Allocations DPD Discussion and Consultation Document

Response of Essex County Council

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific options for development at the general locations identified within the Core Strategy Submission Document will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of options not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District. Similarly, the stated intent (Page 6) to ensure delivery of required infrastructure alongside residential development is fully supported.

The scope and coverage of the Allocations DPD is broadly supported but the general approach to site assessment, selection and definition could benefit from some further considerations, as follows,

1. as presented, many of the site specific options for development suggest artificial and/or straight.site boundaries. The definition of boundaries of the sites eventually selected should be based on and incorporate existing boundaries, in order to,
* respect the often ancient field patterns;
* existing hedges and other vegetation can provide a screen to the development or a feature at the periphery of the development;
* avoid odd parcels of land remaining which are too small to function independently;
* preserve often important wildlife habitats.

2. new single-form entry primary schools will be required to serve proposed residential at two locations - the site North of London Road, Rayleigh, and the site to the West of Rochford. Chapter 5 (Community Facilities) lists site characteristics for school provision at each of these sites (Pages 110 and 111). Essex County Council does not agree to these lists of characteristics. The criteria for identification and selection of school sites are much broader.

Essex County Council has produced an 'Education Contributions Guidelines Supplement' to its 'Developers Guide to Infrastructure Contributions (2010 Edition)' - both of which were subject to a public consultation exercise closing in February 2010. The 'Education Contributions Guidelines Supplement' (copy attached to response) sets out the detailed requirements for provision of new school sites. In the context of the statements on pages 110 and 111 of the Allocations DPD particular attention is drawn to the procedures and requirements for identification and selection of new school sites as set out in Appendices D, E and F. Within Appendix D particular attention is drawn to the section of the Checklist addressing the question of 'suitable safe access' to the site to emphasise that the design of the school and its relationship to the proposed and existing residential areas should facilitate provision of the best and safest walking routes to schools. The Supplement should be referenced within the Allocations DPD and other relevant documents within the Local Development Framework.

3. provision of Early Years and Childcare facilities is not discussed by the Document. Clear statements should be included that the two potential new primary schools would also need to incorporate Early Years and Childcare facilities. The District's Core Strategy (Policy CLT2) also requires provision of new Early Years and Childcare facilities in Hockley. Although it is not currently envisaged that a site could be identified in the Allocations DPD the requirement could be usefully identified in discussion of Hockley Town Centre (Page 144).

4. the proposed allocation of sites for education use is noted. However, allocation of such sites, and other County Council or public service sites, should not be applied such that it seeks to preserve existing uses on sites in perpetuity, thereby restricting the service provider's ability to expand/relocate the facility to better cater for future needs. Should a public service site cease to be required for its current purpose, its future use should be determined on the merits of the site and its location. Public service sites become surplus because local demand for the service has fallen to uneconomic levels or the facility has been replaced by more suitable facilities elsewhere. The Allocations DPD, and other documents within the Local Development Framework, should acknowledge that there will be circumstances when a better option for the community would be redevelopment of a public service site and re-investment of the proceeds elsewhere as part of a strategic programme of infrastructure replacement.

5. Section 4, Environment, of the Allocations DPD would benefit from an additional section that discusses the Historic Environment of Rochford District. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

6. it should be noted that the County Library Service's medium-term plans include moving the existing library from its existing premises in Great Wakering. This may offer the opportunity for a joint project associated with the proposed enhancement of the Leisure Centre in the village, dependent on detailed location, access and other considerations.

7. the selected sites will generally be associated with greenspace creation. Information on greenspace deficiencies in the area is available in the 'Analysis of Accessible Natural Greenspace Provision for Essex, including Southend-on-Sea and Thurrock Unitary Authorities', which may be found on the Essex Wildlife Trust website.

8. the emphasis of the Document on provision of Sustainable Urban Drainage systems is welcomed, but it should be linked to broader support for the use of associated Green Infrastructure and greenspace creation.

9. the Allocations DPD should acknowledge and note the proportion of the development requirements that will be provided on existing development or brownfield sites.

In respect of the proposed site specific options and environmental designations Essex County Council has the following observations,

A. King Edmund School education site - there is an identified need to provide additional land to accommodate expansion of the school to meet additional demand and to secure improved vehicular access to the school via Brays Lane. Options KES2 and KES3 are preferred by Essex County Council because each presents an opportunity to contribute to both identified needs. Improvements to King Edmund School will need to be linked with adjacent proposals for residential development at the East Ashingdon location. Options EA1 or EA3 are preferred because of the opportunities they present to enable the improvements to the school, which Option EA1 does not. Essex County Council would welcome early discussion with the District Council to ensure the suitability of the detailed site specific requirements for improvement to King Edmund School and residential development at the East Ashingdon location. It should be noted that provision of access from King Edmund School to Brays Lane should be of a standard sufficient to accommodate cars and all associated vehicles serving the school.

B. the proposed environmental designations discussed in Chapter 4 (Environment) are supported. The proposed definition of a boundary for the Coastal Protection Belt is particularly supported as assisting realisation of Policy ENV2 of the Core Strategy and reflecting the currently saved Policy CC1 of the Essex and Southend-on-Sea Replacement Structure Plan (2001). Also, the designation of Cherry Orchard Jubilee Country Park and the Upper Roach Valley is supported. However, the Allocations Document should also include the proposed Stonebridge Park, which is highlighted in the Parklands Vision as a potential sub-regional park centred around Great Wakering.

C. further detailed consideration would be required of the potential employment/ business density of the site and its transport and access requirements of Option E18, Michelins Farm (an option for 8.6 hectares of employment uses, Page 88) should the District Council wish to proceed with allocation of the site. The A1245 is classified as a Main Distributor in the Route Hierarchy and direct access from this class of road is normally prohibited. In addition, the distance on the A1245 between the A127 Fairglen junction and the railway line acts against achievement of the required technical specifications for a new junction. Any changes to the Fairglen junction to provide an access to the site would require comprehensive realignment of the northern western sector and, in addition, the existing roundabout contains a pumping station. Direct access to the A127 and A130 is also prohibited due to the classification of those roads and would need third party land.

D. Assessment of the preferred site options should also include specific consideration of their Historic Environment Character in terms of known and potential features and their contribution to the cultural and historic landscapes of the District. There should be a programme of archaeological evaluation to ensure that the cultural heritage potential of each site is taken into account at an early stage in selection of preferred site options and taken forward in subsequent work on the preferred sites. A summary description of the historic environment characteristics and the requirements for archaeological investigation of the residential, brownfield and new employment locations presented in the Allocations DPD is set out in the Annex to this response. The summaries have implications for choice of sites within the locations at West Hockley, South West Hullbridge, South Canewdon and West Great Wakering (residential) and at South of Great Wakering (employment). Essex County Council would be willing to contribute further detailed evaluation of the historic environment characteristics of each site to inform further stages in preparation of the Allocations DPD.


ANNEX TO ESSEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS DPD, DISCUSSION AND CONSULTATION DOCUMENT (REGULATION 25) FEBRUARY 2010

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

1. North of London Road Rayleigh - the Rochford Historic Environment Character (HEC) project identifies the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to any of the four options suggested, given the sites' adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

2. West of Rochford - the Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HEC Zone 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeological potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered

3. West Hockley - this proposed location lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HEC Zone 33) identified in the Rochford Historic Environment Character project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (WH1-5) suggested for land West of Hockley, although options WH2 or WH5 be would preferred due to previous development, they would entail the least impact on any surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

4. South of Hawkwell - within the Rochford HEC the proposed development south of Hawkwell lies within the HEC Z one26, Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites' historic environment character and potential there would be no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

5. East Ashingdon - the site lies within HEC Zone 13, characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie close by. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (EA1-4) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

6. South West Hullbridge - the HEC Zone 36 for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is close by. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. Whilst there would be no objection to the options outlined for South West Hullbridge, there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

7. South Canewdon - the HEC Zone 12 shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of options SC2, 3 and 4 but little to the south, further away from the historic core, in the area of SC1. There would be no objection to the options outlined for South Canewdon, but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

8. South East Ashingdon - the location lies within HEC Zone 13 characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (SEA1-3) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

9. West Great Wakering - options for West Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. There would be no objection to the options (WGW 1-5), although those incorporating, or part incorporating, former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW4 and 5) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

B. Brownfield Sites

1. Stambridge Mills - the location survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. There would be no objection to the redevelopment of the Stambridge Mills site, but there would be a requirement for a historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

1. West of Rayleigh - the Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

2. Michelins Farm - the Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HEC Zone 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

3. London Southend Airport and Environs - within the Rochford Historic Environment Character report the relevant character zones (HEC Zones 17 and 18) identify the areas at this location that not already developed as having a high potential for the survival of historic environment assets. The area is one which, although partially disturbed through construction of the airport and modern industrial buildings, retains a significant archaeological and more general historic environment potential. In addition to known sites, such as the medieval church of St. Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds in the area of the on- going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WWI and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

4. South of Great Wakering - options for south of Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. Due to quarrying, option E22 (south of Star Lane brickworks) and options E23 and& E24 (south of Poynters Road) have no historic environment implications and option E19 would have the least impact of the remaining options. Otherwise non- quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.

Response of Essex County Council

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific options for development at the general locations identified within the Core Strategy Submission Document will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of options not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District. Similarly, the stated intent (Page 6) to ensure delivery of required infrastructure alongside residential development is fully supported.

The scope and coverage of the Allocations DPD is broadly supported but the general approach to site assessment, selection and definition could benefit from some further considerations, as follows,

1. as presented, many of the site specific options for development suggest artificial and/or straight.site boundaries. The definition of boundaries of the sites eventually selected should be based on and incorporate existing boundaries, in order to,
* respect the often ancient field patterns;
* existing hedges and other vegetation can provide a screen to the development or a feature at the periphery of the development;
* avoid odd parcels of land remaining which are too small to function independently;
* preserve often important wildlife habitats.

2. new single-form entry primary schools will be required to serve proposed residential at two locations - the site North of London Road, Rayleigh, and the site to the West of Rochford. Chapter 5 (Community Facilities) lists site characteristics for school provision at each of these sites (Pages 110 and 111). Essex County Council does not agree to these lists of characteristics. The criteria for identification and selection of school sites are much broader.

Essex County Council has produced an 'Education Contributions Guidelines Supplement' to its 'Developers Guide to Infrastructure Contributions (2010 Edition)' - both of which were subject to a public consultation exercise closing in February 2010. The 'Education Contributions Guidelines Supplement' (copy attached to response) sets out the detailed requirements for provision of new school sites. In the context of the statements on pages 110 and 111 of the Allocations DPD particular attention is drawn to the procedures and requirements for identification and selection of new school sites as set out in Appendices D, E and F. Within Appendix D particular attention is drawn to the section of the Checklist addressing the question of 'suitable safe access' to the site to emphasise that the design of the school and its relationship to the proposed and existing residential areas should facilitate provision of the best and safest walking routes to schools. The Supplement should be referenced within the Allocations DPD and other relevant documents within the Local Development Framework.

3. provision of Early Years and Childcare facilities is not discussed by the Document. Clear statements should be included that the two potential new primary schools would also need to incorporate Early Years and Childcare facilities. The District's Core Strategy (Policy CLT2) also requires provision of new Early Years and Childcare facilities in Hockley. Although it is not currently envisaged that a site could be identified in the Allocations DPD the requirement could be usefully identified in discussion of Hockley Town Centre (Page 144).

