Issues and Options Document

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council in
support of land to the south of the former Adult Community Learning Centre ("ACL Centre"),
Rocheway, Rochford (hereby referred to as the "Site").
1.2 The Site is owned by Essex County Council ("ECC") and is currently designated as open space in
the adopted Local Plan. It is used under licence for 10 months of the year by Hambro Colts, a local
youth football team which has aspirations to relocate back to its original home in Rayleigh and is
working collaboratively with ECC to do so. The site is not used for any other purpose despite its
designation.
1.3 The New Local Plan presents Rochford District Council (RDC) with an opportunity to take a
comprehensive approach to the consideration of open space provision alongside housing and
employment strategies, considering the re-provision of existing open spaces where this would
support sustainable patterns of development, where appropriate. This should be informed by
emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
1.4 In this context we therefore consider that the Site has excellent residential redevelopment potential
taking account of its sustainable location within walking distance of Rochford town centre and the
opportunity presented by the extant planning permission for the redevelopment of the former ACL
Centre, granted under 17/00102/FUL, which would provide means of vehicle access to the Site
from the north.
Summary of representations
1.5 Taking account of the above, our representations may be summarised as follows:
● We consider the RDC should plan to meet its full objectively assessed housing need across
the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order
settlements in the hierarchy, such as Rochford;
● We consider that RDC needs to undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate.

2.0 The Site

2.1 The extent of the Site is shown on the accompanying plan at Appendix 1 of this document. The Site is currently designated as open space under adopted policy OSL1 and it falls within the Green Belt.

*PLEASE SEE ATTACHMENT FOR MAP* Above: The Site in context. Note its proximity to Rochford town centre approximately 400 metres to the west.

2.2 The Site is formed of playing fields to the south of the former ACL Centre, constructed in the mid-
1930s as a school which was later converted to its most recent use. The designated open space to the south of the ACL was therefore originally intended as a playing field for the school and not as a purpose built public space.

2.3 The Site is defined by strong physical hedgerow boundaries to its western, southern and eastern sides. Designated amenity open space at Millview Meadows is immediately to the west of the site and arable agricultural land is to the east. The Site located within easy walking distance of Rochford town centre's many services, facilities and retail offer via safe, convenient and well-lit pedestrian routes. Rochford town centre also offers regular bus routes to Southend-on-Sea and Rayleigh and mainline railway links to London Liverpool Street and London Southend Airport. The Site is considered to be sustainably located.

The playing pitches on the Site are currently used under licence for 10 months of the year by the
Hambro Colts, a Rayleigh-based youth football team, for training purposes and on matchdays. The
pitches remain unused for the remainder of the monthly schedule. The Hambro Colts temporarily
relocated from Rayleigh to the current Rocheway Site some years ago, but due to a lack of
available alternative site in the Rayleigh area, have not been able to return to their home location.
It is the club's ultimate intention to do so and is in collaboration with ECC to ensure that suitable
facilities can be delivered equitably.

2.5 Taking account of these existing constraints, we recognise that the appropriate manner for this development potential to be realised is through the new Local Plan, in full consultation with the relevant statutory bodies. This would ensure that any requirements for the quanta and location of open space re-provision may be devised in a collaborative way and in accordance with emerging evidence of need. We also propose that the Green Belt boundary is amended as part of the new Local Plan so that the Site may be included within a revised development boundary for Rochford.

3.0 The Evidence Base
Strategic Housing Land Availability Assessment
3.1 The Strategic Housing and Economic Land Availability Assessment (SHELAA), prepared in 2017,
identifies that the Site is suitable, available and that housing development is achievable. A copy
of that assessment is contained at Appendix 2 of this document.
Open Space Provision
3.2 The evidence of relevance to the Site includes the Open Space Study (2009) and Playing Pitch
Strategy (2012), both prepared by RDC in support of its adopted Development Plan. They
identified at the time of their publication that:
● The Site is one of 48 outdoor sports facilities in the District, which collectively provide a total of
1.6 hectares per 1000 population (excluding golf courses) across Rochford. This falls slightly
short of the recommended 1.8ha per 1000 population standard;
● When provision is assessed across the District by ward, the ward in which the Site is located
has an identified surplus in provision;
● There is an imbalance in geographical spread of play space provision - players tend to reside
on the western side of the District (i.e. Rayleigh and to the west of the District in Wickford and
Basildon) thus clubs travel further to the east (including Rochford) to use pitches.
● There is a shortage of mini and junior football pitches - note that during its preparation, the
Playing Pitch Strategy identified the opening of a new facility at Priory Chase in Rayleigh which includes three mini pitches and two junior pitches. As this new facility was not considered as part of the study, it is considered that this provision would contribute to the shortage - both in terms of geographical spread and type of playing space; and
● Outdoor sports facilities are one of the least visited types of open space, assessed as being only moderately needed in the District, after other types of open space such as natural and semi-natural greenspaces, amenity spaces and play space;
● The Site at Rocheway is listed in the Open Spaces Study as an "Outdoor Sports Facility" but, unlike other such facilities listed in the document, is not individually assessed. The evidence therefore provides no overall conclusion or commentary on the quality or suitability of the Site for recreational purposes at present. We would expect this to be updated and to include the Site as part of the evidence base underpinning the new Local Plan.

3.3 It is possible to ascertain from the above that any historic under-provision of playing pitches in the District may have been met by the introduction of new dedicated play space in the western side of the District, thereby re-balancing an uneven geographical spread previously weighted more heavily to the east.

3.4 It is there of utmost important that RDC updates its assessment of open space provision and need as part of the new Local Plan, including all sites currently designated as open space including an assessment of the Rocheway Site.

4.0 Responses to Issues and Options Questionnaire

4.1 Taking account of the above, we set out our responses to the questions raised in the Issues and Options document which are of relevance to Rochford and to the Site.

Strategic Priority 1: The homes and jobs needed in the area
Question SP1.1 - We have a real identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?
Our comments on the identified issues in respect of objectively assessed housing need:

4.2 We support RDC's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District.

4.3 We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18).
The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery.
We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the Framework, which clearly requires local
planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence
base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

Our comments on the identified options in respect of objectively assessed need:

4.4 The options as set out are:
A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

4.5 Taking account of the issues highlighted above, we consider that Option A is the most appropriate; RDC should seek to provide as much of the district's housing need within its own area. If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

4.6 RDC should therefore plan to meet its full OAHN within its own administrative boundaries as part of the new Local Plan.

Question SP1.3 - How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?
Our comments on the issues:

4.7 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011), as follows:

TIER SETTLEMENTS
1 Rayleigh;
Rochford / Ashingdon;
Hockley / Hawkwell.
2 Hullbridge;
Great Wakering
3 Canewdon
4 All other settlements

4.8 The table shows that Rochford sits within the top tier of settlements in the adopted Core Strategy.

Having regard to its sustainable location with easy access to public transport opportunities including mainline rail and London Southend Airport, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core
Strategy was adopted.

Our comments on the options:
4.9 The realistic options as set out are:
A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
B. Increase density on allocated residential sites
C. Several small extensions to the existing residential area.
D. A number of fewer larger extensions to the existing residential area.
E. A new settlement.

We consider that option D is the most appropriate method of meeting RDC's housing needs.
Taking account of the district's spatial and environmental characteristics, existing settlement
hierarchy and structure, several fewer larger extensions to existing sustainable settlements
including Rochford provide the only realistic method of delivering on the scale required to meet
RDC's full OAHN.
4.11 Our reasoning for this approach is because options A and B would drastically alter the character
of existing settlements and residential land allocations to the extent that would be damaging to
existing character and environmentally. Furthermore these options would be ineffective in meeting
the scale of OAHN the Plan needs to accommodate over the next 20 years.
4.12 We do not consider that Option C would deliver sufficient CIL or s106 receipts to enable the
cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

4.13 Option E would require such substantial infrastructure and funding to make development both acceptable and deliverable and this would seriously inhibit the ability of development to deliver other planning policy objectives, such as affordable housing provision. In any event, we do not consider that the district displays the type of spatial characteristics that could allow it to successfully accommodate a new settlement under Option E.

4.14 This means that the only reasonable option is Option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rochford, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements and CIL to mitigate the impact of any scheme. We agree with and support this approach.

Strategic Priority 4: Supporting Health, Community and Culture

Question SP4.3 - How do we plan to meet the needs for open space, sports and recreational facilities across the district over the next 20 years?
Our comments on the identified issues:

4.15 We note and support RDC in updating its evidence on the demand for playing pitches and that this is needed to inform the planning of future provision. We also support the collaboration with neighbouring authorities on a strategic scale because this would capture trends of movement to and from areas of open space that might otherwise remain unidentified. It is evident from the existing evidence base (refer to section 3 of this document above) that it is not possible for RDC to make informed (and therefore sound) decisions on spatial planning matters without first having a full appreciation of the quantum and quality of all existing open space within the District, including the Rocheway Site.

We also consider that the updated evidence should form part of a comprehensive strategy that considers housing and economic development needs in the round. This is particularly important because as Rochford is a Green Belt authority, it falls to be considered under Framework paragraph 84 in which RDC will need to consider the need to promote sustainable patterns of development as part of a Green Belt Review. Furthermore, Framework paragraph 74 allows the replacement of existing open space with equivalent or better provision in terms of quality and quantity in suitable locations.

4.17 Where under-utilised open space exists in sustainable locations, it would be inappropriate for RDC to overlook the development potential of such sites if such opportunities were considered alongside proposals for their re-provision in more suitable locations, where appropriate.

4.18 The policy approach to this is supported by National Planning Policy Framework paragraph 158 which, in respect of plan-making, says that "local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated and that they take full account of relevant market and economic signals." Furthermore, paragraph 70 says that planning policies and decisions should ensure an integrated approach to considering the location of housing, economic uses and community facilities and services."

4.19 We consider that RDC should use the Local Plan Review to comprehensively consider its approach to the provision and location of open spaces so that opportunities for their use and participation in sport may be maximised. Such an approach would enable new development to be delivered in the most sustainable locations, boosting the health of the community, therefore delivering a range of wider sustainability objectives.
Our comments on the identified options:
4.20 The options set out are:
A. Retain, and where necessary update, the existing overarching policy on open spaces.
B. Retain, and where necessary update, our current policy on existing open space.
C. Retain, and where necessary update, our current policy on new open space.
D. Retain, and where necessary update, our current policies.

