Allocations DPD Discussion and Consultation Document

1.0 INTRODUCTION AND OVERVIEW

1.1 We act on behalf of Bellway Homes Ltd who control some 33.45 ha of land to the
west of Rochford. A Site Boundary Plan is contained at Appendix 1. 'Land to the
West of Rochford' has been identified by Rochford District Council (RDC) as a
location for housing development in the Submission draft of the Core Strategy
Document Plan Document (DPD) (see policy H2 and Appendix H1) and Bellway
support this proposal.

1.2 These representations set out our client's position with respect to the site specific
options for the general locations indentified within the Core Strategy Submission
DPD. Four options for land to the west of Rochford are considered in the Site
Allocations Discussion and Consultation DPD (WR1, WR2, WR3 and WR4) and they
are either wholly, or partially located on our clients site.

1.3 The purpose of the Discussion and Consultation DPD is to provide stakeholders with
the opportunity to consider and comment upon allocation options that have been
put forward for development. We understand that the Consultation and Discussion
DPD will inform the final Site Allocations DPD which is expected to be adopted in
late 2011. RDC first undertook consultation on the Site Allocations DPD in January
2007 when the call for sites process commenced. At this point in time Bellway did
not control the site at Hall Road, but representations were made by the landowner.

The Site

1.4 The Bellway site forms a rectangular area of land abutting the western built up edge
of Rochford. It is currently in agricultural use. It is bounded by Hall Road to the
south. There are a number of large detached residential properties located
immediately to the south of Hall Road. The site is also surrounded by large ditches
along its western, northern and eastern boundaries as well as in part along its
southern boundary. The site is enclosed and contained on its northern boundary by
a tree belt approximately 15 metres in height and a substantial hedgerow
approximately 5 - 6 metres in height comprising oak, ash, maple, hawthorn and
blackthorn species. Ironwell Lane lies to the north of the site, and a footpath
crosses it, north-south, linking Ironwell Lane to Hall Road.

1.5 The site has an open character due to its agricultural (arable) land use. However,
the close proximity to local roads and existing residential areas to the south and
east, as well as its robust boundary vegetation mean that it is well screened in local
views and is well related and connected to the existing urban area.

1.6 The site is located 1000m from Rochford Town Centre and 600m from Rochford
Railway Station. Existing bus services run from the station to Southend and
Rayleigh. Measured from the centre of the site, Southend Airport is located 2km to
the south. The nearest employment centres are in the town centre and the
employment zone adjacent to the airport on Orchard Way.

1.7 The site is generally level and was designated in the Replacement Rochford Local
Plan (2006) as Green Belt countryside (Policy R2). The majority of the site falls
within Flood Zone 1. A small part in the north east corner was designated as flood
Zone 2; analysis by Ardent Consulting of the detailed Topographical Survey has
been demonstrated that the site falls within Flood Zone 1.
Outline Planning Application 10/00234/OUT

1.8 On 12 April 2010 Barton Willmore Planning LLP submitted an outline planning
application to RDC on behalf of Bellway Homes Ltd. The application was validated
on 27 April 2010. The application seeks approval for the following:

"Residential Development (Class C3) of 600 dwellings, associated access and a new primary school on Land north of Hall Road, Rochford. Such development to include the
infrastructure associated with residential development, public open space and new vehicular and pedestrian access routes."

1.9 The purpose of the application is to help RDC meet their strategic housing
requirement. The agreed Planning Performance Agreement (PPA) provides a 10 month timetable through to determination.

1.10 The application has been submitted in outline with all matters reserved except
access. A request for a Screening Opinion was sought from RDC on 29 January
2010 and a response was received on 16 February 2010 stating that an
Environmental Impact Assessment was not required. Appendix 2 contains a list of submitted application documents and plans. In line with emerging Core Strategy Policy H2, Parameters Plan PL-03 (Appendix 3) sets out the key principles of development. They are as follows:

* 600 residential units of a mix of sizes and densities;
* Creation of a high quality open space and landscape feature to the west and
north site to provide a new boundary to the Green Belt;
* Provision of a strategic planting buffer on the western edge to maintain the
character and openness of the Green Belt;
* Provision of two principal site access points from Hall Road;
* An area of at least 1.1 ha for a new primary school including playing fields
in the centre of the development;
* Creation of pedestrian and cycle links to the town centre;
* Provision of sustainable drainage systems;
* Retention and enhancement of Tree Preservation Orders on Hall Road; and
* Retention of views towards key features to enhance the sense of place.