4. the proposed allocation of sites for education use is noted. However, allocation of such sites, and other County Council or public service sites, should not be applied such that it seeks to preserve existing uses on sites in perpetuity, thereby restricting the service provider's ability to expand/relocate the facility to better cater for future needs. Should a public service site cease to be required for its current purpose, its future use should be determined on the merits of the site and its location. Public service sites become surplus because local demand for the service has fallen to uneconomic levels or the facility has been replaced by more suitable facilities elsewhere. The Allocations DPD, and other documents within the Local Development Framework, should acknowledge that there will be circumstances when a better option for the community would be redevelopment of a public service site and re-investment of the proceeds elsewhere as part of a strategic programme of infrastructure replacement.

5. Section 4, Environment, of the Allocations DPD would benefit from an additional section that discusses the Historic Environment of Rochford District. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

6. it should be noted that the County Library Service's medium-term plans include moving the existing library from its existing premises in Great Wakering. This may offer the opportunity for a joint project associated with the proposed enhancement of the Leisure Centre in the village, dependent on detailed location, access and other considerations.

7. the selected sites will generally be associated with greenspace creation. Information on greenspace deficiencies in the area is available in the 'Analysis of Accessible Natural Greenspace Provision for Essex, including Southend-on-Sea and Thurrock Unitary Authorities', which may be found on the Essex Wildlife Trust website.

8. the emphasis of the Document on provision of Sustainable Urban Drainage systems is welcomed, but it should be linked to broader support for the use of associated Green Infrastructure and greenspace creation.

9. the Allocations DPD should acknowledge and note the proportion of the development requirements that will be provided on existing development or brownfield sites.

In respect of the proposed site specific options and environmental designations Essex County Council has the following observations,

A. King Edmund School education site - there is an identified need to provide additional land to accommodate expansion of the school to meet additional demand and to secure improved vehicular access to the school via Brays Lane. Options KES2 and KES3 are preferred by Essex County Council because each presents an opportunity to contribute to both identified needs. Improvements to King Edmund School will need to be linked with adjacent proposals for residential development at the East Ashingdon location. Options EA1 or EA3 are preferred because of the opportunities they present to enable the improvements to the school, which Option EA1 does not. Essex County Council would welcome early discussion with the District Council to ensure the suitability of the detailed site specific requirements for improvement to King Edmund School and residential development at the East Ashingdon location. It should be noted that provision of access from King Edmund School to Brays Lane should be of a standard sufficient to accommodate cars and all associated vehicles serving the school.

B. the proposed environmental designations discussed in Chapter 4 (Environment) are supported. The proposed definition of a boundary for the Coastal Protection Belt is particularly supported as assisting realisation of Policy ENV2 of the Core Strategy and reflecting the currently saved Policy CC1 of the Essex and Southend-on-Sea Replacement Structure Plan (2001). Also, the designation of Cherry Orchard Jubilee Country Park and the Upper Roach Valley is supported. However, the Allocations Document should also include the proposed Stonebridge Park, which is highlighted in the Parklands Vision as a potential sub-regional park centred around Great Wakering.

C. further detailed consideration would be required of the potential employment/ business density of the site and its transport and access requirements of Option E18, Michelins Farm (an option for 8.6 hectares of employment uses, Page 88) should the District Council wish to proceed with allocation of the site. The A1245 is classified as a Main Distributor in the Route Hierarchy and direct access from this class of road is normally prohibited. In addition, the distance on the A1245 between the A127 Fairglen junction and the railway line acts against achievement of the required technical specifications for a new junction. Any changes to the Fairglen junction to provide an access to the site would require comprehensive realignment of the northern western sector and, in addition, the existing roundabout contains a pumping station. Direct access to the A127 and A130 is also prohibited due to the classification of those roads and would need third party land.

D. Assessment of the preferred site options should also include specific consideration of their Historic Environment Character in terms of known and potential features and their contribution to the cultural and historic landscapes of the District. There should be a programme of archaeological evaluation to ensure that the cultural heritage potential of each site is taken into account at an early stage in selection of preferred site options and taken forward in subsequent work on the preferred sites. A summary description of the historic environment characteristics and the requirements for archaeological investigation of the residential, brownfield and new employment locations presented in the Allocations DPD is set out in the Annex to this response. The summaries have implications for choice of sites within the locations at West Hockley, South West Hullbridge, South Canewdon and West Great Wakering (residential) and at South of Great Wakering (employment). Essex County Council would be willing to contribute further detailed evaluation of the historic environment characteristics of each site to inform further stages in preparation of the Allocations DPD.


ANNEX TO ESSEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS DPD, DISCUSSION AND CONSULTATION DOCUMENT (REGULATION 25) FEBRUARY 2010

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

1. North of London Road Rayleigh - the Rochford Historic Environment Character (HEC) project identifies the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to any of the four options suggested, given the sites' adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

2. West of Rochford - the Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HEC Zone 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeological potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered

3. West Hockley - this proposed location lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HEC Zone 33) identified in the Rochford Historic Environment Character project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (WH1-5) suggested for land West of Hockley, although options WH2 or WH5 be would preferred due to previous development, they would entail the least impact on any surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

4. South of Hawkwell - within the Rochford HEC the proposed development south of Hawkwell lies within the HEC Z one26, Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites' historic environment character and potential there would be no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

5. East Ashingdon - the site lies within HEC Zone 13, characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie close by. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (EA1-4) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

6. South West Hullbridge - the HEC Zone 36 for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is close by. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. Whilst there would be no objection to the options outlined for South West Hullbridge, there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

7. South Canewdon - the HEC Zone 12 shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of options SC2, 3 and 4 but little to the south, further away from the historic core, in the area of SC1. There would be no objection to the options outlined for South Canewdon, but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

8. South East Ashingdon - the location lies within HEC Zone 13 characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (SEA1-3) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

9. West Great Wakering - options for West Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. There would be no objection to the options (WGW 1-5), although those incorporating, or part incorporating, former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW4 and 5) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

B. Brownfield Sites

1. Stambridge Mills - the location survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. There would be no objection to the redevelopment of the Stambridge Mills site, but there would be a requirement for a historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

1. West of Rayleigh - the Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

2. Michelins Farm - the Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HEC Zone 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

3. London Southend Airport and Environs - within the Rochford Historic Environment Character report the relevant character zones (HEC Zones 17 and 18) identify the areas at this location that not already developed as having a high potential for the survival of historic environment assets. The area is one which, although partially disturbed through construction of the airport and modern industrial buildings, retains a significant archaeological and more general historic environment potential. In addition to known sites, such as the medieval church of St. Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds in the area of the on- going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WWI and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

4. South of Great Wakering - options for south of Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. Due to quarrying, option E22 (south of Star Lane brickworks) and options E23 and& E24 (south of Poynters Road) have no historic environment implications and option E19 would have the least impact of the remaining options. Otherwise non- quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.

Response of Essex County Council

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific options for development at the general locations identified within the Core Strategy Submission Document will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of options not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District. Similarly, the stated intent (Page 6) to ensure delivery of required infrastructure alongside residential development is fully supported.

The scope and coverage of the Allocations DPD is broadly supported but the general approach to site assessment, selection and definition could benefit from some further considerations, as follows,

1. as presented, many of the site specific options for development suggest artificial and/or straight.site boundaries. The definition of boundaries of the sites eventually selected should be based on and incorporate existing boundaries, in order to,
* respect the often ancient field patterns;
* existing hedges and other vegetation can provide a screen to the development or a feature at the periphery of the development;
* avoid odd parcels of land remaining which are too small to function independently;
* preserve often important wildlife habitats.

2. new single-form entry primary schools will be required to serve proposed residential at two locations - the site North of London Road, Rayleigh, and the site to the West of Rochford. Chapter 5 (Community Facilities) lists site characteristics for school provision at each of these sites (Pages 110 and 111). Essex County Council does not agree to these lists of characteristics. The criteria for identification and selection of school sites are much broader.

Essex County Council has produced an 'Education Contributions Guidelines Supplement' to its 'Developers Guide to Infrastructure Contributions (2010 Edition)' - both of which were subject to a public consultation exercise closing in February 2010. The 'Education Contributions Guidelines Supplement' (copy attached to response) sets out the detailed requirements for provision of new school sites. In the context of the statements on pages 110 and 111 of the Allocations DPD particular attention is drawn to the procedures and requirements for identification and selection of new school sites as set out in Appendices D, E and F. Within Appendix D particular attention is drawn to the section of the Checklist addressing the question of 'suitable safe access' to the site to emphasise that the design of the school and its relationship to the proposed and existing residential areas should facilitate provision of the best and safest walking routes to schools. The Supplement should be referenced within the Allocations DPD and other relevant documents within the Local Development Framework.

3. provision of Early Years and Childcare facilities is not discussed by the Document. Clear statements should be included that the two potential new primary schools would also need to incorporate Early Years and Childcare facilities. The District's Core Strategy (Policy CLT2) also requires provision of new Early Years and Childcare facilities in Hockley. Although it is not currently envisaged that a site could be identified in the Allocations DPD the requirement could be usefully identified in discussion of Hockley Town Centre (Page 144).

4. the proposed allocation of sites for education use is noted. However, allocation of such sites, and other County Council or public service sites, should not be applied such that it seeks to preserve existing uses on sites in perpetuity, thereby restricting the service provider's ability to expand/relocate the facility to better cater for future needs. Should a public service site cease to be required for its current purpose, its future use should be determined on the merits of the site and its location. Public service sites become surplus because local demand for the service has fallen to uneconomic levels or the facility has been replaced by more suitable facilities elsewhere. The Allocations DPD, and other documents within the Local Development Framework, should acknowledge that there will be circumstances when a better option for the community would be redevelopment of a public service site and re-investment of the proceeds elsewhere as part of a strategic programme of infrastructure replacement.

5. Section 4, Environment, of the Allocations DPD would benefit from an additional section that discusses the Historic Environment of Rochford District. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

6. it should be noted that the County Library Service's medium-term plans include moving the existing library from its existing premises in Great Wakering. This may offer the opportunity for a joint project associated with the proposed enhancement of the Leisure Centre in the village, dependent on detailed location, access and other considerations.

7. the selected sites will generally be associated with greenspace creation. Information on greenspace deficiencies in the area is available in the 'Analysis of Accessible Natural Greenspace Provision for Essex, including Southend-on-Sea and Thurrock Unitary Authorities', which may be found on the Essex Wildlife Trust website.

8. the emphasis of the Document on provision of Sustainable Urban Drainage systems is welcomed, but it should be linked to broader support for the use of associated Green Infrastructure and greenspace creation.

9. the Allocations DPD should acknowledge and note the proportion of the development requirements that will be provided on existing development or brownfield sites.

In respect of the proposed site specific options and environmental designations Essex County Council has the following observations,

A. King Edmund School education site - there is an identified need to provide additional land to accommodate expansion of the school to meet additional demand and to secure improved vehicular access to the school via Brays Lane. Options KES2 and KES3 are preferred by Essex County Council because each presents an opportunity to contribute to both identified needs. Improvements to King Edmund School will need to be linked with adjacent proposals for residential development at the East Ashingdon location. Options EA1 or EA3 are preferred because of the opportunities they present to enable the improvements to the school, which Option EA1 does not. Essex County Council would welcome early discussion with the District Council to ensure the suitability of the detailed site specific requirements for improvement to King Edmund School and residential development at the East Ashingdon location. It should be noted that provision of access from King Edmund School to Brays Lane should be of a standard sufficient to accommodate cars and all associated vehicles serving the school.

