Issues and Options Document

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | ROCHFORD PARK EAST, COOMBES FARM

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, to Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.

Please note that details relating to the land at Rochford Park East also formed part of Rochford District Council's 'Call for Sites consultation 2015'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land at Rochford Park East, Coombes Farm
The land at Rochford Park East is identified within the submitted plan (Appendix 1), but for clarity is 20.45ha in size and lies approximately 500m to the east of Rochford town centre and 900m east of Rochford mainline Railway Station. The site is bound by Stambridge Road and existing residential properties fronting Stambridge Road to the north, Stambridge Mills and Mill Lane to the east and the
River Road to the south. To the west, the site boundary abuts the existing urban area and includes allotment gardens that are accessed off Stambridge Road and Rocheway. Residential properties are located along the north eastern corner of the site. The site currently comprises agricultural land with a single Public Right of Way; other informal routes around the site are also used by local walkers. The public safety Zone associated with London Southend Airport lies outside the boundary of the site.
The allocated Stambridge Mills site is located to the South East of the Site, for which an application for redevelopment to provide 96 units was submitted in 2011 (11/00494/FUL). However, due to reliance on 3rd party land for mitigation measures the site has been considered undeliverable. This application was withdrawn.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing through the Local Plan process. Development of the site would provide an obvious and most suitable extension to the development boundary as the site is defined by strong defensible
boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. For this reason development of this site would provide a logical 'rounding off' of the existing urban area. Given the visual (and actual) separation for the wider countryside, the site also has very limited function in safeguarding the countryside from encroachment.

Development of the land at Rochford Park East would also promote growth within Rochford and the wider districts and will help support local employment which would otherwise result in the closure of local businesses and increasing the amount of derelict land elsewhere.
Further benefits of the development of the land at Rochford Park East are explained in more detail throughout these representations.

b. History
The Council will be aware of the history associated with the Site following the refusal of a planning application for 326 residential dwellings in November 2009, the subsequent appeal in May 2010 and a subsequent revised application in March 2012.
Since the determination of the previous schemes on the site, the introduction of the National Planning Policy Framework (NPPF) in 2012 has created an environment in which a proactive and positive approach to planning is essential. At the heart of the NPPF is the presumption in favour of sustainable development' which seeks to ensure the delivery of developments in support of economic growth and provision of the social needs within a community. By ensuring a high quality design, development on this site could wholly accord with the objectives within the NPPF and contribute towards delivering housing required within the District.
c. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - 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 where it is consistent with achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.
Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];

Be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area [17];
 Seek to secure high quality design and good standard of amenity for all existing and future occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]

In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable development; and
 The Duty to Co-operate.

d. Emerging Local Plan Issues and Options Document

The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.

As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.

As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Rochford Park East, presents an opportunity for RDC to contribute positively to the South Essex housing need.
The key 'Core Purpose and Aims' of ASELA, pertinent to Rochford Park East are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.
e. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.
The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.
On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the sub-regional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However, projected completion rates indicate that a 20% buffer plus shortfall is unlikely to be met, although the shortfall is considered by RDC to be relatively minor at an estimated 166 dwellings over the five years.
When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore, when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.
Supporting Economic Growth and Employment
The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.
Protecting the Green Belt
The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.

The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development, 'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.
RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.
Delivering Infrastructure
In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focuses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London Southend Airport.
f. Ensuring the Delivery of Sustainable Development
Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land at Rochford Park East, Coombs Farm is currently located within the Green Belt, promotion of the site for residential development would provide significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location to London Southend Airport.
Rochford Park East, Coombes Farm
The land at Rochford Park East would be suitable for the sensitive expansion of Rochford, which would also help to improve associated infrastructure. It is also suggested that new landscaped parks and open spaces, extended allotments and a new pedestrian link with the town centre could be provided as part of the development, providing added benefits to both the local and wider area.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for Rochford Park East has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix 3).
Social
Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.
As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required housing need.
Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need
Economic
Rochford Park East is located adjacent to the town of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its suitability for residential development.
The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location less than 10min walk from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating 700 jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53 jobs are created in the wider economy.

Environmental
At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site.
Furthermore, the site is approximately 12minute walk from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. New pedestrian access from the allocated site of Stambridge Mills to the town centre would seek to incentivise this form of transport, therefore reducing the need to use private cars for short distances to and from the town.
Development of this site would also provide an opportunity to enhance the riverside walk linking the site between the town centre, Stambridge Mill and the River Roach estuary. By re-establishing this historic pedestrian link the proposal will help to enhance and benefit the associated ecology whilst also encouraging a healthy and more active lifestyle.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land at Rochford Park East meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the NPPF:
Table 1 Rochford Park East 1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. As such, no further development beyond the Site boundary would be possible; and
- The development of this site would provide a logical 'rounding off' of the existing urban area. 2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the west of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
- The location of Stambridge Mills is also significant in this context as the site is clearly well placed between this redevelopment and the existing urban area, therefore containing development on the site and providing a link from Stambridge Mills to the town. 3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, Stambridge Mills and the existing urban edge of Rochford; and
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006. 4. to preserve the setting and special character of historic towns
- Rochford Park East is not in or adjacent to any Conservation Areas and has no listed buildings or other heritage assets in proximity;
- The Inspector confirmed within the appeal decision that 'the character an Appearance of Rochford Conservation Area which encompasses the nearby town would be preserved' (Paragraph 110);
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.
Sustainable Development Scorecard Analysis
Taking the above information into account, the scorecard analysis of the proposed site at Rochford Park East has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 81% and a Parity score of 92%.
The Scorecard analysis shows that the proposed site scores very well for the elements on the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and flood risk alleviation potential.
Proposed development of the site also scores well on both the economic and social aspects, due to the site's proximity to Rochford Town Centre, local employment and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a sustainable location in which to accommodate additional growth due to the presence of a train station with frequent connections to central London and the town's significant range of services.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.
g. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land at Rochford Park East, Coombes Farm will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable, achievable and deliverable sites are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).
For the reasons given in Table 1, the land at Rochford Park East, Coombes Farm should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a logical 'rounding off' of the existing urban area and given the visual (and actual) separation for the wider countryside, the site has very limited function in safeguarding the countryside from encroachment. For these reasons, and the reasons set out above, it is considered that the proposed development site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | ROCHFORD PARK EAST, COOMBES FARM

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, to Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.

Please note that details relating to the land at Rochford Park East also formed part of Rochford District Council's 'Call for Sites consultation 2015'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land at Rochford Park East, Coombes Farm
The land at Rochford Park East is identified within the submitted plan (Appendix 1), but for clarity is 20.45ha in size and lies approximately 500m to the east of Rochford town centre and 900m east of Rochford mainline Railway Station. The site is bound by Stambridge Road and existing residential properties fronting Stambridge Road to the north, Stambridge Mills and Mill Lane to the east and the
River Road to the south. To the west, the site boundary abuts the existing urban area and includes allotment gardens that are accessed off Stambridge Road and Rocheway. Residential properties are located along the north eastern corner of the site. The site currently comprises agricultural land with a single Public Right of Way; other informal routes around the site are also used by local walkers. The public safety Zone associated with London Southend Airport lies outside the boundary of the site.
The allocated Stambridge Mills site is located to the South East of the Site, for which an application for redevelopment to provide 96 units was submitted in 2011 (11/00494/FUL). However, due to reliance on 3rd party land for mitigation measures the site has been considered undeliverable. This application was withdrawn.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing through the Local Plan process. Development of the site would provide an obvious and most suitable extension to the development boundary as the site is defined by strong defensible
boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. For this reason development of this site would provide a logical 'rounding off' of the existing urban area. Given the visual (and actual) separation for the wider countryside, the site also has very limited function in safeguarding the countryside from encroachment.

Development of the land at Rochford Park East would also promote growth within Rochford and the wider districts and will help support local employment which would otherwise result in the closure of local businesses and increasing the amount of derelict land elsewhere.
Further benefits of the development of the land at Rochford Park East are explained in more detail throughout these representations.

b. History
The Council will be aware of the history associated with the Site following the refusal of a planning application for 326 residential dwellings in November 2009, the subsequent appeal in May 2010 and a subsequent revised application in March 2012.
Since the determination of the previous schemes on the site, the introduction of the National Planning Policy Framework (NPPF) in 2012 has created an environment in which a proactive and positive approach to planning is essential. At the heart of the NPPF is the presumption in favour of sustainable development' which seeks to ensure the delivery of developments in support of economic growth and provision of the social needs within a community. By ensuring a high quality design, development on this site could wholly accord with the objectives within the NPPF and contribute towards delivering housing required within the District.
c. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - 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 where it is consistent with achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.
Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];

Be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area [17];
 Seek to secure high quality design and good standard of amenity for all existing and future occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]

In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable development; and
 The Duty to Co-operate.

d. Emerging Local Plan Issues and Options Document

The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.

As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.

As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Rochford Park East, presents an opportunity for RDC to contribute positively to the South Essex housing need.
The key 'Core Purpose and Aims' of ASELA, pertinent to Rochford Park East are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.
e. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.
The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.
On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the sub-regional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However, projected completion rates indicate that a 20% buffer plus shortfall is unlikely to be met, although the shortfall is considered by RDC to be relatively minor at an estimated 166 dwellings over the five years.
When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore, when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.
Supporting Economic Growth and Employment
The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.
Protecting the Green Belt
The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.

The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development, 'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.
RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.
Delivering Infrastructure
In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focuses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London Southend Airport.
f. Ensuring the Delivery of Sustainable Development
Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land at Rochford Park East, Coombs Farm is currently located within the Green Belt, promotion of the site for residential development would provide significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location to London Southend Airport.
Rochford Park East, Coombes Farm
The land at Rochford Park East would be suitable for the sensitive expansion of Rochford, which would also help to improve associated infrastructure. It is also suggested that new landscaped parks and open spaces, extended allotments and a new pedestrian link with the town centre could be provided as part of the development, providing added benefits to both the local and wider area.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for Rochford Park East has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix 3).
Social
Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.
As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required housing need.
Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need
Economic
Rochford Park East is located adjacent to the town of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its suitability for residential development.
The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location less than 10min walk from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating 700 jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53 jobs are created in the wider economy.

