Allocations DPD Discussion and Consultation Document

Background

We recognise that there is both a need for suitable sites for gypsies and travellers, and indeed a requirement under the RSS for provision, and therefore Countryside Properties support the principle of provision through the Site Allocations DPD.

However, in our view, sites GT1, GT2 are not suitable for allocation, for the reasons we set out.

Representations

Sites GT1 and GT2 essentially relate to the same area of land to the immediate east of the A1245, with GT2 representing a slightly larger area of land (which falls within the control of Countryside Properties) compared to GT1.

The Site Allocations DPD notes that "access to the A1245 would need to be negotiated carefully". The site is already used for the siting of mobile homes and caravans, accessed from what is essentially a 90 degree turn from the dual carriageway. Our understanding is that the existing use already causes concerns in terms of the suitability and safety of the access. It is difficult to see how a feasible and viable alternative can be created to accommodate a significant increase in usage. Slip lanes in to and out of the site would be both expensive to provide and would significantly decrease the amount of land available, as well as disrupting the existing occupiers. We are not sure how else an improved access to the site can be provided.

The area of land between the A1245 and the extent of the proposed new development west of Rayleigh has been identified as a 'buffer' in the Core Strategy, and for the provision of a 'Public Park'. Clearly if there is development on the western side of Rayleigh and additional development on the eastern side of the A1245, that 'buffer' will be squeezed from both sides. It is difficult to see how the provision of a substantial additional area of land for mobile homes/caravans is consistent with the concept of the proposed 'buffer'.

In terms of the question raised at the end of this section of the consultation, it would be rare if one site were suitable for the entirety of the gypsy and travelling communities. As with the provision of homes for the remainder of the population, choice is an important consideration in the provision of sites for gypsies and travellers, and providing a range of sites in different locations and of different sizes helps to ensure that those members of the community that have different site or family needs can be catered for. In principle, therefore, provision should be made on several sites, not one large site.

As indicated above, site GT2 includes land under the control of Countryside Properties. Countryside Properties do not support this proposal, and it is difficult to see therefore how this site could be delivered.

Background

We recognise that there is both a need for suitable sites for gypsies and travellers, and indeed a requirement under the RSS for provision, and therefore Countryside Properties support the principle of provision through the Site Allocations DPD.

However, in our view, sites GT1, GT2 are not suitable for allocation, for the reasons we set out.

Representations

Sites GT1 and GT2 essentially relate to the same area of land to the immediate east of the A1245, with GT2 representing a slightly larger area of land (which falls within the control of Countryside Properties) compared to GT1.

The Site Allocations DPD notes that "access to the A1245 would need to be negotiated carefully". The site is already used for the siting of mobile homes and caravans, accessed from what is essentially a 90 degree turn from the dual carriageway. Our understanding is that the existing use already causes concerns in terms of the suitability and safety of the access. It is difficult to see how a feasible and viable alternative can be created to accommodate a significant increase in usage. Slip lanes in to and out of the site would be both expensive to provide and would significantly decrease the amount of land available, as well as disrupting the existing occupiers. We are not sure how else an improved access to the site can be provided.

The area of land between the A1245 and the extent of the proposed new development west of Rayleigh has been identified as a 'buffer' in the Core Strategy, and for the provision of a 'Public Park'. Clearly if there is development on the western side of Rayleigh and additional development on the eastern side of the A1245, that 'buffer' will be squeezed from both sides. It is difficult to see how the provision of a substantial additional area of land for mobile homes/caravans is consistent with the concept of the proposed 'buffer'.

In terms of the question raised at the end of this section of the consultation, it would be rare if one site were suitable for the entirety of the gypsy and travelling communities. As with the provision of homes for the remainder of the population, choice is an important consideration in the provision of sites for gypsies and travellers, and providing a range of sites in different locations and of different sizes helps to ensure that those members of the community that have different site or family needs can be catered for. In principle, therefore, provision should be made on several sites, not one large site.

As indicated above, site GT2 includes land under the control of Countryside Properties. Countryside Properties do not support this proposal, and it is difficult to see therefore how this site could be delivered.

Background

We recognise that there is both a need for suitable sites for gypsies and travellers, and indeed a requirement under the RSS for provision, and therefore Countryside Properties support the principle of provision through the Site Allocations DPD.

However, in our view, sites GT1, GT2 are not suitable for allocation, for the reasons we set out.

Representations

Sites GT1 and GT2 essentially relate to the same area of land to the immediate east of the A1245, with GT2 representing a slightly larger area of land (which falls within the control of Countryside Properties) compared to GT1.