1.11 Bellway has entered into a PPA with Rochford District Council as local planning
authority. The objectives of the PPA are as follows:
1. To establish a shared commitment to an agreed timetable towards the
assessment, consideration and determination of a planning application in due
course.
2. To identify determining issues and agree steps to resolve them wherever
possible.
3. To identify and address the detailed requirements of any planning conditions
and planning obligations which would be necessary should a planning
application be deemed acceptable in principle, subject to such matters.
4. To achieve the determination of an outline planning application relating to
the development of the Land North of Hall Road to provide for 600
residential units (Class C3) associated access and a new primary school. Such development will include the infrastructure associated with residential development, public open space and new vehicular and pedestrian access
routes.

2.0 POLICY CONTEXT, REQUIREMENTS AND CONSIDERATION OF THE SITE

Soundness of the draft Site Allocations DPD

2.1 The emerging DPD will be refined and ultimately tested through Examination
against, inter alia, the advice set out in PPS12. In addition, the Planning Inspectorate has also published 'Local development frameworks examining development plan documents soundness guidance' (July 2008).

2.2 In short, the emerging DPD must be:

* Justified - e.g. whether it complies with the Core Strategy;
* Effective - whether the polices, including site allocations, are deliverable, and
* Consistent with national policy

2.3 It is crucial for the emerging DPD to identify sufficient land to meet strategic
requirements and for such sites to be deliverable. For example, whether necessary
infrastructure has been planned and is certain and whether the delivery parties, in
particular the statutory consultees, are supportive of the DPD. In addition, the
emerging DPD needs to be flexible to respond to changing events and to constraints
on deliverability.

Planning Policy Statement 3

2.4 With respect to deliverability of sites, PPS3 advises at Para 54 that sites must be:
* Available: Is the site available for development in an appropriate timeframe?
* Suitable: Is the site suitable for housing now and would it contribute to the
creation of a sustainable mixed community?
* Achievable: Can the proposed development be achieved in the relevant time frame?

East of England Plan RSS

2.5 The soundness of the Council's proposed spatial strategy and for meeting housing
needs in particular falls to be considered against the polices set out in the East of
England Plan May 2008 (EEP) and of course, national policy, in particular PPS3 and
PPS12. As the Council acknowledge the need to release land from the Green Belt,
PPG2 is also of relevance.

2.6 The East of England Plan identifies a housing requirement for the District of 4,600
(2001 to 2021), at an annualised average (2006 to 2021) of 250. In order to meet
the need for Core Strategies to plan for at least 15 years housing need, RSS advises
that the annualised rate should be rolled forward in advance of the review of RSS.

Core Strategy Submission DPD

2.7 The submission draft confirms the Council's position, and in light of the findings of
the SHLAA, there is insufficient PDL or non Green Belt to meet housing needs
without the need to release Green Belt land (An Alternative Sites Assessment was submitted as part of application 10/00234/OUT). Land to the West of Rochford is identified as providing for 450 dwellings by 2015, and a further 150 dwellings between 2015 - 2021. Bellway submitted representations to the draft Core Strategy DPD in November 2009 and this view was endorsed.

2.8 In considering the soundness of the proposed release of the site, the merit of the
site needs to be tested against the criteria set out at Para 54 and 69 of PPS3.
Namely, is the site available, suitable and achievable (Para 54) and accordance with
Para 69 will the scheme:

* Achieve high quality housing?
* A good mix of dwellings?
* Use land effectively? and
* Be in line with planning for housing objectives?

2.9 In addition, the effect of the release of the land upon the functioning of the Green
Belt should also be tested. PPG2 states that that existing Green Belt boundaries should not be changed unless alterations to the Structure Plan have been approved and necessitate such a revision (Para 2.7). Moreover that when drawing Green Belt boundaries account should be taken of the need for sustainable patterns of
development (Para 2.10) and the need for well defined long-term boundaries to help
ensure the future agricultural, recreational and amenity value of the Green Belt (Para 2.9).

