Rochford Core Strategy Development Plan Document - Schedule of Changes
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Rochford Core Strategy Development Plan Document - Schedule of Changes
Rochford Core Strategy Development Plan Document - Schedule of Changes
Representation ID: 26356
Received: 25/11/2010
Respondent: SE Essex Organic Gardeners
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
I wish to register the following objections and comments regarding the above document:
1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated and are contrary to government policy. There is no sufficient justification for this variance from Government policy.
2. No justification or consultation regarding how the proposed total of 3,800 new homes has been calculated. The council turned down a motion from two members in this regard.
This lack of consultation and inconsistency means the proposals are unsound.
3. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing", and the plan sustainable?
4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.
5. The Core Strategy only takes into account Flood risk identified by the Enviromental Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that the majority of flooding in the area has been caused by the latter and a combination of both.
* Aviva Insurance were not content with the Environmental Agencies evaluation. They conducted their own that included Surface Water and number of claims for an area. This was because flooding was and still is a major concern to their revenue stream so they needed to identify properly all types of flooding risks.
* An additional point that is not captured by either the Environmental Agency or Aviva is there is no need to report flooding occuring regularly in a field; only local people know about this. It is wrong for the Core Strategy only to consider Flovial flood risk.
The Core Strategy is therefore unsound.
6. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the council six months later. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.
I wish to register the following objections and comments regarding the above document:
1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated and are contrary to government policy. There is no sufficient justification for this variance from Government policy.
2. No justification or consultation regarding how the proposed total of 3,800 new homes has been calculated. The council turned down a motion from two members in this regard.
This lack of consultation and inconsistency means the proposals are unsound.
3. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing", and the plan sustainable?
4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.
5. The Core Strategy only takes into account Flood risk identified by the Enviromental Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that the majority of flooding in the area has been caused by the latter and a combination of both.
* Aviva Insurance were not content with the Environmental Agencies evaluation. They conducted their own that included Surface Water and number of claims for an area. This was because flooding was and still is a major concern to their revenue stream so they needed to identify properly all types of flooding risks.
* An additional point that is not captured by either the Environmental Agency or Aviva is there is no need to report flooding occuring regularly in a field; only local people know about this. It is wrong for the Core Strategy only to consider Flovial flood risk.
The Core Strategy is therefore unsound.
6. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the council six months later. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.