The Site Allocations DPD notes that "access to the A1245 would need to be negotiated carefully". The site is already used for the siting of mobile homes and caravans, accessed from what is essentially a 90 degree turn from the dual carriageway. Our understanding is that the existing use already causes concerns in terms of the suitability and safety of the access. It is difficult to see how a feasible and viable alternative can be created to accommodate a significant increase in usage. Slip lanes in to and out of the site would be both expensive to provide and would significantly decrease the amount of land available, as well as disrupting the existing occupiers. We are not sure how else an improved access to the site can be provided.

The area of land between the A1245 and the extent of the proposed new development west of Rayleigh has been identified as a 'buffer' in the Core Strategy, and for the provision of a 'Public Park'. Clearly if there is development on the western side of Rayleigh and additional development on the eastern side of the A1245, that 'buffer' will be squeezed from both sides. It is difficult to see how the provision of a substantial additional area of land for mobile homes/caravans is consistent with the concept of the proposed 'buffer'.

In terms of the question raised at the end of this section of the consultation, it would be rare if one site were suitable for the entirety of the gypsy and travelling communities. As with the provision of homes for the remainder of the population, choice is an important consideration in the provision of sites for gypsies and travellers, and providing a range of sites in different locations and of different sizes helps to ensure that those members of the community that have different site or family needs can be catered for. In principle, therefore, provision should be made on several sites, not one large site.

As indicated above, site GT2 includes land under the control of Countryside Properties. Countryside Properties do not support this proposal, and it is difficult to see therefore how this site could be delivered.

Background

We recognise that there is both a need for suitable sites for gypsies and travellers, and indeed a requirement under the RSS for provision, and therefore Countryside Properties support the principle of provision through the Site Allocations DPD.

However, in our view, sites GT1, GT2 are not suitable for allocation, for the reasons we set out.

Representations

Sites GT1 and GT2 essentially relate to the same area of land to the immediate east of the A1245, with GT2 representing a slightly larger area of land (which falls within the control of Countryside Properties) compared to GT1.

The Site Allocations DPD notes that "access to the A1245 would need to be negotiated carefully". The site is already used for the siting of mobile homes and caravans, accessed from what is essentially a 90 degree turn from the dual carriageway. Our understanding is that the existing use already causes concerns in terms of the suitability and safety of the access. It is difficult to see how a feasible and viable alternative can be created to accommodate a significant increase in usage. Slip lanes in to and out of the site would be both expensive to provide and would significantly decrease the amount of land available, as well as disrupting the existing occupiers. We are not sure how else an improved access to the site can be provided.

The area of land between the A1245 and the extent of the proposed new development west of Rayleigh has been identified as a 'buffer' in the Core Strategy, and for the provision of a 'Public Park'. Clearly if there is development on the western side of Rayleigh and additional development on the eastern side of the A1245, that 'buffer' will be squeezed from both sides. It is difficult to see how the provision of a substantial additional area of land for mobile homes/caravans is consistent with the concept of the proposed 'buffer'.

In terms of the question raised at the end of this section of the consultation, it would be rare if one site were suitable for the entirety of the gypsy and travelling communities. As with the provision of homes for the remainder of the population, choice is an important consideration in the provision of sites for gypsies and travellers, and providing a range of sites in different locations and of different sizes helps to ensure that those members of the community that have different site or family needs can be catered for. In principle, therefore, provision should be made on several sites, not one large site.

As indicated above, site GT2 includes land under the control of Countryside Properties. Countryside Properties do not support this proposal, and it is difficult to see therefore how this site could be delivered.

Background

We recognise that there is both a need for suitable sites for gypsies and travellers, and indeed a requirement under the RSS for provision, and therefore Countryside Properties support the principle of provision through the Site Allocations DPD.

However, in our view, sites GT1, GT2 are not suitable for allocation, for the reasons we set out.

Representations

Sites GT1 and GT2 essentially relate to the same area of land to the immediate east of the A1245, with GT2 representing a slightly larger area of land (which falls within the control of Countryside Properties) compared to GT1.

The Site Allocations DPD notes that "access to the A1245 would need to be negotiated carefully". The site is already used for the siting of mobile homes and caravans, accessed from what is essentially a 90 degree turn from the dual carriageway. Our understanding is that the existing use already causes concerns in terms of the suitability and safety of the access. It is difficult to see how a feasible and viable alternative can be created to accommodate a significant increase in usage. Slip lanes in to and out of the site would be both expensive to provide and would significantly decrease the amount of land available, as well as disrupting the existing occupiers. We are not sure how else an improved access to the site can be provided.