2.10 In considering the soundness of the proposed identification of land to the West of
Rochford, we would suggest that the following matters fall to be considered:

* The housing requirement and availability of land.
* The spatial strategy and centres for growth.
* The infrastructure needs arising.
* Phasing and implementation.

3.0 SITE ALLOCATION OPTIONS

3.1 Page 14 of the Site Allocation DPD identifies 'Land West of Rochford' for 600
dwellings. Bellway support this broad location for development and consider this
aspect compliant with the emerging Core Strategy. The accompanying text on page
14 states that the allocation is required to provide:

* 600 dwellings
* Primary School
* Public Open Space
* Youth and Community Facilities
* Play Space

3.2 Four options for development in this strategic location are considered in the DPD.
Option WR1

3.3 Option WR1 is located north of Hall Road and adjoins the existing residential areas
to the south and east. It is within walking distance of core facilities and services
and the site is large enough to support the required number of dwellings. The site
forms an extension to the urban area.

3.4 The site has the potential to integrate with the existing community. Furthermore,
the infrastructure that could be delivered on site has the potential to benefit the wider community.

3.5 The only criticism is that the site cannot in its current state provide for a defensible
Green Belt boundary. However, if the site boundary were to be moved further west
where there is a defined field boundary that would enable a defensible Green Belt
boundary, Bellway would consider this option to be acceptable.

Option WR2

3.6 Option WR2 is part located in the western half of the Bellway site and part located
further west towards the junction of Hall Road with Orchard Way. This proposal is
dissected from Rochford and does not provide an urban extension. The proposed
development would create an isolated settlement that would not be with walking
distance of core services and facilities. Bellway consider that separation would result in two distinct communities and as a consequence community isolation will occur. This raises issues of sustainability. Furthermore the Green belt boundary would be pushed further west and encroachment into the countryside would be
substantial, resulting in greater environmental impact.

Option WR3

3.7 WR3 is very similar to WR1 except that the site extends further west and does not
extend as far as Ironwell Lane to the north. The site is within walking distance of core services and facilities. We understand that the main aim of this site shape is to create a green buffer around the northern and western perimeter of the site. However, the key states that the shaded green area would provide for open space
as well as built form. Consequently, we consider that a strong defensible Green Belt buffer can be provided through WR1 and there is no need to reduce the site boundary to the north and west through WR3.

Option WR4

3.8 WR4 is similar to WR1 except the site extends further west to the settlement
opposite Cherry Orchard Lane and does not extends as far north as Ironwell Lane.

3.9 Option WR4 constitutes lineated ribbon development and is generally not
encouraged as it would result in dwellings furthest north and west being removed
from the existing community and having to travel a lot further to reach the core
services and facilities.

3.10 Furthermore, development of this site will not provide a strong and defensible
greenbelt boundary, especially on the northern boundary as the shaded area on the
plan does not follow an existing field boundary.

Summary

3.11 Bellway supports the allocation of 600 dwellings to the west of Rochford, but has
reservations about all four options. Options WR2 and WR4 should be discounted
immediately. We do not consider option WR3 to be optimal as it would result in
unnecessary encroachment to the west, which in turn would have a greater impact
on the visual amenity of the Green belt compared to option WR1.

3.12 Option WR1 makes best use of the land and is considered the most sustainable
option. However, in creating a strong defensible Green Belt boundary, Bellway
consider the site should be extended further to the west where there is a defined
field boundary.

4.0 DELIVERIBILTY, SUSTAINABILTY AND SUITABILTY

4.1 PPS3 Para. 69 sets out five criteria to which Council's should have regard in
determining planning applications:

* Achieving high quality housing;
* Ensuring developments achieve a good mix of housing reflecting the
accommodation requirements of specific groups, in particular families and
older people;
* The suitability of the site for housing, including its environmental suitability;
* Using land effectively and efficiently;
* Ensuring the proposed development is in line with planning for housing
objectives, reflecting the need and demand for housing in, and the spatial
vision for, the area and does not undermine wider policy objectives e.g.
addressing housing market renewal issues.

4.2 The above provides a useful mechanism for considering the merits of the proposal.
RDC has identified land to the west of Rochford to be released from the Green Belt
to help meet the strategic housing requirements.

