Full text:
Re: Allocations Submission Document. Site Allocations Ref' SER6 (6a and 6b)
With reference to the Laws empowering the Community to use the Freedom of Information Act, The Localism Act (2011) and the Consultation procedures laid down in the Core Strategy and Site Allocations document.
Some of these policies state: The Community have the Right to Challenge the Plans and Strategies, Neighbourhood Planning and 'consultation' and the National Planning Policy Framework policies.
In response to your last communication dated 26 November 2013, Proposed Main Modifications to the Allocations Submission Document (April 2013), we refer to the first two bullet points making reference to:
(A) 'Viability Testing for Brownfield land development on all proposed development land', specifically Policy SER6 and
(B) 'Removing the 5% cap for residential extensions (Policy SER1-9).
We respectfully ask the Planning Department of the Rochford District Council and all Members of Parliament, County/District/Town and Parish Councillors to join the 98.5% residents of Hullbridge, to help reconsider this Development Submission Document by the District Council, specifically with regard to the proposed development of more than 500 homes on 23.4 hectares of land (SER6) in Hullbridge, Essex.
Homes are proposed on unsuitable agricultural (green belt) land, susceptible to flood, insufficient existing infrastructure, including problems experienced with Watery Lane, congestion, and inadequate accessibility, in spite of overwhelming evidence submitted by the writer, as stated in submissions dated 25-01-13 (85 issues), 'A Plea For Withdrawal' dated 16-08-13 (72 issues) and a speech at the Final Hearing chaired by the Government Planning Inspector, Mr. David Smith, on 4-09-13 (48 issues) to whom I also provided a copy of my speech.
Although the word 'Consultation' is well stated in the Core Strategy and the Allocations Submission Document, regretfully there was no 'Consultation/response' to the fears and inadequacies set out in the writer's submissions.
We assert our 'Rights' under the regulations set out in the Freedom of Information Act and the Localism Act (2011) to demand a comprehensive response to the issues raised and for your 'justification' to over-ride the objections made. We want a 'Consultative' response for our Residents that you have listened to the community and not ignored.
Were the so-called 'Submissions' just a matter of ritual to comply with Government policies? Comments made in the 'media' by some Councillors that the documents had been signed, sealed and delivered in 2011, prior to any Inspector deliberation and any submissions made by the Communities, and we consider democracy has suffered as a consequence.
I had a meeting with the Head of Planning on the 29th September and his answer to my question, among 31 other questions, of why no mention made on the Localism Act, he considered that this Act had no relevance to the Core Strategy.
The 98.5% Community requested the Hullbridge Parish Council for their support (late submissions made by the Parish Council stated the same objectives in principle) but we were met with a derogatory remark, after legal advice from the District Council) in effect labelling the 98.5% support as a 'pressure Group' and the near 100% support was irrelevant. In normal circumstances this comment would be ignored, but the remark was reiterated in the Parish News Bulletin, and has not met with any applause. Indeed this brings into question the Guiding Principles that the Town and Parish Councils are supposed to observe. Needless to say that comments of this sort alienating the community, does not provide an incentive to recruit future Councillors.
Many in the community state that the whole Core Strategy and Allocations Submission Documents were set to satisfy the Political flavour and the supposed 'Consultation' is just to satisfy the 'procedure', noting that a few 'minor' amendments have been made, but no amendments made to take heed of our serious issues set out in our submissions.
A - Brownfield Sites.
I put forward objections to this issue, that there are several sites allocated which seem to disregard infringement of green belt that the 'Brownfield' sites were not properly assessed and justified in the rejections, and the 'evidence base' was faulty.
Similarly, many 'Greenfield' sites have not been properly assessed or justified for inclusion for development, contrary to the many clauses in the Core Strategy/ASD that green belt should be used as a last resort, but only after the proper procedures are adhered to in conversion from Greenfield to Brownfield land and we are not satisfied or confident that RDC have fulfilled their obligation to explore every avenue to find suitable for development land.
Buffer Strip and Cohesion A 'green' dividing strip between the old and new part of the Village can hardly foster greater Community cohesion, but will be a divisive form of demarcation.
