, even if they do not pose significant constraints, and this will inevitably have an impact on the disposition of development and therefore land-take.

At net residential densities of between 30 and 35 dwellings per hectare, 550 residential units would require around 16-18 ha. Allowing a ratio of 60% built area to 40% landscaping, formal open space, incidental open space, children's play space, and green routes (cycleways/pedestrian ways), would produce a gross housing area of 27-30 ha.

The provision of a primary school and other youth/community facilities could equate to around a further 2.0 ha (including parking and servicing etc). We note the site specific requirements for the primary school set out on page 110 of the document, and clearly these could impact on the extent of land required in practice.

Strategic road infrastructure (including bus priority measures) alongside appropriate surface water drainage would equate to around a further 2 ha (a spine road providing bus access at Rawreth Road and linking to London Road could have a distance, avoiding a straight route, or around 1.4km).

Even if no employment land is provided north of London Road, and even assuming no more than 550 residential units, the minimum land-take for the proposed development would in our view be in the order of 30ha, but more likely in the order of 35ha.

(3) Long Term Green Belt Boundary

The Site Allocations DPD provides the mechanism not just by which a specific land allocation will be made to meet the immediate development requirement set out in the Core Strategy, but also by which the long-term, defensible Green Belt boundary will be re-set. PPG2 provides the relevant guidance, and paragraphs 2.8, 2.12 and Annex B are particularly relevant.

Paragraph 2.8 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

There is currently no reference in the Site Allocations DPD to the issue of the revised Green Belt boundary, but under the provisions of PPG2, the immediate land release and the long-term Green Belt boundary are not one and the same issue.

There are exceptional circumstances arising from the RSS development requirement to review the inner Green Belt boundary, but this should be a one-off review that re-establishes a permanent Green Belt for the future, which is capable of accommodating development requirements beyond the Plan period without needing to change. Irrespective therefore of whether or not the Core Strategy identifies a need for more than 550 units at West Rayleigh now, the revised Green Belt boundary should be capable of accommodating more than 550 units, should a need for additional units come forward either within the lifetime of this Plan, or beyond this Plan, to provide the permanence that PPG2 requires.

We feel the Site Allocations DPD needs to address the revised Green Belt boundary explicitly, and set out a proper consideration of the alternative options, having specific regard to the requirements of PPG2, including the need for safeguarded land.


Site Specific Representations (All Site Options)

It follows from the matters raised above that we do not wholly agree with any of the 5 options put forward in the Site Allocations DPD.

We agree that all of the 5 sites have potential for development, but given our comments above regarding likely land-take, we consider that a combination of the sites put forward, together potentially with additional neighbouring land, is likely to provide the right solution at the detailed master-planning stage.

In terms of some specific observations, we would offer the following:

* We do not disagree with the Council regarding the potential desirability of achieving a 'through' public transport route between Rawreth Road and London Road;

* There is a reference under several of the options presented to the need to avoid development in land at risk of flooding. Clearly we agree with the need for development to avoid flood risk areas, which in reality affects only a very small proportion of the site, and a sensible approach to Masterplanning will ensure that flood risk does not impose a constraint on the new development, and that there is no risk to existing development. The need to address flood risk and sustainable drainage within the scheme does however add weight to our argument that the size of the site allocation does require some flexibility, if the Masterplan is to be able to respond positively to existing site features (including but not exclusively flood risk);

* We do not consider that the existing pylon line forms a logical boundary to the development area. As we have set out in submissions elsewhere, these pylons can be re-laid underground (in whole or part, or take a new alignment) and therefore should not be regarded as a determining factor, either on site selection or Masterplanning;

* We do consider that the Core Strategy proposals for additional employment land west of Rayleigh should be accommodated to the north of London Road, as part of a comprehensive mixed-use scheme - we address this matter further in our representations on the employment land options;

* Finally, we note the reference to using a "Public Park" to provide a buffer between any future built development and the A1245. Countryside Properties agree that any development will need to provide appropriate open space, and that there may well be opportunities for greater public access and a Park between the built development and the A1245. This is a substantial area of land, and we do have some concerns that the reference to "park" may imply a substantially landscaped and formal area of open space. We are also unclear as to the extent of land which the Council might be considering for inclusion in the "park". In our experience, access to the countryside is an important source of informal leisure activity, and therefore retaining part at least of this land in agricultural use (perhaps with improved access) may provide both a better 'green' buffer and a greater recreational resource than an (underused) formal "park".

