Rochford Core Strategy Development Plan Document - Schedule of Changes

Response on behalf of West Rochford Action Group to
Proposed Changes to Core Strategy Submission Document, October 2010
Public Consultation Period 18 October 2010 to 30 November 2010

Smart Planning represent West Rochford Action Group (WRAG). Their original validly made objections were given the references 16161 & 6163. WRAG were represented by Smart Planning on Day 2 of the Examination on May 12 2010 for which written submissions were produced, and we subsequently made representations, in a letter dated 28 June 2010 to the Council's Audit Trail of activity.

This current response should be read in conjunction with all the responses made to date and with which these comments are consistent.

The first obvious observation is that the proposed changes were made before the successful challenge by CALA Homes (South) Ltd to the Secretary of State's abolition of Regional Spatial Strategy. This matter ought to be dealt with in accordance with the subsequent advice produced by the Planning Inspectorate for Inspectors. The evolution of this position is not however fundamental to WRAG's objections which deal with matters of principle rather than the precise quantum of development.

The proposed changes do not address WRAG's original objections in part or in full and indeed, the proposed changes replicate fundamental errors in the manner in which broad locations for housing have been identified, assessed and chosen.

There remains no cogent analysis of the loss of best and most versatile land. 'Competent advice' has still not been sought on this matter. There is still no cogent analysis of the importance and sensitivity of the cultural heritage, landscape and townscape of the west side of Rochford. There is still no sensitivity analysis in relation to the historic green belt boundary on the west side of Rochford and its analogy to a walled town.

On each of these three key points, the proposed changes still do not undertake any kind of sensitivity analysis or comparative exercise to determine preferred locations for development for example via scoring on a matrix of sustainability indicators. The LPA continue to fail to provide robust and credible evidence as to why west Rochford has been preferred over other locations when in fact it possesses such high environmental qualities that should presume against any such allocation. This remains a fundamental flaw in the Core Strategy Submission Document (CSSD) as proposed to be amended.

As before, WRAG objects to the revised policy H2 - Extensions to residential envelopes and phasing were it indicates 500 houses to be provided in west Rochford (2011-2021) and a further 100 (2021-2026).

Topic Paper 3 - Housing
The LPA has reassessed Housing Need locally, the detail of which is presented in the proposed changes documentation. The new assessment of housing need (Section 3 of the Topic Paper) has failed to distinguish the local origins of that need (even though such data appears to exist). The absence of a distinction between the urban centres of Rayleigh and Rochford will lead to an unsatisfactory displacement of those in affordable housing need from Rayleigh to Rochford as previously set out in WRAG's written submission (Section 5.0) to the Core Strategy Examination. The proposed changes do not relate the origin of housing need to the ability of the subject town/village to accommodate that need in an environmentally sustainable manner.

Section 4 of the Topic Paper refers to 'Environmental and Physical Constraints within Rochford District'. Paragraph 4.4 states that '...the Sustainability Appraisal concludes that the policies proposed in the Core strategy represent the most sustainable approach to distributing the quantum of development...' WRAG has demonstrated, and it is a matter of fact, that the LPA has no basis for coming to this conclusion because they have not, created a robust and credible evidence base and then undertaken a comparative exercise. WRAG's response to the LPA Audit Trail deals with the absence of cogent assessment in detail.

Topic Paper 4 - Revision to the Green Belt Boundary
This topic favour refers to only four purposes of including land within Green Belts, whereas there are five purposes. The purpose missed by the LPA is 'To preserve the setting and character of historic towns'. WRAG has previously set out how the LPA has failed to properly assess the importance of the setting and character of Rochford and particularly on its west side. The omission in Topic Paper 4 of any reference to setting and character of historic towns is symptomatic of their consistent lack of attention to this important point. It demonstrates again, along with WRAG's earlier submissions that the LPA has not considered the setting and character of historic towns as part of a comparative assessment of possible locations for housing. The CSSD is unsound in this respect.