Green belt land use - Core Strategy document Pages 34, 38 & 44)
The objectives have not been observed. After the said use, the policies suggest that the green belt will be 'strengthened in safeguards, the same policy existed before the encroachment of this green belt land but District Council were able to find a way of over-riding that policy, we are convinced that the Green belt will not be safeguarded in the future.
The core strategy refers to Short and Long term policies stipulating the 'openness and character of the green belt continues to be protected and only small areas released for development', and is at odds with stated policies. The Green belt surrounding Hullbridge will be eroded by 'development by stealth' by the Council, Hullbridge will become part of Battlesbridge/ Rawreth/ Rayleigh, losing its identity as a village. We understand that a population above 8,000 becomes a town.
Boundary line - Part of the land situated in site SER6 (b) is beyond the Hullbridge boundary line and within the Rawreth boundary. The Head of planning stated at a meeting with the writer, when asked why the policies stated in the Core Strategy were being contravened, he answered that the Council did not recognise any boundary lines except the 'district boundary line'. The Council's policy seeks to prioritise the protection of green belt land so this evidence contravenes the Council's own policy of avoiding coalescence of settlements. We are surprised that there was no mention of this in the Planning Inspector's Examination of the Rochford Allocations Submissions Document dated 17th October (EXA175).
B - Removal of 5% development 'cap'.
The removal of the '5% cap' will make Hullbridge much worse with a greater development density than first predicted and the 'Table', below, will emphasise the disastrous implication on this proposed development, making a proper consultation to discuss your assessment and justification for this development most urgent.
The ASD proposes 500 dwellings for SER6 (6a & 6b) but was to be 'capped' at a 5%, increasing the number to 525. Elsewhere, the document suggests the Developer may consider the density to be 30 to 50 dwellings per hectare, this will provide between 600 and 1000 dwellings. An assessment becomes self-explanatory in this respect, certain conflicts exist as considered against a background of an existing population of 6586, representing an increase of only 2.5% on the 2001 census:
Site Capacity We hope the Planning Inspector has taken these anomalies, set out in the following table, into consideration.
Site SER6(6a & 6b)
No. Min Homes for development - 500 (no. homes exist 3100)
On Ha - 19.64
Pop x 4 - 2000
Increase Homes - 16%
Increase Pop - 30%
Total Population - 8586 (total population exist 6586)
Probable Traffic increase - 5300 (4300 present)
No. Max. Homes for development - 525
On Ha - 19.64
Pop x 4 - 2100
Increase Homes - 17%
Increase Pop - 31%
Total Population - 8686
Probable Traffic increase - 5300
30 Homes per HA (Alloc Doc) - 586
On Ha - 19.64
Pop x 4 - 2356
Increase Homes - 19%
Increase Pop - 35%
Total Population - 8942
Probable Traffic increase - 5400
50 Homease per HA (Alloc Doc) - 982
On Ha - 19.64
Pop x 4 - 3928
Increase Homes - 31%
Increase Pop - 59%
Total Population - 10514
Probable Traffic increase - 6000
12 Sites (inclusive) (Site Alloc) - 2919
On Ha - 149.19
Pop x 4 - 11676
Increase Homes - 94%
Increase Pop - 177%
Total Population - 18262
Probable Traffic increase - 10000
12 Sites (inclusive) (Site Alloc) - 4035
On Ha - 149.19
Pop x 4 - 16140
Increase Homes - 130%
Increase Pop - 245%
Total Population - 22726
Probable Traffic increase - 11500
12 Sites (inclusive) (30 Homes/ha) - 4475
On Ha - 149.19
Pop x 4 - 17900
Increase Homes - 144%
Increase Pop - 271%
Total Population - 24486
Probable Traffic increase - 12000
12 Sites (inclusive) (50 Homes/ha) - 7459
On Ha - 149.19
Pop x 4 - 29836
Increase Homes - 240%
Increase Pop - 453%
Total Population - 36422
Probable Traffic increase - 19000
Add 'windfall sites' 30/ha - 4796
On Ha - 159.89
Pop x 4 - 19184
Increase Homes - 154%
Increase Pop - 291%
Total Population - 25770
Probable Traffic increase - 13000
Add 'windfall sites' 50/ha - 7994
On Ha - 159.89
Pop x 4 - 31976
Increase Homes - 257%
Increase Pop - 485%
Total Population - 38562
Probable Traffic increase - 21000
We are concerned that the above 'table' equates to an unacceptable increase in homes and population in Hullbridge with a corresponding knock-on effect on 'traffic', congestions and above all on infrastructure (particularly to the inadequacy of existing drainage) and Watery Lane, and no consideration given to the increased traffic having a detrimental affect on and causing air pollution.
