Rochford Core Strategy Development Plan Document - Schedule of Changes

Dear Sir/ Madam,

Proposed changes to the Core Strategy

Thank you for your letter dated 18th October with reference to the proposed changes to the Core Strategy.

Members have noted changes you have made and have no further comment to make except that they fully agree with the reduced number of houses to be built and the length of time in which they must be built.

Please find enclosed our original comments which were submitted in June for your information.
(1) In the introduction at 1.4 there is a statement that the purpose of the Core Strategy is not to identify specific locations but goes on to state a preference later in the document for one particular area "North of London Road" (i.e. between London Road and Rawreth Lane) thus automatically ruling out consideration of a number of suitable alternatives identified in the "call for sites" exercise and is therefore unsound.
(2) p38 Objectives 4 "Prioritise the redevelopment of appropriate brownfield sites for housing to minimise the release of Green Belt land" However two brownfield sites in the centre of Rawreth village which would be suitable alternatives in part to north of London Road and which are favoured by Rawreth Parish Council have not been included. Which we consider to be unsound.
(3) P18 Priority 5 is unsound in that it ignores the fact that public transport is poor or non-existent with little prospect of improvement in the foreseeable future and that walking or cycling are not viable alternatives for the not so young or fit.
(4) P43 Para 4.19 States that development should have the potential to create a defensible Green Belt boundary.
The proposal for 550 houses on land "north of London Road" is unsound in that it creates a boundary that is difficult to defend until the A1245 road is reached.
A better alternative would be to locate some of these on proposed brownfield sites in Rawreth village. The remainder could be located on smaller sites in Rayleigh which have been ruled out by the preference for this larger area.
This would meet the guidance in PPG2 "to check the unrestricted sprawl of large built up areas" preventing the eventual coalescence of Rayleigh, Rawreth and Shotgate.
(5) P50 Policy H7 Gypsy and traveller accommodation
Where particular traveller sits have been identified as being undesirable on planning grounds (e.g. highway safety) the temptation to ignore the results of legal process and designate such sites as appropriate simply for administration convenience must be resisted. Therefore policy H7 is considered to be unsound and must be more prescriptive particularly on highway safety grounds.
(6) P65 Para 6.3 The majority of the District's 12763 hectares of Green Belt is located in the east of the District. The preference for "north of London Road" would see the release of a disproportionate amount of green belt land in the west of the District and therefore this statement is considered to be unsound.
(7) P80 Policy ENV4 For SUDS to be sustainable it is necessary for the Environment Agency and landowners to maintain ditches and watercourses in a satisfactory manner. This unfortunately is not the case at the moment. Without this there will undoubtedly be future flooding problems. This policy is considered to be unsound in its present form and should be made far more robust in conjunction with ENV3.
(8) P89 Policy CLT1 It has been estimated that approximately £1 billion will be needed to make up the shortfall in infrastructure provision.
It is unrealistic to expect this to be made up by "standard charges" (as much as £300,000 per dwelling across the total number of dwellings proposed)
On this basis this policy is unsound unless it includes a requirement that these plans are unsustainable without considerable Government funding.
(9) P93 Policy CLT5 The second paragraph needs to be more specific and robust in particular forming a barrier between any possible new development and the A1245 road preventing any further westward sprawl and coalescence of Rayleigh and Rawreth. (see (4) above)
(10) P96 Policy CLT9 The second paragraph should be made more specific, in particular seeking the provision of a swimming pool at the Rayleigh Leisure Centre by means of developer contributions.
(11) P106 Policy T3 Encouraging alternatives to the use of the private car must not be used as an excuse by developers to lower standards of parking and vehicle storage. This policy is considered to be unsound unless it includes a statement to this effect and is made more prescriptive.

In addition the Town Council is particularly supportive of the following:-
(a) P65 Para 6.1 Strongly support this
(b) P104 Policy T1 Whilst generally supporting this it is felt that safeguards need to be built in to this policy to ensure that S106 finance is actually used for the infrastructure improvements for which it is intended, particularly in the light of recent revelations of the loss of such monies.
(c) P110 Policy T8 Parking standards We strongly support what is a commonsense approach to the provision of minimum parking standards to residential developments.
(d) P94 Policy CLT6 Strongly support this.