Allocations DPD Discussion and Consultation Document

Representations have been made by Andrew Martin Associates on behalf of MD Smith and Son at previous stages of the Local Development Framework Core Strategy consultations. These representations, together with the attached document which is based on that previously submitted, identifies the potential land available at the Hambro Nursery and Clovelly Works site, Rawreth. Part of this site is set out and identified as Site No. 73 of the Site Allocations Assessment Criteria Document. The available site should be considered more substantial (9.6ha) than that identified in the assessment criteria and should be known to be, suitable, available and achievable for delivering mixed use development in preference to other sites proposed by the Council.

The response is made to the Council's identified preferred development sites set out in the Regulation 25 Development Plan Document (DPD). The strategy behind the earmarked sites stems from the unadopted Core Strategy which is still to undergo Examination in Public (EiP) in order to assess its soundness. MD Smith and Sons therefore question the approach of the overriding spatial strategy in relation to the identification and best use of previously developed land within the district. In particular:
-where sites are no longer in active use;
-are well located to access to the highway network;
-are closely related to existing settlements;
-can provide for improved landscape and public access opportunities; then
-the sustainability of such sites is likely to outweigh the disbenefits of identified Green Belt allocations.

The Council's sustainability assessment is not, however, within the public domain.

MD Smith and Sons object to the identification of parcels of land (NLR1, NLR2, NLR3) to the north of London Road (to the South of Rawreth) which both in isolation and collectively fail to make the best use of available and previously developed land in the locality. Any significant development on this land is likely to bring about a coalesce between the settlement of Rawreth and Rayleigh. This will be to the detriment of the surrounding area as a result of the sites prominence and have an adverse impact in landscape, flood risk and sustainability terms.

In additional, the former Hambro Nursery and Clovely works site adjoins an area of Public Open Space (PoS) which is poorly located for growth proposed to be accommodated on land north of London Road. The Council's approach here fails to recognise the potential for this POS to be added to, improved or enhanced. This POS exists for the benefit of the local community but will not easily link or form part of a new community to the north of London Road. It will become isolated from the proposed sites north of London Road and fail to make the best use of the opportunities in the vicinity. This includes the potential to improve the landscaped setting of the former nursery site on previously developed land which would present an opportunity to remove and/or screen significant development by consolidating the site's built footprint, enhancing the POS in the process.


In the Council's assessment within the Site Allocations Assessment Criteria, it is concluded that the site (No.73) is not within the preferred development location as set out within the Core Strategy Submission Strategy and would need to consider transport routes into the town centre which may impact on highway network. The site is, however, closely located to the proposed NLR1-3 sites and is within 500m of them in the same broad location. The impact upon the highway networks will be limited as the site is accessible off Chelmsford Road. Opportunities for improvements for cycling and pedestrian links would be made possible as the result of any development proposed on the former nursery site.

In addition to the above comments, the allocation of existing employment areas within the district for housing uses is likely to cause otherwise avoidable problems with economic delivery and growth. By allocating land upon which successful business are currently operating, the Council has failed to consider the needs and wishes of those business who would be otherwise unlikely to relocate as a matter of choice to other sites within the district. Such sites are clearly not available and the evidence base has not adequately addressed this matter. A significant employment 'leakage' will result with business likely to relocate outside the district. The costs and benefits of such relocation remains to be assessed adequately in our opinion. The strategy for allocation of such sites therefore remains unsound and wholly vacant or previously developed sites should be considered where the landowners and business are in favour of relocation as part of a holistic redevelopment.

In proposing to take forward a strategy which neglects redundant and previously developed land within the district, a policy favoured nationally, the Council fail in its obligation to direct growth appropriately. For example, in support of this argument Planning Policy Statement 4 (PPS4), Policy EC2, sets out that Council's should seek to make the most efficient and effective use of land, prioritising previously developed land which is suitable for re-use and... reflects the different location requirements of businesses. It goes on to say that LPAs should identify a range of sites, to facilitate a broad range of economic development, including mixed uses. Furthermore, Site allocations should not be carried forward without evidence of the need and reasonable prospect of their take up during the plan period. This evidence base does not address these matters fully.