The area of land between the A1245 and the extent of the proposed new development west of Rayleigh has been identified as a 'buffer' in the Core Strategy, and for the provision of a 'Public Park'. Clearly if there is development on the western side of Rayleigh and additional development on the eastern side of the A1245, that 'buffer' will be squeezed from both sides. It is difficult to see how the provision of a substantial additional area of land for mobile homes/caravans is consistent with the concept of the proposed 'buffer'.

In terms of the question raised at the end of this section of the consultation, it would be rare if one site were suitable for the entirety of the gypsy and travelling communities. As with the provision of homes for the remainder of the population, choice is an important consideration in the provision of sites for gypsies and travellers, and providing a range of sites in different locations and of different sizes helps to ensure that those members of the community that have different site or family needs can be catered for. In principle, therefore, provision should be made on several sites, not one large site.

As indicated above, site GT2 includes land under the control of Countryside Properties. Countryside Properties do not support this proposal, and it is difficult to see therefore how this site could be delivered.

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.

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

In accordance with their representations to the Core Strategy, Countryside Properties are supportive of the proposals for the provision of additional employment land to the west of Rayleigh, but we consider that such provision should be made to the north of London Road as part of a comprehensive mixed-use development, not to the south of London Road (or at Michelins Farm).

Representations

In our view, the most appropriate location for new employment development west of Rayleigh is to the north of London Road, as part of a comprehensive mixed-use scheme. In our original submissions to the Core Strategy, we advanced a number of arguments to support this position, including:

* It is inherently more sustainable in principle to provide for an integrated mixed-use scheme, rather than segregated residential and commercial areas;
* The viability of providing the new employment land is increased as part of a mixed-use scheme, since the costs of infrastructure (including roads, drainage, and utilities) is shared;
* There is more than sufficient land north of London Road to deliver a mixed-use scheme - there is less certainty that the scale of development required could be successfully provided south of London Road;
* To be attractive to new business, a high quality business park of sufficient size will be required - there is more land north of London Road to achieve this;
* There are advantages in terms of public transport accessibility/viability in serving a business location alongside a residential location (greater patronage and two-way passenger flows);
* It is difficult to see how the Green Belt boundary south of London Road could successfully be changed to allow for a large scale employment area, without either creating a ribbon of development along London Road, or an isolated incursion not linked to the existing community;
* Countryside Properties has particular experience in successfully delivering mixed-use schemes, including the creation of modern, flexible business space.

In the light of the above, we do not support the potential employment sites E13, E14, E15, or E16, all of which lie to the south of London Road.

In addition to the general observations above, we note that in relation to the particular sites E13-E16 the following additional points:

* All of these options utilise to some extent of other land already in commercial use. This raises two significant questions: Is the land proposed genuinely available, given the existing uses, and is the land genuinely additional employment land, or simply a replacement of existing jobs?
On the first question, it appears to us that each of these options is based upon land in multiple ownership, and where there are existing businesses/tenancies which together may make the land impossible to bring forward in a comprehensive way.

On the second question, although the existing commercial uses may not be allocated for businesses purposes as such, there are long-standing commercial uses on the site that are an existing source of employment. All four options E13-E16 appear to be premised upon the loss of the existing commercial uses, and therefore any net increase in allocated employment land would need to take in to account the extent of existing land lost.

* Notwithstanding the above, none of the options presented are of sufficient scale to provide for the extent of employment land required under the Core Strategy. The four options vary between a minimum of 2.65 ha and a maximum of 5 ha. The Core Strategy identified a need for 2 ha for office use and 6 ha for the relocation of Rawreth Lane Industrial Estate, making a minimum of 8 ha. In our view (and notwithstanding our concerns regarding practicality), relocating Rawreth Industrial Estate would require more than 6ha - the existing estate is already over-crowded, as the extent of on-street parking demonstrates, allows no scope for businesses to expand, and the existing layout does not provide the quality of environment that the Council would rightly expect (and which new businesses would demand) from a new commercial park.

In our view, around 10 ha is a more realistic land-take for replacing Rawreth Lane Industrial Estate, making around 12 ha of land in total to be found west of Rayleigh to support the employment proposals of the Core Strategy. This scale of development cannot be found south of London Road (or at Michelins Farm).