Sustainable (sic.) Appraisal of the Rochford Core Strategy Submission Document: Addendum
WRAG has already made objections to the Original Sustainability Appraisal. In the Addendum, under the heading 'Uncertainties' it states; '...Impacts on biodiversity and cultural heritage, for example will depend on more detailed information and studies at a site level..'. This is incontrovertible evidence that the LPA has not considered 'biodiversity and cultural heritage, for example...' as part of their sustainability appraisal of broad locations for housing development. Indeed WRAG has shown that the LPA has not considered best and most versatile land, conservation and heritage, green belt boundary in relation to historic town character, demographics and to a lesser extent infrastructure.

It is inimical to the proper consideration of the Core Strategy to relegate such considerations to a later stage. Once the broad locations have been decided then it will be too late. The choice of broad locations for development should be informed by the ' ..detailed information and studies at a site level..'. This is what WRAG has been saying from the outset and forms a major part of their objection.

With regard to infrastructure WRAG has previously criticised the generalised nature of the LPA's reliance on infrastructure improvement, and a failure to acknowledge the superior transport infrastructure that exists in Rayleigh. This situation has now worsened in that the LPA placed some reliance on the South Essex Rapid Transport (SERT) scheme to serve places like Rochford. That scheme has now been scrapped albeit very recently (press cutting 5 November 2010 enclosed). This further weakens the LPA's position in relation to necessary transport infrastructure and, in addition to all the other valid criticisms, places the LPA's CSSD in serious jeopardy. Although it was never undertaken in the first place, the scrapping of SERT should be factored into a Sustainability Appraisal of possible sites as part of the robust assessment of broad locations for development. It is obvious that the absence of SERT will add weight to the case for not indicating broad locations at Rochford, but favouring the better served settlement of Rayleigh.

WRAG are confident that if the ' ..detailed information and studies at a site level..' are done now, as they should be, then it will be safely concluded that land west of Rochford is not sequentially preferable to other sites. Other sites will be shown to possess better environmental sustainability characteristics and which should therefore be identified within the Core Strategy in lieu of west Rochford.

The LPA say that '...these uncertainties have been acknowledged in the appraisal matrices where applicable..'. This does not abrogate the LPA from the responsibility of undertaking the necessary detailed studies before they make proposals for broad locations for housing development.

The LPA acknowledge that the proposed changes do not entail any change to the spatial aspects of policies H1, H2 and H3. WRAG object to the absence of such change for reasons previously stated.

Assessment of Changes to Policies H1, H2, H3 and H7 - Assessment of Effects Table
Under SA Objective 9. 'Climate Change and Energy', the LPA make no reference to the effect climate change will have upon the ability of lower grade soils to produce diverse crops and of a sufficiently high yield. Had they done so, they are likely to have concluded that the Best and Most Versatile Land should not be developed before lower grade land. The highest grade land is the most productive and the most capable of continuing to produce diverse, high yielding crops under the environmental effects of climate change. Such land should therefore be protected from development to allow future generations the ability to feed themselves efficiently from locally derived produce and to minimise imports from remote locations including overseas.

Under SA Objective 11. 'Land and Soil' the LPA is factually incorrect to state that 'there are opportunities elsewhere ...to ensure that the best and most versatile agricultural land is protected particularly through the Allocations Development Plan Document.' With respect if the CSSD broad locations for development are adopted, then the ADPD can do very little to change that. The die will already have been cast. Robust and credible evidence should be gathered first, sustainability appraisals should be undertaken, and comparative assessment of possible sites completed. Only then can all stakeholders be reassured that the broad locations have been properly considered. Allocations through the ADPD can only follow on once the proper background work has been completed. The ADPD cannot change the broad locations after the event. That is a ludicrous suggestion.

The LPA has already published a draft ADPD for public consultation. The draft ADPD was produced without ' ..detailed information and studies at a site level..'. This is testimony to the fact that the LPA intend pressing ahead with the allocations without performing any of the detailed studies that WRAG has pointed out are missing and which the LPA themselves are now suggesting are necessary. This process has attained a momentum that it does not deserve. It is incumbent upon all decision makers to take a rational view of proceedings to date, to conclude that the CSSD is not based on a robust and credible evidence base, to stop work on the ADPD, to undertake the detailed studies now, and to not adopt the Core Strategy until such time as it has been proven to be sound.