Environmental
At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site.
Furthermore, the site is approximately 12minute walk from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. New pedestrian access from the allocated site of Stambridge Mills to the town centre would seek to incentivise this form of transport, therefore reducing the need to use private cars for short distances to and from the town.
Development of this site would also provide an opportunity to enhance the riverside walk linking the site between the town centre, Stambridge Mill and the River Roach estuary. By re-establishing this historic pedestrian link the proposal will help to enhance and benefit the associated ecology whilst also encouraging a healthy and more active lifestyle.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land at Rochford Park East meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the NPPF:
Table 1 Rochford Park East 1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. As such, no further development beyond the Site boundary would be possible; and
- The development of this site would provide a logical 'rounding off' of the existing urban area. 2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the west of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
- The location of Stambridge Mills is also significant in this context as the site is clearly well placed between this redevelopment and the existing urban area, therefore containing development on the site and providing a link from Stambridge Mills to the town. 3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, Stambridge Mills and the existing urban edge of Rochford; and
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006. 4. to preserve the setting and special character of historic towns
- Rochford Park East is not in or adjacent to any Conservation Areas and has no listed buildings or other heritage assets in proximity;
- The Inspector confirmed within the appeal decision that 'the character an Appearance of Rochford Conservation Area which encompasses the nearby town would be preserved' (Paragraph 110);
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.
Sustainable Development Scorecard Analysis
Taking the above information into account, the scorecard analysis of the proposed site at Rochford Park East has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 81% and a Parity score of 92%.
The Scorecard analysis shows that the proposed site scores very well for the elements on the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and flood risk alleviation potential.
Proposed development of the site also scores well on both the economic and social aspects, due to the site's proximity to Rochford Town Centre, local employment and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a sustainable location in which to accommodate additional growth due to the presence of a train station with frequent connections to central London and the town's significant range of services.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.
g. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land at Rochford Park East, Coombes Farm will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable, achievable and deliverable sites are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).
For the reasons given in Table 1, the land at Rochford Park East, Coombes Farm should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a logical 'rounding off' of the existing urban area and given the visual (and actual) separation for the wider countryside, the site has very limited function in safeguarding the countryside from encroachment. For these reasons, and the reasons set out above, it is considered that the proposed development site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | ROCHFORD PARK EAST, COOMBES FARM

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, to Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.

Please note that details relating to the land at Rochford Park East also formed part of Rochford District Council's 'Call for Sites consultation 2015'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land at Rochford Park East, Coombes Farm
The land at Rochford Park East is identified within the submitted plan (Appendix 1), but for clarity is 20.45ha in size and lies approximately 500m to the east of Rochford town centre and 900m east of Rochford mainline Railway Station. The site is bound by Stambridge Road and existing residential properties fronting Stambridge Road to the north, Stambridge Mills and Mill Lane to the east and the
River Road to the south. To the west, the site boundary abuts the existing urban area and includes allotment gardens that are accessed off Stambridge Road and Rocheway. Residential properties are located along the north eastern corner of the site. The site currently comprises agricultural land with a single Public Right of Way; other informal routes around the site are also used by local walkers. The public safety Zone associated with London Southend Airport lies outside the boundary of the site.
The allocated Stambridge Mills site is located to the South East of the Site, for which an application for redevelopment to provide 96 units was submitted in 2011 (11/00494/FUL). However, due to reliance on 3rd party land for mitigation measures the site has been considered undeliverable. This application was withdrawn.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing through the Local Plan process. Development of the site would provide an obvious and most suitable extension to the development boundary as the site is defined by strong defensible
boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. For this reason development of this site would provide a logical 'rounding off' of the existing urban area. Given the visual (and actual) separation for the wider countryside, the site also has very limited function in safeguarding the countryside from encroachment.

Development of the land at Rochford Park East would also promote growth within Rochford and the wider districts and will help support local employment which would otherwise result in the closure of local businesses and increasing the amount of derelict land elsewhere.
Further benefits of the development of the land at Rochford Park East are explained in more detail throughout these representations.

b. History
The Council will be aware of the history associated with the Site following the refusal of a planning application for 326 residential dwellings in November 2009, the subsequent appeal in May 2010 and a subsequent revised application in March 2012.
Since the determination of the previous schemes on the site, the introduction of the National Planning Policy Framework (NPPF) in 2012 has created an environment in which a proactive and positive approach to planning is essential. At the heart of the NPPF is the presumption in favour of sustainable development' which seeks to ensure the delivery of developments in support of economic growth and provision of the social needs within a community. By ensuring a high quality design, development on this site could wholly accord with the objectives within the NPPF and contribute towards delivering housing required within the District.
c. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - 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 where it is consistent with achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.
Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];

Be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area [17];
 Seek to secure high quality design and good standard of amenity for all existing and future occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]

In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable development; and
 The Duty to Co-operate.

d. Emerging Local Plan Issues and Options Document

The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.

As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.

As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Rochford Park East, presents an opportunity for RDC to contribute positively to the South Essex housing need.
The key 'Core Purpose and Aims' of ASELA, pertinent to Rochford Park East are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.
e. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.
The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.
On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the sub-regional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However, projected completion rates indicate that a 20% buffer plus shortfall is unlikely to be met, although the shortfall is considered by RDC to be relatively minor at an estimated 166 dwellings over the five years.
When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore, when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.
Supporting Economic Growth and Employment
The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.
Protecting the Green Belt
The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.

The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development, 'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.
RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.
Delivering Infrastructure
In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focuses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London Southend Airport.
f. Ensuring the Delivery of Sustainable Development
Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land at Rochford Park East, Coombs Farm is currently located within the Green Belt, promotion of the site for residential development would provide significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location to London Southend Airport.
Rochford Park East, Coombes Farm
The land at Rochford Park East would be suitable for the sensitive expansion of Rochford, which would also help to improve associated infrastructure. It is also suggested that new landscaped parks and open spaces, extended allotments and a new pedestrian link with the town centre could be provided as part of the development, providing added benefits to both the local and wider area.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for Rochford Park East has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix 3).
Social
Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.
As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required housing need.
Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need
Economic
Rochford Park East is located adjacent to the town of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its suitability for residential development.
The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location less than 10min walk from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating 700 jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53 jobs are created in the wider economy.

Environmental
At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site.
Furthermore, the site is approximately 12minute walk from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. New pedestrian access from the allocated site of Stambridge Mills to the town centre would seek to incentivise this form of transport, therefore reducing the need to use private cars for short distances to and from the town.
Development of this site would also provide an opportunity to enhance the riverside walk linking the site between the town centre, Stambridge Mill and the River Roach estuary. By re-establishing this historic pedestrian link the proposal will help to enhance and benefit the associated ecology whilst also encouraging a healthy and more active lifestyle.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land at Rochford Park East meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the NPPF:
Table 1 Rochford Park East 1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. As such, no further development beyond the Site boundary would be possible; and
- The development of this site would provide a logical 'rounding off' of the existing urban area. 2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the west of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
- The location of Stambridge Mills is also significant in this context as the site is clearly well placed between this redevelopment and the existing urban area, therefore containing development on the site and providing a link from Stambridge Mills to the town. 3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, Stambridge Mills and the existing urban edge of Rochford; and
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006. 4. to preserve the setting and special character of historic towns
- Rochford Park East is not in or adjacent to any Conservation Areas and has no listed buildings or other heritage assets in proximity;
- The Inspector confirmed within the appeal decision that 'the character an Appearance of Rochford Conservation Area which encompasses the nearby town would be preserved' (Paragraph 110);
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.
Sustainable Development Scorecard Analysis
Taking the above information into account, the scorecard analysis of the proposed site at Rochford Park East has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 81% and a Parity score of 92%.
The Scorecard analysis shows that the proposed site scores very well for the elements on the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and flood risk alleviation potential.
Proposed development of the site also scores well on both the economic and social aspects, due to the site's proximity to Rochford Town Centre, local employment and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a sustainable location in which to accommodate additional growth due to the presence of a train station with frequent connections to central London and the town's significant range of services.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.
g. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land at Rochford Park East, Coombes Farm will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable, achievable and deliverable sites are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).
For the reasons given in Table 1, the land at Rochford Park East, Coombes Farm should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a logical 'rounding off' of the existing urban area and given the visual (and actual) separation for the wider countryside, the site has very limited function in safeguarding the countryside from encroachment. For these reasons, and the reasons set out above, it is considered that the proposed development site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | ROCHFORD PARK EAST, COOMBES FARM

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, to Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.

Please note that details relating to the land at Rochford Park East also formed part of Rochford District Council's 'Call for Sites consultation 2015'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land at Rochford Park East, Coombes Farm
The land at Rochford Park East is identified within the submitted plan (Appendix 1), but for clarity is 20.45ha in size and lies approximately 500m to the east of Rochford town centre and 900m east of Rochford mainline Railway Station. The site is bound by Stambridge Road and existing residential properties fronting Stambridge Road to the north, Stambridge Mills and Mill Lane to the east and the
River Road to the south. To the west, the site boundary abuts the existing urban area and includes allotment gardens that are accessed off Stambridge Road and Rocheway. Residential properties are located along the north eastern corner of the site. The site currently comprises agricultural land with a single Public Right of Way; other informal routes around the site are also used by local walkers. The public safety Zone associated with London Southend Airport lies outside the boundary of the site.
The allocated Stambridge Mills site is located to the South East of the Site, for which an application for redevelopment to provide 96 units was submitted in 2011 (11/00494/FUL). However, due to reliance on 3rd party land for mitigation measures the site has been considered undeliverable. This application was withdrawn.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing through the Local Plan process. Development of the site would provide an obvious and most suitable extension to the development boundary as the site is defined by strong defensible
boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. For this reason development of this site would provide a logical 'rounding off' of the existing urban area. Given the visual (and actual) separation for the wider countryside, the site also has very limited function in safeguarding the countryside from encroachment.