In terms of the individual options, our preliminary comments would be as follows:

* NLR1 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints, is suitable for residential development, and is deliverable. In isolation, it is not of sufficient size, nor does it have the benefit of a frontage to London Road, which it is assumed at this stage will be the primary point of access;

* NLR2 - This site is constrained by flood risk, and in isolation has no suitable access. It is not a realistic option for development, except as part of a wider scheme.

* NLR3 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints (assuming the pylons are laid underground or diverted), and it is likely that the principle point of access to London Road will lie on this part of the frontage to London Road. The site is not of sufficient size on its own, and also would not provide for a public transport link to Rawreth Lane, and therefore we assume this site would need to form part of a more comprehensive allocation.

* NLR4 - Our comments in relation to this land are largely the same as for NLR1 - a minimum of physical/environmental constraint (small area of flood risk), but a developable and deliverable site. It is not large enough in isolation, and does not have a frontage to London Road where we assume the primary access will be taken. It appears as if the western boundary is based on the line of the pylons, but as stated elsewhere in our representations, we do not consider the pylons to form a logical boundary to the development area.

* NLR5 - Our comments in relation to this land are largely the same as for NLR4 - although this option does have a frontage to London Road, it would necessitate disruption to the existing playing fields, and we feel that there are better options for accessing London Road. Again, the site is not large enough in isolation.

Background

Countryside Properties have control of some 98 ha of land to the north of London Road, Rayleigh, which it is seeking to bring forward to meet the development proposals set out in the emerging Rochford Core Strategy (alongside adjoining owners, as appropriate).

Notwithstanding the matters of detail raised in these submissions, Countryside Properties are committed to working with the District Council towards the successful delivery of these proposals.

Over-Arching Representations (All Site Options)

The Site Allocations DPD sets out 5 potential land parcels on the western side of Rayleigh north of London Road, ranging from 23ha to 29ha, as possible locations for accommodating the 550 houses, primary school, youth/community facilities and play space proposed in the current draft of the Core Strategy. We assume the proposed Public Park would be accommodated on land outside the identified parcels, but with some open space accommodated within the allocated area (as implied by the notation used to describe each area in the published document).

In common with the representations made by Countryside Properties to the Core Strategy, there are we consider some important points to bear in mind in respect of all of the options being put forward, being:

(1) Flexibility - The need for flexibility in the area to be allocated, to cater for lack of delivery elsewhere and to reflect the fact that the proposed allocation is a "minimum";
(2) Site Area - Delivering even the minimum level of development as currently set out in the Core Strategy will require a greater land allocation that the Site Allocations options imply; and
(3) Long-term Green Belt boundary - In allocating new development land and amending the Green Belt boundary, the Site Allocations document will be setting a new, long term defensible Green Belt boundary, and under the terms of PPG2, this will require consideration of both potential development needs in the post-Plan period, and consideration of the most appropriate Green Belt boundary.

Before turning to consider site specific matters, we set out our comments on the above points more fully below.

(1) The need for flexibility

Countryside Properties have highlighted in their representations to the Core Strategy the requirement in PPS12 for Development Plan documents to have flexibility, in order to respond to changing circumstances. Also highlighted was the fact that the RSS housing requirement is a "minimum", and that all strategic site allocations need likewise to be considered as a minimum if the requirements of the RSS in this respect are to be enacted at the local level.