4.21 We consider that RDC should pursue option B. We recognise the value of designated existing open space but the policy must be updated where relevant to properly reflect the most up-to-date evidence of identified local need. This should take account of shifts in patterns of development, take account of new development and changing trends in use of open space, including playing pitches. Crucially the evidence needs to fully assess in quantitative and qualitative terms the quality of all presently designated open spaces across the district, including the Rocheway Site.

4.22 The designated open space at the Site on Rocheway is only used by one youth football team under licence for 10 months of the year. It is not used by any other group at any other point despite its open space designation. If the existing youth football team were to relocate to premises better suited to its requirements, coupled with an emerging RDC open space strategy that enables the re-apportionment of open space where evidenced, this would present an excellent opportunity for the Site to be re-allocated for residential development; in a sustainable location. This would make
best use of underutilised land and would promote sustainable patterns of development. We recognise and would support the reapportionment of designated playing pitches undertaken in full collaboration with Sport England.

Strategic Priority 5: Protecting and Enhancing our Environment

SP5.1 - How do we balance protection of the district's Green Belt that meets the five Green
Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

Our comments on the issue are as follows:

4.23 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be posible to balance these competing objectives by ensuring that a fully up-to-date evidence base is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

4.24 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries
(paragraph 84). Furthermore, it says that local planning authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).
4.25 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.
Our comments on the options:
A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
B. Amend the current Green Belt policy in the Core Strategy.
C. Do not have a policy on the Green Belt.

4.26 We support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's FOAN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A Green
Belt Review would enable RDC to assess land parcels against the five Green Belt purposes:
● to check the unrestricted sprawl of large built-up areas;
● to prevent neighbouring towns merging into one another;
● to assist in safeguarding the countryside from encroachment;
● to preserve the setting and special character of historic towns; and
● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4.27 Only once the Green Belt Review is complete, RDC may then come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

5.0 Summary

5.1 These representations have been prepared on behalf of Essex Housing, Essex County Council, in support of the Land south of the former Adult Community Learning Centre, Rocheway, Rochford.
5.2 The site is currently designated as open space in the Local Plan but it is only used by one youth football team, Hambro Colts, who have aspirations to relocate back to a suitable site closer to their original home in Rayleigh. The Colts are in collaboration with ECC to enable them to do so.
Allocation of this underused, yet sustainably located, parcel of land for residential development would enable Rochford District Council to:
● Promote sustainable patterns of development in the New Local Plan; and
● Plan for open space and playing pitch provision in a comprehensive manner, taking account of
emerging evidence of need, housing and employment growth.
5.3 Our review of RDC's evidence base of relevance to open space provision reveals that it needs to be fully updated as part of the new Local Plan process and that its scope needs to include all sites currently designated as open space. The evidence underpinning the adopted Development Plan suggests that this is presently not the case. Only with a comprehensive assessment of such provision could RDC make fully informed, robust and therefore sound planning policy decisions on the District's growth.
5.4 In conclusion we therefore consider that:
● RDC should plan to meet its full objectively assessed housing need across the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order settlements in the hierarchy, such as Rochford;
● RDC should undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate. This should be informed by emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
● The Site is considered favourably in the SHELAA in which it is defined as suitable, available and that development would be achievable.

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council in
support of land to the south of the former Adult Community Learning Centre ("ACL Centre"),
Rocheway, Rochford (hereby referred to as the "Site").
1.2 The Site is owned by Essex County Council ("ECC") and is currently designated as open space in
the adopted Local Plan. It is used under licence for 10 months of the year by Hambro Colts, a local
youth football team which has aspirations to relocate back to its original home in Rayleigh and is
working collaboratively with ECC to do so. The site is not used for any other purpose despite its
designation.
1.3 The New Local Plan presents Rochford District Council (RDC) with an opportunity to take a
comprehensive approach to the consideration of open space provision alongside housing and
employment strategies, considering the re-provision of existing open spaces where this would
support sustainable patterns of development, where appropriate. This should be informed by
emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
1.4 In this context we therefore consider that the Site has excellent residential redevelopment potential
taking account of its sustainable location within walking distance of Rochford town centre and the
opportunity presented by the extant planning permission for the redevelopment of the former ACL
Centre, granted under 17/00102/FUL, which would provide means of vehicle access to the Site
from the north.
Summary of representations
1.5 Taking account of the above, our representations may be summarised as follows:
● We consider the RDC should plan to meet its full objectively assessed housing need across
the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order
settlements in the hierarchy, such as Rochford;
● We consider that RDC needs to undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate.

2.0 The Site

2.1 The extent of the Site is shown on the accompanying plan at Appendix 1 of this document. The Site is currently designated as open space under adopted policy OSL1 and it falls within the Green Belt.

*PLEASE SEE ATTACHMENT FOR MAP* Above: The Site in context. Note its proximity to Rochford town centre approximately 400 metres to the west.

2.2 The Site is formed of playing fields to the south of the former ACL Centre, constructed in the mid-
1930s as a school which was later converted to its most recent use. The designated open space to the south of the ACL was therefore originally intended as a playing field for the school and not as a purpose built public space.

2.3 The Site is defined by strong physical hedgerow boundaries to its western, southern and eastern sides. Designated amenity open space at Millview Meadows is immediately to the west of the site and arable agricultural land is to the east. The Site located within easy walking distance of Rochford town centre's many services, facilities and retail offer via safe, convenient and well-lit pedestrian routes. Rochford town centre also offers regular bus routes to Southend-on-Sea and Rayleigh and mainline railway links to London Liverpool Street and London Southend Airport. The Site is considered to be sustainably located.

The playing pitches on the Site are currently used under licence for 10 months of the year by the
Hambro Colts, a Rayleigh-based youth football team, for training purposes and on matchdays. The
pitches remain unused for the remainder of the monthly schedule. The Hambro Colts temporarily
relocated from Rayleigh to the current Rocheway Site some years ago, but due to a lack of
available alternative site in the Rayleigh area, have not been able to return to their home location.
It is the club's ultimate intention to do so and is in collaboration with ECC to ensure that suitable
facilities can be delivered equitably.

2.5 Taking account of these existing constraints, we recognise that the appropriate manner for this development potential to be realised is through the new Local Plan, in full consultation with the relevant statutory bodies. This would ensure that any requirements for the quanta and location of open space re-provision may be devised in a collaborative way and in accordance with emerging evidence of need. We also propose that the Green Belt boundary is amended as part of the new Local Plan so that the Site may be included within a revised development boundary for Rochford.

3.0 The Evidence Base
Strategic Housing Land Availability Assessment
3.1 The Strategic Housing and Economic Land Availability Assessment (SHELAA), prepared in 2017,
identifies that the Site is suitable, available and that housing development is achievable. A copy
of that assessment is contained at Appendix 2 of this document.
Open Space Provision
3.2 The evidence of relevance to the Site includes the Open Space Study (2009) and Playing Pitch
Strategy (2012), both prepared by RDC in support of its adopted Development Plan. They
identified at the time of their publication that:
● The Site is one of 48 outdoor sports facilities in the District, which collectively provide a total of
1.6 hectares per 1000 population (excluding golf courses) across Rochford. This falls slightly
short of the recommended 1.8ha per 1000 population standard;
● When provision is assessed across the District by ward, the ward in which the Site is located
has an identified surplus in provision;
● There is an imbalance in geographical spread of play space provision - players tend to reside
on the western side of the District (i.e. Rayleigh and to the west of the District in Wickford and
Basildon) thus clubs travel further to the east (including Rochford) to use pitches.
● There is a shortage of mini and junior football pitches - note that during its preparation, the
Playing Pitch Strategy identified the opening of a new facility at Priory Chase in Rayleigh which includes three mini pitches and two junior pitches. As this new facility was not considered as part of the study, it is considered that this provision would contribute to the shortage - both in terms of geographical spread and type of playing space; and
● Outdoor sports facilities are one of the least visited types of open space, assessed as being only moderately needed in the District, after other types of open space such as natural and semi-natural greenspaces, amenity spaces and play space;
● The Site at Rocheway is listed in the Open Spaces Study as an "Outdoor Sports Facility" but, unlike other such facilities listed in the document, is not individually assessed. The evidence therefore provides no overall conclusion or commentary on the quality or suitability of the Site for recreational purposes at present. We would expect this to be updated and to include the Site as part of the evidence base underpinning the new Local Plan.

3.3 It is possible to ascertain from the above that any historic under-provision of playing pitches in the District may have been met by the introduction of new dedicated play space in the western side of the District, thereby re-balancing an uneven geographical spread previously weighted more heavily to the east.

3.4 It is there of utmost important that RDC updates its assessment of open space provision and need as part of the new Local Plan, including all sites currently designated as open space including an assessment of the Rocheway Site.

4.0 Responses to Issues and Options Questionnaire

4.1 Taking account of the above, we set out our responses to the questions raised in the Issues and Options document which are of relevance to Rochford and to the Site.

Strategic Priority 1: The homes and jobs needed in the area
Question SP1.1 - We have a real identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?
Our comments on the identified issues in respect of objectively assessed housing need:

4.2 We support RDC's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District.

4.3 We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18).
The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery.
We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the Framework, which clearly requires local
planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence
base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

Our comments on the identified options in respect of objectively assessed need:

4.4 The options as set out are:
A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

4.5 Taking account of the issues highlighted above, we consider that Option A is the most appropriate; RDC should seek to provide as much of the district's housing need within its own area. If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

4.6 RDC should therefore plan to meet its full OAHN within its own administrative boundaries as part of the new Local Plan.

Question SP1.3 - How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?
Our comments on the issues:

4.7 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011), as follows:

TIER SETTLEMENTS
1 Rayleigh;
Rochford / Ashingdon;
Hockley / Hawkwell.
2 Hullbridge;
Great Wakering
3 Canewdon
4 All other settlements

4.8 The table shows that Rochford sits within the top tier of settlements in the adopted Core Strategy.

Having regard to its sustainable location with easy access to public transport opportunities including mainline rail and London Southend Airport, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core
Strategy was adopted.

Our comments on the options:
4.9 The realistic options as set out are:
A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
B. Increase density on allocated residential sites
C. Several small extensions to the existing residential area.
D. A number of fewer larger extensions to the existing residential area.
E. A new settlement.