Response on behalf of West Rochford Action Group to
Proposed Changes to Core Strategy Submission Document, October 2010
Public Consultation Period 18 October 2010 to 30 November 2010

Smart Planning represent West Rochford Action Group (WRAG). Their original validly made objections were given the references 16161 & 6163. WRAG were represented by Smart Planning on Day 2 of the Examination on May 12 2010 for which written submissions were produced, and we subsequently made representations, in a letter dated 28 June 2010 to the Council's Audit Trail of activity.

This current response should be read in conjunction with all the responses made to date and with which these comments are consistent.

The first obvious observation is that the proposed changes were made before the successful challenge by CALA Homes (South) Ltd to the Secretary of State's abolition of Regional Spatial Strategy. This matter ought to be dealt with in accordance with the subsequent advice produced by the Planning Inspectorate for Inspectors. The evolution of this position is not however fundamental to WRAG's objections which deal with matters of principle rather than the precise quantum of development.

The proposed changes do not address WRAG's original objections in part or in full and indeed, the proposed changes replicate fundamental errors in the manner in which broad locations for housing have been identified, assessed and chosen.

There remains no cogent analysis of the loss of best and most versatile land. 'Competent advice' has still not been sought on this matter. There is still no cogent analysis of the importance and sensitivity of the cultural heritage, landscape and townscape of the west side of Rochford. There is still no sensitivity analysis in relation to the historic green belt boundary on the west side of Rochford and its analogy to a walled town.

On each of these three key points, the proposed changes still do not undertake any kind of sensitivity analysis or comparative exercise to determine preferred locations for development for example via scoring on a matrix of sustainability indicators. The LPA continue to fail to provide robust and credible evidence as to why west Rochford has been preferred over other locations when in fact it possesses such high environmental qualities that should presume against any such allocation. This remains a fundamental flaw in the Core Strategy Submission Document (CSSD) as proposed to be amended.

As before, WRAG objects to the revised policy H2 - Extensions to residential envelopes and phasing were it indicates 500 houses to be provided in west Rochford (2011-2021) and a further 100 (2021-2026).

Topic Paper 3 - Housing
The LPA has reassessed Housing Need locally, the detail of which is presented in the proposed changes documentation. The new assessment of housing need (Section 3 of the Topic Paper) has failed to distinguish the local origins of that need (even though such data appears to exist). The absence of a distinction between the urban centres of Rayleigh and Rochford will lead to an unsatisfactory displacement of those in affordable housing need from Rayleigh to Rochford as previously set out in WRAG's written submission (Section 5.0) to the Core Strategy Examination. The proposed changes do not relate the origin of housing need to the ability of the subject town/village to accommodate that need in an environmentally sustainable manner.

Section 4 of the Topic Paper refers to 'Environmental and Physical Constraints within Rochford District'. Paragraph 4.4 states that '...the Sustainability Appraisal concludes that the policies proposed in the Core strategy represent the most sustainable approach to distributing the quantum of development...' WRAG has demonstrated, and it is a matter of fact, that the LPA has no basis for coming to this conclusion because they have not, created a robust and credible evidence base and then undertaken a comparative exercise. WRAG's response to the LPA Audit Trail deals with the absence of cogent assessment in detail.

Topic Paper 4 - Revision to the Green Belt Boundary
This topic favour refers to only four purposes of including land within Green Belts, whereas there are five purposes. The purpose missed by the LPA is 'To preserve the setting and character of historic towns'. WRAG has previously set out how the LPA has failed to properly assess the importance of the setting and character of Rochford and particularly on its west side. The omission in Topic Paper 4 of any reference to setting and character of historic towns is symptomatic of their consistent lack of attention to this important point. It demonstrates again, along with WRAG's earlier submissions that the LPA has not considered the setting and character of historic towns as part of a comparative assessment of possible locations for housing. The CSSD is unsound in this respect.