B. the proposed environmental designations discussed in Chapter 4 (Environment) are supported. The proposed definition of a boundary for the Coastal Protection Belt is particularly supported as assisting realisation of Policy ENV2 of the Core Strategy and reflecting the currently saved Policy CC1 of the Essex and Southend-on-Sea Replacement Structure Plan (2001). Also, the designation of Cherry Orchard Jubilee Country Park and the Upper Roach Valley is supported. However, the Allocations Document should also include the proposed Stonebridge Park, which is highlighted in the Parklands Vision as a potential sub-regional park centred around Great Wakering.

C. further detailed consideration would be required of the potential employment/ business density of the site and its transport and access requirements of Option E18, Michelins Farm (an option for 8.6 hectares of employment uses, Page 88) should the District Council wish to proceed with allocation of the site. The A1245 is classified as a Main Distributor in the Route Hierarchy and direct access from this class of road is normally prohibited. In addition, the distance on the A1245 between the A127 Fairglen junction and the railway line acts against achievement of the required technical specifications for a new junction. Any changes to the Fairglen junction to provide an access to the site would require comprehensive realignment of the northern western sector and, in addition, the existing roundabout contains a pumping station. Direct access to the A127 and A130 is also prohibited due to the classification of those roads and would need third party land.

D. Assessment of the preferred site options should also include specific consideration of their Historic Environment Character in terms of known and potential features and their contribution to the cultural and historic landscapes of the District. There should be a programme of archaeological evaluation to ensure that the cultural heritage potential of each site is taken into account at an early stage in selection of preferred site options and taken forward in subsequent work on the preferred sites. A summary description of the historic environment characteristics and the requirements for archaeological investigation of the residential, brownfield and new employment locations presented in the Allocations DPD is set out in the Annex to this response. The summaries have implications for choice of sites within the locations at West Hockley, South West Hullbridge, South Canewdon and West Great Wakering (residential) and at South of Great Wakering (employment). Essex County Council would be willing to contribute further detailed evaluation of the historic environment characteristics of each site to inform further stages in preparation of the Allocations DPD.


ANNEX TO ESSEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS DPD, DISCUSSION AND CONSULTATION DOCUMENT (REGULATION 25) FEBRUARY 2010

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

1. North of London Road Rayleigh - the Rochford Historic Environment Character (HEC) project identifies the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to any of the four options suggested, given the sites' adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

2. West of Rochford - the Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HEC Zone 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeological potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered

3. West Hockley - this proposed location lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HEC Zone 33) identified in the Rochford Historic Environment Character project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (WH1-5) suggested for land West of Hockley, although options WH2 or WH5 be would preferred due to previous development, they would entail the least impact on any surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

4. South of Hawkwell - within the Rochford HEC the proposed development south of Hawkwell lies within the HEC Z one26, Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites' historic environment character and potential there would be no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

5. East Ashingdon - the site lies within HEC Zone 13, characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie close by. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (EA1-4) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

6. South West Hullbridge - the HEC Zone 36 for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is close by. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. Whilst there would be no objection to the options outlined for South West Hullbridge, there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

7. South Canewdon - the HEC Zone 12 shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of options SC2, 3 and 4 but little to the south, further away from the historic core, in the area of SC1. There would be no objection to the options outlined for South Canewdon, but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

8. South East Ashingdon - the location lies within HEC Zone 13 characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (SEA1-3) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

9. West Great Wakering - options for West Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. There would be no objection to the options (WGW 1-5), although those incorporating, or part incorporating, former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW4 and 5) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

B. Brownfield Sites

1. Stambridge Mills - the location survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. There would be no objection to the redevelopment of the Stambridge Mills site, but there would be a requirement for a historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

1. West of Rayleigh - the Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

2. Michelins Farm - the Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HEC Zone 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

3. London Southend Airport and Environs - within the Rochford Historic Environment Character report the relevant character zones (HEC Zones 17 and 18) identify the areas at this location that not already developed as having a high potential for the survival of historic environment assets. The area is one which, although partially disturbed through construction of the airport and modern industrial buildings, retains a significant archaeological and more general historic environment potential. In addition to known sites, such as the medieval church of St. Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds in the area of the on- going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WWI and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

4. South of Great Wakering - options for south of Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. Due to quarrying, option E22 (south of Star Lane brickworks) and options E23 and& E24 (south of Poynters Road) have no historic environment implications and option E19 would have the least impact of the remaining options. Otherwise non- quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.

Response of Essex County Council

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific options for development at the general locations identified within the Core Strategy Submission Document will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of options not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District. Similarly, the stated intent (Page 6) to ensure delivery of required infrastructure alongside residential development is fully supported.

The scope and coverage of the Allocations DPD is broadly supported but the general approach to site assessment, selection and definition could benefit from some further considerations, as follows,

1. as presented, many of the site specific options for development suggest artificial and/or straight.site boundaries. The definition of boundaries of the sites eventually selected should be based on and incorporate existing boundaries, in order to,
* respect the often ancient field patterns;
* existing hedges and other vegetation can provide a screen to the development or a feature at the periphery of the development;
* avoid odd parcels of land remaining which are too small to function independently;
* preserve often important wildlife habitats.

2. new single-form entry primary schools will be required to serve proposed residential at two locations - the site North of London Road, Rayleigh, and the site to the West of Rochford. Chapter 5 (Community Facilities) lists site characteristics for school provision at each of these sites (Pages 110 and 111). Essex County Council does not agree to these lists of characteristics. The criteria for identification and selection of school sites are much broader.

Essex County Council has produced an 'Education Contributions Guidelines Supplement' to its 'Developers Guide to Infrastructure Contributions (2010 Edition)' - both of which were subject to a public consultation exercise closing in February 2010. The 'Education Contributions Guidelines Supplement' (copy attached to response) sets out the detailed requirements for provision of new school sites. In the context of the statements on pages 110 and 111 of the Allocations DPD particular attention is drawn to the procedures and requirements for identification and selection of new school sites as set out in Appendices D, E and F. Within Appendix D particular attention is drawn to the section of the Checklist addressing the question of 'suitable safe access' to the site to emphasise that the design of the school and its relationship to the proposed and existing residential areas should facilitate provision of the best and safest walking routes to schools. The Supplement should be referenced within the Allocations DPD and other relevant documents within the Local Development Framework.

3. provision of Early Years and Childcare facilities is not discussed by the Document. Clear statements should be included that the two potential new primary schools would also need to incorporate Early Years and Childcare facilities. The District's Core Strategy (Policy CLT2) also requires provision of new Early Years and Childcare facilities in Hockley. Although it is not currently envisaged that a site could be identified in the Allocations DPD the requirement could be usefully identified in discussion of Hockley Town Centre (Page 144).

4. the proposed allocation of sites for education use is noted. However, allocation of such sites, and other County Council or public service sites, should not be applied such that it seeks to preserve existing uses on sites in perpetuity, thereby restricting the service provider's ability to expand/relocate the facility to better cater for future needs. Should a public service site cease to be required for its current purpose, its future use should be determined on the merits of the site and its location. Public service sites become surplus because local demand for the service has fallen to uneconomic levels or the facility has been replaced by more suitable facilities elsewhere. The Allocations DPD, and other documents within the Local Development Framework, should acknowledge that there will be circumstances when a better option for the community would be redevelopment of a public service site and re-investment of the proceeds elsewhere as part of a strategic programme of infrastructure replacement.

5. Section 4, Environment, of the Allocations DPD would benefit from an additional section that discusses the Historic Environment of Rochford District. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

6. it should be noted that the County Library Service's medium-term plans include moving the existing library from its existing premises in Great Wakering. This may offer the opportunity for a joint project associated with the proposed enhancement of the Leisure Centre in the village, dependent on detailed location, access and other considerations.

7. the selected sites will generally be associated with greenspace creation. Information on greenspace deficiencies in the area is available in the 'Analysis of Accessible Natural Greenspace Provision for Essex, including Southend-on-Sea and Thurrock Unitary Authorities', which may be found on the Essex Wildlife Trust website.

8. the emphasis of the Document on provision of Sustainable Urban Drainage systems is welcomed, but it should be linked to broader support for the use of associated Green Infrastructure and greenspace creation.

9. the Allocations DPD should acknowledge and note the proportion of the development requirements that will be provided on existing development or brownfield sites.

In respect of the proposed site specific options and environmental designations Essex County Council has the following observations,

A. King Edmund School education site - there is an identified need to provide additional land to accommodate expansion of the school to meet additional demand and to secure improved vehicular access to the school via Brays Lane. Options KES2 and KES3 are preferred by Essex County Council because each presents an opportunity to contribute to both identified needs. Improvements to King Edmund School will need to be linked with adjacent proposals for residential development at the East Ashingdon location. Options EA1 or EA3 are preferred because of the opportunities they present to enable the improvements to the school, which Option EA1 does not. Essex County Council would welcome early discussion with the District Council to ensure the suitability of the detailed site specific requirements for improvement to King Edmund School and residential development at the East Ashingdon location. It should be noted that provision of access from King Edmund School to Brays Lane should be of a standard sufficient to accommodate cars and all associated vehicles serving the school.

B. the proposed environmental designations discussed in Chapter 4 (Environment) are supported. The proposed definition of a boundary for the Coastal Protection Belt is particularly supported as assisting realisation of Policy ENV2 of the Core Strategy and reflecting the currently saved Policy CC1 of the Essex and Southend-on-Sea Replacement Structure Plan (2001). Also, the designation of Cherry Orchard Jubilee Country Park and the Upper Roach Valley is supported. However, the Allocations Document should also include the proposed Stonebridge Park, which is highlighted in the Parklands Vision as a potential sub-regional park centred around Great Wakering.

C. further detailed consideration would be required of the potential employment/ business density of the site and its transport and access requirements of Option E18, Michelins Farm (an option for 8.6 hectares of employment uses, Page 88) should the District Council wish to proceed with allocation of the site. The A1245 is classified as a Main Distributor in the Route Hierarchy and direct access from this class of road is normally prohibited. In addition, the distance on the A1245 between the A127 Fairglen junction and the railway line acts against achievement of the required technical specifications for a new junction. Any changes to the Fairglen junction to provide an access to the site would require comprehensive realignment of the northern western sector and, in addition, the existing roundabout contains a pumping station. Direct access to the A127 and A130 is also prohibited due to the classification of those roads and would need third party land.

D. Assessment of the preferred site options should also include specific consideration of their Historic Environment Character in terms of known and potential features and their contribution to the cultural and historic landscapes of the District. There should be a programme of archaeological evaluation to ensure that the cultural heritage potential of each site is taken into account at an early stage in selection of preferred site options and taken forward in subsequent work on the preferred sites. A summary description of the historic environment characteristics and the requirements for archaeological investigation of the residential, brownfield and new employment locations presented in the Allocations DPD is set out in the Annex to this response. The summaries have implications for choice of sites within the locations at West Hockley, South West Hullbridge, South Canewdon and West Great Wakering (residential) and at South of Great Wakering (employment). Essex County Council would be willing to contribute further detailed evaluation of the historic environment characteristics of each site to inform further stages in preparation of the Allocations DPD.