We consider that option D is the most appropriate method of meeting RDC's housing needs.
Taking account of the district's spatial and environmental characteristics, existing settlement
hierarchy and structure, several fewer larger extensions to existing sustainable settlements
including Rochford provide the only realistic method of delivering on the scale required to meet
RDC's full OAHN.
4.11 Our reasoning for this approach is because options A and B would drastically alter the character
of existing settlements and residential land allocations to the extent that would be damaging to
existing character and environmentally. Furthermore these options would be ineffective in meeting
the scale of OAHN the Plan needs to accommodate over the next 20 years.
4.12 We do not consider that Option C would deliver sufficient CIL or s106 receipts to enable the
cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

4.13 Option E would require such substantial infrastructure and funding to make development both acceptable and deliverable and this would seriously inhibit the ability of development to deliver other planning policy objectives, such as affordable housing provision. In any event, we do not consider that the district displays the type of spatial characteristics that could allow it to successfully accommodate a new settlement under Option E.

4.14 This means that the only reasonable option is Option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rochford, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements and CIL to mitigate the impact of any scheme. We agree with and support this approach.

Strategic Priority 4: Supporting Health, Community and Culture

Question SP4.3 - How do we plan to meet the needs for open space, sports and recreational facilities across the district over the next 20 years?
Our comments on the identified issues:

4.15 We note and support RDC in updating its evidence on the demand for playing pitches and that this is needed to inform the planning of future provision. We also support the collaboration with neighbouring authorities on a strategic scale because this would capture trends of movement to and from areas of open space that might otherwise remain unidentified. It is evident from the existing evidence base (refer to section 3 of this document above) that it is not possible for RDC to make informed (and therefore sound) decisions on spatial planning matters without first having a full appreciation of the quantum and quality of all existing open space within the District, including the Rocheway Site.

We also consider that the updated evidence should form part of a comprehensive strategy that considers housing and economic development needs in the round. This is particularly important because as Rochford is a Green Belt authority, it falls to be considered under Framework paragraph 84 in which RDC will need to consider the need to promote sustainable patterns of development as part of a Green Belt Review. Furthermore, Framework paragraph 74 allows the replacement of existing open space with equivalent or better provision in terms of quality and quantity in suitable locations.

4.17 Where under-utilised open space exists in sustainable locations, it would be inappropriate for RDC to overlook the development potential of such sites if such opportunities were considered alongside proposals for their re-provision in more suitable locations, where appropriate.

4.18 The policy approach to this is supported by National Planning Policy Framework paragraph 158 which, in respect of plan-making, says that "local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated and that they take full account of relevant market and economic signals." Furthermore, paragraph 70 says that planning policies and decisions should ensure an integrated approach to considering the location of housing, economic uses and community facilities and services."

4.19 We consider that RDC should use the Local Plan Review to comprehensively consider its approach to the provision and location of open spaces so that opportunities for their use and participation in sport may be maximised. Such an approach would enable new development to be delivered in the most sustainable locations, boosting the health of the community, therefore delivering a range of wider sustainability objectives.
Our comments on the identified options:
4.20 The options set out are:
A. Retain, and where necessary update, the existing overarching policy on open spaces.
B. Retain, and where necessary update, our current policy on existing open space.
C. Retain, and where necessary update, our current policy on new open space.
D. Retain, and where necessary update, our current policies.

4.21 We consider that RDC should pursue option B. We recognise the value of designated existing open space but the policy must be updated where relevant to properly reflect the most up-to-date evidence of identified local need. This should take account of shifts in patterns of development, take account of new development and changing trends in use of open space, including playing pitches. Crucially the evidence needs to fully assess in quantitative and qualitative terms the quality of all presently designated open spaces across the district, including the Rocheway Site.

4.22 The designated open space at the Site on Rocheway is only used by one youth football team under licence for 10 months of the year. It is not used by any other group at any other point despite its open space designation. If the existing youth football team were to relocate to premises better suited to its requirements, coupled with an emerging RDC open space strategy that enables the re-apportionment of open space where evidenced, this would present an excellent opportunity for the Site to be re-allocated for residential development; in a sustainable location. This would make
best use of underutilised land and would promote sustainable patterns of development. We recognise and would support the reapportionment of designated playing pitches undertaken in full collaboration with Sport England.

Strategic Priority 5: Protecting and Enhancing our Environment

SP5.1 - How do we balance protection of the district's Green Belt that meets the five Green
Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

Our comments on the issue are as follows:

4.23 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be posible to balance these competing objectives by ensuring that a fully up-to-date evidence base is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

4.24 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries
(paragraph 84). Furthermore, it says that local planning authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).
4.25 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.
Our comments on the options:
A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
B. Amend the current Green Belt policy in the Core Strategy.
C. Do not have a policy on the Green Belt.

4.26 We support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's FOAN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A Green
Belt Review would enable RDC to assess land parcels against the five Green Belt purposes:
● to check the unrestricted sprawl of large built-up areas;
● to prevent neighbouring towns merging into one another;
● to assist in safeguarding the countryside from encroachment;
● to preserve the setting and special character of historic towns; and
● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4.27 Only once the Green Belt Review is complete, RDC may then come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

5.0 Summary

5.1 These representations have been prepared on behalf of Essex Housing, Essex County Council, in support of the Land south of the former Adult Community Learning Centre, Rocheway, Rochford.
5.2 The site is currently designated as open space in the Local Plan but it is only used by one youth football team, Hambro Colts, who have aspirations to relocate back to a suitable site closer to their original home in Rayleigh. The Colts are in collaboration with ECC to enable them to do so.
Allocation of this underused, yet sustainably located, parcel of land for residential development would enable Rochford District Council to:
● Promote sustainable patterns of development in the New Local Plan; and
● Plan for open space and playing pitch provision in a comprehensive manner, taking account of
emerging evidence of need, housing and employment growth.
5.3 Our review of RDC's evidence base of relevance to open space provision reveals that it needs to be fully updated as part of the new Local Plan process and that its scope needs to include all sites currently designated as open space. The evidence underpinning the adopted Development Plan suggests that this is presently not the case. Only with a comprehensive assessment of such provision could RDC make fully informed, robust and therefore sound planning policy decisions on the District's growth.
5.4 In conclusion we therefore consider that:
● RDC should plan to meet its full objectively assessed housing need across the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order settlements in the hierarchy, such as Rochford;
● RDC should undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate. This should be informed by emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
● The Site is considered favourably in the SHELAA in which it is defined as suitable, available and that development would be achievable.

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council in
support of land to the south of the former Adult Community Learning Centre ("ACL Centre"),
Rocheway, Rochford (hereby referred to as the "Site").
1.2 The Site is owned by Essex County Council ("ECC") and is currently designated as open space in
the adopted Local Plan. It is used under licence for 10 months of the year by Hambro Colts, a local
youth football team which has aspirations to relocate back to its original home in Rayleigh and is
working collaboratively with ECC to do so. The site is not used for any other purpose despite its
designation.
1.3 The New Local Plan presents Rochford District Council (RDC) with an opportunity to take a
comprehensive approach to the consideration of open space provision alongside housing and
employment strategies, considering the re-provision of existing open spaces where this would
support sustainable patterns of development, where appropriate. This should be informed by
emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
1.4 In this context we therefore consider that the Site has excellent residential redevelopment potential
taking account of its sustainable location within walking distance of Rochford town centre and the
opportunity presented by the extant planning permission for the redevelopment of the former ACL
Centre, granted under 17/00102/FUL, which would provide means of vehicle access to the Site
from the north.
Summary of representations
1.5 Taking account of the above, our representations may be summarised as follows:
● We consider the RDC should plan to meet its full objectively assessed housing need across
the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order
settlements in the hierarchy, such as Rochford;
● We consider that RDC needs to undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate.

2.0 The Site

2.1 The extent of the Site is shown on the accompanying plan at Appendix 1 of this document. The Site is currently designated as open space under adopted policy OSL1 and it falls within the Green Belt.

*PLEASE SEE ATTACHMENT FOR MAP* Above: The Site in context. Note its proximity to Rochford town centre approximately 400 metres to the west.

2.2 The Site is formed of playing fields to the south of the former ACL Centre, constructed in the mid-
1930s as a school which was later converted to its most recent use. The designated open space to the south of the ACL was therefore originally intended as a playing field for the school and not as a purpose built public space.

2.3 The Site is defined by strong physical hedgerow boundaries to its western, southern and eastern sides. Designated amenity open space at Millview Meadows is immediately to the west of the site and arable agricultural land is to the east. The Site located within easy walking distance of Rochford town centre's many services, facilities and retail offer via safe, convenient and well-lit pedestrian routes. Rochford town centre also offers regular bus routes to Southend-on-Sea and Rayleigh and mainline railway links to London Liverpool Street and London Southend Airport. The Site is considered to be sustainably located.

The playing pitches on the Site are currently used under licence for 10 months of the year by the
Hambro Colts, a Rayleigh-based youth football team, for training purposes and on matchdays. The
pitches remain unused for the remainder of the monthly schedule. The Hambro Colts temporarily
relocated from Rayleigh to the current Rocheway Site some years ago, but due to a lack of
available alternative site in the Rayleigh area, have not been able to return to their home location.
It is the club's ultimate intention to do so and is in collaboration with ECC to ensure that suitable
facilities can be delivered equitably.

2.5 Taking account of these existing constraints, we recognise that the appropriate manner for this development potential to be realised is through the new Local Plan, in full consultation with the relevant statutory bodies. This would ensure that any requirements for the quanta and location of open space re-provision may be devised in a collaborative way and in accordance with emerging evidence of need. We also propose that the Green Belt boundary is amended as part of the new Local Plan so that the Site may be included within a revised development boundary for Rochford.