Development of the land at Rochford Park East would also promote growth within Rochford and the wider districts and will help support local employment which would otherwise result in the closure of local businesses and increasing the amount of derelict land elsewhere.
Further benefits of the development of the land at Rochford Park East are explained in more detail throughout these representations.

b. History
The Council will be aware of the history associated with the Site following the refusal of a planning application for 326 residential dwellings in November 2009, the subsequent appeal in May 2010 and a subsequent revised application in March 2012.
Since the determination of the previous schemes on the site, the introduction of the National Planning Policy Framework (NPPF) in 2012 has created an environment in which a proactive and positive approach to planning is essential. At the heart of the NPPF is the presumption in favour of sustainable development' which seeks to ensure the delivery of developments in support of economic growth and provision of the social needs within a community. By ensuring a high quality design, development on this site could wholly accord with the objectives within the NPPF and contribute towards delivering housing required within the District.
c. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - 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 where it is consistent with achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.
Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];

Be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area [17];
 Seek to secure high quality design and good standard of amenity for all existing and future occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]

In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable development; and
 The Duty to Co-operate.

d. Emerging Local Plan Issues and Options Document

The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.

As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.

As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Rochford Park East, presents an opportunity for RDC to contribute positively to the South Essex housing need.
The key 'Core Purpose and Aims' of ASELA, pertinent to Rochford Park East are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.
e. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.
The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.
On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the sub-regional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However, projected completion rates indicate that a 20% buffer plus shortfall is unlikely to be met, although the shortfall is considered by RDC to be relatively minor at an estimated 166 dwellings over the five years.
When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore, when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.
Supporting Economic Growth and Employment
The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.
Protecting the Green Belt
The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.

The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development, 'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.
RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.
Delivering Infrastructure
In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focuses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London Southend Airport.
f. Ensuring the Delivery of Sustainable Development
Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land at Rochford Park East, Coombs Farm is currently located within the Green Belt, promotion of the site for residential development would provide significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location to London Southend Airport.
Rochford Park East, Coombes Farm
The land at Rochford Park East would be suitable for the sensitive expansion of Rochford, which would also help to improve associated infrastructure. It is also suggested that new landscaped parks and open spaces, extended allotments and a new pedestrian link with the town centre could be provided as part of the development, providing added benefits to both the local and wider area.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for Rochford Park East has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix 3).
Social
Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.
As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required housing need.
Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need
Economic
Rochford Park East is located adjacent to the town of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its suitability for residential development.
The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location less than 10min walk from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating 700 jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53 jobs are created in the wider economy.

Environmental
At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site.
Furthermore, the site is approximately 12minute walk from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. New pedestrian access from the allocated site of Stambridge Mills to the town centre would seek to incentivise this form of transport, therefore reducing the need to use private cars for short distances to and from the town.
Development of this site would also provide an opportunity to enhance the riverside walk linking the site between the town centre, Stambridge Mill and the River Roach estuary. By re-establishing this historic pedestrian link the proposal will help to enhance and benefit the associated ecology whilst also encouraging a healthy and more active lifestyle.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land at Rochford Park East meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the NPPF:
Table 1 Rochford Park East 1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. As such, no further development beyond the Site boundary would be possible; and
- The development of this site would provide a logical 'rounding off' of the existing urban area. 2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the west of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
- The location of Stambridge Mills is also significant in this context as the site is clearly well placed between this redevelopment and the existing urban area, therefore containing development on the site and providing a link from Stambridge Mills to the town. 3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, Stambridge Mills and the existing urban edge of Rochford; and
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006. 4. to preserve the setting and special character of historic towns
- Rochford Park East is not in or adjacent to any Conservation Areas and has no listed buildings or other heritage assets in proximity;
- The Inspector confirmed within the appeal decision that 'the character an Appearance of Rochford Conservation Area which encompasses the nearby town would be preserved' (Paragraph 110);
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.
Sustainable Development Scorecard Analysis
Taking the above information into account, the scorecard analysis of the proposed site at Rochford Park East has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 81% and a Parity score of 92%.
The Scorecard analysis shows that the proposed site scores very well for the elements on the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and flood risk alleviation potential.
Proposed development of the site also scores well on both the economic and social aspects, due to the site's proximity to Rochford Town Centre, local employment and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a sustainable location in which to accommodate additional growth due to the presence of a train station with frequent connections to central London and the town's significant range of services.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.
g. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land at Rochford Park East, Coombes Farm will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable, achievable and deliverable sites are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).
For the reasons given in Table 1, the land at Rochford Park East, Coombes Farm should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a logical 'rounding off' of the existing urban area and given the visual (and actual) separation for the wider countryside, the site has very limited function in safeguarding the countryside from encroachment. For these reasons, and the reasons set out above, it is considered that the proposed development site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | ROCHFORD PARK EAST, COOMBES FARM

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, to Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.

Please note that details relating to the land at Rochford Park East also formed part of Rochford District Council's 'Call for Sites consultation 2015'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land at Rochford Park East, Coombes Farm
The land at Rochford Park East is identified within the submitted plan (Appendix 1), but for clarity is 20.45ha in size and lies approximately 500m to the east of Rochford town centre and 900m east of Rochford mainline Railway Station. The site is bound by Stambridge Road and existing residential properties fronting Stambridge Road to the north, Stambridge Mills and Mill Lane to the east and the
River Road to the south. To the west, the site boundary abuts the existing urban area and includes allotment gardens that are accessed off Stambridge Road and Rocheway. Residential properties are located along the north eastern corner of the site. The site currently comprises agricultural land with a single Public Right of Way; other informal routes around the site are also used by local walkers. The public safety Zone associated with London Southend Airport lies outside the boundary of the site.
The allocated Stambridge Mills site is located to the South East of the Site, for which an application for redevelopment to provide 96 units was submitted in 2011 (11/00494/FUL). However, due to reliance on 3rd party land for mitigation measures the site has been considered undeliverable. This application was withdrawn.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing through the Local Plan process. Development of the site would provide an obvious and most suitable extension to the development boundary as the site is defined by strong defensible
boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. For this reason development of this site would provide a logical 'rounding off' of the existing urban area. Given the visual (and actual) separation for the wider countryside, the site also has very limited function in safeguarding the countryside from encroachment.

Development of the land at Rochford Park East would also promote growth within Rochford and the wider districts and will help support local employment which would otherwise result in the closure of local businesses and increasing the amount of derelict land elsewhere.
Further benefits of the development of the land at Rochford Park East are explained in more detail throughout these representations.

b. History
The Council will be aware of the history associated with the Site following the refusal of a planning application for 326 residential dwellings in November 2009, the subsequent appeal in May 2010 and a subsequent revised application in March 2012.
Since the determination of the previous schemes on the site, the introduction of the National Planning Policy Framework (NPPF) in 2012 has created an environment in which a proactive and positive approach to planning is essential. At the heart of the NPPF is the presumption in favour of sustainable development' which seeks to ensure the delivery of developments in support of economic growth and provision of the social needs within a community. By ensuring a high quality design, development on this site could wholly accord with the objectives within the NPPF and contribute towards delivering housing required within the District.
c. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - 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 where it is consistent with achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.
Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];

Be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area [17];
 Seek to secure high quality design and good standard of amenity for all existing and future occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]

In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable development; and
 The Duty to Co-operate.

d. Emerging Local Plan Issues and Options Document

The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.

As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.

As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Rochford Park East, presents an opportunity for RDC to contribute positively to the South Essex housing need.
The key 'Core Purpose and Aims' of ASELA, pertinent to Rochford Park East are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.
e. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.
The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.
On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the sub-regional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However, projected completion rates indicate that a 20% buffer plus shortfall is unlikely to be met, although the shortfall is considered by RDC to be relatively minor at an estimated 166 dwellings over the five years.
When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore, when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.
Supporting Economic Growth and Employment
The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.
Protecting the Green Belt
The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.

The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development, 'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.
RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.
Delivering Infrastructure
In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focuses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London Southend Airport.
f. Ensuring the Delivery of Sustainable Development
Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land at Rochford Park East, Coombs Farm is currently located within the Green Belt, promotion of the site for residential development would provide significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location to London Southend Airport.
Rochford Park East, Coombes Farm
The land at Rochford Park East would be suitable for the sensitive expansion of Rochford, which would also help to improve associated infrastructure. It is also suggested that new landscaped parks and open spaces, extended allotments and a new pedestrian link with the town centre could be provided as part of the development, providing added benefits to both the local and wider area.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for Rochford Park East has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix 3).
Social
Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.
As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required housing need.
Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need
Economic
Rochford Park East is located adjacent to the town of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its suitability for residential development.
The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location less than 10min walk from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating 700 jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53 jobs are created in the wider economy.

Environmental
At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site.
Furthermore, the site is approximately 12minute walk from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. New pedestrian access from the allocated site of Stambridge Mills to the town centre would seek to incentivise this form of transport, therefore reducing the need to use private cars for short distances to and from the town.
Development of this site would also provide an opportunity to enhance the riverside walk linking the site between the town centre, Stambridge Mill and the River Roach estuary. By re-establishing this historic pedestrian link the proposal will help to enhance and benefit the associated ecology whilst also encouraging a healthy and more active lifestyle.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land at Rochford Park East meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the NPPF:
Table 1 Rochford Park East 1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the south. As such, no further development beyond the Site boundary would be possible; and
- The development of this site would provide a logical 'rounding off' of the existing urban area. 2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the west of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
- The location of Stambridge Mills is also significant in this context as the site is clearly well placed between this redevelopment and the existing urban area, therefore containing development on the site and providing a link from Stambridge Mills to the town. 3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, Stambridge Mills and the existing urban edge of Rochford; and
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006. 4. to preserve the setting and special character of historic towns
- Rochford Park East is not in or adjacent to any Conservation Areas and has no listed buildings or other heritage assets in proximity;
- The Inspector confirmed within the appeal decision that 'the character an Appearance of Rochford Conservation Area which encompasses the nearby town would be preserved' (Paragraph 110);
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.
Sustainable Development Scorecard Analysis
Taking the above information into account, the scorecard analysis of the proposed site at Rochford Park East has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 81% and a Parity score of 92%.
The Scorecard analysis shows that the proposed site scores very well for the elements on the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and flood risk alleviation potential.
Proposed development of the site also scores well on both the economic and social aspects, due to the site's proximity to Rochford Town Centre, local employment and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a sustainable location in which to accommodate additional growth due to the presence of a train station with frequent connections to central London and the town's significant range of services.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.
g. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land at Rochford Park East, Coombes Farm will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable, achievable and deliverable sites are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).
For the reasons given in Table 1, the land at Rochford Park East, Coombes Farm should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a logical 'rounding off' of the existing urban area and given the visual (and actual) separation for the wider countryside, the site has very limited function in safeguarding the countryside from encroachment. For these reasons, and the reasons set out above, it is considered that the proposed development site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | LAND EAST AND WEST OF SUTTON ROAD

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, on Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.
Please note that details relating to the Land East and West of Sutton Road also formed part of Rochford District Council's 'Call for Sites consultation 2016'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land east and west of Sutton Road
The land east and west of Sutton Road is identified within the submitted plan (Appendix A1), but for clarity the site is divided into two sections by Sutton Road. The land to the west of Sutton Road is 56.3ha in size while the Land east of Sutton Road is 36.8ha. The site is located approximately 1km to the south east of Rochford Town Centre and Rochford mainline Railway Station. The site is bound by residential development to the east, employment and commercial facilities to the north (Purdeys Industrial Estate) and Temple Farm Industrial Estate to the south, Fossets Park to the South West. Reads of Sutton Road Nursery is located to the west of Sutton Road. The site is also bordered by an existing road network, including Shopland Road/Sutton Road to the north and Southend Road to the east. The site currently comprises agricultural land. The public safety Zone associated with Local Southend Airport lies outside the boundary of the site. The site can be accessed via Sutton Road and Fossetts Way.
New Hall Grade II listed building is located on the western side of Sutton Road and any new development on this site will have to be sympathetic to this heritage asset.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. Development of the site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing
Public Safety Zone to Southend Airport and the existing road network.
Promotion of this site for residential use will provide additional sustainable and infrastructure benefits to Rochford and the wider South Essex district. These benefits will include.