4.3 As discussed in Para 1.8, an outline application for 600 dwellings has been
submitted to RDC and Appendix 2 contains a list of supporting application documents that can be viewed at the Council Offices or through the Councils website. The only application document appended to this representation is the
Design and Access Statement (DAS) (Appendix 4).

Deliverability

4.4 The site is in single control and it is immediately available for development.
Design Quality

4.5 The submitted application is parameters based and the DAS demonstrates how the
parameters will set the principles of development in a manner that enables the
provision of a quality development.

4.6 The development will be consistent with the principles set out in the emerging Core
Strategy and Site Allocations DPD's with all development built to Lifetimes Homes
Standards (where applicable) and to the prevailing Code (Code for Sustainable
Homes) in accordance with emerging Core Streagy polices ENV9 and ENV10.

4.7 The DAS demonstrates how development of the site will be integrated with the
existing urban form and remaining countryside. The scheme will:

* Seek to reflect the character of the residential development to the south,
opposite on Hall Road;
* Provide a landscape buffer and protect the character of Ironwell Lane;
* Provide a new and robust defensible boundary to the Green Belt;
* Provide a site for a new primary school, integrated with the development and
existing community;
* Provide a range of open space for the enjoyment of residents;
* Protect and enhance biodiversity; and
* Maintain the character of the existing footpath.
Housing Needs and Mix

4.8 The Parameters Plan (Appendix 3) provides for 20 ha of developable land for
residential purposes, which would enable the provision of a range of dwelling types.
This equates to an average density of 30 dwellings per hectare. In addition, 35 %
of dwellings will be made available on an affordable basis at a tenure and mix to be
agreed with the Council.

4.9 The scheme will provide a range of unit types and sizes. All dwellings will meet the
criteria set out in the 'Dwelling Space Standards Supplementary Planning Document
- Consultation Draft'. They are also designed to meet Code for Sustainable Homes
Level 4 (Code 3 for open market housing); Secured by Design standards and all
affordable dwellings will meet the Housing Corporations Design and Quality
Standards.

Suitability

4.10 The submitted application is accompanied by a range of technical assessments,
including Flood Risk Assessment, Transport Assessment, Agricultural Assessment,
Arboricultural Impact Assessment, Archaeological Assessment, Ecological Assessment and Landscape and Visual Impact Assessment. They conclude that the site is well located to the existing local services, free of technical constraints and can be effectively integrated with the existing urban form and remaining
countryside. The following provides a brief summary and the full assessments can
be accessed through the Council if required.
Flood and Drainage

4.11 The Flood Risk Assessment states that following an inspection of the Environment
Agency's website, the site is confirmed as being entirely within Flood Risk Zones 1,
2 and 3. It has been demonstrated that Environment Agency's flood maps
definitions of Flood Risk Zones 2 and 3 within the site is inaccurate. The extent of
Flood Risk Zones 2 and 3 has been redefined to a much smaller area to that shown
on the Environment Agency's flood maps. All development proposals are therefore
within Flood Risk Zone 1. The existing site is almost entirely surrounded by
watercourses with no connection to the public sewers. A public foul water sewer
runs along the eastern boundary of the site. A surface water drainage strategy has
been prepared to demonstrate that the development proposals can be successfully
implemented and designed to withstand the impact of a 1:100 year rainfall event
(including climate change), in accordance with PPS25.

4.12 The surface water discharge rate will be limited to existing greenfield is charge
rates with flow matching for the 1:1 year, 1:30 year and 1:100 year storm event
including an allowance of 30% for climate change.

4.13 Anglian Water has been commissioned to undertake a foul water capacity appraisal
due to concerns over the capacity of the downstream pumping station. Anglian
Water has confirmed that the Rochford Sewage Treatment Works presently has
capacity available to accommodate this development's foul water flows.