Sustainable (sic.) Appraisal of the Rochford Core Strategy Submission Document: Addendum
WRAG has already made objections to the Original Sustainability Appraisal. In the Addendum, under the heading 'Uncertainties' it states; '...Impacts on biodiversity and cultural heritage, for example will depend on more detailed information and studies at a site level..'. This is incontrovertible evidence that the LPA has not considered 'biodiversity and cultural heritage, for example...' as part of their sustainability appraisal of broad locations for housing development. Indeed WRAG has shown that the LPA has not considered best and most versatile land, conservation and heritage, green belt boundary in relation to historic town character, demographics and to a lesser extent infrastructure.

It is inimical to the proper consideration of the Core Strategy to relegate such considerations to a later stage. Once the broad locations have been decided then it will be too late. The choice of broad locations for development should be informed by the ' ..detailed information and studies at a site level..'. This is what WRAG has been saying from the outset and forms a major part of their objection.

With regard to infrastructure WRAG has previously criticised the generalised nature of the LPA's reliance on infrastructure improvement, and a failure to acknowledge the superior transport infrastructure that exists in Rayleigh. This situation has now worsened in that the LPA placed some reliance on the South Essex Rapid Transport (SERT) scheme to serve places like Rochford. That scheme has now been scrapped albeit very recently (press cutting 5 November 2010 enclosed). This further weakens the LPA's position in relation to necessary transport infrastructure and, in addition to all the other valid criticisms, places the LPA's CSSD in serious jeopardy. Although it was never undertaken in the first place, the scrapping of SERT should be factored into a Sustainability Appraisal of possible sites as part of the robust assessment of broad locations for development. It is obvious that the absence of SERT will add weight to the case for not indicating broad locations at Rochford, but favouring the better served settlement of Rayleigh.

WRAG are confident that if the ' ..detailed information and studies at a site level..' are done now, as they should be, then it will be safely concluded that land west of Rochford is not sequentially preferable to other sites. Other sites will be shown to possess better environmental sustainability characteristics and which should therefore be identified within the Core Strategy in lieu of west Rochford.

The LPA say that '...these uncertainties have been acknowledged in the appraisal matrices where applicable..'. This does not abrogate the LPA from the responsibility of undertaking the necessary detailed studies before they make proposals for broad locations for housing development.

The LPA acknowledge that the proposed changes do not entail any change to the spatial aspects of policies H1, H2 and H3. WRAG object to the absence of such change for reasons previously stated.

Assessment of Changes to Policies H1, H2, H3 and H7 - Assessment of Effects Table
Under SA Objective 9. 'Climate Change and Energy', the LPA make no reference to the effect climate change will have upon the ability of lower grade soils to produce diverse crops and of a sufficiently high yield. Had they done so, they are likely to have concluded that the Best and Most Versatile Land should not be developed before lower grade land. The highest grade land is the most productive and the most capable of continuing to produce diverse, high yielding crops under the environmental effects of climate change. Such land should therefore be protected from development to allow future generations the ability to feed themselves efficiently from locally derived produce and to minimise imports from remote locations including overseas.

Under SA Objective 11. 'Land and Soil' the LPA is factually incorrect to state that 'there are opportunities elsewhere ...to ensure that the best and most versatile agricultural land is protected particularly through the Allocations Development Plan Document.' With respect if the CSSD broad locations for development are adopted, then the ADPD can do very little to change that. The die will already have been cast. Robust and credible evidence should be gathered first, sustainability appraisals should be undertaken, and comparative assessment of possible sites completed. Only then can all stakeholders be reassured that the broad locations have been properly considered. Allocations through the ADPD can only follow on once the proper background work has been completed. The ADPD cannot change the broad locations after the event. That is a ludicrous suggestion.

The LPA has already published a draft ADPD for public consultation. The draft ADPD was produced without ' ..detailed information and studies at a site level..'. This is testimony to the fact that the LPA intend pressing ahead with the allocations without performing any of the detailed studies that WRAG has pointed out are missing and which the LPA themselves are now suggesting are necessary. This process has attained a momentum that it does not deserve. It is incumbent upon all decision makers to take a rational view of proceedings to date, to conclude that the CSSD is not based on a robust and credible evidence base, to stop work on the ADPD, to undertake the detailed studies now, and to not adopt the Core Strategy until such time as it has been proven to be sound.