We also understand that a recent bore-hole on the site proved the water table to be 150mm from the surface of the ground on a dry day.
We doubt the RDC are being honest with this community about the total potential numbers of homes proposed. We remain sceptical by the lack of 'Consultation' as explained before, we believe the development was designed to satisfy Government requirements and 205 issues in the submissions do not matter or have any influence on the final deliberation. We note that the inspector did not mention Hullbridge in his notes, referenced EXA 175. We hope the final decision is a 'withdrawal or at least a delay to allow further consultation. There is a danger that the Community will not respond to any Public Consultation in future because of complete disregard of all the legislation which is supposed to be designed to protect the Community.
Vehicular Access points to the proposed development
The Watery Lane/Hullbridge Road junction & Malyons Lane are indicated as access points to the proposed development.
The Writer produced a Road/Street Survey indicating the potential risk to 28 Streets which indicates 1521 existing properties would be directly affected (about 3500 residents). No risk analysis has been produced showing the volume of traffic using Hullbridge Road/ Watery Lane and Ferry Road. The pressure and congestion will be obvious, refer to our Traffic Survey below. Other access points will become apparent when development begins, and are very conveniently identified by gates erected at various points (identified in the Road/Street map attached). The number of existing residents affected will be 3500 (53%).
LDF Allocations Submission Document Page 60. Cl 3.177 & 3.178 Transport Impact Assessment stipulates that the developer should make a financial contribution towards the improvements to the highway network and the infrastructure and do the works prior to commencement. No assessments have been provided for examination to deal with the existing infrastructure as indicated on our attached Street Survey mentioned above. We doubt that this site will be economically viable for any prospective Developer unless there is external funding arrangements to satisfy the developers Business Plans.
Congestion- We have traffic congestion during the hours of 6.00 - 9.00 am and 15.30 -19.00 pm.
Our recent 'traffic survey' indicated an average of 1128 vehicles leaving or passing through the village per hour (675 using our village from Rochford and other close villages), to access the Chelmsford A130 road through Watery Lane or to access the link road via Rawreth to the A127/A130/A1245. Some 40% of vehicles using Watery Lane/Hullbridge Road treat Watery Lane as a thoroughfare to reach the A130 (Chelmsford Road) via Battlesbridge.
At times of flood and road works in Watery Lane (frequent), this causes 'gridlock' to the whole local traffic system in and around Hullbridge. The impact of future increased traffic as mentioned above will be immense.
Health Care Impact Assessment. A meeting with our Doctors at the Riverside Clinic in Hullbridge revealed that they had not been consulted about the proposed development. In the absence of an assessment by the Council, our own assessment for the future is showing a detrimental outlook in terms of numbers of Doctors/nurses in relation to the increased number of residents/patients and the space required for accommodation. The writer was the first to raise the subject with them. Perhaps they are not considered a priority for consideration.
Generally
We state that insufficient time was set aside or planned at the outset for community consultation, and for this reason we ask that the proposed development be withdrawn or to at least delay planning approval until the community are satisfied by the ensuing consultation this subject so rightly deserves, particularly to satisfy the clauses in the Localism Act (2011), and indeed the strong feelings expressed by 98.5% of this community, democracy being well served.
Affordable Housing. Refer to policy 4.15 page 47.
In view of the difficult building development situation due to flooding, problems with 'Watery Lane', environmental issues, preparatory and enabling works (prior to the required infrastructure works). It is difficult to believe the evaluation of 80% of the market rent or sale price will be achievable, given that there is great doubt that the properties would be adequately insurable, furthermore where is the evidence that these evaluations were updated since the time of writing.