 Enable east/west connections without impacting on A1159;
 Provide access to the outer town retail uses and sport stadium potential to reduce impact on
A2259;
 Reconfiguration of Rochford/Southend Road at harp house roundabout;
 Provide better access to the airport to reduce highways impact on Warners Bridge Chase
residents and rebuilding Warners Bridge;
 Improvement to be made to Anne Boleyn roundabout on junction of Rochford Road and Sutton
Road, easing congestion within the district by providing a loop road;
 Provide landscape buffer to Shoplands Equestrian Centre heritage asset providing a through link
to Shopland and potential eastward connections; and
 Development of the site will also provide a landscape setting for Brookes and ecological site.
It is envisaged that the site is suitable for approximately 1,400 dwellings a primary school and a local centre. Alternatively the site could be suitable for industrial use, offices or a mixed use development. Development of the land east and west of Sutton Road will promote growth within Rochford and the neighbouring authorities. It will be of a scale to justify strategic infrastructure investment, in what should
be a key growth corridor for Rochford and Southend. Furthermore it will help support local employment and encourage economic growth. New development will ensure the long term vitality and viability of existing services and business in the local area, and encourage new businesses to locate to this location.
Further benefits of the development of the land east and west of Sutton Road are explained in more detail throughout these representations.

b. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and
the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - 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 where it is consistent with
achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the
reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on
cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.

Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];
 Be based upon and reflect the presumption in favour of sustainable development, with clear
policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area
[17];
 Seek to secure high quality design and good standard of amenity for all existing and future
occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]
In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with
respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable
development; and
 The Duty to Co-operate.

c. Emerging Local Plan Issues and Options Document
The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.
As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.
As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-
Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Land east and west of Sutton Road, presents an opportunity for both RDC and SBC to contribute positively to the South Essex housing and wider infrastructure investment need.
The key 'Core Purpose and Aims' of ASELA, pertinent to land east and west of Sutton Road are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.

d. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.

The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.

On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the subregional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's required housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAHN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However projected completion rates indicate that a 20% buffer plus shortfall is unlikely to not be met, although the shortfall is considered by RDC to be relatively minor at an
estimated 166 dwellings over the five years.

When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore,
when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.

Supporting Economic Growth and Employment

The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate
controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.

Protecting the Green Belt

The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.
The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development,
'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.

RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.

Delivering Infrastructure

In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focusses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London
Southend Airport.

e. Ensuring the Delivery of Sustainable Development

Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land to the east and west of Sutton Road is currently located within the Green Belt, promotion of the site for residential development provides significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location in relation to London Southend Airport.

Land East and West of Sutton Road

The land east and west of Sutton Road, is in a sustainable location, in close proximity to existing services and facilities as well as employment opportunities. It is suitable for residential development and would help to improve associated roads and infrastructure, easing congestion and providing better access to Rochford, Southend, and London Southend Airport. It is also suggested that new landscaped parks and open spaces which will provide a landscape buffer to Shoplands equestrian centre and heritage assets as well as providing a potential new link to Shoplands and eastward connections.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for land east and west of Sutton Road has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix A3).

Social

Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.

As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required
housing need. Development of this site could help to deliver approximately 1,400 homes towards RDC required housing need target.

Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need.
Development of this site would also bring improvements to the local infrastructure helping to provide better access to the town centre and London Southend Airport. These improvements will also help to ease congestion around the district and the wider area.

Economic

Land east and west of Sutton Road is located adjacent to the south east of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport and Temple Farm Industrial Estate. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its
suitability for residential development.

The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location which is within walking distance from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local
service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK
average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating a significant number jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53
jobs are created in the wider economy.
It is envisaged that development of this site could also provide new jobs as the proposal will look to include the erection of a new primary school and one local centre.

Environmental

At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site. Development of the site would also provide a landscape buffer to Shoplands equestrian centre heritage
asset, providing a through link to Shoplands and potential eastward connections. Within the site, development would provide a landscape setting for Brookes ecological sites.
Development of the site will also be sympathetic to New Hall Grade II listed building located on the western side of Sutton Road by securing a high quality design which will reflect the area.
Furthermore, the site is within walking distance from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land east and west of Sutton Road meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the
NPPF:

Table 1
Land East and West of Sutton Road
1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the north and Temple Farm Industrial estate to the south as well as the existing road network.
- The development of this site would provide a logical 'rounding off' of the existing urban area.
2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the North West of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, London Southend Airport, Fossetts Park and Temple Farm Industrial Estate.
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006.
4. to preserve the setting and special character of historic towns
- Land east and west of Sutton Road is not in or adjacent to any Conservation Areas. A high quality designed development which is sympathetic and aims to protect New Hall Grade II Listed Building.
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land
- There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.

Sustainable Development Scorecard Analysis

Taking the above information into account, the scorecard analysis of the proposed site east and west of Sutton Road has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 84% and a Parity score of 88%.
The Scorecard analysis shows that the proposed site scores very well for the elements of the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and reduce transport emissions as a result of the proximity to sustainable transport options.
The scheme also scores well on both the economic and social aspects, due to the site's proximity to London Southend Airport, Temple Farm and Purdeys Industrial estate and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a prominent location in which to accommodate additional growth due to the presence of two train stations (Rochford and London Southend Airport) with frequent, sustainable connections to central London and Southend-on-Sea.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.

f. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land east and west of Sutton Road will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area. It
is envisaged that development on the site could provide approximately 1,400 towards RDC's required housing need.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable,
achievable and deliverable sites, such as this one, are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

For the reasons given in Table 1, the land east and west of Sutton Road should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing Public Safety Zone to London Southend Airport and the existing road network.
Through development of the site there is also potential to make several infrastructure improvements to the local road network which will have wider benefits for the South Essex Districts.

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | LAND EAST AND WEST OF SUTTON ROAD

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, on Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.
Please note that details relating to the Land East and West of Sutton Road also formed part of Rochford District Council's 'Call for Sites consultation 2016'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land east and west of Sutton Road
The land east and west of Sutton Road is identified within the submitted plan (Appendix A1), but for clarity the site is divided into two sections by Sutton Road. The land to the west of Sutton Road is 56.3ha in size while the Land east of Sutton Road is 36.8ha. The site is located approximately 1km to the south east of Rochford Town Centre and Rochford mainline Railway Station. The site is bound by residential development to the east, employment and commercial facilities to the north (Purdeys Industrial Estate) and Temple Farm Industrial Estate to the south, Fossets Park to the South West. Reads of Sutton Road Nursery is located to the west of Sutton Road. The site is also bordered by an existing road network, including Shopland Road/Sutton Road to the north and Southend Road to the east. The site currently comprises agricultural land. The public safety Zone associated with Local Southend Airport lies outside the boundary of the site. The site can be accessed via Sutton Road and Fossetts Way.
New Hall Grade II listed building is located on the western side of Sutton Road and any new development on this site will have to be sympathetic to this heritage asset.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. Development of the site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing
Public Safety Zone to Southend Airport and the existing road network.
Promotion of this site for residential use will provide additional sustainable and infrastructure benefits to Rochford and the wider South Essex district. These benefits will include.

 Enable east/west connections without impacting on A1159;
 Provide access to the outer town retail uses and sport stadium potential to reduce impact on
A2259;
 Reconfiguration of Rochford/Southend Road at harp house roundabout;
 Provide better access to the airport to reduce highways impact on Warners Bridge Chase
residents and rebuilding Warners Bridge;
 Improvement to be made to Anne Boleyn roundabout on junction of Rochford Road and Sutton
Road, easing congestion within the district by providing a loop road;
 Provide landscape buffer to Shoplands Equestrian Centre heritage asset providing a through link
to Shopland and potential eastward connections; and
 Development of the site will also provide a landscape setting for Brookes and ecological site.
It is envisaged that the site is suitable for approximately 1,400 dwellings a primary school and a local centre. Alternatively the site could be suitable for industrial use, offices or a mixed use development. Development of the land east and west of Sutton Road will promote growth within Rochford and the neighbouring authorities. It will be of a scale to justify strategic infrastructure investment, in what should
be a key growth corridor for Rochford and Southend. Furthermore it will help support local employment and encourage economic growth. New development will ensure the long term vitality and viability of existing services and business in the local area, and encourage new businesses to locate to this location.
Further benefits of the development of the land east and west of Sutton Road are explained in more detail throughout these representations.

b. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and
the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - 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 where it is consistent with
achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the
reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on
cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.

Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];
 Be based upon and reflect the presumption in favour of sustainable development, with clear
policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area
[17];
 Seek to secure high quality design and good standard of amenity for all existing and future
occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]
In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with
respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable
development; and
 The Duty to Co-operate.

c. Emerging Local Plan Issues and Options Document
The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.
As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.
As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-
Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Land east and west of Sutton Road, presents an opportunity for both RDC and SBC to contribute positively to the South Essex housing and wider infrastructure investment need.
The key 'Core Purpose and Aims' of ASELA, pertinent to land east and west of Sutton Road are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.

d. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.