E17 is the only option put forward to the north of London Road, and clearly therefore on the basis of the above, we feel this option warrants further consideration, albeit in isolation it would still not be large enough to accommodate the full employment land requirement (if Rawreth Lane Industrial Estate is to be redeveloped).

There is however potential to increase the size of site E17, whether by extension to the north (whilst still avoiding areas of flood risk), or by extension to the east, as part of or linking in with the proposed new residential neighbourhood. The potential to integrate with the proposed residential uses is a major advantage of land to the north of London Road, compared to the options proposed for south of London Road.

We note that the description of site E17 states that it is detached from any residential settlement, though it is not clear whether or not this is put forward as a point in its favour or against. It is of course a similar distance to Rayleigh as the most of the options south of London Road, but moreover has the potential to integrate with the proposed new residential development north of London Road, whilst still enabling good access to the highway network for commercial vehicles.

There is no reason why commercial uses should be separated from residential uses, and indeed planning policy at all levels extols the virtues of mixed-used development in sustainability terms. Our view is very strongly in favour of having commercial uses integrated with residential uses as part of a comprehensive mixed-use masterplan, that protects residential amenity whilst still promoting ease of access. Sites that are "detached" should not be favoured over sites that have the potential to create strong mixed-use neighbourhoods.

Turning then lastly to E18, we do not consider this to be a suitable site for commercial development.

Although it may be possible to enhance the existing sub-standard access to the site from the A127/A1245 slip road, the site is removed from the residential communities that the employment would serve, and there is no realistic prospect of accessing the site by public transport or by non-vehicular modes. This is an isolated site in the countryside, accessible only by car, where development would be contrary to advice in PPG13 regarding location of development attracting large numbers of trips and sustainable travel.

As an isolated development site in the heart of the countryside, development here would also have significant adverse impacts on the strategic purposes of the Green Belt, introducing an expanse of commercial development in a highly prominent location between the A127, A1245, A130 and Southend-Liverpool Street railway. This is not development that would be compatible with the retention of the site in the Green Belt, and it would therefore result in a release of Green Belt land in the heart of an area of strategic Green Belt significance.

In summary, in our view the most appropriate location for new employment land west of Rayleigh is to the north of London Road, as part of a comprehensive mixed-use scheme. The employment land provision could include all or part of E17, or alternative locations north of London Road.

Background

In accordance with their representations to the Core Strategy, Countryside Properties are supportive of the proposals for the provision of additional employment land to the west of Rayleigh, but we consider that such provision should be made to the north of London Road as part of a comprehensive mixed-use development, not to the south of London Road (or at Michelins Farm).

Representations

In our view, the most appropriate location for new employment development west of Rayleigh is to the north of London Road, as part of a comprehensive mixed-use scheme. In our original submissions to the Core Strategy, we advanced a number of arguments to support this position, including:

* It is inherently more sustainable in principle to provide for an integrated mixed-use scheme, rather than segregated residential and commercial areas;
* The viability of providing the new employment land is increased as part of a mixed-use scheme, since the costs of infrastructure (including roads, drainage, and utilities) is shared;
* There is more than sufficient land north of London Road to deliver a mixed-use scheme - there is less certainty that the scale of development required could be successfully provided south of London Road;
* To be attractive to new business, a high quality business park of sufficient size will be required - there is more land north of London Road to achieve this;
* There are advantages in terms of public transport accessibility/viability in serving a business location alongside a residential location (greater patronage and two-way passenger flows);
* It is difficult to see how the Green Belt boundary south of London Road could successfully be changed to allow for a large scale employment area, without either creating a ribbon of development along London Road, or an isolated incursion not linked to the existing community;
* Countryside Properties has particular experience in successfully delivering mixed-use schemes, including the creation of modern, flexible business space.

In the light of the above, we do not support the potential employment sites E13, E14, E15, or E16, all of which lie to the south of London Road.

In addition to the general observations above, we note that in relation to the particular sites E13-E16 the following additional points:

* All of these options utilise to some extent of other land already in commercial use. This raises two significant questions: Is the land proposed genuinely available, given the existing uses, and is the land genuinely additional employment land, or simply a replacement of existing jobs?
On the first question, it appears to us that each of these options is based upon land in multiple ownership, and where there are existing businesses/tenancies which together may make the land impossible to bring forward in a comprehensive way.

On the second question, although the existing commercial uses may not be allocated for businesses purposes as such, there are long-standing commercial uses on the site that are an existing source of employment. All four options E13-E16 appear to be premised upon the loss of the existing commercial uses, and therefore any net increase in allocated employment land would need to take in to account the extent of existing land lost.