3.0 The Evidence Base
Strategic Housing Land Availability Assessment
3.1 The Strategic Housing and Economic Land Availability Assessment (SHELAA), prepared in 2017,
identifies that the Site is suitable, available and that housing development is achievable. A copy
of that assessment is contained at Appendix 2 of this document.
Open Space Provision
3.2 The evidence of relevance to the Site includes the Open Space Study (2009) and Playing Pitch
Strategy (2012), both prepared by RDC in support of its adopted Development Plan. They
identified at the time of their publication that:
● The Site is one of 48 outdoor sports facilities in the District, which collectively provide a total of
1.6 hectares per 1000 population (excluding golf courses) across Rochford. This falls slightly
short of the recommended 1.8ha per 1000 population standard;
● When provision is assessed across the District by ward, the ward in which the Site is located
has an identified surplus in provision;
● There is an imbalance in geographical spread of play space provision - players tend to reside
on the western side of the District (i.e. Rayleigh and to the west of the District in Wickford and
Basildon) thus clubs travel further to the east (including Rochford) to use pitches.
● There is a shortage of mini and junior football pitches - note that during its preparation, the
Playing Pitch Strategy identified the opening of a new facility at Priory Chase in Rayleigh which includes three mini pitches and two junior pitches. As this new facility was not considered as part of the study, it is considered that this provision would contribute to the shortage - both in terms of geographical spread and type of playing space; and
● Outdoor sports facilities are one of the least visited types of open space, assessed as being only moderately needed in the District, after other types of open space such as natural and semi-natural greenspaces, amenity spaces and play space;
● The Site at Rocheway is listed in the Open Spaces Study as an "Outdoor Sports Facility" but, unlike other such facilities listed in the document, is not individually assessed. The evidence therefore provides no overall conclusion or commentary on the quality or suitability of the Site for recreational purposes at present. We would expect this to be updated and to include the Site as part of the evidence base underpinning the new Local Plan.

3.3 It is possible to ascertain from the above that any historic under-provision of playing pitches in the District may have been met by the introduction of new dedicated play space in the western side of the District, thereby re-balancing an uneven geographical spread previously weighted more heavily to the east.

3.4 It is there of utmost important that RDC updates its assessment of open space provision and need as part of the new Local Plan, including all sites currently designated as open space including an assessment of the Rocheway Site.

4.0 Responses to Issues and Options Questionnaire

4.1 Taking account of the above, we set out our responses to the questions raised in the Issues and Options document which are of relevance to Rochford and to the Site.

Strategic Priority 1: The homes and jobs needed in the area
Question SP1.1 - We have a real identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?
Our comments on the identified issues in respect of objectively assessed housing need:

4.2 We support RDC's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District.

4.3 We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18).
The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery.
We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the Framework, which clearly requires local
planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence
base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

Our comments on the identified options in respect of objectively assessed need:

4.4 The options as set out are:
A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

4.5 Taking account of the issues highlighted above, we consider that Option A is the most appropriate; RDC should seek to provide as much of the district's housing need within its own area. If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

4.6 RDC should therefore plan to meet its full OAHN within its own administrative boundaries as part of the new Local Plan.

Question SP1.3 - How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?
Our comments on the issues:

4.7 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011), as follows:

TIER SETTLEMENTS
1 Rayleigh;
Rochford / Ashingdon;
Hockley / Hawkwell.
2 Hullbridge;
Great Wakering
3 Canewdon
4 All other settlements

4.8 The table shows that Rochford sits within the top tier of settlements in the adopted Core Strategy.

Having regard to its sustainable location with easy access to public transport opportunities including mainline rail and London Southend Airport, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core
Strategy was adopted.

Our comments on the options:
4.9 The realistic options as set out are:
A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
B. Increase density on allocated residential sites
C. Several small extensions to the existing residential area.
D. A number of fewer larger extensions to the existing residential area.
E. A new settlement.

We consider that option D is the most appropriate method of meeting RDC's housing needs.
Taking account of the district's spatial and environmental characteristics, existing settlement
hierarchy and structure, several fewer larger extensions to existing sustainable settlements
including Rochford provide the only realistic method of delivering on the scale required to meet
RDC's full OAHN.
4.11 Our reasoning for this approach is because options A and B would drastically alter the character
of existing settlements and residential land allocations to the extent that would be damaging to
existing character and environmentally. Furthermore these options would be ineffective in meeting
the scale of OAHN the Plan needs to accommodate over the next 20 years.
4.12 We do not consider that Option C would deliver sufficient CIL or s106 receipts to enable the
cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

4.13 Option E would require such substantial infrastructure and funding to make development both acceptable and deliverable and this would seriously inhibit the ability of development to deliver other planning policy objectives, such as affordable housing provision. In any event, we do not consider that the district displays the type of spatial characteristics that could allow it to successfully accommodate a new settlement under Option E.

4.14 This means that the only reasonable option is Option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rochford, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements and CIL to mitigate the impact of any scheme. We agree with and support this approach.

Strategic Priority 4: Supporting Health, Community and Culture

Question SP4.3 - How do we plan to meet the needs for open space, sports and recreational facilities across the district over the next 20 years?
Our comments on the identified issues:

4.15 We note and support RDC in updating its evidence on the demand for playing pitches and that this is needed to inform the planning of future provision. We also support the collaboration with neighbouring authorities on a strategic scale because this would capture trends of movement to and from areas of open space that might otherwise remain unidentified. It is evident from the existing evidence base (refer to section 3 of this document above) that it is not possible for RDC to make informed (and therefore sound) decisions on spatial planning matters without first having a full appreciation of the quantum and quality of all existing open space within the District, including the Rocheway Site.

We also consider that the updated evidence should form part of a comprehensive strategy that considers housing and economic development needs in the round. This is particularly important because as Rochford is a Green Belt authority, it falls to be considered under Framework paragraph 84 in which RDC will need to consider the need to promote sustainable patterns of development as part of a Green Belt Review. Furthermore, Framework paragraph 74 allows the replacement of existing open space with equivalent or better provision in terms of quality and quantity in suitable locations.

4.17 Where under-utilised open space exists in sustainable locations, it would be inappropriate for RDC to overlook the development potential of such sites if such opportunities were considered alongside proposals for their re-provision in more suitable locations, where appropriate.

4.18 The policy approach to this is supported by National Planning Policy Framework paragraph 158 which, in respect of plan-making, says that "local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated and that they take full account of relevant market and economic signals." Furthermore, paragraph 70 says that planning policies and decisions should ensure an integrated approach to considering the location of housing, economic uses and community facilities and services."

4.19 We consider that RDC should use the Local Plan Review to comprehensively consider its approach to the provision and location of open spaces so that opportunities for their use and participation in sport may be maximised. Such an approach would enable new development to be delivered in the most sustainable locations, boosting the health of the community, therefore delivering a range of wider sustainability objectives.
Our comments on the identified options:
4.20 The options set out are:
A. Retain, and where necessary update, the existing overarching policy on open spaces.
B. Retain, and where necessary update, our current policy on existing open space.
C. Retain, and where necessary update, our current policy on new open space.
D. Retain, and where necessary update, our current policies.

4.21 We consider that RDC should pursue option B. We recognise the value of designated existing open space but the policy must be updated where relevant to properly reflect the most up-to-date evidence of identified local need. This should take account of shifts in patterns of development, take account of new development and changing trends in use of open space, including playing pitches. Crucially the evidence needs to fully assess in quantitative and qualitative terms the quality of all presently designated open spaces across the district, including the Rocheway Site.

4.22 The designated open space at the Site on Rocheway is only used by one youth football team under licence for 10 months of the year. It is not used by any other group at any other point despite its open space designation. If the existing youth football team were to relocate to premises better suited to its requirements, coupled with an emerging RDC open space strategy that enables the re-apportionment of open space where evidenced, this would present an excellent opportunity for the Site to be re-allocated for residential development; in a sustainable location. This would make
best use of underutilised land and would promote sustainable patterns of development. We recognise and would support the reapportionment of designated playing pitches undertaken in full collaboration with Sport England.

Strategic Priority 5: Protecting and Enhancing our Environment

SP5.1 - How do we balance protection of the district's Green Belt that meets the five Green
Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

Our comments on the issue are as follows:

4.23 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be posible to balance these competing objectives by ensuring that a fully up-to-date evidence base is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

4.24 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries
(paragraph 84). Furthermore, it says that local planning authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).
4.25 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.
Our comments on the options:
A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
B. Amend the current Green Belt policy in the Core Strategy.
C. Do not have a policy on the Green Belt.

4.26 We support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's FOAN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A Green
Belt Review would enable RDC to assess land parcels against the five Green Belt purposes:
● to check the unrestricted sprawl of large built-up areas;
● to prevent neighbouring towns merging into one another;
● to assist in safeguarding the countryside from encroachment;
● to preserve the setting and special character of historic towns; and
● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4.27 Only once the Green Belt Review is complete, RDC may then come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

5.0 Summary

5.1 These representations have been prepared on behalf of Essex Housing, Essex County Council, in support of the Land south of the former Adult Community Learning Centre, Rocheway, Rochford.
5.2 The site is currently designated as open space in the Local Plan but it is only used by one youth football team, Hambro Colts, who have aspirations to relocate back to a suitable site closer to their original home in Rayleigh. The Colts are in collaboration with ECC to enable them to do so.
Allocation of this underused, yet sustainably located, parcel of land for residential development would enable Rochford District Council to:
● Promote sustainable patterns of development in the New Local Plan; and
● Plan for open space and playing pitch provision in a comprehensive manner, taking account of
emerging evidence of need, housing and employment growth.
5.3 Our review of RDC's evidence base of relevance to open space provision reveals that it needs to be fully updated as part of the new Local Plan process and that its scope needs to include all sites currently designated as open space. The evidence underpinning the adopted Development Plan suggests that this is presently not the case. Only with a comprehensive assessment of such provision could RDC make fully informed, robust and therefore sound planning policy decisions on the District's growth.
5.4 In conclusion we therefore consider that:
● RDC should plan to meet its full objectively assessed housing need across the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order settlements in the hierarchy, such as Rochford;
● RDC should undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate. This should be informed by emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
● The Site is considered favourably in the SHELAA in which it is defined as suitable, available and that development would be achievable.

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council in
support of land to the south of the former Adult Community Learning Centre ("ACL Centre"),
Rocheway, Rochford (hereby referred to as the "Site").
1.2 The Site is owned by Essex County Council ("ECC") and is currently designated as open space in
the adopted Local Plan. It is used under licence for 10 months of the year by Hambro Colts, a local
youth football team which has aspirations to relocate back to its original home in Rayleigh and is
working collaboratively with ECC to do so. The site is not used for any other purpose despite its
designation.
1.3 The New Local Plan presents Rochford District Council (RDC) with an opportunity to take a
comprehensive approach to the consideration of open space provision alongside housing and
employment strategies, considering the re-provision of existing open spaces where this would
support sustainable patterns of development, where appropriate. This should be informed by
emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
1.4 In this context we therefore consider that the Site has excellent residential redevelopment potential
taking account of its sustainable location within walking distance of Rochford town centre and the
opportunity presented by the extant planning permission for the redevelopment of the former ACL
Centre, granted under 17/00102/FUL, which would provide means of vehicle access to the Site
from the north.
Summary of representations
1.5 Taking account of the above, our representations may be summarised as follows:
● We consider the RDC should plan to meet its full objectively assessed housing need across
the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order
settlements in the hierarchy, such as Rochford;
● We consider that RDC needs to undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate.