The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.

On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the subregional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's required housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAHN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However projected completion rates indicate that a 20% buffer plus shortfall is unlikely to not be met, although the shortfall is considered by RDC to be relatively minor at an
estimated 166 dwellings over the five years.

When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore,
when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.

Supporting Economic Growth and Employment

The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate
controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.

Protecting the Green Belt

The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.
The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development,
'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.

RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.

Delivering Infrastructure

In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focusses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London
Southend Airport.

e. Ensuring the Delivery of Sustainable Development

Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land to the east and west of Sutton Road is currently located within the Green Belt, promotion of the site for residential development provides significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location in relation to London Southend Airport.

Land East and West of Sutton Road

The land east and west of Sutton Road, is in a sustainable location, in close proximity to existing services and facilities as well as employment opportunities. It is suitable for residential development and would help to improve associated roads and infrastructure, easing congestion and providing better access to Rochford, Southend, and London Southend Airport. It is also suggested that new landscaped parks and open spaces which will provide a landscape buffer to Shoplands equestrian centre and heritage assets as well as providing a potential new link to Shoplands and eastward connections.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for land east and west of Sutton Road has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix A3).

Social

Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.

As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required
housing need. Development of this site could help to deliver approximately 1,400 homes towards RDC required housing need target.

Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need.
Development of this site would also bring improvements to the local infrastructure helping to provide better access to the town centre and London Southend Airport. These improvements will also help to ease congestion around the district and the wider area.

Economic

Land east and west of Sutton Road is located adjacent to the south east of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport and Temple Farm Industrial Estate. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its
suitability for residential development.

The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location which is within walking distance from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local
service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK
average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating a significant number jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53
jobs are created in the wider economy.
It is envisaged that development of this site could also provide new jobs as the proposal will look to include the erection of a new primary school and one local centre.

Environmental

At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site. Development of the site would also provide a landscape buffer to Shoplands equestrian centre heritage
asset, providing a through link to Shoplands and potential eastward connections. Within the site, development would provide a landscape setting for Brookes ecological sites.
Development of the site will also be sympathetic to New Hall Grade II listed building located on the western side of Sutton Road by securing a high quality design which will reflect the area.
Furthermore, the site is within walking distance from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land east and west of Sutton Road meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the
NPPF:

Table 1
Land East and West of Sutton Road
1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the north and Temple Farm Industrial estate to the south as well as the existing road network.
- The development of this site would provide a logical 'rounding off' of the existing urban area.
2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the North West of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, London Southend Airport, Fossetts Park and Temple Farm Industrial Estate.
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006.
4. to preserve the setting and special character of historic towns
- Land east and west of Sutton Road is not in or adjacent to any Conservation Areas. A high quality designed development which is sympathetic and aims to protect New Hall Grade II Listed Building.
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land
- There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.

Sustainable Development Scorecard Analysis

Taking the above information into account, the scorecard analysis of the proposed site east and west of Sutton Road has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 84% and a Parity score of 88%.
The Scorecard analysis shows that the proposed site scores very well for the elements of the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and reduce transport emissions as a result of the proximity to sustainable transport options.
The scheme also scores well on both the economic and social aspects, due to the site's proximity to London Southend Airport, Temple Farm and Purdeys Industrial estate and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a prominent location in which to accommodate additional growth due to the presence of two train stations (Rochford and London Southend Airport) with frequent, sustainable connections to central London and Southend-on-Sea.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.

f. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land east and west of Sutton Road will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area. It
is envisaged that development on the site could provide approximately 1,400 towards RDC's required housing need.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable,
achievable and deliverable sites, such as this one, are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

For the reasons given in Table 1, the land east and west of Sutton Road should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing Public Safety Zone to London Southend Airport and the existing road network.
Through development of the site there is also potential to make several infrastructure improvements to the local road network which will have wider benefits for the South Essex Districts.

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | LAND EAST AND WEST OF SUTTON ROAD

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, on Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.
Please note that details relating to the Land East and West of Sutton Road also formed part of Rochford District Council's 'Call for Sites consultation 2016'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land east and west of Sutton Road
The land east and west of Sutton Road is identified within the submitted plan (Appendix A1), but for clarity the site is divided into two sections by Sutton Road. The land to the west of Sutton Road is 56.3ha in size while the Land east of Sutton Road is 36.8ha. The site is located approximately 1km to the south east of Rochford Town Centre and Rochford mainline Railway Station. The site is bound by residential development to the east, employment and commercial facilities to the north (Purdeys Industrial Estate) and Temple Farm Industrial Estate to the south, Fossets Park to the South West. Reads of Sutton Road Nursery is located to the west of Sutton Road. The site is also bordered by an existing road network, including Shopland Road/Sutton Road to the north and Southend Road to the east. The site currently comprises agricultural land. The public safety Zone associated with Local Southend Airport lies outside the boundary of the site. The site can be accessed via Sutton Road and Fossetts Way.
New Hall Grade II listed building is located on the western side of Sutton Road and any new development on this site will have to be sympathetic to this heritage asset.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. Development of the site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing
Public Safety Zone to Southend Airport and the existing road network.
Promotion of this site for residential use will provide additional sustainable and infrastructure benefits to Rochford and the wider South Essex district. These benefits will include.

 Enable east/west connections without impacting on A1159;
 Provide access to the outer town retail uses and sport stadium potential to reduce impact on
A2259;
 Reconfiguration of Rochford/Southend Road at harp house roundabout;
 Provide better access to the airport to reduce highways impact on Warners Bridge Chase
residents and rebuilding Warners Bridge;
 Improvement to be made to Anne Boleyn roundabout on junction of Rochford Road and Sutton
Road, easing congestion within the district by providing a loop road;
 Provide landscape buffer to Shoplands Equestrian Centre heritage asset providing a through link
to Shopland and potential eastward connections; and
 Development of the site will also provide a landscape setting for Brookes and ecological site.
It is envisaged that the site is suitable for approximately 1,400 dwellings a primary school and a local centre. Alternatively the site could be suitable for industrial use, offices or a mixed use development. Development of the land east and west of Sutton Road will promote growth within Rochford and the neighbouring authorities. It will be of a scale to justify strategic infrastructure investment, in what should
be a key growth corridor for Rochford and Southend. Furthermore it will help support local employment and encourage economic growth. New development will ensure the long term vitality and viability of existing services and business in the local area, and encourage new businesses to locate to this location.
Further benefits of the development of the land east and west of Sutton Road are explained in more detail throughout these representations.

b. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and
the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - 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 where it is consistent with
achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the
reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on
cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.

Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];
 Be based upon and reflect the presumption in favour of sustainable development, with clear
policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area
[17];
 Seek to secure high quality design and good standard of amenity for all existing and future
occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]
In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with
respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable
development; and
 The Duty to Co-operate.

c. Emerging Local Plan Issues and Options Document
The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.
As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.
As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-
Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Land east and west of Sutton Road, presents an opportunity for both RDC and SBC to contribute positively to the South Essex housing and wider infrastructure investment need.
The key 'Core Purpose and Aims' of ASELA, pertinent to land east and west of Sutton Road are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.

d. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.

The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.

On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the subregional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's required housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAHN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However projected completion rates indicate that a 20% buffer plus shortfall is unlikely to not be met, although the shortfall is considered by RDC to be relatively minor at an
estimated 166 dwellings over the five years.

When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore,
when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.

Supporting Economic Growth and Employment

The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate
controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.

Protecting the Green Belt

The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.
The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development,
'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.

RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.

Delivering Infrastructure

In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focusses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London
Southend Airport.

e. Ensuring the Delivery of Sustainable Development

Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land to the east and west of Sutton Road is currently located within the Green Belt, promotion of the site for residential development provides significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location in relation to London Southend Airport.

Land East and West of Sutton Road

The land east and west of Sutton Road, is in a sustainable location, in close proximity to existing services and facilities as well as employment opportunities. It is suitable for residential development and would help to improve associated roads and infrastructure, easing congestion and providing better access to Rochford, Southend, and London Southend Airport. It is also suggested that new landscaped parks and open spaces which will provide a landscape buffer to Shoplands equestrian centre and heritage assets as well as providing a potential new link to Shoplands and eastward connections.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for land east and west of Sutton Road has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix A3).

Social

Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.

As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required
housing need. Development of this site could help to deliver approximately 1,400 homes towards RDC required housing need target.

Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need.
Development of this site would also bring improvements to the local infrastructure helping to provide better access to the town centre and London Southend Airport. These improvements will also help to ease congestion around the district and the wider area.

Economic

Land east and west of Sutton Road is located adjacent to the south east of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport and Temple Farm Industrial Estate. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its
suitability for residential development.

The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location which is within walking distance from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local
service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK
average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating a significant number jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53
jobs are created in the wider economy.
It is envisaged that development of this site could also provide new jobs as the proposal will look to include the erection of a new primary school and one local centre.

Environmental

At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site. Development of the site would also provide a landscape buffer to Shoplands equestrian centre heritage
asset, providing a through link to Shoplands and potential eastward connections. Within the site, development would provide a landscape setting for Brookes ecological sites.
Development of the site will also be sympathetic to New Hall Grade II listed building located on the western side of Sutton Road by securing a high quality design which will reflect the area.
Furthermore, the site is within walking distance from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land east and west of Sutton Road meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the
NPPF:

Table 1
Land East and West of Sutton Road
1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the north and Temple Farm Industrial estate to the south as well as the existing road network.
- The development of this site would provide a logical 'rounding off' of the existing urban area.
2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the North West of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, London Southend Airport, Fossetts Park and Temple Farm Industrial Estate.
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006.
4. to preserve the setting and special character of historic towns
- Land east and west of Sutton Road is not in or adjacent to any Conservation Areas. A high quality designed development which is sympathetic and aims to protect New Hall Grade II Listed Building.
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land
- There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.