* Notwithstanding the above, none of the options presented are of sufficient scale to provide for the extent of employment land required under the Core Strategy. The four options vary between a minimum of 2.65 ha and a maximum of 5 ha. The Core Strategy identified a need for 2 ha for office use and 6 ha for the relocation of Rawreth Lane Industrial Estate, making a minimum of 8 ha. In our view (and notwithstanding our concerns regarding practicality), relocating Rawreth Industrial Estate would require more than 6ha - the existing estate is already over-crowded, as the extent of on-street parking demonstrates, allows no scope for businesses to expand, and the existing layout does not provide the quality of environment that the Council would rightly expect (and which new businesses would demand) from a new commercial park.

In our view, around 10 ha is a more realistic land-take for replacing Rawreth Lane Industrial Estate, making around 12 ha of land in total to be found west of Rayleigh to support the employment proposals of the Core Strategy. This scale of development cannot be found south of London Road (or at Michelins Farm).

E17 is the only option put forward to the north of London Road, and clearly therefore on the basis of the above, we feel this option warrants further consideration, albeit in isolation it would still not be large enough to accommodate the full employment land requirement (if Rawreth Lane Industrial Estate is to be redeveloped).

There is however potential to increase the size of site E17, whether by extension to the north (whilst still avoiding areas of flood risk), or by extension to the east, as part of or linking in with the proposed new residential neighbourhood. The potential to integrate with the proposed residential uses is a major advantage of land to the north of London Road, compared to the options proposed for south of London Road.

We note that the description of site E17 states that it is detached from any residential settlement, though it is not clear whether or not this is put forward as a point in its favour or against. It is of course a similar distance to Rayleigh as the most of the options south of London Road, but moreover has the potential to integrate with the proposed new residential development north of London Road, whilst still enabling good access to the highway network for commercial vehicles.

There is no reason why commercial uses should be separated from residential uses, and indeed planning policy at all levels extols the virtues of mixed-used development in sustainability terms. Our view is very strongly in favour of having commercial uses integrated with residential uses as part of a comprehensive mixed-use masterplan, that protects residential amenity whilst still promoting ease of access. Sites that are "detached" should not be favoured over sites that have the potential to create strong mixed-use neighbourhoods.

Turning then lastly to E18, we do not consider this to be a suitable site for commercial development.

Although it may be possible to enhance the existing sub-standard access to the site from the A127/A1245 slip road, the site is removed from the residential communities that the employment would serve, and there is no realistic prospect of accessing the site by public transport or by non-vehicular modes. This is an isolated site in the countryside, accessible only by car, where development would be contrary to advice in PPG13 regarding location of development attracting large numbers of trips and sustainable travel.

As an isolated development site in the heart of the countryside, development here would also have significant adverse impacts on the strategic purposes of the Green Belt, introducing an expanse of commercial development in a highly prominent location between the A127, A1245, A130 and Southend-Liverpool Street railway. This is not development that would be compatible with the retention of the site in the Green Belt, and it would therefore result in a release of Green Belt land in the heart of an area of strategic Green Belt significance.

In summary, in our view the most appropriate location for new employment land west of Rayleigh is to the north of London Road, as part of a comprehensive mixed-use scheme. The employment land provision could include all or part of E17, or alternative locations north of London Road.

Background

In accordance with their representations to the Core Strategy, Countryside Properties are supportive of the proposals for the provision of additional employment land to the west of Rayleigh, but we consider that such provision should be made to the north of London Road as part of a comprehensive mixed-use development, not to the south of London Road (or at Michelins Farm).

Representations

In our view, the most appropriate location for new employment development west of Rayleigh is to the north of London Road, as part of a comprehensive mixed-use scheme. In our original submissions to the Core Strategy, we advanced a number of arguments to support this position, including:

* It is inherently more sustainable in principle to provide for an integrated mixed-use scheme, rather than segregated residential and commercial areas;
* The viability of providing the new employment land is increased as part of a mixed-use scheme, since the costs of infrastructure (including roads, drainage, and utilities) is shared;
* There is more than sufficient land north of London Road to deliver a mixed-use scheme - there is less certainty that the scale of development required could be successfully provided south of London Road;
* To be attractive to new business, a high quality business park of sufficient size will be required - there is more land north of London Road to achieve this;
* There are advantages in terms of public transport accessibility/viability in serving a business location alongside a residential location (greater patronage and two-way passenger flows);
* It is difficult to see how the Green Belt boundary south of London Road could successfully be changed to allow for a large scale employment area, without either creating a ribbon of development along London Road, or an isolated incursion not linked to the existing community;
* Countryside Properties has particular experience in successfully delivering mixed-use schemes, including the creation of modern, flexible business space.