2.0 The Site

2.1 The extent of the Site is shown on the accompanying plan at Appendix 1 of this document. The Site is currently designated as open space under adopted policy OSL1 and it falls within the Green Belt.

*PLEASE SEE ATTACHMENT FOR MAP* Above: The Site in context. Note its proximity to Rochford town centre approximately 400 metres to the west.

2.2 The Site is formed of playing fields to the south of the former ACL Centre, constructed in the mid-
1930s as a school which was later converted to its most recent use. The designated open space to the south of the ACL was therefore originally intended as a playing field for the school and not as a purpose built public space.

2.3 The Site is defined by strong physical hedgerow boundaries to its western, southern and eastern sides. Designated amenity open space at Millview Meadows is immediately to the west of the site and arable agricultural land is to the east. The Site located within easy walking distance of Rochford town centre's many services, facilities and retail offer via safe, convenient and well-lit pedestrian routes. Rochford town centre also offers regular bus routes to Southend-on-Sea and Rayleigh and mainline railway links to London Liverpool Street and London Southend Airport. The Site is considered to be sustainably located.

The playing pitches on the Site are currently used under licence for 10 months of the year by the
Hambro Colts, a Rayleigh-based youth football team, for training purposes and on matchdays. The
pitches remain unused for the remainder of the monthly schedule. The Hambro Colts temporarily
relocated from Rayleigh to the current Rocheway Site some years ago, but due to a lack of
available alternative site in the Rayleigh area, have not been able to return to their home location.
It is the club's ultimate intention to do so and is in collaboration with ECC to ensure that suitable
facilities can be delivered equitably.

2.5 Taking account of these existing constraints, we recognise that the appropriate manner for this development potential to be realised is through the new Local Plan, in full consultation with the relevant statutory bodies. This would ensure that any requirements for the quanta and location of open space re-provision may be devised in a collaborative way and in accordance with emerging evidence of need. We also propose that the Green Belt boundary is amended as part of the new Local Plan so that the Site may be included within a revised development boundary for Rochford.

3.0 The Evidence Base
Strategic Housing Land Availability Assessment
3.1 The Strategic Housing and Economic Land Availability Assessment (SHELAA), prepared in 2017,
identifies that the Site is suitable, available and that housing development is achievable. A copy
of that assessment is contained at Appendix 2 of this document.
Open Space Provision
3.2 The evidence of relevance to the Site includes the Open Space Study (2009) and Playing Pitch
Strategy (2012), both prepared by RDC in support of its adopted Development Plan. They
identified at the time of their publication that:
● The Site is one of 48 outdoor sports facilities in the District, which collectively provide a total of
1.6 hectares per 1000 population (excluding golf courses) across Rochford. This falls slightly
short of the recommended 1.8ha per 1000 population standard;
● When provision is assessed across the District by ward, the ward in which the Site is located
has an identified surplus in provision;
● There is an imbalance in geographical spread of play space provision - players tend to reside
on the western side of the District (i.e. Rayleigh and to the west of the District in Wickford and
Basildon) thus clubs travel further to the east (including Rochford) to use pitches.
● There is a shortage of mini and junior football pitches - note that during its preparation, the
Playing Pitch Strategy identified the opening of a new facility at Priory Chase in Rayleigh which includes three mini pitches and two junior pitches. As this new facility was not considered as part of the study, it is considered that this provision would contribute to the shortage - both in terms of geographical spread and type of playing space; and
● Outdoor sports facilities are one of the least visited types of open space, assessed as being only moderately needed in the District, after other types of open space such as natural and semi-natural greenspaces, amenity spaces and play space;
● The Site at Rocheway is listed in the Open Spaces Study as an "Outdoor Sports Facility" but, unlike other such facilities listed in the document, is not individually assessed. The evidence therefore provides no overall conclusion or commentary on the quality or suitability of the Site for recreational purposes at present. We would expect this to be updated and to include the Site as part of the evidence base underpinning the new Local Plan.

3.3 It is possible to ascertain from the above that any historic under-provision of playing pitches in the District may have been met by the introduction of new dedicated play space in the western side of the District, thereby re-balancing an uneven geographical spread previously weighted more heavily to the east.

3.4 It is there of utmost important that RDC updates its assessment of open space provision and need as part of the new Local Plan, including all sites currently designated as open space including an assessment of the Rocheway Site.

4.0 Responses to Issues and Options Questionnaire

4.1 Taking account of the above, we set out our responses to the questions raised in the Issues and Options document which are of relevance to Rochford and to the Site.

Strategic Priority 1: The homes and jobs needed in the area
Question SP1.1 - We have a real identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?
Our comments on the identified issues in respect of objectively assessed housing need:

4.2 We support RDC's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District.

4.3 We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18).
The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery.
We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the Framework, which clearly requires local
planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence
base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

Our comments on the identified options in respect of objectively assessed need:

4.4 The options as set out are:
A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

4.5 Taking account of the issues highlighted above, we consider that Option A is the most appropriate; RDC should seek to provide as much of the district's housing need within its own area. If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

4.6 RDC should therefore plan to meet its full OAHN within its own administrative boundaries as part of the new Local Plan.

Question SP1.3 - How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?
Our comments on the issues:

4.7 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011), as follows:

TIER SETTLEMENTS
1 Rayleigh;
Rochford / Ashingdon;
Hockley / Hawkwell.
2 Hullbridge;
Great Wakering
3 Canewdon
4 All other settlements

4.8 The table shows that Rochford sits within the top tier of settlements in the adopted Core Strategy.

Having regard to its sustainable location with easy access to public transport opportunities including mainline rail and London Southend Airport, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core
Strategy was adopted.

Our comments on the options:
4.9 The realistic options as set out are:
A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
B. Increase density on allocated residential sites
C. Several small extensions to the existing residential area.
D. A number of fewer larger extensions to the existing residential area.
E. A new settlement.

We consider that option D is the most appropriate method of meeting RDC's housing needs.
Taking account of the district's spatial and environmental characteristics, existing settlement
hierarchy and structure, several fewer larger extensions to existing sustainable settlements
including Rochford provide the only realistic method of delivering on the scale required to meet
RDC's full OAHN.
4.11 Our reasoning for this approach is because options A and B would drastically alter the character
of existing settlements and residential land allocations to the extent that would be damaging to
existing character and environmentally. Furthermore these options would be ineffective in meeting
the scale of OAHN the Plan needs to accommodate over the next 20 years.
4.12 We do not consider that Option C would deliver sufficient CIL or s106 receipts to enable the
cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

4.13 Option E would require such substantial infrastructure and funding to make development both acceptable and deliverable and this would seriously inhibit the ability of development to deliver other planning policy objectives, such as affordable housing provision. In any event, we do not consider that the district displays the type of spatial characteristics that could allow it to successfully accommodate a new settlement under Option E.

4.14 This means that the only reasonable option is Option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rochford, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements and CIL to mitigate the impact of any scheme. We agree with and support this approach.

Strategic Priority 4: Supporting Health, Community and Culture

Question SP4.3 - How do we plan to meet the needs for open space, sports and recreational facilities across the district over the next 20 years?
Our comments on the identified issues:

4.15 We note and support RDC in updating its evidence on the demand for playing pitches and that this is needed to inform the planning of future provision. We also support the collaboration with neighbouring authorities on a strategic scale because this would capture trends of movement to and from areas of open space that might otherwise remain unidentified. It is evident from the existing evidence base (refer to section 3 of this document above) that it is not possible for RDC to make informed (and therefore sound) decisions on spatial planning matters without first having a full appreciation of the quantum and quality of all existing open space within the District, including the Rocheway Site.

We also consider that the updated evidence should form part of a comprehensive strategy that considers housing and economic development needs in the round. This is particularly important because as Rochford is a Green Belt authority, it falls to be considered under Framework paragraph 84 in which RDC will need to consider the need to promote sustainable patterns of development as part of a Green Belt Review. Furthermore, Framework paragraph 74 allows the replacement of existing open space with equivalent or better provision in terms of quality and quantity in suitable locations.

4.17 Where under-utilised open space exists in sustainable locations, it would be inappropriate for RDC to overlook the development potential of such sites if such opportunities were considered alongside proposals for their re-provision in more suitable locations, where appropriate.

4.18 The policy approach to this is supported by National Planning Policy Framework paragraph 158 which, in respect of plan-making, says that "local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated and that they take full account of relevant market and economic signals." Furthermore, paragraph 70 says that planning policies and decisions should ensure an integrated approach to considering the location of housing, economic uses and community facilities and services."

4.19 We consider that RDC should use the Local Plan Review to comprehensively consider its approach to the provision and location of open spaces so that opportunities for their use and participation in sport may be maximised. Such an approach would enable new development to be delivered in the most sustainable locations, boosting the health of the community, therefore delivering a range of wider sustainability objectives.
Our comments on the identified options:
4.20 The options set out are:
A. Retain, and where necessary update, the existing overarching policy on open spaces.
B. Retain, and where necessary update, our current policy on existing open space.
C. Retain, and where necessary update, our current policy on new open space.
D. Retain, and where necessary update, our current policies.

4.21 We consider that RDC should pursue option B. We recognise the value of designated existing open space but the policy must be updated where relevant to properly reflect the most up-to-date evidence of identified local need. This should take account of shifts in patterns of development, take account of new development and changing trends in use of open space, including playing pitches. Crucially the evidence needs to fully assess in quantitative and qualitative terms the quality of all presently designated open spaces across the district, including the Rocheway Site.