ANNEX TO ESSEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS DPD, DISCUSSION AND CONSULTATION DOCUMENT (REGULATION 25) FEBRUARY 2010

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

1. North of London Road Rayleigh - the Rochford Historic Environment Character (HEC) project identifies the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to any of the four options suggested, given the sites' adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

2. West of Rochford - the Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HEC Zone 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeological potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered

3. West Hockley - this proposed location lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HEC Zone 33) identified in the Rochford Historic Environment Character project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (WH1-5) suggested for land West of Hockley, although options WH2 or WH5 be would preferred due to previous development, they would entail the least impact on any surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

4. South of Hawkwell - within the Rochford HEC the proposed development south of Hawkwell lies within the HEC Z one26, Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites' historic environment character and potential there would be no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

5. East Ashingdon - the site lies within HEC Zone 13, characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie close by. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (EA1-4) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

6. South West Hullbridge - the HEC Zone 36 for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is close by. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. Whilst there would be no objection to the options outlined for South West Hullbridge, there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

7. South Canewdon - the HEC Zone 12 shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of options SC2, 3 and 4 but little to the south, further away from the historic core, in the area of SC1. There would be no objection to the options outlined for South Canewdon, but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

8. South East Ashingdon - the location lies within HEC Zone 13 characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (SEA1-3) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

9. West Great Wakering - options for West Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. There would be no objection to the options (WGW 1-5), although those incorporating, or part incorporating, former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW4 and 5) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

B. Brownfield Sites

1. Stambridge Mills - the location survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. There would be no objection to the redevelopment of the Stambridge Mills site, but there would be a requirement for a historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

1. West of Rayleigh - the Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

2. Michelins Farm - the Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HEC Zone 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

3. London Southend Airport and Environs - within the Rochford Historic Environment Character report the relevant character zones (HEC Zones 17 and 18) identify the areas at this location that not already developed as having a high potential for the survival of historic environment assets. The area is one which, although partially disturbed through construction of the airport and modern industrial buildings, retains a significant archaeological and more general historic environment potential. In addition to known sites, such as the medieval church of St. Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds in the area of the on- going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WWI and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

4. South of Great Wakering - options for south of Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. Due to quarrying, option E22 (south of Star Lane brickworks) and options E23 and& E24 (south of Poynters Road) have no historic environment implications and option E19 would have the least impact of the remaining options. Otherwise non- quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.

Response of Essex County Council

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific options for development at the general locations identified within the Core Strategy Submission Document will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of options not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District. Similarly, the stated intent (Page 6) to ensure delivery of required infrastructure alongside residential development is fully supported.

The scope and coverage of the Allocations DPD is broadly supported but the general approach to site assessment, selection and definition could benefit from some further considerations, as follows,

1. as presented, many of the site specific options for development suggest artificial and/or straight.site boundaries. The definition of boundaries of the sites eventually selected should be based on and incorporate existing boundaries, in order to,
* respect the often ancient field patterns;
* existing hedges and other vegetation can provide a screen to the development or a feature at the periphery of the development;
* avoid odd parcels of land remaining which are too small to function independently;
* preserve often important wildlife habitats.

2. new single-form entry primary schools will be required to serve proposed residential at two locations - the site North of London Road, Rayleigh, and the site to the West of Rochford. Chapter 5 (Community Facilities) lists site characteristics for school provision at each of these sites (Pages 110 and 111). Essex County Council does not agree to these lists of characteristics. The criteria for identification and selection of school sites are much broader.

Essex County Council has produced an 'Education Contributions Guidelines Supplement' to its 'Developers Guide to Infrastructure Contributions (2010 Edition)' - both of which were subject to a public consultation exercise closing in February 2010. The 'Education Contributions Guidelines Supplement' (copy attached to response) sets out the detailed requirements for provision of new school sites. In the context of the statements on pages 110 and 111 of the Allocations DPD particular attention is drawn to the procedures and requirements for identification and selection of new school sites as set out in Appendices D, E and F. Within Appendix D particular attention is drawn to the section of the Checklist addressing the question of 'suitable safe access' to the site to emphasise that the design of the school and its relationship to the proposed and existing residential areas should facilitate provision of the best and safest walking routes to schools. The Supplement should be referenced within the Allocations DPD and other relevant documents within the Local Development Framework.

3. provision of Early Years and Childcare facilities is not discussed by the Document. Clear statements should be included that the two potential new primary schools would also need to incorporate Early Years and Childcare facilities. The District's Core Strategy (Policy CLT2) also requires provision of new Early Years and Childcare facilities in Hockley. Although it is not currently envisaged that a site could be identified in the Allocations DPD the requirement could be usefully identified in discussion of Hockley Town Centre (Page 144).

4. the proposed allocation of sites for education use is noted. However, allocation of such sites, and other County Council or public service sites, should not be applied such that it seeks to preserve existing uses on sites in perpetuity, thereby restricting the service provider's ability to expand/relocate the facility to better cater for future needs. Should a public service site cease to be required for its current purpose, its future use should be determined on the merits of the site and its location. Public service sites become surplus because local demand for the service has fallen to uneconomic levels or the facility has been replaced by more suitable facilities elsewhere. The Allocations DPD, and other documents within the Local Development Framework, should acknowledge that there will be circumstances when a better option for the community would be redevelopment of a public service site and re-investment of the proceeds elsewhere as part of a strategic programme of infrastructure replacement.

5. Section 4, Environment, of the Allocations DPD would benefit from an additional section that discusses the Historic Environment of Rochford District. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

6. it should be noted that the County Library Service's medium-term plans include moving the existing library from its existing premises in Great Wakering. This may offer the opportunity for a joint project associated with the proposed enhancement of the Leisure Centre in the village, dependent on detailed location, access and other considerations.

7. the selected sites will generally be associated with greenspace creation. Information on greenspace deficiencies in the area is available in the 'Analysis of Accessible Natural Greenspace Provision for Essex, including Southend-on-Sea and Thurrock Unitary Authorities', which may be found on the Essex Wildlife Trust website.

8. the emphasis of the Document on provision of Sustainable Urban Drainage systems is welcomed, but it should be linked to broader support for the use of associated Green Infrastructure and greenspace creation.

9. the Allocations DPD should acknowledge and note the proportion of the development requirements that will be provided on existing development or brownfield sites.

In respect of the proposed site specific options and environmental designations Essex County Council has the following observations,

A. King Edmund School education site - there is an identified need to provide additional land to accommodate expansion of the school to meet additional demand and to secure improved vehicular access to the school via Brays Lane. Options KES2 and KES3 are preferred by Essex County Council because each presents an opportunity to contribute to both identified needs. Improvements to King Edmund School will need to be linked with adjacent proposals for residential development at the East Ashingdon location. Options EA1 or EA3 are preferred because of the opportunities they present to enable the improvements to the school, which Option EA1 does not. Essex County Council would welcome early discussion with the District Council to ensure the suitability of the detailed site specific requirements for improvement to King Edmund School and residential development at the East Ashingdon location. It should be noted that provision of access from King Edmund School to Brays Lane should be of a standard sufficient to accommodate cars and all associated vehicles serving the school.

B. the proposed environmental designations discussed in Chapter 4 (Environment) are supported. The proposed definition of a boundary for the Coastal Protection Belt is particularly supported as assisting realisation of Policy ENV2 of the Core Strategy and reflecting the currently saved Policy CC1 of the Essex and Southend-on-Sea Replacement Structure Plan (2001). Also, the designation of Cherry Orchard Jubilee Country Park and the Upper Roach Valley is supported. However, the Allocations Document should also include the proposed Stonebridge Park, which is highlighted in the Parklands Vision as a potential sub-regional park centred around Great Wakering.

C. further detailed consideration would be required of the potential employment/ business density of the site and its transport and access requirements of Option E18, Michelins Farm (an option for 8.6 hectares of employment uses, Page 88) should the District Council wish to proceed with allocation of the site. The A1245 is classified as a Main Distributor in the Route Hierarchy and direct access from this class of road is normally prohibited. In addition, the distance on the A1245 between the A127 Fairglen junction and the railway line acts against achievement of the required technical specifications for a new junction. Any changes to the Fairglen junction to provide an access to the site would require comprehensive realignment of the northern western sector and, in addition, the existing roundabout contains a pumping station. Direct access to the A127 and A130 is also prohibited due to the classification of those roads and would need third party land.

D. Assessment of the preferred site options should also include specific consideration of their Historic Environment Character in terms of known and potential features and their contribution to the cultural and historic landscapes of the District. There should be a programme of archaeological evaluation to ensure that the cultural heritage potential of each site is taken into account at an early stage in selection of preferred site options and taken forward in subsequent work on the preferred sites. A summary description of the historic environment characteristics and the requirements for archaeological investigation of the residential, brownfield and new employment locations presented in the Allocations DPD is set out in the Annex to this response. The summaries have implications for choice of sites within the locations at West Hockley, South West Hullbridge, South Canewdon and West Great Wakering (residential) and at South of Great Wakering (employment). Essex County Council would be willing to contribute further detailed evaluation of the historic environment characteristics of each site to inform further stages in preparation of the Allocations DPD.


ANNEX TO ESSEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS DPD, DISCUSSION AND CONSULTATION DOCUMENT (REGULATION 25) FEBRUARY 2010

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

1. North of London Road Rayleigh - the Rochford Historic Environment Character (HEC) project identifies the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to any of the four options suggested, given the sites' adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

2. West of Rochford - the Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HEC Zone 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeological potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered

3. West Hockley - this proposed location lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HEC Zone 33) identified in the Rochford Historic Environment Character project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (WH1-5) suggested for land West of Hockley, although options WH2 or WH5 be would preferred due to previous development, they would entail the least impact on any surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

4. South of Hawkwell - within the Rochford HEC the proposed development south of Hawkwell lies within the HEC Z one26, Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites' historic environment character and potential there would be no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

5. East Ashingdon - the site lies within HEC Zone 13, characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie close by. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (EA1-4) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

6. South West Hullbridge - the HEC Zone 36 for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is close by. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. Whilst there would be no objection to the options outlined for South West Hullbridge, there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

7. South Canewdon - the HEC Zone 12 shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of options SC2, 3 and 4 but little to the south, further away from the historic core, in the area of SC1. There would be no objection to the options outlined for South Canewdon, but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

8. South East Ashingdon - the location lies within HEC Zone 13 characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (SEA1-3) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

9. West Great Wakering - options for West Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. There would be no objection to the options (WGW 1-5), although those incorporating, or part incorporating, former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW4 and 5) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

B. Brownfield Sites

1. Stambridge Mills - the location survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. There would be no objection to the redevelopment of the Stambridge Mills site, but there would be a requirement for a historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

1. West of Rayleigh - the Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

2. Michelins Farm - the Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HEC Zone 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

3. London Southend Airport and Environs - within the Rochford Historic Environment Character report the relevant character zones (HEC Zones 17 and 18) identify the areas at this location that not already developed as having a high potential for the survival of historic environment assets. The area is one which, although partially disturbed through construction of the airport and modern industrial buildings, retains a significant archaeological and more general historic environment potential. In addition to known sites, such as the medieval church of St. Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds in the area of the on- going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WWI and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

4. South of Great Wakering - options for south of Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. Due to quarrying, option E22 (south of Star Lane brickworks) and options E23 and& E24 (south of Poynters Road) have no historic environment implications and option E19 would have the least impact of the remaining options. Otherwise non- quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.