Response on behalf of West Rochford Action Group to
Proposed Changes to Core Strategy Submission Document, October 2010
Public Consultation Period 18 October 2010 to 30 November 2010

Smart Planning represent West Rochford Action Group (WRAG). Their original validly made objections were given the references 16161 & 6163. WRAG were represented by Smart Planning on Day 2 of the Examination on May 12 2010 for which written submissions were produced, and we subsequently made representations, in a letter dated 28 June 2010 to the Council's Audit Trail of activity.

This current response should be read in conjunction with all the responses made to date and with which these comments are consistent.

The first obvious observation is that the proposed changes were made before the successful challenge by CALA Homes (South) Ltd to the Secretary of State's abolition of Regional Spatial Strategy. This matter ought to be dealt with in accordance with the subsequent advice produced by the Planning Inspectorate for Inspectors. The evolution of this position is not however fundamental to WRAG's objections which deal with matters of principle rather than the precise quantum of development.

The proposed changes do not address WRAG's original objections in part or in full and indeed, the proposed changes replicate fundamental errors in the manner in which broad locations for housing have been identified, assessed and chosen.

There remains no cogent analysis of the loss of best and most versatile land. 'Competent advice' has still not been sought on this matter. There is still no cogent analysis of the importance and sensitivity of the cultural heritage, landscape and townscape of the west side of Rochford. There is still no sensitivity analysis in relation to the historic green belt boundary on the west side of Rochford and its analogy to a walled town.

On each of these three key points, the proposed changes still do not undertake any kind of sensitivity analysis or comparative exercise to determine preferred locations for development for example via scoring on a matrix of sustainability indicators. The LPA continue to fail to provide robust and credible evidence as to why west Rochford has been preferred over other locations when in fact it possesses such high environmental qualities that should presume against any such allocation. This remains a fundamental flaw in the Core Strategy Submission Document (CSSD) as proposed to be amended.

As before, WRAG objects to the revised policy H2 - Extensions to residential envelopes and phasing were it indicates 500 houses to be provided in west Rochford (2011-2021) and a further 100 (2021-2026).

Topic Paper 3 - Housing
The LPA has reassessed Housing Need locally, the detail of which is presented in the proposed changes documentation. The new assessment of housing need (Section 3 of the Topic Paper) has failed to distinguish the local origins of that need (even though such data appears to exist). The absence of a distinction between the urban centres of Rayleigh and Rochford will lead to an unsatisfactory displacement of those in affordable housing need from Rayleigh to Rochford as previously set out in WRAG's written submission (Section 5.0) to the Core Strategy Examination. The proposed changes do not relate the origin of housing need to the ability of the subject town/village to accommodate that need in an environmentally sustainable manner.

Section 4 of the Topic Paper refers to 'Environmental and Physical Constraints within Rochford District'. Paragraph 4.4 states that '...the Sustainability Appraisal concludes that the policies proposed in the Core strategy represent the most sustainable approach to distributing the quantum of development...' WRAG has demonstrated, and it is a matter of fact, that the LPA has no basis for coming to this conclusion because they have not, created a robust and credible evidence base and then undertaken a comparative exercise. WRAG's response to the LPA Audit Trail deals with the absence of cogent assessment in detail.

Topic Paper 4 - Revision to the Green Belt Boundary
This topic favour refers to only four purposes of including land within Green Belts, whereas there are five purposes. The purpose missed by the LPA is 'To preserve the setting and character of historic towns'. WRAG has previously set out how the LPA has failed to properly assess the importance of the setting and character of Rochford and particularly on its west side. The omission in Topic Paper 4 of any reference to setting and character of historic towns is symptomatic of their consistent lack of attention to this important point. It demonstrates again, along with WRAG's earlier submissions that the LPA has not considered the setting and character of historic towns as part of a comparative assessment of possible locations for housing. The CSSD is unsound in this respect.