4.14 The report concludes that:
1) The development proposals are situated wholly within the flood risk zone 1 area;
2) The Development and its occupants are not at an increased risk of flooding;
3) The Development does not increase the risk of flooding elsewhere; and
4) The development can be drained in a sustainable manner;

4.15 The findings of the FRA identifies the opportunity to promote the sustainable re-use
of existing resources and potential to implement an appropriate SUDS strategy with
no detrimental effects to the flood risk status in the area. In this respect, it is recommended that planning permission be granted for this application in terms of flood risk and drainage matters. Should additional or detailed information be required it is anticipated that appropriate planning conditions will be recommended for future consideration.
Transport and Highway Improvements

4.16 The Transport Assessment concludes that the development would be accessed by
means of two new priority T-junctions on Hall Road, with right turn lanes on the
main road (requiring carriageway widening into the site). The eastern access will
also be used to access the proposed primary school.

4.17 A foot/cycleway will be provided along the north side of Hall Road along the site
frontage, and the section of Ironwell Lane to the west of the railway bridge along
the site frontage will also be surfaced and lit to provide a second pedestrian and
cycle route between the development and the town centre.

4.18 The Transport Assessment demonstrates that the site is within walking distance of
local services in Rochford town centre, of bus stops and Rochford railway station,
with direct access to the London-bound platform from Hall Road. The site is
therefore accessible by modes of travel other than the private car and hence is well
suited for residential development in accordance with current national, regional and
local planning policy guidance.

4.19 The Transport Assessment has predicted weekday peak hour trip generation of the
proposed development by each mode of travel. The expected increase in bus and
train passengers is minimal and can be accommodated by existing services. The
impact of the expected vehicle trips generated by the development on the operation
of the local highway network has been considered for assessment years of 2017 and
2022, allowing for projected growth of background traffic. To ensure a robust
assessment, the predicted traffic associated with both the committed developments,
and the proposed developments which are currently the subject of ongoing planning
appeals have also been included.

4.20 The proposed site accesses on Hall Road will have ample capacity to accommodate
the predicted Development Case flows in both weekday peak hours in each of the
two years. The Hall Road/Ashingdon Road/West Street mini roundabout could be
signalised in order to minimise the impact of the development. This will also provide
improved crossing facilities for pedestrians in the form of splitter islands on the
Ashingdon Road and West Street arms. It is proposed to widen the Southend Road
approach to the Bradley Way/South Street mini roundabout to alleviate the impact
of the development and achieve 'nil detriment'.

4.21 The Cherry Orchard Way/Eastwoodbury Lane roundabout is proposed to have
revised lane delineation on the Cherry Orchard Way approach to allow traffic to use
either lane to turn right, as the left turn flows will be reduced further due by the
diversion of Eastwoodbury Lane to accommodate the extension of the airport
runway. This will more than offset the impact from the proposed development. It is
proposed to widen the Eastwoodbury Lane and Nestuda Way approaches to the
roundabout at the junction of these two roads with Comet Way to ensure that nil
detriment as achieved at this junction.
Agriculture

4.22 The Agricultural Assessment demonstrates that, although leading to the loss of a
large Grade 2 arable field, the land can be developed for housing led purposes
without harm to the viability of the remaining farm.

Ecology

4.23 The Ecological Assessment confirms that the site is generally of low intrinsic value
from an ecological perspective, although the hedgerows, individual trees and pond
are considered to be of greater ecological value within the context of the site as a
whole. The hedgerows and trees are to be retained and incorporated into the
Development Proposals, whilst new wildlife habitat is to be created which will
significantly increase the nature conservation value of the Site over its current value.

4.24 The Crouch and Roach Estuaries Site of Special Scientific Interest (SSSI) is
approximately 2.2km to the east of the Site. The SSSI is also part of the Crouch and
Roach Estuaries Special Protection Area / Ramsar site and the Essex Estuaries
Special Areas of Conservation. The Ecology Assessment considered it highly unlikely
that the Development Proposals would impact upon these statutorily designated
sites, which are separated from the site by existing built form.

Archaeology

4.25 The Archaeology Assessment states the majority of the study area has been in
agricultural use for many years and as such the disturbance of any archaeological
remains present is likely to have arisen through ploughing.

4.26 Based on guidance given in PPG 16 (Planning and Archaeology), the developer in
conjunction with Essex County Council is required to carry out further archaeological
investigations prior to development. These are on going.

