Allocations Submission Document

The Council states that to be Sound the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.

Essex County Council, Alastair Southgate, Transportation Strategy Manager, stated in an email to me on 21 December 2012 "On a local level every strategic development proposal is accompanied by a transport assessment, the scope of which must be agreed with the Highway Authority. This assessment considers the impact the proposed development will have on the highway network and includes industry standard forecasted growth (TEMPRO) to ensure a comprehensive approach that accounts for present traffic conditions (including any new and committed development) and future traffic growth."

It is concluded by me that the Allocations DPD is not legally compliant and not sound as the Highways Authority has evidently not looked strategically at the cumulative effect of traffic impacts on the Rochford Core Strategy through the Local Transport Plan because the information quoted by Mr. Southgate has not been published in the Evidence Base.

The Evidence Base for the Allocations of Sites DPD comes from the Core Strategy and that renders the Allocation of Sites DPD Unsound because it, and the strategic development proposed in the Allocations of Sites DPD, is not supported by sustainable evidence from a cumulative traffic assessment for the District.

The Planning Inspector is asked to reject the Allocations DPD and return this to Council with the requirement to await the formal and reported assessment of the strategic cumulative effects of all developments contemplated by the Core Strategy on Highways infrastructure in Rochford District by ECC in accordance with the LTP 2011.

By the same argument the HAAP is a proposal for strategic development which again according to ECC this must be accompanied by a transport assessment, the scope of which must be agreed with the Highway Authority. This assessment considers the impact the proposed development will have on the highway network and includes industry standard forecasted growth (TEMPRO) to ensure a comprehensive approach that accounts for present traffic conditions (including any new and committed development) and future traffic growth.

For the same reasons the Planning Inspector is asked to reject the HAAP and return this to Council with the requirement to await the formal and reported assessment of the strategic effect of such proposed strategic development on Highways infrastructure in Rochford District by ECC.

Furrther Evidence

According to ECC, Mr. Southgate, "the current Essex Local Transport Plan (LTP) was developed in line with Department for Transport Guidance on LTPs. This LTP represents a significant change from previous LTPs. It is not a 5 year plan that sets out a specific programme, instead it is a long term document that provides the framework within which transport programmes can be developed."

Further according to ECC, Mr. Southgate, The Rochford District Council response to the LTP Consultation was as follows;

"Rochford District Council are generally supportive of the approach taken in the Local Transport Plan, particularly of the five outcomes that the plan must deliver. RDC are also supportive of the approach taken in outlining both Rayleigh and Rochford as areas that currently suffer from peak period congestion and pockets of poor air quality. It should be noted that the location of London Southend Airport is in Rochford District, and the expansion of this airport is likely to have impacts on the highway network."

It is evident, therefore, that RDC is concerned about highways congestion and must evidence by future traffic assessment that the strategic development proposals in the Rochford Core Strategy can be delivered with or without fully funded strategic highway infrastructure improvements. ECC has a similar obligation according to Mr. Southgate.

According to RDC (Minutes of Council 27/11/12);

"Responding to a supplementary Member question relating to the cumulative effect of all the proposed development on the local highways, officers advised that the Highways Authority was looking strategically at the cumulative effect of traffic impacts through the Local Transport Plan; in addition, the emerging community infrastructure levy should facilitate strategic highways improvements."

ECC as Highways Authority has been asked by me to "advise in detail what ECC is currently looking at strategically with regard to the cumulative effect of traffic impacts of the Rochford District Core Strategy through the Local Transport Plan. When and how will ECC consult with the community and when and how will ECC report on findings with a funded strategic action plan for highway improvement. Please confirm that ECC is looking at the effects of all developments contemplated by the Core Strategy."

ECC has declined to directly answer these questions.

But

Essex County Council, Alastair Southgate, Transportation Strategy Manager, agrees in an email to me on 21 December 2012 "On a local level every strategic development proposal is accompanied by a transport assessment, the scope of which must be agreed with the Highway Authority. This assessment considers the impact the proposed development will have on the highway network and includes industry standard forecasted growth (TEMPRO) to ensure a comprehensive approach that accounts for present traffic conditions (including any new and committed development) and future traffic growth."

It is concluded by me that the Allocations Submission Document is not sound as the Highways Authority is evidently not currently looking strategically at the cumulative effect of traffic impacts on the Rochford Core Strategy through the Local Transport Plan as stated by Officers at Council on 27 November 2012.

This is of particular concern because in excess of 1000 (926 in one central part of the District) new dwellings have been approved in planning applications since 13 December 2011 (date of adoption of the Core Strategy by RDC) and still no strategic cumulative assessment has been undertaken.

The Planning Inspector is asked to examine this failure.

The Planning Inspector is asked to reject the Allocations DPD and return this to Council with the requirement to await the formal and reported assessment of the strategic cumulative effects of all developments contemplated by the Core Strategy on Highways infrastructure in Rochford District by ECC in accordance with the LTP 2011.