Sustainable (sic.) Appraisal of the Rochford Core Strategy Submission Document: Addendum
WRAG has already made objections to the Original Sustainability Appraisal. In the Addendum, under the heading 'Uncertainties' it states; '...Impacts on biodiversity and cultural heritage, for example will depend on more detailed information and studies at a site level..'. This is incontrovertible evidence that the LPA has not considered 'biodiversity and cultural heritage, for example...' as part of their sustainability appraisal of broad locations for housing development. Indeed WRAG has shown that the LPA has not considered best and most versatile land, conservation and heritage, green belt boundary in relation to historic town character, demographics and to a lesser extent infrastructure.

It is inimical to the proper consideration of the Core Strategy to relegate such considerations to a later stage. Once the broad locations have been decided then it will be too late. The choice of broad locations for development should be informed by the ' ..detailed information and studies at a site level..'. This is what WRAG has been saying from the outset and forms a major part of their objection.

With regard to infrastructure WRAG has previously criticised the generalised nature of the LPA's reliance on infrastructure improvement, and a failure to acknowledge the superior transport infrastructure that exists in Rayleigh. This situation has now worsened in that the LPA placed some reliance on the South Essex Rapid Transport (SERT) scheme to serve places like Rochford. That scheme has now been scrapped albeit very recently (press cutting 5 November 2010 enclosed). This further weakens the LPA's position in relation to necessary transport infrastructure and, in addition to all the other valid criticisms, places the LPA's CSSD in serious jeopardy. Although it was never undertaken in the first place, the scrapping of SERT should be factored into a Sustainability Appraisal of possible sites as part of the robust assessment of broad locations for development. It is obvious that the absence of SERT will add weight to the case for not indicating broad locations at Rochford, but favouring the better served settlement of Rayleigh.

WRAG are confident that if the ' ..detailed information and studies at a site level..' are done now, as they should be, then it will be safely concluded that land west of Rochford is not sequentially preferable to other sites. Other sites will be shown to possess better environmental sustainability characteristics and which should therefore be identified within the Core Strategy in lieu of west Rochford.

The LPA say that '...these uncertainties have been acknowledged in the appraisal matrices where applicable..'. This does not abrogate the LPA from the responsibility of undertaking the necessary detailed studies before they make proposals for broad locations for housing development.

The LPA acknowledge that the proposed changes do not entail any change to the spatial aspects of policies H1, H2 and H3. WRAG object to the absence of such change for reasons previously stated.

Assessment of Changes to Policies H1, H2, H3 and H7 - Assessment of Effects Table
Under SA Objective 9. 'Climate Change and Energy', the LPA make no reference to the effect climate change will have upon the ability of lower grade soils to produce diverse crops and of a sufficiently high yield. Had they done so, they are likely to have concluded that the Best and Most Versatile Land should not be developed before lower grade land. The highest grade land is the most productive and the most capable of continuing to produce diverse, high yielding crops under the environmental effects of climate change. Such land should therefore be protected from development to allow future generations the ability to feed themselves efficiently from locally derived produce and to minimise imports from remote locations including overseas.

Under SA Objective 11. 'Land and Soil' the LPA is factually incorrect to state that 'there are opportunities elsewhere ...to ensure that the best and most versatile agricultural land is protected particularly through the Allocations Development Plan Document.' With respect if the CSSD broad locations for development are adopted, then the ADPD can do very little to change that. The die will already have been cast. Robust and credible evidence should be gathered first, sustainability appraisals should be undertaken, and comparative assessment of possible sites completed. Only then can all stakeholders be reassured that the broad locations have been properly considered. Allocations through the ADPD can only follow on once the proper background work has been completed. The ADPD cannot change the broad locations after the event. That is a ludicrous suggestion.

The LPA has already published a draft ADPD for public consultation. The draft ADPD was produced without ' ..detailed information and studies at a site level..'. This is testimony to the fact that the LPA intend pressing ahead with the allocations without performing any of the detailed studies that WRAG has pointed out are missing and which the LPA themselves are now suggesting are necessary. This process has attained a momentum that it does not deserve. It is incumbent upon all decision makers to take a rational view of proceedings to date, to conclude that the CSSD is not based on a robust and credible evidence base, to stop work on the ADPD, to undertake the detailed studies now, and to not adopt the Core Strategy until such time as it has been proven to be sound.