4.22 The designated open space at the Site on Rocheway is only used by one youth football team under licence for 10 months of the year. It is not used by any other group at any other point despite its open space designation. If the existing youth football team were to relocate to premises better suited to its requirements, coupled with an emerging RDC open space strategy that enables the re-apportionment of open space where evidenced, this would present an excellent opportunity for the Site to be re-allocated for residential development; in a sustainable location. This would make
best use of underutilised land and would promote sustainable patterns of development. We recognise and would support the reapportionment of designated playing pitches undertaken in full collaboration with Sport England.

Strategic Priority 5: Protecting and Enhancing our Environment

SP5.1 - How do we balance protection of the district's Green Belt that meets the five Green
Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

Our comments on the issue are as follows:

4.23 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be posible to balance these competing objectives by ensuring that a fully up-to-date evidence base is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

4.24 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries
(paragraph 84). Furthermore, it says that local planning authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).
4.25 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.
Our comments on the options:
A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
B. Amend the current Green Belt policy in the Core Strategy.
C. Do not have a policy on the Green Belt.

4.26 We support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's FOAN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A Green
Belt Review would enable RDC to assess land parcels against the five Green Belt purposes:
● to check the unrestricted sprawl of large built-up areas;
● to prevent neighbouring towns merging into one another;
● to assist in safeguarding the countryside from encroachment;
● to preserve the setting and special character of historic towns; and
● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4.27 Only once the Green Belt Review is complete, RDC may then come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

5.0 Summary

5.1 These representations have been prepared on behalf of Essex Housing, Essex County Council, in support of the Land south of the former Adult Community Learning Centre, Rocheway, Rochford.
5.2 The site is currently designated as open space in the Local Plan but it is only used by one youth football team, Hambro Colts, who have aspirations to relocate back to a suitable site closer to their original home in Rayleigh. The Colts are in collaboration with ECC to enable them to do so.
Allocation of this underused, yet sustainably located, parcel of land for residential development would enable Rochford District Council to:
● Promote sustainable patterns of development in the New Local Plan; and
● Plan for open space and playing pitch provision in a comprehensive manner, taking account of
emerging evidence of need, housing and employment growth.
5.3 Our review of RDC's evidence base of relevance to open space provision reveals that it needs to be fully updated as part of the new Local Plan process and that its scope needs to include all sites currently designated as open space. The evidence underpinning the adopted Development Plan suggests that this is presently not the case. Only with a comprehensive assessment of such provision could RDC make fully informed, robust and therefore sound planning policy decisions on the District's growth.
5.4 In conclusion we therefore consider that:
● RDC should plan to meet its full objectively assessed housing need across the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order settlements in the hierarchy, such as Rochford;
● RDC should undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate. This should be informed by emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
● The Site is considered favourably in the SHELAA in which it is defined as suitable, available and that development would be achievable.

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council in
support of land to the south of the former Adult Community Learning Centre ("ACL Centre"),
Rocheway, Rochford (hereby referred to as the "Site").
1.2 The Site is owned by Essex County Council ("ECC") and is currently designated as open space in
the adopted Local Plan. It is used under licence for 10 months of the year by Hambro Colts, a local
youth football team which has aspirations to relocate back to its original home in Rayleigh and is
working collaboratively with ECC to do so. The site is not used for any other purpose despite its
designation.
1.3 The New Local Plan presents Rochford District Council (RDC) with an opportunity to take a
comprehensive approach to the consideration of open space provision alongside housing and
employment strategies, considering the re-provision of existing open spaces where this would
support sustainable patterns of development, where appropriate. This should be informed by
emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
1.4 In this context we therefore consider that the Site has excellent residential redevelopment potential
taking account of its sustainable location within walking distance of Rochford town centre and the
opportunity presented by the extant planning permission for the redevelopment of the former ACL
Centre, granted under 17/00102/FUL, which would provide means of vehicle access to the Site
from the north.
Summary of representations
1.5 Taking account of the above, our representations may be summarised as follows:
● We consider the RDC should plan to meet its full objectively assessed housing need across
the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order
settlements in the hierarchy, such as Rochford;
● We consider that RDC needs to undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate.

2.0 The Site

2.1 The extent of the Site is shown on the accompanying plan at Appendix 1 of this document. The Site is currently designated as open space under adopted policy OSL1 and it falls within the Green Belt.

*PLEASE SEE ATTACHMENT FOR MAP* Above: The Site in context. Note its proximity to Rochford town centre approximately 400 metres to the west.

2.2 The Site is formed of playing fields to the south of the former ACL Centre, constructed in the mid-
1930s as a school which was later converted to its most recent use. The designated open space to the south of the ACL was therefore originally intended as a playing field for the school and not as a purpose built public space.

2.3 The Site is defined by strong physical hedgerow boundaries to its western, southern and eastern sides. Designated amenity open space at Millview Meadows is immediately to the west of the site and arable agricultural land is to the east. The Site located within easy walking distance of Rochford town centre's many services, facilities and retail offer via safe, convenient and well-lit pedestrian routes. Rochford town centre also offers regular bus routes to Southend-on-Sea and Rayleigh and mainline railway links to London Liverpool Street and London Southend Airport. The Site is considered to be sustainably located.

The playing pitches on the Site are currently used under licence for 10 months of the year by the
Hambro Colts, a Rayleigh-based youth football team, for training purposes and on matchdays. The
pitches remain unused for the remainder of the monthly schedule. The Hambro Colts temporarily
relocated from Rayleigh to the current Rocheway Site some years ago, but due to a lack of
available alternative site in the Rayleigh area, have not been able to return to their home location.
It is the club's ultimate intention to do so and is in collaboration with ECC to ensure that suitable
facilities can be delivered equitably.

2.5 Taking account of these existing constraints, we recognise that the appropriate manner for this development potential to be realised is through the new Local Plan, in full consultation with the relevant statutory bodies. This would ensure that any requirements for the quanta and location of open space re-provision may be devised in a collaborative way and in accordance with emerging evidence of need. We also propose that the Green Belt boundary is amended as part of the new Local Plan so that the Site may be included within a revised development boundary for Rochford.

3.0 The Evidence Base
Strategic Housing Land Availability Assessment
3.1 The Strategic Housing and Economic Land Availability Assessment (SHELAA), prepared in 2017,
identifies that the Site is suitable, available and that housing development is achievable. A copy
of that assessment is contained at Appendix 2 of this document.
Open Space Provision
3.2 The evidence of relevance to the Site includes the Open Space Study (2009) and Playing Pitch
Strategy (2012), both prepared by RDC in support of its adopted Development Plan. They
identified at the time of their publication that:
● The Site is one of 48 outdoor sports facilities in the District, which collectively provide a total of
1.6 hectares per 1000 population (excluding golf courses) across Rochford. This falls slightly
short of the recommended 1.8ha per 1000 population standard;
● When provision is assessed across the District by ward, the ward in which the Site is located
has an identified surplus in provision;
● There is an imbalance in geographical spread of play space provision - players tend to reside
on the western side of the District (i.e. Rayleigh and to the west of the District in Wickford and
Basildon) thus clubs travel further to the east (including Rochford) to use pitches.
● There is a shortage of mini and junior football pitches - note that during its preparation, the
Playing Pitch Strategy identified the opening of a new facility at Priory Chase in Rayleigh which includes three mini pitches and two junior pitches. As this new facility was not considered as part of the study, it is considered that this provision would contribute to the shortage - both in terms of geographical spread and type of playing space; and
● Outdoor sports facilities are one of the least visited types of open space, assessed as being only moderately needed in the District, after other types of open space such as natural and semi-natural greenspaces, amenity spaces and play space;
● The Site at Rocheway is listed in the Open Spaces Study as an "Outdoor Sports Facility" but, unlike other such facilities listed in the document, is not individually assessed. The evidence therefore provides no overall conclusion or commentary on the quality or suitability of the Site for recreational purposes at present. We would expect this to be updated and to include the Site as part of the evidence base underpinning the new Local Plan.

3.3 It is possible to ascertain from the above that any historic under-provision of playing pitches in the District may have been met by the introduction of new dedicated play space in the western side of the District, thereby re-balancing an uneven geographical spread previously weighted more heavily to the east.

3.4 It is there of utmost important that RDC updates its assessment of open space provision and need as part of the new Local Plan, including all sites currently designated as open space including an assessment of the Rocheway Site.

4.0 Responses to Issues and Options Questionnaire

4.1 Taking account of the above, we set out our responses to the questions raised in the Issues and Options document which are of relevance to Rochford and to the Site.

Strategic Priority 1: The homes and jobs needed in the area
Question SP1.1 - We have a real identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?
Our comments on the identified issues in respect of objectively assessed housing need:

4.2 We support RDC's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District.

4.3 We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18).
The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery.
We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the Framework, which clearly requires local
planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence
base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

Our comments on the identified options in respect of objectively assessed need:

4.4 The options as set out are:
A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

4.5 Taking account of the issues highlighted above, we consider that Option A is the most appropriate; RDC should seek to provide as much of the district's housing need within its own area. If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

4.6 RDC should therefore plan to meet its full OAHN within its own administrative boundaries as part of the new Local Plan.

Question SP1.3 - How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?
Our comments on the issues:

4.7 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011), as follows:

TIER SETTLEMENTS
1 Rayleigh;
Rochford / Ashingdon;
Hockley / Hawkwell.
2 Hullbridge;
Great Wakering
3 Canewdon
4 All other settlements

4.8 The table shows that Rochford sits within the top tier of settlements in the adopted Core Strategy.

Having regard to its sustainable location with easy access to public transport opportunities including mainline rail and London Southend Airport, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core
Strategy was adopted.

Our comments on the options:
4.9 The realistic options as set out are:
A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
B. Increase density on allocated residential sites
C. Several small extensions to the existing residential area.
D. A number of fewer larger extensions to the existing residential area.
E. A new settlement.

We consider that option D is the most appropriate method of meeting RDC's housing needs.
Taking account of the district's spatial and environmental characteristics, existing settlement
hierarchy and structure, several fewer larger extensions to existing sustainable settlements
including Rochford provide the only realistic method of delivering on the scale required to meet
RDC's full OAHN.
4.11 Our reasoning for this approach is because options A and B would drastically alter the character
of existing settlements and residential land allocations to the extent that would be damaging to
existing character and environmentally. Furthermore these options would be ineffective in meeting
the scale of OAHN the Plan needs to accommodate over the next 20 years.
4.12 We do not consider that Option C would deliver sufficient CIL or s106 receipts to enable the
cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

4.13 Option E would require such substantial infrastructure and funding to make development both acceptable and deliverable and this would seriously inhibit the ability of development to deliver other planning policy objectives, such as affordable housing provision. In any event, we do not consider that the district displays the type of spatial characteristics that could allow it to successfully accommodate a new settlement under Option E.