Response of Essex County Council

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific options for development at the general locations identified within the Core Strategy Submission Document will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of options not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District. Similarly, the stated intent (Page 6) to ensure delivery of required infrastructure alongside residential development is fully supported.

The scope and coverage of the Allocations DPD is broadly supported but the general approach to site assessment, selection and definition could benefit from some further considerations, as follows,

1. as presented, many of the site specific options for development suggest artificial and/or straight.site boundaries. The definition of boundaries of the sites eventually selected should be based on and incorporate existing boundaries, in order to,
* respect the often ancient field patterns;
* existing hedges and other vegetation can provide a screen to the development or a feature at the periphery of the development;
* avoid odd parcels of land remaining which are too small to function independently;
* preserve often important wildlife habitats.

2. new single-form entry primary schools will be required to serve proposed residential at two locations - the site North of London Road, Rayleigh, and the site to the West of Rochford. Chapter 5 (Community Facilities) lists site characteristics for school provision at each of these sites (Pages 110 and 111). Essex County Council does not agree to these lists of characteristics. The criteria for identification and selection of school sites are much broader.

Essex County Council has produced an 'Education Contributions Guidelines Supplement' to its 'Developers Guide to Infrastructure Contributions (2010 Edition)' - both of which were subject to a public consultation exercise closing in February 2010. The 'Education Contributions Guidelines Supplement' (copy attached to response) sets out the detailed requirements for provision of new school sites. In the context of the statements on pages 110 and 111 of the Allocations DPD particular attention is drawn to the procedures and requirements for identification and selection of new school sites as set out in Appendices D, E and F. Within Appendix D particular attention is drawn to the section of the Checklist addressing the question of 'suitable safe access' to the site to emphasise that the design of the school and its relationship to the proposed and existing residential areas should facilitate provision of the best and safest walking routes to schools. The Supplement should be referenced within the Allocations DPD and other relevant documents within the Local Development Framework.

3. provision of Early Years and Childcare facilities is not discussed by the Document. Clear statements should be included that the two potential new primary schools would also need to incorporate Early Years and Childcare facilities. The District's Core Strategy (Policy CLT2) also requires provision of new Early Years and Childcare facilities in Hockley. Although it is not currently envisaged that a site could be identified in the Allocations DPD the requirement could be usefully identified in discussion of Hockley Town Centre (Page 144).

4. the proposed allocation of sites for education use is noted. However, allocation of such sites, and other County Council or public service sites, should not be applied such that it seeks to preserve existing uses on sites in perpetuity, thereby restricting the service provider's ability to expand/relocate the facility to better cater for future needs. Should a public service site cease to be required for its current purpose, its future use should be determined on the merits of the site and its location. Public service sites become surplus because local demand for the service has fallen to uneconomic levels or the facility has been replaced by more suitable facilities elsewhere. The Allocations DPD, and other documents within the Local Development Framework, should acknowledge that there will be circumstances when a better option for the community would be redevelopment of a public service site and re-investment of the proceeds elsewhere as part of a strategic programme of infrastructure replacement.

5. Section 4, Environment, of the Allocations DPD would benefit from an additional section that discusses the Historic Environment of Rochford District. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

6. it should be noted that the County Library Service's medium-term plans include moving the existing library from its existing premises in Great Wakering. This may offer the opportunity for a joint project associated with the proposed enhancement of the Leisure Centre in the village, dependent on detailed location, access and other considerations.

7. the selected sites will generally be associated with greenspace creation. Information on greenspace deficiencies in the area is available in the 'Analysis of Accessible Natural Greenspace Provision for Essex, including Southend-on-Sea and Thurrock Unitary Authorities', which may be found on the Essex Wildlife Trust website.

8. the emphasis of the Document on provision of Sustainable Urban Drainage systems is welcomed, but it should be linked to broader support for the use of associated Green Infrastructure and greenspace creation.

9. the Allocations DPD should acknowledge and note the proportion of the development requirements that will be provided on existing development or brownfield sites.

In respect of the proposed site specific options and environmental designations Essex County Council has the following observations,

A. King Edmund School education site - there is an identified need to provide additional land to accommodate expansion of the school to meet additional demand and to secure improved vehicular access to the school via Brays Lane. Options KES2 and KES3 are preferred by Essex County Council because each presents an opportunity to contribute to both identified needs. Improvements to King Edmund School will need to be linked with adjacent proposals for residential development at the East Ashingdon location. Options EA1 or EA3 are preferred because of the opportunities they present to enable the improvements to the school, which Option EA1 does not. Essex County Council would welcome early discussion with the District Council to ensure the suitability of the detailed site specific requirements for improvement to King Edmund School and residential development at the East Ashingdon location. It should be noted that provision of access from King Edmund School to Brays Lane should be of a standard sufficient to accommodate cars and all associated vehicles serving the school.

B. the proposed environmental designations discussed in Chapter 4 (Environment) are supported. The proposed definition of a boundary for the Coastal Protection Belt is particularly supported as assisting realisation of Policy ENV2 of the Core Strategy and reflecting the currently saved Policy CC1 of the Essex and Southend-on-Sea Replacement Structure Plan (2001). Also, the designation of Cherry Orchard Jubilee Country Park and the Upper Roach Valley is supported. However, the Allocations Document should also include the proposed Stonebridge Park, which is highlighted in the Parklands Vision as a potential sub-regional park centred around Great Wakering.

C. further detailed consideration would be required of the potential employment/ business density of the site and its transport and access requirements of Option E18, Michelins Farm (an option for 8.6 hectares of employment uses, Page 88) should the District Council wish to proceed with allocation of the site. The A1245 is classified as a Main Distributor in the Route Hierarchy and direct access from this class of road is normally prohibited. In addition, the distance on the A1245 between the A127 Fairglen junction and the railway line acts against achievement of the required technical specifications for a new junction. Any changes to the Fairglen junction to provide an access to the site would require comprehensive realignment of the northern western sector and, in addition, the existing roundabout contains a pumping station. Direct access to the A127 and A130 is also prohibited due to the classification of those roads and would need third party land.

D. Assessment of the preferred site options should also include specific consideration of their Historic Environment Character in terms of known and potential features and their contribution to the cultural and historic landscapes of the District. There should be a programme of archaeological evaluation to ensure that the cultural heritage potential of each site is taken into account at an early stage in selection of preferred site options and taken forward in subsequent work on the preferred sites. A summary description of the historic environment characteristics and the requirements for archaeological investigation of the residential, brownfield and new employment locations presented in the Allocations DPD is set out in the Annex to this response. The summaries have implications for choice of sites within the locations at West Hockley, South West Hullbridge, South Canewdon and West Great Wakering (residential) and at South of Great Wakering (employment). Essex County Council would be willing to contribute further detailed evaluation of the historic environment characteristics of each site to inform further stages in preparation of the Allocations DPD.


ANNEX TO ESSEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS DPD, DISCUSSION AND CONSULTATION DOCUMENT (REGULATION 25) FEBRUARY 2010

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

1. North of London Road Rayleigh - the Rochford Historic Environment Character (HEC) project identifies the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to any of the four options suggested, given the sites' adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

2. West of Rochford - the Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HEC Zone 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeological potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered

3. West Hockley - this proposed location lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HEC Zone 33) identified in the Rochford Historic Environment Character project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (WH1-5) suggested for land West of Hockley, although options WH2 or WH5 be would preferred due to previous development, they would entail the least impact on any surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

4. South of Hawkwell - within the Rochford HEC the proposed development south of Hawkwell lies within the HEC Z one26, Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites' historic environment character and potential there would be no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

5. East Ashingdon - the site lies within HEC Zone 13, characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie close by. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (EA1-4) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

6. South West Hullbridge - the HEC Zone 36 for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is close by. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. Whilst there would be no objection to the options outlined for South West Hullbridge, there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

7. South Canewdon - the HEC Zone 12 shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of options SC2, 3 and 4 but little to the south, further away from the historic core, in the area of SC1. There would be no objection to the options outlined for South Canewdon, but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

8. South East Ashingdon - the location lies within HEC Zone 13 characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (SEA1-3) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

9. West Great Wakering - options for West Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. There would be no objection to the options (WGW 1-5), although those incorporating, or part incorporating, former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW4 and 5) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

B. Brownfield Sites

1. Stambridge Mills - the location survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. There would be no objection to the redevelopment of the Stambridge Mills site, but there would be a requirement for a historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

1. West of Rayleigh - the Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

2. Michelins Farm - the Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HEC Zone 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

3. London Southend Airport and Environs - within the Rochford Historic Environment Character report the relevant character zones (HEC Zones 17 and 18) identify the areas at this location that not already developed as having a high potential for the survival of historic environment assets. The area is one which, although partially disturbed through construction of the airport and modern industrial buildings, retains a significant archaeological and more general historic environment potential. In addition to known sites, such as the medieval church of St. Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds in the area of the on- going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WWI and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

4. South of Great Wakering - options for south of Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. Due to quarrying, option E22 (south of Star Lane brickworks) and options E23 and& E24 (south of Poynters Road) have no historic environment implications and option E19 would have the least impact of the remaining options. Otherwise non- quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.

Response of Essex County Council

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific options for development at the general locations identified within the Core Strategy Submission Document will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of options not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District. Similarly, the stated intent (Page 6) to ensure delivery of required infrastructure alongside residential development is fully supported.

The scope and coverage of the Allocations DPD is broadly supported but the general approach to site assessment, selection and definition could benefit from some further considerations, as follows,

1. as presented, many of the site specific options for development suggest artificial and/or straight.site boundaries. The definition of boundaries of the sites eventually selected should be based on and incorporate existing boundaries, in order to,
* respect the often ancient field patterns;
* existing hedges and other vegetation can provide a screen to the development or a feature at the periphery of the development;
* avoid odd parcels of land remaining which are too small to function independently;
* preserve often important wildlife habitats.

2. new single-form entry primary schools will be required to serve proposed residential at two locations - the site North of London Road, Rayleigh, and the site to the West of Rochford. Chapter 5 (Community Facilities) lists site characteristics for school provision at each of these sites (Pages 110 and 111). Essex County Council does not agree to these lists of characteristics. The criteria for identification and selection of school sites are much broader.

Essex County Council has produced an 'Education Contributions Guidelines Supplement' to its 'Developers Guide to Infrastructure Contributions (2010 Edition)' - both of which were subject to a public consultation exercise closing in February 2010. The 'Education Contributions Guidelines Supplement' (copy attached to response) sets out the detailed requirements for provision of new school sites. In the context of the statements on pages 110 and 111 of the Allocations DPD particular attention is drawn to the procedures and requirements for identification and selection of new school sites as set out in Appendices D, E and F. Within Appendix D particular attention is drawn to the section of the Checklist addressing the question of 'suitable safe access' to the site to emphasise that the design of the school and its relationship to the proposed and existing residential areas should facilitate provision of the best and safest walking routes to schools. The Supplement should be referenced within the Allocations DPD and other relevant documents within the Local Development Framework.

3. provision of Early Years and Childcare facilities is not discussed by the Document. Clear statements should be included that the two potential new primary schools would also need to incorporate Early Years and Childcare facilities. The District's Core Strategy (Policy CLT2) also requires provision of new Early Years and Childcare facilities in Hockley. Although it is not currently envisaged that a site could be identified in the Allocations DPD the requirement could be usefully identified in discussion of Hockley Town Centre (Page 144).