Sustainable Development Scorecard Analysis

Taking the above information into account, the scorecard analysis of the proposed site east and west of Sutton Road has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 84% and a Parity score of 88%.
The Scorecard analysis shows that the proposed site scores very well for the elements of the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and reduce transport emissions as a result of the proximity to sustainable transport options.
The scheme also scores well on both the economic and social aspects, due to the site's proximity to London Southend Airport, Temple Farm and Purdeys Industrial estate and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a prominent location in which to accommodate additional growth due to the presence of two train stations (Rochford and London Southend Airport) with frequent, sustainable connections to central London and Southend-on-Sea.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.

f. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land east and west of Sutton Road will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area. It
is envisaged that development on the site could provide approximately 1,400 towards RDC's required housing need.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable,
achievable and deliverable sites, such as this one, are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

For the reasons given in Table 1, the land east and west of Sutton Road should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing Public Safety Zone to London Southend Airport and the existing road network.
Through development of the site there is also potential to make several infrastructure improvements to the local road network which will have wider benefits for the South Essex Districts.

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | LAND EAST AND WEST OF SUTTON ROAD

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, on Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.
Please note that details relating to the Land East and West of Sutton Road also formed part of Rochford District Council's 'Call for Sites consultation 2016'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land east and west of Sutton Road
The land east and west of Sutton Road is identified within the submitted plan (Appendix A1), but for clarity the site is divided into two sections by Sutton Road. The land to the west of Sutton Road is 56.3ha in size while the Land east of Sutton Road is 36.8ha. The site is located approximately 1km to the south east of Rochford Town Centre and Rochford mainline Railway Station. The site is bound by residential development to the east, employment and commercial facilities to the north (Purdeys Industrial Estate) and Temple Farm Industrial Estate to the south, Fossets Park to the South West. Reads of Sutton Road Nursery is located to the west of Sutton Road. The site is also bordered by an existing road network, including Shopland Road/Sutton Road to the north and Southend Road to the east. The site currently comprises agricultural land. The public safety Zone associated with Local Southend Airport lies outside the boundary of the site. The site can be accessed via Sutton Road and Fossetts Way.
New Hall Grade II listed building is located on the western side of Sutton Road and any new development on this site will have to be sympathetic to this heritage asset.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. Development of the site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing
Public Safety Zone to Southend Airport and the existing road network.
Promotion of this site for residential use will provide additional sustainable and infrastructure benefits to Rochford and the wider South Essex district. These benefits will include.

 Enable east/west connections without impacting on A1159;
 Provide access to the outer town retail uses and sport stadium potential to reduce impact on
A2259;
 Reconfiguration of Rochford/Southend Road at harp house roundabout;
 Provide better access to the airport to reduce highways impact on Warners Bridge Chase
residents and rebuilding Warners Bridge;
 Improvement to be made to Anne Boleyn roundabout on junction of Rochford Road and Sutton
Road, easing congestion within the district by providing a loop road;
 Provide landscape buffer to Shoplands Equestrian Centre heritage asset providing a through link
to Shopland and potential eastward connections; and
 Development of the site will also provide a landscape setting for Brookes and ecological site.
It is envisaged that the site is suitable for approximately 1,400 dwellings a primary school and a local centre. Alternatively the site could be suitable for industrial use, offices or a mixed use development. Development of the land east and west of Sutton Road will promote growth within Rochford and the neighbouring authorities. It will be of a scale to justify strategic infrastructure investment, in what should
be a key growth corridor for Rochford and Southend. Furthermore it will help support local employment and encourage economic growth. New development will ensure the long term vitality and viability of existing services and business in the local area, and encourage new businesses to locate to this location.
Further benefits of the development of the land east and west of Sutton Road are explained in more detail throughout these representations.

b. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and
the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - 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 where it is consistent with
achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the
reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on
cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.

Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];
 Be based upon and reflect the presumption in favour of sustainable development, with clear
policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area
[17];
 Seek to secure high quality design and good standard of amenity for all existing and future
occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]
In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with
respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable
development; and
 The Duty to Co-operate.

c. Emerging Local Plan Issues and Options Document
The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.
As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.
As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-
Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Land east and west of Sutton Road, presents an opportunity for both RDC and SBC to contribute positively to the South Essex housing and wider infrastructure investment need.
The key 'Core Purpose and Aims' of ASELA, pertinent to land east and west of Sutton Road are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.

d. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.

The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.

On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the subregional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's required housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAHN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However projected completion rates indicate that a 20% buffer plus shortfall is unlikely to not be met, although the shortfall is considered by RDC to be relatively minor at an
estimated 166 dwellings over the five years.

When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore,
when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.

Supporting Economic Growth and Employment

The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate
controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.

Protecting the Green Belt

The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.
The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development,
'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.

RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.

Delivering Infrastructure

In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focusses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London
Southend Airport.

e. Ensuring the Delivery of Sustainable Development

Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land to the east and west of Sutton Road is currently located within the Green Belt, promotion of the site for residential development provides significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location in relation to London Southend Airport.

Land East and West of Sutton Road

The land east and west of Sutton Road, is in a sustainable location, in close proximity to existing services and facilities as well as employment opportunities. It is suitable for residential development and would help to improve associated roads and infrastructure, easing congestion and providing better access to Rochford, Southend, and London Southend Airport. It is also suggested that new landscaped parks and open spaces which will provide a landscape buffer to Shoplands equestrian centre and heritage assets as well as providing a potential new link to Shoplands and eastward connections.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for land east and west of Sutton Road has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix A3).

Social

Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.

As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required
housing need. Development of this site could help to deliver approximately 1,400 homes towards RDC required housing need target.

Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need.
Development of this site would also bring improvements to the local infrastructure helping to provide better access to the town centre and London Southend Airport. These improvements will also help to ease congestion around the district and the wider area.

Economic

Land east and west of Sutton Road is located adjacent to the south east of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport and Temple Farm Industrial Estate. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its
suitability for residential development.

The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location which is within walking distance from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local
service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK
average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating a significant number jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53
jobs are created in the wider economy.
It is envisaged that development of this site could also provide new jobs as the proposal will look to include the erection of a new primary school and one local centre.

Environmental

At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site. Development of the site would also provide a landscape buffer to Shoplands equestrian centre heritage
asset, providing a through link to Shoplands and potential eastward connections. Within the site, development would provide a landscape setting for Brookes ecological sites.
Development of the site will also be sympathetic to New Hall Grade II listed building located on the western side of Sutton Road by securing a high quality design which will reflect the area.
Furthermore, the site is within walking distance from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land east and west of Sutton Road meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the
NPPF:

Table 1
Land East and West of Sutton Road
1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the north and Temple Farm Industrial estate to the south as well as the existing road network.
- The development of this site would provide a logical 'rounding off' of the existing urban area.
2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the North West of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, London Southend Airport, Fossetts Park and Temple Farm Industrial Estate.
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006.
4. to preserve the setting and special character of historic towns
- Land east and west of Sutton Road is not in or adjacent to any Conservation Areas. A high quality designed development which is sympathetic and aims to protect New Hall Grade II Listed Building.
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land
- There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.

Sustainable Development Scorecard Analysis

Taking the above information into account, the scorecard analysis of the proposed site east and west of Sutton Road has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 84% and a Parity score of 88%.
The Scorecard analysis shows that the proposed site scores very well for the elements of the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and reduce transport emissions as a result of the proximity to sustainable transport options.
The scheme also scores well on both the economic and social aspects, due to the site's proximity to London Southend Airport, Temple Farm and Purdeys Industrial estate and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a prominent location in which to accommodate additional growth due to the presence of two train stations (Rochford and London Southend Airport) with frequent, sustainable connections to central London and Southend-on-Sea.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.

f. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land east and west of Sutton Road will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area. It
is envisaged that development on the site could provide approximately 1,400 towards RDC's required housing need.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable,
achievable and deliverable sites, such as this one, are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

For the reasons given in Table 1, the land east and west of Sutton Road should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing Public Safety Zone to London Southend Airport and the existing road network.
Through development of the site there is also potential to make several infrastructure improvements to the local road network which will have wider benefits for the South Essex Districts.

REPRESENTATIONS TO ROCHFORD DISTRICT COUNCIL'S LOCAL PLAN ISSUES AND
OPTIONS (STAGE 1) CONSULTATION | LAND EAST AND WEST OF SUTTON ROAD

On Behalf of our client, Cogent Land LLP (CL), we wish to make representations, in respect of the land at the above address, on Rochford District Council's (RDC) emerging Local Plan Issues and Options Consultation ('the plan'). A site location plan of our client's landholding is attached at Appendix A1.
Please note that details relating to the Land East and West of Sutton Road also formed part of Rochford District Council's 'Call for Sites consultation 2016'. The information submitted as part of this 'Call for Sites' process is enclosed as Appendix A2.

a. Land east and west of Sutton Road
The land east and west of Sutton Road is identified within the submitted plan (Appendix A1), but for clarity the site is divided into two sections by Sutton Road. The land to the west of Sutton Road is 56.3ha in size while the Land east of Sutton Road is 36.8ha. The site is located approximately 1km to the south east of Rochford Town Centre and Rochford mainline Railway Station. The site is bound by residential development to the east, employment and commercial facilities to the north (Purdeys Industrial Estate) and Temple Farm Industrial Estate to the south, Fossets Park to the South West. Reads of Sutton Road Nursery is located to the west of Sutton Road. The site is also bordered by an existing road network, including Shopland Road/Sutton Road to the north and Southend Road to the east. The site currently comprises agricultural land. The public safety Zone associated with Local Southend Airport lies outside the boundary of the site. The site can be accessed via Sutton Road and Fossetts Way.
New Hall Grade II listed building is located on the western side of Sutton Road and any new development on this site will have to be sympathetic to this heritage asset.
It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. Development of the site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing
Public Safety Zone to Southend Airport and the existing road network.
Promotion of this site for residential use will provide additional sustainable and infrastructure benefits to Rochford and the wider South Essex district. These benefits will include.

