Allocations Submission Document

Site Context

Green Belt Land
Paragraph 2 refers to the site being agricultural land with very few buildings but nowhere in this document is there any mention of the site being currently designated as Green Belt which is stated within Strategic housing land Availability Assessment 2012.
This would seem to be a somewhat misleading omission as all new development is now controlled by the National Planning Policy Framework which has a very stringent policy on Green Belt development:-
Paragraph 87 states: "inappropriate development is by definition harmful to green belt and should not be approved except in very special circumstances".
The topography of this site is such that the height of the land northwards from Lower Road will mean that the dwellings will create an unacceptable blot on the landscape and it is for this reason that this development must be deemed to be harmful to the green belt and therefore "inappropriate" within the context of the NPPF.
It follows that a case for its approval must rely on a test of "very special circumstances'".
Paragraph 88 states:-"When considering any planning policy, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt "Very special circumstances" will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations."
It is apparent that it will be difficult if not impossible to provide evidence to show that "the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations."
Paragraph 89 states:-"A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are:-
* buildings for agriculture and forestry
* provision of appropriate facilities for outdoor sport......
* the extension or alteration of a building provided it does not result in disproportionate additions over and above the size of the original building.
* the replacement of a building, provided the new building is the same size and not materially larger than the one it replaces.
* limited infilling in villages...........

This development cannot be seen to qualify under any of these exceptions.
Paragraph 90 states:-"Certain other forms of development are also not inappropriate in Green Belt provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land in Green Belt." These are:
* mineral extraction;
* engineering operations;
* local transport infrastructure which can demonstrate a requirement for a Green Belt location;
* the re-use of buildings provided that the buildings are of permanent and substantial construction; and
* development brought forward under a Community Right to Build Order.
This development cannot be seen to qualify under any of these exceptions.

Site Capacity
Paragraph 1 states that densities will be restricted to 30 dwellings per hectare which is relatively low and would be supported by CPRE but we would question whether that level of density could support the cost of any affordable housing.
Concept Statement

Design Standards
We are pleased to see under paragraph 5 that dwellings will be built to lifetime home standards with provision for some wheelchair housing. Similarly we note under paragraph 6 that compliance is required to appropriate Code for appropriate sustainable Homes Standards. We are surprised that Rochford has not stated the minimum Code level requirement? 10% renewables should be stated as being a minimum requirement.
Green Buffer
Paragraph 9 We welcome the introduction of planting in garden areas but cannot understand how the creation of a green buffer/lung in perpetuity between new and existing development can be expected to promote integration?
Youth Community & Leisure Facilities
Paragraph 13 notes that these facilities are to be provide as part of the first phase of this development which we would assess to be circa 290 dwellings. We would question whether there is a real need for additional youth facilities as some already exist in Hullbridge and in any case would doubt whether it is realistic to assume that they could be funded by the first phase of this development

Community Infrastructure
There would not appear to be any mention within Policy SER6 about essential community buildings specifically doctors surgery and school. Has any research been done on this as I am told that exiting doctors surgeries cannot accommodate a substantial increase in patients.
Highways
Paragraph 19 of Policy SER6 states that "alongside the first phase of development local highway capacity and infrastructure improvements including improvements in Watery Lane and Watery Lane, Hullbridge Road,junction should be made."
We note also that service enhancements will be required by which we presume that upgrading of utilities and sewage systems will be needed. The Strategic Housing Land Availability Assessment 2012 identified extent of works as being low to average but it is our understanding that the sewage systems are close to capacity. What further investigations if any have been made?
Paragraph 20 says that "financial contributions towards local highway capacity and infrastructure improvements and public infrastructure improvements and service enhancements will be required".
There is no statement made about the extent of these works and it would seem that Rochford District Council will be relying on a Traffic Impact Assessment to be commissioned by a prospective developer(s). However it seems evident that the cost of these works are likely to be very significant indeed as most of the existing road networks in that area are already at a high capacity.
Flooding
Paragraph 24 says that a drainage strategy should be prepared for this site The Strategic Housing Land Availability Assessment 2012 identified risk of flooding as low for this development. There is no mention of this within Policy SER6 but has any detailed risk assessment been made?