4.14 This means that the only reasonable option is Option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rochford, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements and CIL to mitigate the impact of any scheme. We agree with and support this approach.

Strategic Priority 4: Supporting Health, Community and Culture

Question SP4.3 - How do we plan to meet the needs for open space, sports and recreational facilities across the district over the next 20 years?
Our comments on the identified issues:

4.15 We note and support RDC in updating its evidence on the demand for playing pitches and that this is needed to inform the planning of future provision. We also support the collaboration with neighbouring authorities on a strategic scale because this would capture trends of movement to and from areas of open space that might otherwise remain unidentified. It is evident from the existing evidence base (refer to section 3 of this document above) that it is not possible for RDC to make informed (and therefore sound) decisions on spatial planning matters without first having a full appreciation of the quantum and quality of all existing open space within the District, including the Rocheway Site.

We also consider that the updated evidence should form part of a comprehensive strategy that considers housing and economic development needs in the round. This is particularly important because as Rochford is a Green Belt authority, it falls to be considered under Framework paragraph 84 in which RDC will need to consider the need to promote sustainable patterns of development as part of a Green Belt Review. Furthermore, Framework paragraph 74 allows the replacement of existing open space with equivalent or better provision in terms of quality and quantity in suitable locations.

4.17 Where under-utilised open space exists in sustainable locations, it would be inappropriate for RDC to overlook the development potential of such sites if such opportunities were considered alongside proposals for their re-provision in more suitable locations, where appropriate.

4.18 The policy approach to this is supported by National Planning Policy Framework paragraph 158 which, in respect of plan-making, says that "local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated and that they take full account of relevant market and economic signals." Furthermore, paragraph 70 says that planning policies and decisions should ensure an integrated approach to considering the location of housing, economic uses and community facilities and services."

4.19 We consider that RDC should use the Local Plan Review to comprehensively consider its approach to the provision and location of open spaces so that opportunities for their use and participation in sport may be maximised. Such an approach would enable new development to be delivered in the most sustainable locations, boosting the health of the community, therefore delivering a range of wider sustainability objectives.
Our comments on the identified options:
4.20 The options set out are:
A. Retain, and where necessary update, the existing overarching policy on open spaces.
B. Retain, and where necessary update, our current policy on existing open space.
C. Retain, and where necessary update, our current policy on new open space.
D. Retain, and where necessary update, our current policies.

4.21 We consider that RDC should pursue option B. We recognise the value of designated existing open space but the policy must be updated where relevant to properly reflect the most up-to-date evidence of identified local need. This should take account of shifts in patterns of development, take account of new development and changing trends in use of open space, including playing pitches. Crucially the evidence needs to fully assess in quantitative and qualitative terms the quality of all presently designated open spaces across the district, including the Rocheway Site.

4.22 The designated open space at the Site on Rocheway is only used by one youth football team under licence for 10 months of the year. It is not used by any other group at any other point despite its open space designation. If the existing youth football team were to relocate to premises better suited to its requirements, coupled with an emerging RDC open space strategy that enables the re-apportionment of open space where evidenced, this would present an excellent opportunity for the Site to be re-allocated for residential development; in a sustainable location. This would make
best use of underutilised land and would promote sustainable patterns of development. We recognise and would support the reapportionment of designated playing pitches undertaken in full collaboration with Sport England.

Strategic Priority 5: Protecting and Enhancing our Environment

SP5.1 - How do we balance protection of the district's Green Belt that meets the five Green
Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

Our comments on the issue are as follows:

4.23 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be posible to balance these competing objectives by ensuring that a fully up-to-date evidence base is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

4.24 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries
(paragraph 84). Furthermore, it says that local planning authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).
4.25 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.
Our comments on the options:
A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
B. Amend the current Green Belt policy in the Core Strategy.
C. Do not have a policy on the Green Belt.

4.26 We support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's FOAN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A Green
Belt Review would enable RDC to assess land parcels against the five Green Belt purposes:
● to check the unrestricted sprawl of large built-up areas;
● to prevent neighbouring towns merging into one another;
● to assist in safeguarding the countryside from encroachment;
● to preserve the setting and special character of historic towns; and
● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4.27 Only once the Green Belt Review is complete, RDC may then come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

5.0 Summary

5.1 These representations have been prepared on behalf of Essex Housing, Essex County Council, in support of the Land south of the former Adult Community Learning Centre, Rocheway, Rochford.
5.2 The site is currently designated as open space in the Local Plan but it is only used by one youth football team, Hambro Colts, who have aspirations to relocate back to a suitable site closer to their original home in Rayleigh. The Colts are in collaboration with ECC to enable them to do so.
Allocation of this underused, yet sustainably located, parcel of land for residential development would enable Rochford District Council to:
● Promote sustainable patterns of development in the New Local Plan; and
● Plan for open space and playing pitch provision in a comprehensive manner, taking account of
emerging evidence of need, housing and employment growth.
5.3 Our review of RDC's evidence base of relevance to open space provision reveals that it needs to be fully updated as part of the new Local Plan process and that its scope needs to include all sites currently designated as open space. The evidence underpinning the adopted Development Plan suggests that this is presently not the case. Only with a comprehensive assessment of such provision could RDC make fully informed, robust and therefore sound planning policy decisions on the District's growth.
5.4 In conclusion we therefore consider that:
● RDC should plan to meet its full objectively assessed housing need across the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order settlements in the hierarchy, such as Rochford;
● RDC should undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate. This should be informed by emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
● The Site is considered favourably in the SHELAA in which it is defined as suitable, available and that development would be achievable.

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council in
support of land to the south of the former Adult Community Learning Centre ("ACL Centre"),
Rocheway, Rochford (hereby referred to as the "Site").
1.2 The Site is owned by Essex County Council ("ECC") and is currently designated as open space in
the adopted Local Plan. It is used under licence for 10 months of the year by Hambro Colts, a local
youth football team which has aspirations to relocate back to its original home in Rayleigh and is
working collaboratively with ECC to do so. The site is not used for any other purpose despite its
designation.
1.3 The New Local Plan presents Rochford District Council (RDC) with an opportunity to take a
comprehensive approach to the consideration of open space provision alongside housing and
employment strategies, considering the re-provision of existing open spaces where this would
support sustainable patterns of development, where appropriate. This should be informed by
emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
1.4 In this context we therefore consider that the Site has excellent residential redevelopment potential
taking account of its sustainable location within walking distance of Rochford town centre and the
opportunity presented by the extant planning permission for the redevelopment of the former ACL
Centre, granted under 17/00102/FUL, which would provide means of vehicle access to the Site
from the north.
Summary of representations
1.5 Taking account of the above, our representations may be summarised as follows:
● We consider the RDC should plan to meet its full objectively assessed housing need across
the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order
settlements in the hierarchy, such as Rochford;
● We consider that RDC needs to undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate.

2.0 The Site

2.1 The extent of the Site is shown on the accompanying plan at Appendix 1 of this document. The Site is currently designated as open space under adopted policy OSL1 and it falls within the Green Belt.

*PLEASE SEE ATTACHMENT FOR MAP* Above: The Site in context. Note its proximity to Rochford town centre approximately 400 metres to the west.

2.2 The Site is formed of playing fields to the south of the former ACL Centre, constructed in the mid-
1930s as a school which was later converted to its most recent use. The designated open space to the south of the ACL was therefore originally intended as a playing field for the school and not as a purpose built public space.

2.3 The Site is defined by strong physical hedgerow boundaries to its western, southern and eastern sides. Designated amenity open space at Millview Meadows is immediately to the west of the site and arable agricultural land is to the east. The Site located within easy walking distance of Rochford town centre's many services, facilities and retail offer via safe, convenient and well-lit pedestrian routes. Rochford town centre also offers regular bus routes to Southend-on-Sea and Rayleigh and mainline railway links to London Liverpool Street and London Southend Airport. The Site is considered to be sustainably located.

The playing pitches on the Site are currently used under licence for 10 months of the year by the
Hambro Colts, a Rayleigh-based youth football team, for training purposes and on matchdays. The
pitches remain unused for the remainder of the monthly schedule. The Hambro Colts temporarily
relocated from Rayleigh to the current Rocheway Site some years ago, but due to a lack of
available alternative site in the Rayleigh area, have not been able to return to their home location.
It is the club's ultimate intention to do so and is in collaboration with ECC to ensure that suitable
facilities can be delivered equitably.

2.5 Taking account of these existing constraints, we recognise that the appropriate manner for this development potential to be realised is through the new Local Plan, in full consultation with the relevant statutory bodies. This would ensure that any requirements for the quanta and location of open space re-provision may be devised in a collaborative way and in accordance with emerging evidence of need. We also propose that the Green Belt boundary is amended as part of the new Local Plan so that the Site may be included within a revised development boundary for Rochford.

3.0 The Evidence Base
Strategic Housing Land Availability Assessment
3.1 The Strategic Housing and Economic Land Availability Assessment (SHELAA), prepared in 2017,
identifies that the Site is suitable, available and that housing development is achievable. A copy
of that assessment is contained at Appendix 2 of this document.
Open Space Provision
3.2 The evidence of relevance to the Site includes the Open Space Study (2009) and Playing Pitch
Strategy (2012), both prepared by RDC in support of its adopted Development Plan. They
identified at the time of their publication that:
● The Site is one of 48 outdoor sports facilities in the District, which collectively provide a total of
1.6 hectares per 1000 population (excluding golf courses) across Rochford. This falls slightly
short of the recommended 1.8ha per 1000 population standard;
● When provision is assessed across the District by ward, the ward in which the Site is located
has an identified surplus in provision;
● There is an imbalance in geographical spread of play space provision - players tend to reside
on the western side of the District (i.e. Rayleigh and to the west of the District in Wickford and
Basildon) thus clubs travel further to the east (including Rochford) to use pitches.
● There is a shortage of mini and junior football pitches - note that during its preparation, the
Playing Pitch Strategy identified the opening of a new facility at Priory Chase in Rayleigh which includes three mini pitches and two junior pitches. As this new facility was not considered as part of the study, it is considered that this provision would contribute to the shortage - both in terms of geographical spread and type of playing space; and
● Outdoor sports facilities are one of the least visited types of open space, assessed as being only moderately needed in the District, after other types of open space such as natural and semi-natural greenspaces, amenity spaces and play space;
● The Site at Rocheway is listed in the Open Spaces Study as an "Outdoor Sports Facility" but, unlike other such facilities listed in the document, is not individually assessed. The evidence therefore provides no overall conclusion or commentary on the quality or suitability of the Site for recreational purposes at present. We would expect this to be updated and to include the Site as part of the evidence base underpinning the new Local Plan.