In the light of the above, we do not support the potential employment sites E13, E14, E15, or E16, all of which lie to the south of London Road.

In addition to the general observations above, we note that in relation to the particular sites E13-E16 the following additional points:

* All of these options utilise to some extent of other land already in commercial use. This raises two significant questions: Is the land proposed genuinely available, given the existing uses, and is the land genuinely additional employment land, or simply a replacement of existing jobs?
On the first question, it appears to us that each of these options is based upon land in multiple ownership, and where there are existing businesses/tenancies which together may make the land impossible to bring forward in a comprehensive way.

On the second question, although the existing commercial uses may not be allocated for businesses purposes as such, there are long-standing commercial uses on the site that are an existing source of employment. All four options E13-E16 appear to be premised upon the loss of the existing commercial uses, and therefore any net increase in allocated employment land would need to take in to account the extent of existing land lost.

* Notwithstanding the above, none of the options presented are of sufficient scale to provide for the extent of employment land required under the Core Strategy. The four options vary between a minimum of 2.65 ha and a maximum of 5 ha. The Core Strategy identified a need for 2 ha for office use and 6 ha for the relocation of Rawreth Lane Industrial Estate, making a minimum of 8 ha. In our view (and notwithstanding our concerns regarding practicality), relocating Rawreth Industrial Estate would require more than 6ha - the existing estate is already over-crowded, as the extent of on-street parking demonstrates, allows no scope for businesses to expand, and the existing layout does not provide the quality of environment that the Council would rightly expect (and which new businesses would demand) from a new commercial park.

In our view, around 10 ha is a more realistic land-take for replacing Rawreth Lane Industrial Estate, making around 12 ha of land in total to be found west of Rayleigh to support the employment proposals of the Core Strategy. This scale of development cannot be found south of London Road (or at Michelins Farm).

E17 is the only option put forward to the north of London Road, and clearly therefore on the basis of the above, we feel this option warrants further consideration, albeit in isolation it would still not be large enough to accommodate the full employment land requirement (if Rawreth Lane Industrial Estate is to be redeveloped).

There is however potential to increase the size of site E17, whether by extension to the north (whilst still avoiding areas of flood risk), or by extension to the east, as part of or linking in with the proposed new residential neighbourhood. The potential to integrate with the proposed residential uses is a major advantage of land to the north of London Road, compared to the options proposed for south of London Road.

We note that the description of site E17 states that it is detached from any residential settlement, though it is not clear whether or not this is put forward as a point in its favour or against. It is of course a similar distance to Rayleigh as the most of the options south of London Road, but moreover has the potential to integrate with the proposed new residential development north of London Road, whilst still enabling good access to the highway network for commercial vehicles.

There is no reason why commercial uses should be separated from residential uses, and indeed planning policy at all levels extols the virtues of mixed-used development in sustainability terms. Our view is very strongly in favour of having commercial uses integrated with residential uses as part of a comprehensive mixed-use masterplan, that protects residential amenity whilst still promoting ease of access. Sites that are "detached" should not be favoured over sites that have the potential to create strong mixed-use neighbourhoods.

Turning then lastly to E18, we do not consider this to be a suitable site for commercial development.

Although it may be possible to enhance the existing sub-standard access to the site from the A127/A1245 slip road, the site is removed from the residential communities that the employment would serve, and there is no realistic prospect of accessing the site by public transport or by non-vehicular modes. This is an isolated site in the countryside, accessible only by car, where development would be contrary to advice in PPG13 regarding location of development attracting large numbers of trips and sustainable travel.

As an isolated development site in the heart of the countryside, development here would also have significant adverse impacts on the strategic purposes of the Green Belt, introducing an expanse of commercial development in a highly prominent location between the A127, A1245, A130 and Southend-Liverpool Street railway. This is not development that would be compatible with the retention of the site in the Green Belt, and it would therefore result in a release of Green Belt land in the heart of an area of strategic Green Belt significance.

In summary, in our view the most appropriate location for new employment land west of Rayleigh is to the north of London Road, as part of a comprehensive mixed-use scheme. The employment land provision could include all or part of E17, or alternative locations north of London Road.