 Enable east/west connections without impacting on A1159;
 Provide access to the outer town retail uses and sport stadium potential to reduce impact on
A2259;
 Reconfiguration of Rochford/Southend Road at harp house roundabout;
 Provide better access to the airport to reduce highways impact on Warners Bridge Chase
residents and rebuilding Warners Bridge;
 Improvement to be made to Anne Boleyn roundabout on junction of Rochford Road and Sutton
Road, easing congestion within the district by providing a loop road;
 Provide landscape buffer to Shoplands Equestrian Centre heritage asset providing a through link
to Shopland and potential eastward connections; and
 Development of the site will also provide a landscape setting for Brookes and ecological site.
It is envisaged that the site is suitable for approximately 1,400 dwellings a primary school and a local centre. Alternatively the site could be suitable for industrial use, offices or a mixed use development. Development of the land east and west of Sutton Road will promote growth within Rochford and the neighbouring authorities. It will be of a scale to justify strategic infrastructure investment, in what should
be a key growth corridor for Rochford and Southend. Furthermore it will help support local employment and encourage economic growth. New development will ensure the long term vitality and viability of existing services and business in the local area, and encourage new businesses to locate to this location.
Further benefits of the development of the land east and west of Sutton Road are explained in more detail throughout these representations.

b. Key Policy Considerations
The decision of RDC to bring forward a new Local Plan to prepare for the growth of the Borough is supported in principle. However, the Council has a duty to prepare a plan that accords with the requirements of the NPPF.
The Government requires that Local Plans be kept up-to-date. It is therefore important that the Council brings forward a plan which is positively prepared, justified, effective and consistent with national policy in accordance with section 20 of the Planning and Compulsory Purchase Act 2004 (as amended) and
the NPPF.
Paragraph 182 of the NPPF confirms that, to be sound, a plan must be:
 Positively prepared - 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 where it is consistent with
achieving sustainable development;
 Justified - the plan should be the most appropriate strategy, when considered against the
reasonable alternatives, based on proportionate evidence;
 Effective - the plan should be deliverable over its period and based on effective joint working on
cross-boundary strategic priorities; and
 Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the polices in the Framework.

Furthermore, in order for the Local Plan to comply with the NPPF, it is therefore necessary for the Local Plan document to, inter alia:
 Widen the choice of high quality homes [9];
 Positively seek opportunities to meet the development needs of the area [14];
 Contain sufficient flexibility to adapt to rapid change [14];
 Be based upon and reflect the presumption in favour of sustainable development, with clear
policies that will guide how the presumption in favour should apply locally [15];
 Respond positively to wider opportunities for growth [17];
 Set out a clear strategy for allocating sufficient land which is suitable for development in the area
[17];
 Seek to secure high quality design and good standard of amenity for all existing and future
occupants of land and buildings [17];
 Boost significantly the supply of housing [17];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Meet the full objectively assessed housing needs of the housing market area and identify key sites that are critical to delivery of the housing strategy over the plan period [47];
 Plan for a mix of housing based on current future demographic trends, market trends and the needs of different groups [50];
 Set out the strategic policies for the area, including policies to deliver the homes and jobs needed in the area [156 & 178];
 Be drawn up over an appropriate time scale, preferably a 15 year time horizon, take account of longer term requirements, and be kept up to date [157];
 Identify land where development would be inappropriate due to environmental or historical significance [157]; and
 Be deliverable and viable [173]
In the context of the NPPF it is inevitable that significant questions will be asked of the Plan with
respect to:
 The extent of development needs;
 The strategic distribution of development in relation to existing and proposed infrastructure;
 The extent of the evidence necessary to demonstrate that the Plan will deliver sustainable
development; and
 The Duty to Co-operate.

c. Emerging Local Plan Issues and Options Document
The Issues and Options Document is the first stage in the review of the current Local Development Plan for Rochford District Council. The document considers how the Council can plan for growth in the future, up to and beyond the current plan period of 2025 - and deliver the necessary infrastructure to support this.
The Issues and Options Document has been produced to encourage the involvement of local communities, businesses and other stakeholders at the beginning of the plan-making process so that their views can be taken into account when drafting the new Local Plan.
As part of the South Essex sub region, RDC recognises the need to have a close relationship with their neighbouring boroughs and engage with them on issues that are strategic and cross boundary in nature.
As a district, RDC share a sub-regional Housing Market Area with Southend, Castle Point, Thurrock and Basildon Borough Council, the most recent publications being 2016 South Essex SHMA and 2017 Addendum. These five South Essex Authorities and Essex County Council (ECC) have signed a South Essex Strategic Planning Memorandum of Understanding (MoU) which sets out the Council's Duty-to-
Cooperate and engagement arrangements roles and inter-relationships between the relevant authorities. The strategic cross boundary matters that have been agreed include (inter alia):
 Delivering Houses;
 Supporting Economic Growth and Employment;
 Protecting the Green Belt; and
 Delivering Infrastructure.
Furthermore, the recently established Association of South Essex Local Authorities (ASELA), of which Rochford is a party, denotes a recognition of the importance of cross-boundary working in dealing with planning for growth at a strategic level, including delivery of housing numbers.
ASELA acknowledges that not only is cross-boundary strategic planning of infrastructure and growth a planning requirement, it is also an opportunity. As noted above, under the Duty to Cooperate, Land east and west of Sutton Road, presents an opportunity for both RDC and SBC to contribute positively to the South Essex housing and wider infrastructure investment need.
The key 'Core Purpose and Aims' of ASELA, pertinent to land east and west of Sutton Road are:
 Open up spaces for housing, business and leisure development;
 Transform transport connectivity;
 Shape local labour & skill markets;
 Influence and secure funding necessary strategic infrastructure; and
 Enhance health and social care through co-ordinated planning.

d. Key Strategic Matters
Delivering Houses - Meeting an Objectively Assessed Housing Need (OAHN)
The most recent South Essex SHMA (addendum 2017) sets out that the revised Objectively Assessed Housing Need (OAHN) for the district and projects a need of between 331 and 361 homes per year up until 2037. This relates to an addition of between 6620 - 7220 homes over the course of the plan period (2017-2037). When combined with the shortfall in housing delivery as set out within the OAHN 2014 data base the overall baseline over the plan period will be between 7,181 - 7,871 additional homes.

The 2017 Addendum also identifies that there is a need for around 296 affordable homes per year up to 2037 as well as a need for 50 specialist private homes per annum for older people and 62 homes/units a year for adults with disabilities.

On top of this, RDC need to consider their Duty to Co-operate with the neighbouring authorities in South Essex in relation to housing need. As explained within the Duty to Co-operate Topic Paper 2017, collectively the South Essex Authorities are working together to address housing need at the subregional level.

As highlighted within the New Local Plan: Issues and Options Document 2017, due to physical constraints, both SBC and CPBC have expressed that they will be unable to meet all of their housing need within their own boundaries. It will therefore fall on other authorities within the South Essex Local Enterprise Partnership (SELEP), such as RDC, to help deliver this required shortfall. This is likely to increase RDC's required housing need to beyond 8,000 homes over the course of the emerging Local Plan period.
When assessing the Council's 5YHLS position, the latest Authority Monitoring Report (AMR) (2016) acknowledges that 'due to unexpected delays in the delivery of some of the key strategic sites, allocated in the Council's adopted Allocations Plan there is likely to be a shortfall in the early part of the five year supply'. However, it is expected that this will be compensated through a projected increase in delivery as these sites begin to contribute to housing supply.
At 312 dwellings per year projected completions indicate that the five year housing supply can be met at this lower end of the recommended OAHN range. A 5% buffer including shortfall can also be met within the 5 Year supply. However projected completion rates indicate that a 20% buffer plus shortfall is unlikely to not be met, although the shortfall is considered by RDC to be relatively minor at an
estimated 166 dwellings over the five years.

When considering this in the context of the 392 dwellings per year target, rebased from 2014/15 projected completions, it is clear that the five-year supply is unlikely to be met at this upper end of the recommended OAHN range, with a potential shortfall of 109 dwellings. This presents a shortfall within the five year supply of around 432 dwellings (when including a 5% buffer plus shortfall). Therefore,
when considering a 20% buffer plus shortfall over the five years this is expected to rise to approximately 726 dwellings.
Given the clear shortfall in housing delivery within the RDC and the South Essex Districts as a whole, and the number of constraints limiting the amount of land available, it is vital that new suitable sites come forward to help meet the growing housing need.

Supporting Economic Growth and Employment

The 'Duty to Co-operate' Topic Paper 2017 stipulates that, due to its small economy, RDC experiences a high level of out commuting to neighbouring areas. As part of a planned approach to deliver new local job opportunities in proximity to London Southend Airport, RDC have worked in partnership with SBC over a number of years to deliver a joint plan for a new high-quality business park and appropriate
controls to the airport as it grows. The London Southend Airport and Environs Joint Area Action Plan (JAAP) (adopted 2014) outlines that this new business park and airport expansion could lead to an additional 99,000sq.m of employment floorspace.
The South Essex Growth Strategy, which has been put together by Opportunity South Essex (OSE) incorporating the five South Essex LPA's (including RDC), seeks to support and promote the diversity and growth of the South Essex Economy. The group have overseen SELEP bids for funding and have been successful in securing monies to support development of the new business park and improvements to the A127 interchange.
The Economic Development Needs Topic Paper 2017 (EDNA) has been prepared to provide a broad overview of the projected need for new employment land. The emerging evidence from the EDNA 2017 suggests that there is a need for up to 16ha of new employment land between 2016 and 2036.
This increase in employment provision will lead to more economic growth within the district. This in turn will lead to an increase in the need for sustainably located housing, within close proximity to these new employment opportunities to help stimulate this economic growth further.

Protecting the Green Belt

The Metropolitan Green Belt extends eastwards from London across the five Local Authority areas of South Essex.
The New Local Plan: Issues and Options Document 2017 recognises that 'given that the majority of the district's open land is designated as Green Belt, and that significant areas are also protected for their historic, ecological or wildlife importance' and because of this and the need for more development,
'the purpose of the Green Belt such as the preservation of openness may be difficult to maintain'.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need.

RDC should use this opportunity to strategically review its own Green Belt boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to a Green Belt review.