The definition of the specific land allocation at the Site Allocations stage needs to have regard to that strategic context. It needs to ensure that there is sufficient flexibility within the allocated area to respond to potential changes in development requirements over the Plan period, including the possibility that additional land for housing (or indeed other development needs) may need to be delivered.

(2) Site Area

Even without the requirement for flexibility, we do not consider that the Options put forward have fully considered the land-take required for the scale of development envisaged.

Within the allocated area, there will be a requirement not only to provide the number of homes specified, but also to deliver the highway infrastructure necessary to serve the residential use, to deliver the appropriate social and community infrastructure necessary to support the housing proposed, the associated open space and strategic landscaping, and the drainage infrastructure and sustainable drainage systems necessary to create the quality of residential environment that both Countryside Properties and residents will expect to see.

We also note the requirement in the Core Strategy to provide additional employment land to the West of Rayleigh. For the reasons set out in our representations to the Core Strategy, and set out in our response to the site options presented in the Site Allocations DPD, the additional employment land proposed should be located north of London Road as part of a comprehensive mixed-use scheme.

In our experience of creating successful new residential and mixed-use communities, it is essential not to under-estimate the land required to deliver a quality scheme. In particular for and edge-of-settlement location, integrating a structural landscape framework to 'green' the environment and achieve a successful transition between town and country is essential.

The land west of Rayleigh is relatively free of physical or environmental constraints, but that does not mean that any Masterplan for the site can ignore such features as do exist - there is a public sewer, some specific areas identified as being at flood risk, the potential for existing sports pitches to be retained, the potential need for a buffer to the existing Rayleigh Industrial Estate (assuming it does not relocate), a nearby Listed Building, and existing trees and hedgerows. Any Masterplan will need to be sensitive to these existing features, even if they do not pose significant constraints, and this will inevitably have an impact on the disposition of development and therefore land-take.

At net residential densities of between 30 and 35 dwellings per hectare, 550 residential units would require around 16-18 ha. Allowing a ratio of 60% built area to 40% landscaping, formal open space, incidental open space, children's play space, and green routes (cycleways/pedestrian ways), would produce a gross housing area of 27-30 ha.

The provision of a primary school and other youth/community facilities could equate to around a further 2.0 ha (including parking and servicing etc). We note the site specific requirements for the primary school set out on page 110 of the document, and clearly these could impact on the extent of land required in practice.

Strategic road infrastructure (including bus priority measures) alongside appropriate surface water drainage would equate to around a further 2 ha (a spine road providing bus access at Rawreth Road and linking to London Road could have a distance, avoiding a straight route, or around 1.4km).

Even if no employment land is provided north of London Road, and even assuming no more than 550 residential units, the minimum land-take for the proposed development would in our view be in the order of 30ha, but more likely in the order of 35ha.

(3) Long Term Green Belt Boundary

The Site Allocations DPD provides the mechanism not just by which a specific land allocation will be made to meet the immediate development requirement set out in the Core Strategy, but also by which the long-term, defensible Green Belt boundary will be re-set. PPG2 provides the relevant guidance, and paragraphs 2.8, 2.12 and Annex B are particularly relevant.

Paragraph 2.8 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

There is currently no reference in the Site Allocations DPD to the issue of the revised Green Belt boundary, but under the provisions of PPG2, the immediate land release and the long-term Green Belt boundary are not one and the same issue.

There are exceptional circumstances arising from the RSS development requirement to review the inner Green Belt boundary, but this should be a one-off review that re-establishes a permanent Green Belt for the future, which is capable of accommodating development requirements beyond the Plan period without needing to change. Irrespective therefore of whether or not the Core Strategy identifies a need for more than 550 units at West Rayleigh now, the revised Green Belt boundary should be capable of accommodating more than 550 units, should a need for additional units come forward either within the lifetime of this Plan, or beyond this Plan, to provide the permanence that PPG2 requires.