4. the proposed allocation of sites for education use is noted. However, allocation of such sites, and other County Council or public service sites, should not be applied such that it seeks to preserve existing uses on sites in perpetuity, thereby restricting the service provider's ability to expand/relocate the facility to better cater for future needs. Should a public service site cease to be required for its current purpose, its future use should be determined on the merits of the site and its location. Public service sites become surplus because local demand for the service has fallen to uneconomic levels or the facility has been replaced by more suitable facilities elsewhere. The Allocations DPD, and other documents within the Local Development Framework, should acknowledge that there will be circumstances when a better option for the community would be redevelopment of a public service site and re-investment of the proceeds elsewhere as part of a strategic programme of infrastructure replacement.

5. Section 4, Environment, of the Allocations DPD would benefit from an additional section that discusses the Historic Environment of Rochford District. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

6. it should be noted that the County Library Service's medium-term plans include moving the existing library from its existing premises in Great Wakering. This may offer the opportunity for a joint project associated with the proposed enhancement of the Leisure Centre in the village, dependent on detailed location, access and other considerations.

7. the selected sites will generally be associated with greenspace creation. Information on greenspace deficiencies in the area is available in the 'Analysis of Accessible Natural Greenspace Provision for Essex, including Southend-on-Sea and Thurrock Unitary Authorities', which may be found on the Essex Wildlife Trust website.

8. the emphasis of the Document on provision of Sustainable Urban Drainage systems is welcomed, but it should be linked to broader support for the use of associated Green Infrastructure and greenspace creation.

9. the Allocations DPD should acknowledge and note the proportion of the development requirements that will be provided on existing development or brownfield sites.

In respect of the proposed site specific options and environmental designations Essex County Council has the following observations,

A. King Edmund School education site - there is an identified need to provide additional land to accommodate expansion of the school to meet additional demand and to secure improved vehicular access to the school via Brays Lane. Options KES2 and KES3 are preferred by Essex County Council because each presents an opportunity to contribute to both identified needs. Improvements to King Edmund School will need to be linked with adjacent proposals for residential development at the East Ashingdon location. Options EA1 or EA3 are preferred because of the opportunities they present to enable the improvements to the school, which Option EA1 does not. Essex County Council would welcome early discussion with the District Council to ensure the suitability of the detailed site specific requirements for improvement to King Edmund School and residential development at the East Ashingdon location. It should be noted that provision of access from King Edmund School to Brays Lane should be of a standard sufficient to accommodate cars and all associated vehicles serving the school.

B. the proposed environmental designations discussed in Chapter 4 (Environment) are supported. The proposed definition of a boundary for the Coastal Protection Belt is particularly supported as assisting realisation of Policy ENV2 of the Core Strategy and reflecting the currently saved Policy CC1 of the Essex and Southend-on-Sea Replacement Structure Plan (2001). Also, the designation of Cherry Orchard Jubilee Country Park and the Upper Roach Valley is supported. However, the Allocations Document should also include the proposed Stonebridge Park, which is highlighted in the Parklands Vision as a potential sub-regional park centred around Great Wakering.

C. further detailed consideration would be required of the potential employment/ business density of the site and its transport and access requirements of Option E18, Michelins Farm (an option for 8.6 hectares of employment uses, Page 88) should the District Council wish to proceed with allocation of the site. The A1245 is classified as a Main Distributor in the Route Hierarchy and direct access from this class of road is normally prohibited. In addition, the distance on the A1245 between the A127 Fairglen junction and the railway line acts against achievement of the required technical specifications for a new junction. Any changes to the Fairglen junction to provide an access to the site would require comprehensive realignment of the northern western sector and, in addition, the existing roundabout contains a pumping station. Direct access to the A127 and A130 is also prohibited due to the classification of those roads and would need third party land.

D. Assessment of the preferred site options should also include specific consideration of their Historic Environment Character in terms of known and potential features and their contribution to the cultural and historic landscapes of the District. There should be a programme of archaeological evaluation to ensure that the cultural heritage potential of each site is taken into account at an early stage in selection of preferred site options and taken forward in subsequent work on the preferred sites. A summary description of the historic environment characteristics and the requirements for archaeological investigation of the residential, brownfield and new employment locations presented in the Allocations DPD is set out in the Annex to this response. The summaries have implications for choice of sites within the locations at West Hockley, South West Hullbridge, South Canewdon and West Great Wakering (residential) and at South of Great Wakering (employment). Essex County Council would be willing to contribute further detailed evaluation of the historic environment characteristics of each site to inform further stages in preparation of the Allocations DPD.


ANNEX TO ESSEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS DPD, DISCUSSION AND CONSULTATION DOCUMENT (REGULATION 25) FEBRUARY 2010

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

1. North of London Road Rayleigh - the Rochford Historic Environment Character (HEC) project identifies the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to any of the four options suggested, given the sites' adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

2. West of Rochford - the Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HEC Zone 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeological potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered

3. West Hockley - this proposed location lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HEC Zone 33) identified in the Rochford Historic Environment Character project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (WH1-5) suggested for land West of Hockley, although options WH2 or WH5 be would preferred due to previous development, they would entail the least impact on any surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

4. South of Hawkwell - within the Rochford HEC the proposed development south of Hawkwell lies within the HEC Z one26, Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites' historic environment character and potential there would be no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

5. East Ashingdon - the site lies within HEC Zone 13, characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie close by. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (EA1-4) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

6. South West Hullbridge - the HEC Zone 36 for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is close by. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. Whilst there would be no objection to the options outlined for South West Hullbridge, there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

7. South Canewdon - the HEC Zone 12 shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of options SC2, 3 and 4 but little to the south, further away from the historic core, in the area of SC1. There would be no objection to the options outlined for South Canewdon, but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

8. South East Ashingdon - the location lies within HEC Zone 13 characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (SEA1-3) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

9. West Great Wakering - options for West Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. There would be no objection to the options (WGW 1-5), although those incorporating, or part incorporating, former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW4 and 5) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

B. Brownfield Sites

1. Stambridge Mills - the location survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. There would be no objection to the redevelopment of the Stambridge Mills site, but there would be a requirement for a historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

1. West of Rayleigh - the Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

2. Michelins Farm - the Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HEC Zone 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

3. London Southend Airport and Environs - within the Rochford Historic Environment Character report the relevant character zones (HEC Zones 17 and 18) identify the areas at this location that not already developed as having a high potential for the survival of historic environment assets. The area is one which, although partially disturbed through construction of the airport and modern industrial buildings, retains a significant archaeological and more general historic environment potential. In addition to known sites, such as the medieval church of St. Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds in the area of the on- going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WWI and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

4. South of Great Wakering - options for south of Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. Due to quarrying, option E22 (south of Star Lane brickworks) and options E23 and& E24 (south of Poynters Road) have no historic environment implications and option E19 would have the least impact of the remaining options. Otherwise non- quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.

Response of Essex County Council

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific options for development at the general locations identified within the Core Strategy Submission Document will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of options not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District. Similarly, the stated intent (Page 6) to ensure delivery of required infrastructure alongside residential development is fully supported.

The scope and coverage of the Allocations DPD is broadly supported but the general approach to site assessment, selection and definition could benefit from some further considerations, as follows,

1. as presented, many of the site specific options for development suggest artificial and/or straight.site boundaries. The definition of boundaries of the sites eventually selected should be based on and incorporate existing boundaries, in order to,
* respect the often ancient field patterns;
* existing hedges and other vegetation can provide a screen to the development or a feature at the periphery of the development;
* avoid odd parcels of land remaining which are too small to function independently;
* preserve often important wildlife habitats.

2. new single-form entry primary schools will be required to serve proposed residential at two locations - the site North of London Road, Rayleigh, and the site to the West of Rochford. Chapter 5 (Community Facilities) lists site characteristics for school provision at each of these sites (Pages 110 and 111). Essex County Council does not agree to these lists of characteristics. The criteria for identification and selection of school sites are much broader.

Essex County Council has produced an 'Education Contributions Guidelines Supplement' to its 'Developers Guide to Infrastructure Contributions (2010 Edition)' - both of which were subject to a public consultation exercise closing in February 2010. The 'Education Contributions Guidelines Supplement' (copy attached to response) sets out the detailed requirements for provision of new school sites. In the context of the statements on pages 110 and 111 of the Allocations DPD particular attention is drawn to the procedures and requirements for identification and selection of new school sites as set out in Appendices D, E and F. Within Appendix D particular attention is drawn to the section of the Checklist addressing the question of 'suitable safe access' to the site to emphasise that the design of the school and its relationship to the proposed and existing residential areas should facilitate provision of the best and safest walking routes to schools. The Supplement should be referenced within the Allocations DPD and other relevant documents within the Local Development Framework.

3. provision of Early Years and Childcare facilities is not discussed by the Document. Clear statements should be included that the two potential new primary schools would also need to incorporate Early Years and Childcare facilities. The District's Core Strategy (Policy CLT2) also requires provision of new Early Years and Childcare facilities in Hockley. Although it is not currently envisaged that a site could be identified in the Allocations DPD the requirement could be usefully identified in discussion of Hockley Town Centre (Page 144).

4. the proposed allocation of sites for education use is noted. However, allocation of such sites, and other County Council or public service sites, should not be applied such that it seeks to preserve existing uses on sites in perpetuity, thereby restricting the service provider's ability to expand/relocate the facility to better cater for future needs. Should a public service site cease to be required for its current purpose, its future use should be determined on the merits of the site and its location. Public service sites become surplus because local demand for the service has fallen to uneconomic levels or the facility has been replaced by more suitable facilities elsewhere. The Allocations DPD, and other documents within the Local Development Framework, should acknowledge that there will be circumstances when a better option for the community would be redevelopment of a public service site and re-investment of the proceeds elsewhere as part of a strategic programme of infrastructure replacement.

5. Section 4, Environment, of the Allocations DPD would benefit from an additional section that discusses the Historic Environment of Rochford District. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

6. it should be noted that the County Library Service's medium-term plans include moving the existing library from its existing premises in Great Wakering. This may offer the opportunity for a joint project associated with the proposed enhancement of the Leisure Centre in the village, dependent on detailed location, access and other considerations.

7. the selected sites will generally be associated with greenspace creation. Information on greenspace deficiencies in the area is available in the 'Analysis of Accessible Natural Greenspace Provision for Essex, including Southend-on-Sea and Thurrock Unitary Authorities', which may be found on the Essex Wildlife Trust website.

8. the emphasis of the Document on provision of Sustainable Urban Drainage systems is welcomed, but it should be linked to broader support for the use of associated Green Infrastructure and greenspace creation.

9. the Allocations DPD should acknowledge and note the proportion of the development requirements that will be provided on existing development or brownfield sites.

In respect of the proposed site specific options and environmental designations Essex County Council has the following observations,

A. King Edmund School education site - there is an identified need to provide additional land to accommodate expansion of the school to meet additional demand and to secure improved vehicular access to the school via Brays Lane. Options KES2 and KES3 are preferred by Essex County Council because each presents an opportunity to contribute to both identified needs. Improvements to King Edmund School will need to be linked with adjacent proposals for residential development at the East Ashingdon location. Options EA1 or EA3 are preferred because of the opportunities they present to enable the improvements to the school, which Option EA1 does not. Essex County Council would welcome early discussion with the District Council to ensure the suitability of the detailed site specific requirements for improvement to King Edmund School and residential development at the East Ashingdon location. It should be noted that provision of access from King Edmund School to Brays Lane should be of a standard sufficient to accommodate cars and all associated vehicles serving the school.