Response on behalf of West Rochford Action Group to
Proposed Changes to Core Strategy Submission Document, October 2010
Public Consultation Period 18 October 2010 to 30 November 2010

Smart Planning represent West Rochford Action Group (WRAG). Their original validly made objections were given the references 16161 & 6163. WRAG were represented by Smart Planning on Day 2 of the Examination on May 12 2010 for which written submissions were produced, and we subsequently made representations, in a letter dated 28 June 2010 to the Council's Audit Trail of activity.

This current response should be read in conjunction with all the responses made to date and with which these comments are consistent.

The first obvious observation is that the proposed changes were made before the successful challenge by CALA Homes (South) Ltd to the Secretary of State's abolition of Regional Spatial Strategy. This matter ought to be dealt with in accordance with the subsequent advice produced by the Planning Inspectorate for Inspectors. The evolution of this position is not however fundamental to WRAG's objections which deal with matters of principle rather than the precise quantum of development.

The proposed changes do not address WRAG's original objections in part or in full and indeed, the proposed changes replicate fundamental errors in the manner in which broad locations for housing have been identified, assessed and chosen.

There remains no cogent analysis of the loss of best and most versatile land. 'Competent advice' has still not been sought on this matter. There is still no cogent analysis of the importance and sensitivity of the cultural heritage, landscape and townscape of the west side of Rochford. There is still no sensitivity analysis in relation to the historic green belt boundary on the west side of Rochford and its analogy to a walled town.

On each of these three key points, the proposed changes still do not undertake any kind of sensitivity analysis or comparative exercise to determine preferred locations for development for example via scoring on a matrix of sustainability indicators. The LPA continue to fail to provide robust and credible evidence as to why west Rochford has been preferred over other locations when in fact it possesses such high environmental qualities that should presume against any such allocation. This remains a fundamental flaw in the Core Strategy Submission Document (CSSD) as proposed to be amended.

As before, WRAG objects to the revised policy H2 - Extensions to residential envelopes and phasing were it indicates 500 houses to be provided in west Rochford (2011-2021) and a further 100 (2021-2026).

Topic Paper 3 - Housing
The LPA has reassessed Housing Need locally, the detail of which is presented in the proposed changes documentation. The new assessment of housing need (Section 3 of the Topic Paper) has failed to distinguish the local origins of that need (even though such data appears to exist). The absence of a distinction between the urban centres of Rayleigh and Rochford will lead to an unsatisfactory displacement of those in affordable housing need from Rayleigh to Rochford as previously set out in WRAG's written submission (Section 5.0) to the Core Strategy Examination. The proposed changes do not relate the origin of housing need to the ability of the subject town/village to accommodate that need in an environmentally sustainable manner.

Section 4 of the Topic Paper refers to 'Environmental and Physical Constraints within Rochford District'. Paragraph 4.4 states that '...the Sustainability Appraisal concludes that the policies proposed in the Core strategy represent the most sustainable approach to distributing the quantum of development...' WRAG has demonstrated, and it is a matter of fact, that the LPA has no basis for coming to this conclusion because they have not, created a robust and credible evidence base and then undertaken a comparative exercise. WRAG's response to the LPA Audit Trail deals with the absence of cogent assessment in detail.

Topic Paper 4 - Revision to the Green Belt Boundary
This topic favour refers to only four purposes of including land within Green Belts, whereas there are five purposes. The purpose missed by the LPA is 'To preserve the setting and character of historic towns'. WRAG has previously set out how the LPA has failed to properly assess the importance of the setting and character of Rochford and particularly on its west side. The omission in Topic Paper 4 of any reference to setting and character of historic towns is symptomatic of their consistent lack of attention to this important point. It demonstrates again, along with WRAG's earlier submissions that the LPA has not considered the setting and character of historic towns as part of a comparative assessment of possible locations for housing. The CSSD is unsound in this respect.