We feel the Site Allocations DPD needs to address the revised Green Belt boundary explicitly, and set out a proper consideration of the alternative options, having specific regard to the requirements of PPG2, including the need for safeguarded land.


Site Specific Representations (All Site Options)

It follows from the matters raised above that we do not wholly agree with any of the 5 options put forward in the Site Allocations DPD.

We agree that all of the 5 sites have potential for development, but given our comments above regarding likely land-take, we consider that a combination of the sites put forward, together potentially with additional neighbouring land, is likely to provide the right solution at the detailed master-planning stage.

In terms of some specific observations, we would offer the following:

* We do not disagree with the Council regarding the potential desirability of achieving a 'through' public transport route between Rawreth Road and London Road;

* There is a reference under several of the options presented to the need to avoid development in land at risk of flooding. Clearly we agree with the need for development to avoid flood risk areas, which in reality affects only a very small proportion of the site, and a sensible approach to Masterplanning will ensure that flood risk does not impose a constraint on the new development, and that there is no risk to existing development. The need to address flood risk and sustainable drainage within the scheme does however add weight to our argument that the size of the site allocation does require some flexibility, if the Masterplan is to be able to respond positively to existing site features (including but not exclusively flood risk);

* We do not consider that the existing pylon line forms a logical boundary to the development area. As we have set out in submissions elsewhere, these pylons can be re-laid underground (in whole or part, or take a new alignment) and therefore should not be regarded as a determining factor, either on site selection or Masterplanning;

* We do consider that the Core Strategy proposals for additional employment land west of Rayleigh should be accommodated to the north of London Road, as part of a comprehensive mixed-use scheme - we address this matter further in our representations on the employment land options;

* Finally, we note the reference to using a "Public Park" to provide a buffer between any future built development and the A1245. Countryside Properties agree that any development will need to provide appropriate open space, and that there may well be opportunities for greater public access and a Park between the built development and the A1245. This is a substantial area of land, and we do have some concerns that the reference to "park" may imply a substantially landscaped and formal area of open space. We are also unclear as to the extent of land which the Council might be considering for inclusion in the "park". In our experience, access to the countryside is an important source of informal leisure activity, and therefore retaining part at least of this land in agricultural use (perhaps with improved access) may provide both a better 'green' buffer and a greater recreational resource than an (underused) formal "park".

In terms of the individual options, our preliminary comments would be as follows:

* NLR1 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints, is suitable for residential development, and is deliverable. In isolation, it is not of sufficient size, nor does it have the benefit of a frontage to London Road, which it is assumed at this stage will be the primary point of access;

* NLR2 - This site is constrained by flood risk, and in isolation has no suitable access. It is not a realistic option for development, except as part of a wider scheme.

* NLR3 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints (assuming the pylons are laid underground or diverted), and it is likely that the principle point of access to London Road will lie on this part of the frontage to London Road. The site is not of sufficient size on its own, and also would not provide for a public transport link to Rawreth Lane, and therefore we assume this site would need to form part of a more comprehensive allocation.

* NLR4 - Our comments in relation to this land are largely the same as for NLR1 - a minimum of physical/environmental constraint (small area of flood risk), but a developable and deliverable site. It is not large enough in isolation, and does not have a frontage to London Road where we assume the primary access will be taken. It appears as if the western boundary is based on the line of the pylons, but as stated elsewhere in our representations, we do not consider the pylons to form a logical boundary to the development area.

* NLR5 - Our comments in relation to this land are largely the same as for NLR4 - although this option does have a frontage to London Road, it would necessitate disruption to the existing playing fields, and we feel that there are better options for accessing London Road. Again, the site is not large enough in isolation.

Background

Both the Core Strategy and the Site Allocations DPD identify Rawreth Industrial Estate for re-allocation to residential uses. For the reasons set out by Countryside Properties in their submissions to the Core Strategy (re-iterated below), we do not consider that the site is necessarily desirable, suitable or deliverable for residential development. We consider that the site can remain as an important source of local employment, and this should be reflected in both the Core Strategy and the Site Allocations DPD.