Arboriculture

4.27 The Arboricultural Impact Assessment concludes that during the construction build
phase adequate provision is made for the protection of existing trees on site. This
will include:
1) Tree protective fencing as shown on the tree protective plan.
2) That those parts of the tree protection zone (TPZ) that cannot be protected
by fencing are protected using ground protection fit for purpose.
3) Design and implementation of new access roads and splay lines to take
account of retained trees. This means minimal or no excavation within tree
protection zones so finished levels need to take account of this.
4) The specific location of services where possible to avoid excavations within
RPAs, or if necessary to be undertaken by supervised hand dig only.

4.28 The recommendations for foundation depth and design should be in accordance with
NHBC 'Building near Trees', Chapter 4.2. It is advised that a copy of the report,
including the site specific method statements and tree protection plan is kept on
site at all times. Furthermore, the Appellants accept a condition will be imposed
stating that there must be arboricultural supervision at critical stages.

Landscape

4.29 The Landscape and Visual Assessment concludes that the site has an open character
due to its existing land use. However the close proximity to local roads and existing
residential areas to the south and east, as well as its robust boundary vegetation
mean that it is well screened in local views and is well related and connected to the
existing urban area.

4.30 Whilst development would inevitably change the existing character of the site, it
would have no material impact on the function of the Green Belt or the rural character of the surrounding landscape and the identity of Rochford. Residential development would include substantial structure planting along its boundaries and throughout a high quality streetscape. Once established, this planting would achieve an effective physical and visual screen. Along the western, northern and southern parts of the site, usable open space is proposed and existing boundary vegetation
would be strengthened and enhanced to reinforce the existing pattern of vegetation
apparent throughout the site and reinforce the contribution of the site to its local
landscape context. It is therefore considered that the proposed development would
be absorbed and assimilated into the surrounding landscape and would have no
material impact on views from surrounding areas including from within the green belt.

4.31 In conclusion, the proposed development is considered to be acceptable in landscape and visual terms and have no material landscape or adverse visual effects on the surrounding landscape including on the function of the Green belt.

Effective and Efficient Use of Land

4.32 The total application area is 33.45 ha. There is a need to provide for a defined
boundary to the Green Belt and a buffer to Ironwell Lane. In addition, the Council
seeks the provision of 1.1ha of land to accommodate a new primary school. As a
result, the developable land amounts to some 24.95 ha. This will provide sufficient
land area to accommodate the proposed 600 dwellings and provide flexibility to
provide a range of dwelling types and meet the Council's adopted standards.

Deliverability, Build-out Rates and Phasing

4.33 The residential element can be delivered within a seven year period, as per the
following programme:

* 2010: Apply and achieve a grant of outline planning permission
* 2011 (reserved matters application approved)
* 2012: Site preparation works and delivery of 50 dwellings
* 2013: Deliver 150 dwellings
* 2014: Deliver 150 dwellings
* 2015: Deliver 100 dwellings
* 2016: Deliver 100 dwellings
* 2017: Deliver 50 dwellings

4.34 In line with policy H2 of the emerging Core Strategy, 450 dwellings will be delivered
by April 2015. This phase will also include the primary school. A further 150
dwellings will be delivered in 2016 and 2017.

5.0 SUMMARY AND OVERVIEW

5.1 Bellway Homes Ltd supports the identification of land to the west of Rochford for
development of 600 units, a new primary school and public open space.

5.2 The site as outlined in Appendix 1 has been the subject of a host of technical
assessments and these accompany the outline planning application submitted on 27
April 2010. The assessments conclude that the site is well located to existing local
services, free of technical constraints and can be effectively integrated with the
existing urban form and remaining countryside.

5.3 Whilst Bellway supports the allocation of 600 dwellings to the west of Rochford,
they raise an objection to aspects of the four options. Options WR2 and WR4
should be discounted immediately as they do not meet spatial policies for urban
extensions. Option WR3 does not make the most efficient use of the site.

5.4 Option WR1 makes best use of the land and is considered the most sustainable
option. However, in creating a strong defensible Green Belt boundary, Bellway
consider the site should be extended further to the west where there is a defined
field boundary.

5.5 Bellway request that they are contacted should any sites be added to the emerging
DPD. The pre submission DPD is expected to be released for consultation in
October / November 2010 and we look forward to providing our views at this stage.