B. the proposed environmental designations discussed in Chapter 4 (Environment) are supported. The proposed definition of a boundary for the Coastal Protection Belt is particularly supported as assisting realisation of Policy ENV2 of the Core Strategy and reflecting the currently saved Policy CC1 of the Essex and Southend-on-Sea Replacement Structure Plan (2001). Also, the designation of Cherry Orchard Jubilee Country Park and the Upper Roach Valley is supported. However, the Allocations Document should also include the proposed Stonebridge Park, which is highlighted in the Parklands Vision as a potential sub-regional park centred around Great Wakering.

C. further detailed consideration would be required of the potential employment/ business density of the site and its transport and access requirements of Option E18, Michelins Farm (an option for 8.6 hectares of employment uses, Page 88) should the District Council wish to proceed with allocation of the site. The A1245 is classified as a Main Distributor in the Route Hierarchy and direct access from this class of road is normally prohibited. In addition, the distance on the A1245 between the A127 Fairglen junction and the railway line acts against achievement of the required technical specifications for a new junction. Any changes to the Fairglen junction to provide an access to the site would require comprehensive realignment of the northern western sector and, in addition, the existing roundabout contains a pumping station. Direct access to the A127 and A130 is also prohibited due to the classification of those roads and would need third party land.

D. Assessment of the preferred site options should also include specific consideration of their Historic Environment Character in terms of known and potential features and their contribution to the cultural and historic landscapes of the District. There should be a programme of archaeological evaluation to ensure that the cultural heritage potential of each site is taken into account at an early stage in selection of preferred site options and taken forward in subsequent work on the preferred sites. A summary description of the historic environment characteristics and the requirements for archaeological investigation of the residential, brownfield and new employment locations presented in the Allocations DPD is set out in the Annex to this response. The summaries have implications for choice of sites within the locations at West Hockley, South West Hullbridge, South Canewdon and West Great Wakering (residential) and at South of Great Wakering (employment). Essex County Council would be willing to contribute further detailed evaluation of the historic environment characteristics of each site to inform further stages in preparation of the Allocations DPD.


ANNEX TO ESSEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS DPD, DISCUSSION AND CONSULTATION DOCUMENT (REGULATION 25) FEBRUARY 2010

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

1. North of London Road Rayleigh - the Rochford Historic Environment Character (HEC) project identifies the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to any of the four options suggested, given the sites' adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

2. West of Rochford - the Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HEC Zone 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeological potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered

3. West Hockley - this proposed location lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HEC Zone 33) identified in the Rochford Historic Environment Character project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (WH1-5) suggested for land West of Hockley, although options WH2 or WH5 be would preferred due to previous development, they would entail the least impact on any surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

4. South of Hawkwell - within the Rochford HEC the proposed development south of Hawkwell lies within the HEC Z one26, Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites' historic environment character and potential there would be no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

5. East Ashingdon - the site lies within HEC Zone 13, characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie close by. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (EA1-4) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

6. South West Hullbridge - the HEC Zone 36 for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is close by. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. Whilst there would be no objection to the options outlined for South West Hullbridge, there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

7. South Canewdon - the HEC Zone 12 shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of options SC2, 3 and 4 but little to the south, further away from the historic core, in the area of SC1. There would be no objection to the options outlined for South Canewdon, but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

8. South East Ashingdon - the location lies within HEC Zone 13 characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (SEA1-3) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

9. West Great Wakering - options for West Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. There would be no objection to the options (WGW 1-5), although those incorporating, or part incorporating, former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW4 and 5) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

B. Brownfield Sites

1. Stambridge Mills - the location survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. There would be no objection to the redevelopment of the Stambridge Mills site, but there would be a requirement for a historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

1. West of Rayleigh - the Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

2. Michelins Farm - the Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HEC Zone 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

3. London Southend Airport and Environs - within the Rochford Historic Environment Character report the relevant character zones (HEC Zones 17 and 18) identify the areas at this location that not already developed as having a high potential for the survival of historic environment assets. The area is one which, although partially disturbed through construction of the airport and modern industrial buildings, retains a significant archaeological and more general historic environment potential. In addition to known sites, such as the medieval church of St. Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds in the area of the on- going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WWI and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

4. South of Great Wakering - options for south of Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. Due to quarrying, option E22 (south of Star Lane brickworks) and options E23 and& E24 (south of Poynters Road) have no historic environment implications and option E19 would have the least impact of the remaining options. Otherwise non- quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.

Response of Essex County Council

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific options for development at the general locations identified within the Core Strategy Submission Document will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of options not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District. Similarly, the stated intent (Page 6) to ensure delivery of required infrastructure alongside residential development is fully supported.

The scope and coverage of the Allocations DPD is broadly supported but the general approach to site assessment, selection and definition could benefit from some further considerations, as follows,

1. as presented, many of the site specific options for development suggest artificial and/or straight.site boundaries. The definition of boundaries of the sites eventually selected should be based on and incorporate existing boundaries, in order to,
* respect the often ancient field patterns;
* existing hedges and other vegetation can provide a screen to the development or a feature at the periphery of the development;
* avoid odd parcels of land remaining which are too small to function independently;
* preserve often important wildlife habitats.

2. new single-form entry primary schools will be required to serve proposed residential at two locations - the site North of London Road, Rayleigh, and the site to the West of Rochford. Chapter 5 (Community Facilities) lists site characteristics for school provision at each of these sites (Pages 110 and 111). Essex County Council does not agree to these lists of characteristics. The criteria for identification and selection of school sites are much broader.

Essex County Council has produced an 'Education Contributions Guidelines Supplement' to its 'Developers Guide to Infrastructure Contributions (2010 Edition)' - both of which were subject to a public consultation exercise closing in February 2010. The 'Education Contributions Guidelines Supplement' (copy attached to response) sets out the detailed requirements for provision of new school sites. In the context of the statements on pages 110 and 111 of the Allocations DPD particular attention is drawn to the procedures and requirements for identification and selection of new school sites as set out in Appendices D, E and F. Within Appendix D particular attention is drawn to the section of the Checklist addressing the question of 'suitable safe access' to the site to emphasise that the design of the school and its relationship to the proposed and existing residential areas should facilitate provision of the best and safest walking routes to schools. The Supplement should be referenced within the Allocations DPD and other relevant documents within the Local Development Framework.

3. provision of Early Years and Childcare facilities is not discussed by the Document. Clear statements should be included that the two potential new primary schools would also need to incorporate Early Years and Childcare facilities. The District's Core Strategy (Policy CLT2) also requires provision of new Early Years and Childcare facilities in Hockley. Although it is not currently envisaged that a site could be identified in the Allocations DPD the requirement could be usefully identified in discussion of Hockley Town Centre (Page 144).

4. the proposed allocation of sites for education use is noted. However, allocation of such sites, and other County Council or public service sites, should not be applied such that it seeks to preserve existing uses on sites in perpetuity, thereby restricting the service provider's ability to expand/relocate the facility to better cater for future needs. Should a public service site cease to be required for its current purpose, its future use should be determined on the merits of the site and its location. Public service sites become surplus because local demand for the service has fallen to uneconomic levels or the facility has been replaced by more suitable facilities elsewhere. The Allocations DPD, and other documents within the Local Development Framework, should acknowledge that there will be circumstances when a better option for the community would be redevelopment of a public service site and re-investment of the proceeds elsewhere as part of a strategic programme of infrastructure replacement.

5. Section 4, Environment, of the Allocations DPD would benefit from an additional section that discusses the Historic Environment of Rochford District. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

6. it should be noted that the County Library Service's medium-term plans include moving the existing library from its existing premises in Great Wakering. This may offer the opportunity for a joint project associated with the proposed enhancement of the Leisure Centre in the village, dependent on detailed location, access and other considerations.

7. the selected sites will generally be associated with greenspace creation. Information on greenspace deficiencies in the area is available in the 'Analysis of Accessible Natural Greenspace Provision for Essex, including Southend-on-Sea and Thurrock Unitary Authorities', which may be found on the Essex Wildlife Trust website.

8. the emphasis of the Document on provision of Sustainable Urban Drainage systems is welcomed, but it should be linked to broader support for the use of associated Green Infrastructure and greenspace creation.

9. the Allocations DPD should acknowledge and note the proportion of the development requirements that will be provided on existing development or brownfield sites.

In respect of the proposed site specific options and environmental designations Essex County Council has the following observations,

A. King Edmund School education site - there is an identified need to provide additional land to accommodate expansion of the school to meet additional demand and to secure improved vehicular access to the school via Brays Lane. Options KES2 and KES3 are preferred by Essex County Council because each presents an opportunity to contribute to both identified needs. Improvements to King Edmund School will need to be linked with adjacent proposals for residential development at the East Ashingdon location. Options EA1 or EA3 are preferred because of the opportunities they present to enable the improvements to the school, which Option EA1 does not. Essex County Council would welcome early discussion with the District Council to ensure the suitability of the detailed site specific requirements for improvement to King Edmund School and residential development at the East Ashingdon location. It should be noted that provision of access from King Edmund School to Brays Lane should be of a standard sufficient to accommodate cars and all associated vehicles serving the school.

B. the proposed environmental designations discussed in Chapter 4 (Environment) are supported. The proposed definition of a boundary for the Coastal Protection Belt is particularly supported as assisting realisation of Policy ENV2 of the Core Strategy and reflecting the currently saved Policy CC1 of the Essex and Southend-on-Sea Replacement Structure Plan (2001). Also, the designation of Cherry Orchard Jubilee Country Park and the Upper Roach Valley is supported. However, the Allocations Document should also include the proposed Stonebridge Park, which is highlighted in the Parklands Vision as a potential sub-regional park centred around Great Wakering.

C. further detailed consideration would be required of the potential employment/ business density of the site and its transport and access requirements of Option E18, Michelins Farm (an option for 8.6 hectares of employment uses, Page 88) should the District Council wish to proceed with allocation of the site. The A1245 is classified as a Main Distributor in the Route Hierarchy and direct access from this class of road is normally prohibited. In addition, the distance on the A1245 between the A127 Fairglen junction and the railway line acts against achievement of the required technical specifications for a new junction. Any changes to the Fairglen junction to provide an access to the site would require comprehensive realignment of the northern western sector and, in addition, the existing roundabout contains a pumping station. Direct access to the A127 and A130 is also prohibited due to the classification of those roads and would need third party land.

D. Assessment of the preferred site options should also include specific consideration of their Historic Environment Character in terms of known and potential features and their contribution to the cultural and historic landscapes of the District. There should be a programme of archaeological evaluation to ensure that the cultural heritage potential of each site is taken into account at an early stage in selection of preferred site options and taken forward in subsequent work on the preferred sites. A summary description of the historic environment characteristics and the requirements for archaeological investigation of the residential, brownfield and new employment locations presented in the Allocations DPD is set out in the Annex to this response. The summaries have implications for choice of sites within the locations at West Hockley, South West Hullbridge, South Canewdon and West Great Wakering (residential) and at South of Great Wakering (employment). Essex County Council would be willing to contribute further detailed evaluation of the historic environment characteristics of each site to inform further stages in preparation of the Allocations DPD.