Delivering Infrastructure

In association with ECC and SBC, The A127 'Corridor for Growth' has been prepared. The A127 forms a key strategic route for the JAAP area and thus directly impacts on Rochford District. The A127 is therefore a vital artery to economic competitiveness of the South Essex sub-region, which includes the Rochford District. The efficiency of the A127 from an economic development perspective is crucial, and it is vital the route is well maintained as a strategic transport network.
RDC, ECC and SBC are also, collectively, working on ways to provide a strategy which focusses on improving public transport and finding ways to encourage passengers, new and existing staff, to use sustainable modes for their journeys to and from the airport.
Improvements to the local and wider district infrastructure will lead to more opportunities for development and further establish both economic growth. Future development opportunities must ensure that measures are provided to maintain these improvements to the highways network whilst also promoting sustainable modes of transport to and from new employment facilities and London
Southend Airport.

e. Ensuring the Delivery of Sustainable Development

Taking these cross boundary strategic matters into account it is evident that RDC need to work together with neighbouring authorities to deliver more sites that will help the South Essex District to meet their required housing need, improve the districts economic growth and employment, maintains the protection of the Green Belt and allows for the necessary road infrastructure to be improved.
With this in mind, although acknowledged that the land to the east and west of Sutton Road is currently located within the Green Belt, promotion of the site for residential development provides significant wider benefits to the district, in line with the key strategic matters highlighted above.
The site would constitute sustainable development which will help to encourage and maximise growth in the region whilst using existing infrastructure and transport links, especially given its prime location in relation to London Southend Airport.

Land East and West of Sutton Road

The land east and west of Sutton Road, is in a sustainable location, in close proximity to existing services and facilities as well as employment opportunities. It is suitable for residential development and would help to improve associated roads and infrastructure, easing congestion and providing better access to Rochford, Southend, and London Southend Airport. It is also suggested that new landscaped parks and open spaces which will provide a landscape buffer to Shoplands equestrian centre and heritage assets as well as providing a potential new link to Shoplands and eastward connections.
In line with the three pillars of sustainable development, as defined by the NPPF, the social and economic benefits as well as environmental constraints and opportunities have been evaluated and considered in respect to this site.

A Sustainable Development Scorecard for land east and west of Sutton Road has also been prepared and is submitted in conjunction with these representations (see enclosed at Appendix A3).

Social

Future development of the site would significantly help to meet RDC's demonstrable housing need and affordable housing requirements, therefore reducing the intergenerational imbalance caused by lack of housing supply and implications this has for society and the economy for both current and future residents. A policy compliant affordable housing provision on the site would assist RDC in meeting this significant need.

As highlighted above, RDC have an OAHN shortfall of circa 8,000 homes which need to be delivered on the emerging Plan period (2017-2037) at an average of more than 392 dwellings per annum. RDC are also currently unable to successfully identify an up-to-date five year housing land supply and thus are required to promote additional suitable, deliverable and achievable sites to fulfil the required
housing need. Development of this site could help to deliver approximately 1,400 homes towards RDC required housing need target.

Although the latest SHMA acknowledges that this shortfall does not take into consideration strategic sites from later on in the plan period which could be delivered earlier than currently predicted and when taking these sites into account, a further delivery of dwellings as a conservative estimate could be delivered between 2020 and 2022, it is measured that this will still not provide a sufficient amount of land, on its own, to meet the projected housing need.
Development of this site would also bring improvements to the local infrastructure helping to provide better access to the town centre and London Southend Airport. These improvements will also help to ease congestion around the district and the wider area.

Economic

Land east and west of Sutton Road is located adjacent to the south east of Rochford and its associated facilities and job opportunities, as well in close proximity to Purdeys Industrial Estate and London Southend Airport and Temple Farm Industrial Estate. The jobs and associated infrastructure these provide include the new railways station, reinforces the economic sustainability of the site and its
suitability for residential development.

The provision of well-designed and quality housing on this site would attract both first time buyers and families to a location which is within walking distance from a town centre that provides an excellent array of amenities and services. This is confirmed by Indices of Multiple Deprivation Data (as published by the DCLG) which demonstrates that Rochford has a significantly above average level of local
service provision. This excellent provision invariably means that new residents would be likely to use local shops and services, meaning investment into local businesses will increase and Rochford's small businesses will benefit.
As demonstrated in Rochford Districts Council's Strategic Environmental Assessment and Sustainability Appraisal, the local population is expected to age significantly over the next period up to 2021, therefore demonstrating a need to encourage working age residents to the area (25% fewer residents aged 25-44 compared to the national average). According to LSL Property Services data, the average first-time house buyer is aged 30 and has a salary 36.5% higher than the overall UK
average, therefore meeting this need for a working age population will also contribute significantly to the local economy through the use of local services and amenities.
The Smith Institute in their report "The Thames Gateway - Where Next?" state that the Thames Gateway (including Rochford) is the largest and most significant growth and regeneration site in the UK. The site location benefits from a wide variety of strong employment centres both locally and in close commuter distance, which would further appeal to the predicted demographic of house buyers on the site with their generally higher salaries than the UK average.
Furthermore, the proposed development would be capable of creating a significant number jobs during the construction phase. In addition, based on Ernst & Young LLP's Economic Impact Assessment for the Berkeley Group (2012), for every additional job created in the construction industry a further 1.53
jobs are created in the wider economy.
It is envisaged that development of this site could also provide new jobs as the proposal will look to include the erection of a new primary school and one local centre.

Environmental

At present the site is farmed monoculture, with little ecological or biodiversity interest. Future development of this site would seek to enhance the ecological value of the site and surrounding area by providing a new landscaped park conducive to attracting new habitats to colonise the site. Development of the site would also provide a landscape buffer to Shoplands equestrian centre heritage
asset, providing a through link to Shoplands and potential eastward connections. Within the site, development would provide a landscape setting for Brookes ecological sites.
Development of the site will also be sympathetic to New Hall Grade II listed building located on the western side of Sutton Road by securing a high quality design which will reflect the area.
Furthermore, the site is within walking distance from Rochford Train Station with regular services to London and Southend and several bus stops are located within a short walk of the site. These operate services between Rochford, Southend, Southend Airport and Rayleigh. This further demonstrates the site is sustainable. It is acknowledged that the site is currently located in the Green Belt. However, given the clear housing need, there is sufficient justification for the release of suitable sites from the Green Belt for the purpose of new housing. The following provides an assessment of the extent to which the land east and west of Sutton Road meets the objectives (or otherwise) of the Green Belt as set out at Paragraph 80 in the
NPPF:

Table 1
Land East and West of Sutton Road
1. to check the unrestricted sprawl of large built-up areas
- Site is defined by strong defensible boundaries formed by the existing Public Safety Zone to Southend Airport, the EA Flood Zones and the existing Purdey's Industrial Estate to the north and Temple Farm Industrial estate to the south as well as the existing road network.
- The development of this site would provide a logical 'rounding off' of the existing urban area.
2. to prevent neighbouring towns merging into one another
- The nearest settlement is Rochford which is located to the North West of the site, there is no settlement to the east of the site and as such development on this site would not risk any coalescence of towns; and
3. to assist in safeguarding the countryside from encroachment
- The site has very limited function in safeguarding the countryside from encroachment given the visual (and actual) separation from the wider countryside arising from the neighbouring land uses, including Purdey's Industrial Estate, London Southend Airport, Fossetts Park and Temple Farm Industrial Estate.
- This area of the countryside is considered to be the least sensitive to change in the Borough, as per the Landscape Assessment undertaken by the Council for the Local Plan evidence base in 2006.
4. to preserve the setting and special character of historic towns
- Land east and west of Sutton Road is not in or adjacent to any Conservation Areas. A high quality designed development which is sympathetic and aims to protect New Hall Grade II Listed Building.
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land
- There is no potential to utilise existing brownfield land in the GB on this site; however, there is a clear and identified need to identify further sites within the countryside to accommodate Rochford's growth needs which should be taken into consideration; and
- Growth in this area would help support local employment which would otherwise result in the closure of the local businesses, increasing the amount of derelict land elsewhere.

Sustainable Development Scorecard Analysis

Taking the above information into account, the scorecard analysis of the proposed site east and west of Sutton Road has concluded that, when assessed against the principle of sustainable development defined by the NPPF, the site achieves a Sustainability Score of 84% and a Parity score of 88%.
The Scorecard analysis shows that the proposed site scores very well for the elements of the environmental dimensions, due to the enhancement in biodiversity, energy efficiency and reduce transport emissions as a result of the proximity to sustainable transport options.
The scheme also scores well on both the economic and social aspects, due to the site's proximity to London Southend Airport, Temple Farm and Purdeys Industrial estate and the provision of a range of housing typologies and tenures.
The proposed development will provide much needed housing to the area, helping to alleviate supply shortages for those who work in nearby areas. Rochford provides a prominent location in which to accommodate additional growth due to the presence of two train stations (Rochford and London Southend Airport) with frequent, sustainable connections to central London and Southend-on-Sea.
The enclosed Sustainable Development Scorecard highlights further sustainable benefits of developing this site for residential use whilst also providing further recommendations to enhance the contributions that such development could make to the wider area.

f. Summary and Conclusions
On behalf of CL, we thank you for the opportunity to comment on the Rochford Local Plan Issues and Options (Stage 1) document. As detailed above the land east and west of Sutton Road will help realise RDC and the wider South Essex Districts aspirations by bringing forward a suitable, achievable and deliverable site to help address the increasing shortfall of suitable land for housing within the area. It
is envisaged that development on the site could provide approximately 1,400 towards RDC's required housing need.
RDC should use this opportunity to strategically review its own boundaries in line with sustainable strategic growth sites of the Emerging Local Plan, especially given the constraints inflicted on the neighbouring districts such as CPBS and SBC. Under 'Duty to Co-operate', South Essex Authorities should encourage a joined up strategic approach to Green Belt review. This would ensure that suitable,
achievable and deliverable sites, such as this one, are brought forward for release, ensuring that the housing needs are met and, in turn, the permanence of the revised boundaries throughout and beyond the life of the plan are retained.
Given the clear shortfall in housing delivery within the Rochford District and South Essex district as a whole and the number of constraints on land available, it is vital that new suitable, deliverable and achievable sites come forward, where possible, to help deliver the growing housing need. This includes sites that fall within constraints such as the countryside and in some instances the Green Belt. With this in mind it is critical to acknowledge that the site does not serve a clear Green Belt purpose (as set out in Paragraph 80 of the NPPF).

For the reasons given in Table 1, the land east and west of Sutton Road should be excluded from the Green Belt through the undertaking of a Green Belt review. The development of this site would provide a suitable extension to the existing development boundary as the site is defined by a strong defensible boundary formed by the existing Public Safety Zone to London Southend Airport and the existing road network.
Through development of the site there is also potential to make several infrastructure improvements to the local road network which will have wider benefits for the South Essex Districts.