Sustainable (sic.) Appraisal of the Rochford Core Strategy Submission Document: Addendum
WRAG has already made objections to the Original Sustainability Appraisal. In the Addendum, under the heading 'Uncertainties' it states; '...Impacts on biodiversity and cultural heritage, for example will depend on more detailed information and studies at a site level..'. This is incontrovertible evidence that the LPA has not considered 'biodiversity and cultural heritage, for example...' as part of their sustainability appraisal of broad locations for housing development. Indeed WRAG has shown that the LPA has not considered best and most versatile land, conservation and heritage, green belt boundary in relation to historic town character, demographics and to a lesser extent infrastructure.

It is inimical to the proper consideration of the Core Strategy to relegate such considerations to a later stage. Once the broad locations have been decided then it will be too late. The choice of broad locations for development should be informed by the ' ..detailed information and studies at a site level..'. This is what WRAG has been saying from the outset and forms a major part of their objection.

With regard to infrastructure WRAG has previously criticised the generalised nature of the LPA's reliance on infrastructure improvement, and a failure to acknowledge the superior transport infrastructure that exists in Rayleigh. This situation has now worsened in that the LPA placed some reliance on the South Essex Rapid Transport (SERT) scheme to serve places like Rochford. That scheme has now been scrapped albeit very recently (press cutting 5 November 2010 enclosed). This further weakens the LPA's position in relation to necessary transport infrastructure and, in addition to all the other valid criticisms, places the LPA's CSSD in serious jeopardy. Although it was never undertaken in the first place, the scrapping of SERT should be factored into a Sustainability Appraisal of possible sites as part of the robust assessment of broad locations for development. It is obvious that the absence of SERT will add weight to the case for not indicating broad locations at Rochford, but favouring the better served settlement of Rayleigh.

WRAG are confident that if the ' ..detailed information and studies at a site level..' are done now, as they should be, then it will be safely concluded that land west of Rochford is not sequentially preferable to other sites. Other sites will be shown to possess better environmental sustainability characteristics and which should therefore be identified within the Core Strategy in lieu of west Rochford.

The LPA say that '...these uncertainties have been acknowledged in the appraisal matrices where applicable..'. This does not abrogate the LPA from the responsibility of undertaking the necessary detailed studies before they make proposals for broad locations for housing development.

The LPA acknowledge that the proposed changes do not entail any change to the spatial aspects of policies H1, H2 and H3. WRAG object to the absence of such change for reasons previously stated.

Assessment of Changes to Policies H1, H2, H3 and H7 - Assessment of Effects Table
Under SA Objective 9. 'Climate Change and Energy', the LPA make no reference to the effect climate change will have upon the ability of lower grade soils to produce diverse crops and of a sufficiently high yield. Had they done so, they are likely to have concluded that the Best and Most Versatile Land should not be developed before lower grade land. The highest grade land is the most productive and the most capable of continuing to produce diverse, high yielding crops under the environmental effects of climate change. Such land should therefore be protected from development to allow future generations the ability to feed themselves efficiently from locally derived produce and to minimise imports from remote locations including overseas.

Under SA Objective 11. 'Land and Soil' the LPA is factually incorrect to state that 'there are opportunities elsewhere ...to ensure that the best and most versatile agricultural land is protected particularly through the Allocations Development Plan Document.' With respect if the CSSD broad locations for development are adopted, then the ADPD can do very little to change that. The die will already have been cast. Robust and credible evidence should be gathered first, sustainability appraisals should be undertaken, and comparative assessment of possible sites completed. Only then can all stakeholders be reassured that the broad locations have been properly considered. Allocations through the ADPD can only follow on once the proper background work has been completed. The ADPD cannot change the broad locations after the event. That is a ludicrous suggestion.

The LPA has already published a draft ADPD for public consultation. The draft ADPD was produced without ' ..detailed information and studies at a site level..'. This is testimony to the fact that the LPA intend pressing ahead with the allocations without performing any of the detailed studies that WRAG has pointed out are missing and which the LPA themselves are now suggesting are necessary. This process has attained a momentum that it does not deserve. It is incumbent upon all decision makers to take a rational view of proceedings to date, to conclude that the CSSD is not based on a robust and credible evidence base, to stop work on the ADPD, to undertake the detailed studies now, and to not adopt the Core Strategy until such time as it has been proven to be sound.