ANNEX TO ESSEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS DPD, DISCUSSION AND CONSULTATION DOCUMENT (REGULATION 25) FEBRUARY 2010

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

1. North of London Road Rayleigh - the Rochford Historic Environment Character (HEC) project identifies the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to any of the four options suggested, given the sites' adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

2. West of Rochford - the Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HEC Zone 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeological potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered

3. West Hockley - this proposed location lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HEC Zone 33) identified in the Rochford Historic Environment Character project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (WH1-5) suggested for land West of Hockley, although options WH2 or WH5 be would preferred due to previous development, they would entail the least impact on any surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

4. South of Hawkwell - within the Rochford HEC the proposed development south of Hawkwell lies within the HEC Z one26, Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites' historic environment character and potential there would be no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

5. East Ashingdon - the site lies within HEC Zone 13, characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie close by. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (EA1-4) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

6. South West Hullbridge - the HEC Zone 36 for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is close by. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. Whilst there would be no objection to the options outlined for South West Hullbridge, there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

7. South Canewdon - the HEC Zone 12 shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of options SC2, 3 and 4 but little to the south, further away from the historic core, in the area of SC1. There would be no objection to the options outlined for South Canewdon, but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

8. South East Ashingdon - the location lies within HEC Zone 13 characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (SEA1-3) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

9. West Great Wakering - options for West Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. There would be no objection to the options (WGW 1-5), although those incorporating, or part incorporating, former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW4 and 5) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

B. Brownfield Sites

1. Stambridge Mills - the location survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. There would be no objection to the redevelopment of the Stambridge Mills site, but there would be a requirement for a historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

1. West of Rayleigh - the Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

2. Michelins Farm - the Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HEC Zone 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

3. London Southend Airport and Environs - within the Rochford Historic Environment Character report the relevant character zones (HEC Zones 17 and 18) identify the areas at this location that not already developed as having a high potential for the survival of historic environment assets. The area is one which, although partially disturbed through construction of the airport and modern industrial buildings, retains a significant archaeological and more general historic environment potential. In addition to known sites, such as the medieval church of St. Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds in the area of the on- going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WWI and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

4. South of Great Wakering - options for south of Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. Due to quarrying, option E22 (south of Star Lane brickworks) and options E23 and& E24 (south of Poynters Road) have no historic environment implications and option E19 would have the least impact of the remaining options. Otherwise non- quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.

Response of Essex County Council

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific options for development at the general locations identified within the Core Strategy Submission Document will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of options not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District. Similarly, the stated intent (Page 6) to ensure delivery of required infrastructure alongside residential development is fully supported.

The scope and coverage of the Allocations DPD is broadly supported but the general approach to site assessment, selection and definition could benefit from some further considerations, as follows,

1. as presented, many of the site specific options for development suggest artificial and/or straight.site boundaries. The definition of boundaries of the sites eventually selected should be based on and incorporate existing boundaries, in order to,
* respect the often ancient field patterns;
* existing hedges and other vegetation can provide a screen to the development or a feature at the periphery of the development;
* avoid odd parcels of land remaining which are too small to function independently;
* preserve often important wildlife habitats.

2. new single-form entry primary schools will be required to serve proposed residential at two locations - the site North of London Road, Rayleigh, and the site to the West of Rochford. Chapter 5 (Community Facilities) lists site characteristics for school provision at each of these sites (Pages 110 and 111). Essex County Council does not agree to these lists of characteristics. The criteria for identification and selection of school sites are much broader.

Essex County Council has produced an 'Education Contributions Guidelines Supplement' to its 'Developers Guide to Infrastructure Contributions (2010 Edition)' - both of which were subject to a public consultation exercise closing in February 2010. The 'Education Contributions Guidelines Supplement' (copy attached to response) sets out the detailed requirements for provision of new school sites. In the context of the statements on pages 110 and 111 of the Allocations DPD particular attention is drawn to the procedures and requirements for identification and selection of new school sites as set out in Appendices D, E and F. Within Appendix D particular attention is drawn to the section of the Checklist addressing the question of 'suitable safe access' to the site to emphasise that the design of the school and its relationship to the proposed and existing residential areas should facilitate provision of the best and safest walking routes to schools. The Supplement should be referenced within the Allocations DPD and other relevant documents within the Local Development Framework.

3. provision of Early Years and Childcare facilities is not discussed by the Document. Clear statements should be included that the two potential new primary schools would also need to incorporate Early Years and Childcare facilities. The District's Core Strategy (Policy CLT2) also requires provision of new Early Years and Childcare facilities in Hockley. Although it is not currently envisaged that a site could be identified in the Allocations DPD the requirement could be usefully identified in discussion of Hockley Town Centre (Page 144).

4. the proposed allocation of sites for education use is noted. However, allocation of such sites, and other County Council or public service sites, should not be applied such that it seeks to preserve existing uses on sites in perpetuity, thereby restricting the service provider's ability to expand/relocate the facility to better cater for future needs. Should a public service site cease to be required for its current purpose, its future use should be determined on the merits of the site and its location. Public service sites become surplus because local demand for the service has fallen to uneconomic levels or the facility has been replaced by more suitable facilities elsewhere. The Allocations DPD, and other documents within the Local Development Framework, should acknowledge that there will be circumstances when a better option for the community would be redevelopment of a public service site and re-investment of the proceeds elsewhere as part of a strategic programme of infrastructure replacement.

5. Section 4, Environment, of the Allocations DPD would benefit from an additional section that discusses the Historic Environment of Rochford District. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

6. it should be noted that the County Library Service's medium-term plans include moving the existing library from its existing premises in Great Wakering. This may offer the opportunity for a joint project associated with the proposed enhancement of the Leisure Centre in the village, dependent on detailed location, access and other considerations.

7. the selected sites will generally be associated with greenspace creation. Information on greenspace deficiencies in the area is available in the 'Analysis of Accessible Natural Greenspace Provision for Essex, including Southend-on-Sea and Thurrock Unitary Authorities', which may be found on the Essex Wildlife Trust website.

8. the emphasis of the Document on provision of Sustainable Urban Drainage systems is welcomed, but it should be linked to broader support for the use of associated Green Infrastructure and greenspace creation.

9. the Allocations DPD should acknowledge and note the proportion of the development requirements that will be provided on existing development or brownfield sites.

In respect of the proposed site specific options and environmental designations Essex County Council has the following observations,

A. King Edmund School education site - there is an identified need to provide additional land to accommodate expansion of the school to meet additional demand and to secure improved vehicular access to the school via Brays Lane. Options KES2 and KES3 are preferred by Essex County Council because each presents an opportunity to contribute to both identified needs. Improvements to King Edmund School will need to be linked with adjacent proposals for residential development at the East Ashingdon location. Options EA1 or EA3 are preferred because of the opportunities they present to enable the improvements to the school, which Option EA1 does not. Essex County Council would welcome early discussion with the District Council to ensure the suitability of the detailed site specific requirements for improvement to King Edmund School and residential development at the East Ashingdon location. It should be noted that provision of access from King Edmund School to Brays Lane should be of a standard sufficient to accommodate cars and all associated vehicles serving the school.

B. the proposed environmental designations discussed in Chapter 4 (Environment) are supported. The proposed definition of a boundary for the Coastal Protection Belt is particularly supported as assisting realisation of Policy ENV2 of the Core Strategy and reflecting the currently saved Policy CC1 of the Essex and Southend-on-Sea Replacement Structure Plan (2001). Also, the designation of Cherry Orchard Jubilee Country Park and the Upper Roach Valley is supported. However, the Allocations Document should also include the proposed Stonebridge Park, which is highlighted in the Parklands Vision as a potential sub-regional park centred around Great Wakering.

C. further detailed consideration would be required of the potential employment/ business density of the site and its transport and access requirements of Option E18, Michelins Farm (an option for 8.6 hectares of employment uses, Page 88) should the District Council wish to proceed with allocation of the site. The A1245 is classified as a Main Distributor in the Route Hierarchy and direct access from this class of road is normally prohibited. In addition, the distance on the A1245 between the A127 Fairglen junction and the railway line acts against achievement of the required technical specifications for a new junction. Any changes to the Fairglen junction to provide an access to the site would require comprehensive realignment of the northern western sector and, in addition, the existing roundabout contains a pumping station. Direct access to the A127 and A130 is also prohibited due to the classification of those roads and would need third party land.

D. Assessment of the preferred site options should also include specific consideration of their Historic Environment Character in terms of known and potential features and their contribution to the cultural and historic landscapes of the District. There should be a programme of archaeological evaluation to ensure that the cultural heritage potential of each site is taken into account at an early stage in selection of preferred site options and taken forward in subsequent work on the preferred sites. A summary description of the historic environment characteristics and the requirements for archaeological investigation of the residential, brownfield and new employment locations presented in the Allocations DPD is set out in the Annex to this response. The summaries have implications for choice of sites within the locations at West Hockley, South West Hullbridge, South Canewdon and West Great Wakering (residential) and at South of Great Wakering (employment). Essex County Council would be willing to contribute further detailed evaluation of the historic environment characteristics of each site to inform further stages in preparation of the Allocations DPD.


ANNEX TO ESSEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS DPD, DISCUSSION AND CONSULTATION DOCUMENT (REGULATION 25) FEBRUARY 2010

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

1. North of London Road Rayleigh - the Rochford Historic Environment Character (HEC) project identifies the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to any of the four options suggested, given the sites' adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

2. West of Rochford - the Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HEC Zone 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeological potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered

3. West Hockley - this proposed location lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HEC Zone 33) identified in the Rochford Historic Environment Character project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (WH1-5) suggested for land West of Hockley, although options WH2 or WH5 be would preferred due to previous development, they would entail the least impact on any surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

4. South of Hawkwell - within the Rochford HEC the proposed development south of Hawkwell lies within the HEC Z one26, Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites' historic environment character and potential there would be no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

5. East Ashingdon - the site lies within HEC Zone 13, characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie close by. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (EA1-4) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

6. South West Hullbridge - the HEC Zone 36 for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is close by. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. Whilst there would be no objection to the options outlined for South West Hullbridge, there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

7. South Canewdon - the HEC Zone 12 shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of options SC2, 3 and 4 but little to the south, further away from the historic core, in the area of SC1. There would be no objection to the options outlined for South Canewdon, but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

8. South East Ashingdon - the location lies within HEC Zone 13 characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (SEA1-3) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

9. West Great Wakering - options for West Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. There would be no objection to the options (WGW 1-5), although those incorporating, or part incorporating, former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW4 and 5) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

B. Brownfield Sites

1. Stambridge Mills - the location survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. There would be no objection to the redevelopment of the Stambridge Mills site, but there would be a requirement for a historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

1. West of Rayleigh - the Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

2. Michelins Farm - the Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HEC Zone 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

3. London Southend Airport and Environs - within the Rochford Historic Environment Character report the relevant character zones (HEC Zones 17 and 18) identify the areas at this location that not already developed as having a high potential for the survival of historic environment assets. The area is one which, although partially disturbed through construction of the airport and modern industrial buildings, retains a significant archaeological and more general historic environment potential. In addition to known sites, such as the medieval church of St. Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds in the area of the on- going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WWI and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

4. South of Great Wakering - options for south of Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. Due to quarrying, option E22 (south of Star Lane brickworks) and options E23 and& E24 (south of Poynters Road) have no historic environment implications and option E19 would have the least impact of the remaining options. Otherwise non- quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.