We understand that there was the absence of a feasibility study, risk assessments or analysis of all the issues mentioned above, how can we be assured that the overall plan will be sound, along with a comparison schedule of possible environmental changes that have been predicted for the foreseeable future.
Various policies stated in the Localism Act 2011 may have been breached.
The recent Environment report on the Tide Surge serves as a wake up call to the coastal areas of Essex which includes Hullbridge, with the RDC, Highways and water authorities insisting there ar no problems affecting the 'Sites' or watery lane.
Investment
We are not convinced that this proposed Domestic development will attract 'investment' except for the development itself over a period of 12 years without a guarantee that the residents will be given first preference for employment.
We are sceptical that this development is for the indigenous population but is 'ear marked' for the 'economic migrants' and London Overspill population.
Development costs.
A feasibility study by Brian Marsden-Carleton suggests an average cost for the development of 500 dwellings distributed as 175 Social Housing (35%), 292 2-storey housing and 33 bungalows may be £461,851.00 with a total cost of £231m and infrastructure costs being £16.4m.
However, the Core strategy document suggests between 30 to 50 units per hectare which equates to 603 or 1005 units.
Therefore 603 units will cost £278.5m or 1005 units will cost £464.1m, with reciprocal increases on further development and infrastructure works being given planning permission.
However, considering the potential development of all the sites mentioned in the Site Allocation Document (Hullbridge) the total area ripe for development is 153 hectares. Using the same units per hectare mentioned above this will equate to 4590 or 7650 dwelling units.
If the Council chose to have all the sites delivered within a 12 year 'disruptive' period, we would experience a huge population increase to some 30,600 (larger than Rayleigh).
Please take into account the reduced space allocation to the greater volume of units per Ha, which may also be detrimental for sales or rent and certainly create development congestion.
General Conclusion
We cannot find a statement that there will not be another review to build new homes before 2031.
The 'submissions' attracted significant opposition at the consultation stages against the development, supported by 98.5% of the village (population 6586). Serious shortcomings were identified at the meeting held on 19 June 2013 which attracted further objections from the local residents. The plan is seeking to deal with an extremely complicated situation but fails to deal properly and comprehensively with circumstances which are likely to arise, and the number and extent of the main modifications required will be significant enough to have the plan wholly withdrawn.
We submit, in view of 'evidence base', the review of housing and employment growth options, further transport modelling, sustainability appraisals, flood, congestion, infrastructure, population and traffic etc. will need a completely new implementation programme and at least two rounds of public consultation, We consider that the changes required are so significant that you will be unable to deal with the matter through modifications, and that the best course of action is for the Council to withdraw or delay the proposed development.
Quite recently Nick Boles the Planning Minister advocated that communities should be allowed to make their own assessments on the developments in their areas, we welcome this approach along with changes to the way Councils treat their communities. We are heartened to read Mr. Nick Boles' article in the Times in respect of 'Villagers promised more say over developments' and we are ready to heed this call immediately, commencing with this proposed development, and if this becomes a forerunner for the future, we will be delighted to help.
We are currently promoting the setting up of a Non-Political Hullbridge Community Councillors Forum, with individual responsibility, for democracy to be well served, and look forward to your support for 98.5% residents of Hullbridge.
If this proposed development is approved you will have lost all credibility or the ability to consult with the community in the future and bring into disrepute all the recent legislation which was supposed to serve the community such as The Localism Act (2011), Guidance towards the Soundness & Legal Compliance of the Plans and Legislation Guidance in the National Planning Framework.
Regretfully, a number of Councillors have made public utterances, extended to the media, that 'this is a done deal', and that they had signed off the Core Strategy in its entirety in advance of the public consultation & examination, which is objectionable and contrary to the District Council's Constitution and the Guiding Principles of Town and Parish Councils. Bringing democracy into disrepute and these remarks by the Councillors' imply there is no need for the Community to be consulted, rendering the hearing by the Inspector unnecessary.
The Hullbridge community deserve better treatment than this and many of the community are now convinced that the 'political line' observance takes precedence over their views.
Perhaps the Council can promote an educational training programme to enlist a culture of true democracy.
Had these issues not been genuine and serious, we would not have had such a magnificent 98.5% response to justify this petition.
Thanking you,
in anticipation for a favourable response,