Representations

The representations to the Core Strategy raise significant concerns regarding both the desirability/suitability of redeveloping Rawreth Lane Industrial Estate, and the achievability of this proposal.

The Core Strategy seeks the provision of an equivalent area of land to compensate for redevelopment, and notes that this will require the use of Green Belt land. Although notionally the redevelopment of the Estate for housing will reduce the amount of housing in the Green Belt, there will be no lesser amount of Green Belt development in total. Indeed, it will be evident that the existing Estate is actually already over-crowded, with substantial on-street parking, limited opportunities for servicing, limited landscaping, and no space for firms to expand.

To meet current standards and design expectations, the replacement Industrial Estate will inevitably end up being materially larger than the existing site, if it is to be attractive to occupiers and if it is to meet the Council's expectations. Ironically, this proposal is therefore likely to lead to a greater loss of Green Belt than would be the case if the Estate were to stay in its current location.

We have reservations as to whether or not existing firms will be able to relocate in any event. The Council will note that many of the existing businesses are relatively 'low value' users, that are well established in their existing premises. They are likely to be paying relatively low rents, given the nature of the site. Even if new premises can be provided at equivalent rents, relocating a business is expensive. Existing (and often fixed) plant, equipment, tools, stocks and materials have to be moved, as well as the disruption to trading caused by moving. Even where uses operate primarily from open yards, new portacabins/buildings have to be paid for and installed. Relocation will be a substantial cost to these existing businesses, and if the existing estate is redeveloped, it has to be open to question as to how many would in fact be able to afford to relocate.

In the meantime, in advance of redevelopment, there is likely to be a disincentive to owners to invest in the existing infrastructure, and a lack of will to take on new long-term tenants. The effect is likely to be years of decline and job losses, before new land is brought forward. Whilst this may be compensated in the future by the creation of new employment at West Rayleigh, this is as much likely to be based on new investment and new enterprises, as it is the relocation of existing users from Rawreth Lane.

We are also doubtful as to whether or not redevelopment will be practically possible. The existing Estate contains numerous tenants, many of whom may have long term tenancies or even own their own premises. The site has a long history of potentially contaminative uses, which would be likely to add significantly to the cost of redevelopment for suburban residential development, and which would also make partial redevelopment very unlikely. There is therefore no certainty either that the land is genuinely available for redevelopment, or that redevelopment is viable.

In accordance with representations made by Countryside Properties to the Core Strategy, we consider either that the Estate should continue to be identified for commercial purposes, or at least that the Site Allocations Document does not prevent or prejudice continued commercial use or commercial re-development, even if an option for residential redevelopment remains.

Background

Both the Core Strategy and the Site Allocations DPD identify Stambridge Mills for re-allocation to residential uses. For the reasons set out in the submissions made by Countryside Properties to the Core Strategy (re-iterated below), we do not consider that the site is necessarily suitable, desirable or deliverable for residential development. We consider that the site can remain as an important source of local employment, and this should be reflected in both the Core Strategy and the Site Allocations DPD.

Representations

The Council will be well aware of the objections made by various parties to the Core Strategy proposal to redevelop this site on Flood Risk grounds. We do not consider that the exceptions test in PPS25 is passed in this case, since there are options for development on land outside flood zone 3 (we do not agree with the approach put forward by the Council in Core Strategy Topic Paper 1, that defence of the Green Belt is an adequate rationale to build homes on land at risk of flooding).

Even if an exception can be justified under PPS25, 250 homes at a density of just under 140 dph is a very high density for a site in such a relatively remote and unsustainable location (page 120 of the Core Strategy gives the site area as 1.8ha). It is difficult to see how this intensity of development is justified, when the recommended density for town centres is only 75+ dph.

If retained, therefore, the quantum of development proposed needs to reflect the relatively isolated and unsustainable location of the site.