3.3 It is possible to ascertain from the above that any historic under-provision of playing pitches in the District may have been met by the introduction of new dedicated play space in the western side of the District, thereby re-balancing an uneven geographical spread previously weighted more heavily to the east.

3.4 It is there of utmost important that RDC updates its assessment of open space provision and need as part of the new Local Plan, including all sites currently designated as open space including an assessment of the Rocheway Site.

4.0 Responses to Issues and Options Questionnaire

4.1 Taking account of the above, we set out our responses to the questions raised in the Issues and Options document which are of relevance to Rochford and to the Site.

Strategic Priority 1: The homes and jobs needed in the area
Question SP1.1 - We have a real identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?
Our comments on the identified issues in respect of objectively assessed housing need:

4.2 We support RDC's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District.

4.3 We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18).
The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery.
We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the Framework, which clearly requires local
planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence
base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

Our comments on the identified options in respect of objectively assessed need:

4.4 The options as set out are:
A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

4.5 Taking account of the issues highlighted above, we consider that Option A is the most appropriate; RDC should seek to provide as much of the district's housing need within its own area. If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

4.6 RDC should therefore plan to meet its full OAHN within its own administrative boundaries as part of the new Local Plan.

Question SP1.3 - How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?
Our comments on the issues:

4.7 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011), as follows:

TIER SETTLEMENTS
1 Rayleigh;
Rochford / Ashingdon;
Hockley / Hawkwell.
2 Hullbridge;
Great Wakering
3 Canewdon
4 All other settlements

4.8 The table shows that Rochford sits within the top tier of settlements in the adopted Core Strategy.

Having regard to its sustainable location with easy access to public transport opportunities including mainline rail and London Southend Airport, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core
Strategy was adopted.

Our comments on the options:
4.9 The realistic options as set out are:
A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
B. Increase density on allocated residential sites
C. Several small extensions to the existing residential area.
D. A number of fewer larger extensions to the existing residential area.
E. A new settlement.

We consider that option D is the most appropriate method of meeting RDC's housing needs.
Taking account of the district's spatial and environmental characteristics, existing settlement
hierarchy and structure, several fewer larger extensions to existing sustainable settlements
including Rochford provide the only realistic method of delivering on the scale required to meet
RDC's full OAHN.
4.11 Our reasoning for this approach is because options A and B would drastically alter the character
of existing settlements and residential land allocations to the extent that would be damaging to
existing character and environmentally. Furthermore these options would be ineffective in meeting
the scale of OAHN the Plan needs to accommodate over the next 20 years.
4.12 We do not consider that Option C would deliver sufficient CIL or s106 receipts to enable the
cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

4.13 Option E would require such substantial infrastructure and funding to make development both acceptable and deliverable and this would seriously inhibit the ability of development to deliver other planning policy objectives, such as affordable housing provision. In any event, we do not consider that the district displays the type of spatial characteristics that could allow it to successfully accommodate a new settlement under Option E.

4.14 This means that the only reasonable option is Option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rochford, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements and CIL to mitigate the impact of any scheme. We agree with and support this approach.

Strategic Priority 4: Supporting Health, Community and Culture

Question SP4.3 - How do we plan to meet the needs for open space, sports and recreational facilities across the district over the next 20 years?
Our comments on the identified issues:

4.15 We note and support RDC in updating its evidence on the demand for playing pitches and that this is needed to inform the planning of future provision. We also support the collaboration with neighbouring authorities on a strategic scale because this would capture trends of movement to and from areas of open space that might otherwise remain unidentified. It is evident from the existing evidence base (refer to section 3 of this document above) that it is not possible for RDC to make informed (and therefore sound) decisions on spatial planning matters without first having a full appreciation of the quantum and quality of all existing open space within the District, including the Rocheway Site.

We also consider that the updated evidence should form part of a comprehensive strategy that considers housing and economic development needs in the round. This is particularly important because as Rochford is a Green Belt authority, it falls to be considered under Framework paragraph 84 in which RDC will need to consider the need to promote sustainable patterns of development as part of a Green Belt Review. Furthermore, Framework paragraph 74 allows the replacement of existing open space with equivalent or better provision in terms of quality and quantity in suitable locations.

4.17 Where under-utilised open space exists in sustainable locations, it would be inappropriate for RDC to overlook the development potential of such sites if such opportunities were considered alongside proposals for their re-provision in more suitable locations, where appropriate.

4.18 The policy approach to this is supported by National Planning Policy Framework paragraph 158 which, in respect of plan-making, says that "local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated and that they take full account of relevant market and economic signals." Furthermore, paragraph 70 says that planning policies and decisions should ensure an integrated approach to considering the location of housing, economic uses and community facilities and services."

4.19 We consider that RDC should use the Local Plan Review to comprehensively consider its approach to the provision and location of open spaces so that opportunities for their use and participation in sport may be maximised. Such an approach would enable new development to be delivered in the most sustainable locations, boosting the health of the community, therefore delivering a range of wider sustainability objectives.
Our comments on the identified options:
4.20 The options set out are:
A. Retain, and where necessary update, the existing overarching policy on open spaces.
B. Retain, and where necessary update, our current policy on existing open space.
C. Retain, and where necessary update, our current policy on new open space.
D. Retain, and where necessary update, our current policies.

4.21 We consider that RDC should pursue option B. We recognise the value of designated existing open space but the policy must be updated where relevant to properly reflect the most up-to-date evidence of identified local need. This should take account of shifts in patterns of development, take account of new development and changing trends in use of open space, including playing pitches. Crucially the evidence needs to fully assess in quantitative and qualitative terms the quality of all presently designated open spaces across the district, including the Rocheway Site.

4.22 The designated open space at the Site on Rocheway is only used by one youth football team under licence for 10 months of the year. It is not used by any other group at any other point despite its open space designation. If the existing youth football team were to relocate to premises better suited to its requirements, coupled with an emerging RDC open space strategy that enables the re-apportionment of open space where evidenced, this would present an excellent opportunity for the Site to be re-allocated for residential development; in a sustainable location. This would make
best use of underutilised land and would promote sustainable patterns of development. We recognise and would support the reapportionment of designated playing pitches undertaken in full collaboration with Sport England.

Strategic Priority 5: Protecting and Enhancing our Environment

SP5.1 - How do we balance protection of the district's Green Belt that meets the five Green
Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

Our comments on the issue are as follows:

4.23 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be posible to balance these competing objectives by ensuring that a fully up-to-date evidence base is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

4.24 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries
(paragraph 84). Furthermore, it says that local planning authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).
4.25 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.
Our comments on the options:
A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
B. Amend the current Green Belt policy in the Core Strategy.
C. Do not have a policy on the Green Belt.

4.26 We support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's FOAN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A Green
Belt Review would enable RDC to assess land parcels against the five Green Belt purposes:
● to check the unrestricted sprawl of large built-up areas;
● to prevent neighbouring towns merging into one another;
● to assist in safeguarding the countryside from encroachment;
● to preserve the setting and special character of historic towns; and
● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4.27 Only once the Green Belt Review is complete, RDC may then come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

5.0 Summary

5.1 These representations have been prepared on behalf of Essex Housing, Essex County Council, in support of the Land south of the former Adult Community Learning Centre, Rocheway, Rochford.
5.2 The site is currently designated as open space in the Local Plan but it is only used by one youth football team, Hambro Colts, who have aspirations to relocate back to a suitable site closer to their original home in Rayleigh. The Colts are in collaboration with ECC to enable them to do so.
Allocation of this underused, yet sustainably located, parcel of land for residential development would enable Rochford District Council to:
● Promote sustainable patterns of development in the New Local Plan; and
● Plan for open space and playing pitch provision in a comprehensive manner, taking account of
emerging evidence of need, housing and employment growth.
5.3 Our review of RDC's evidence base of relevance to open space provision reveals that it needs to be fully updated as part of the new Local Plan process and that its scope needs to include all sites currently designated as open space. The evidence underpinning the adopted Development Plan suggests that this is presently not the case. Only with a comprehensive assessment of such provision could RDC make fully informed, robust and therefore sound planning policy decisions on the District's growth.
5.4 In conclusion we therefore consider that:
● RDC should plan to meet its full objectively assessed housing need across the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order settlements in the hierarchy, such as Rochford;
● RDC should undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate. This should be informed by emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
● The Site is considered favourably in the SHELAA in which it is defined as suitable, available and that development would be achievable.

*THIS REPRESENTATION IS ACCOMPANIED BY MULTIPLE ATTACHMENTS INCLUDING A SITE MAP AND VISION DOCUMENT*

These representations have been prepared on behalf of Crest Nicholson Eastern in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the "Site") for consideration in the Rochford District Council ("RDC") Issues and Options Local Plan ("the emerging Plan") consultation of March 2018.

Appendix 1 contains a Site Location Plan which shows the extent of the boundaries
of the site.

1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council's strategic housing need as part of the wider full Objectively Assessed Housing Need (OAHN) for the district. A proposed indicated layout is included within the Vision Document in Appendix 2 of these representations.

1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full OAHN. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council's settlement hierarchy.

1.4 Crest Nicholson is an award-winning national housebuilder with a proven track record of delivery, so if the site were allocated in the emerging Local Plan, the residential development of the site could be guaranteed.

1.5 The specific emerging Plan sections that these representations refer to are as follows:
● Vision
● Strategic Priority 1 - the homes and jobs needed in the area
 Strategic Priority 1.1
 Strategic Priority 1.3
 Strategic Priority 1.4
● Strategic Priority 3 - the provision of infrastructure
 Strategic Priority 3.1
● Strategic Priority 5 - protecting and enhancing our environment

 Strategic Priority 5.1

1.6 Full responses to the relevant issues and options within the emerging Plan are detailed in section 2 of this report and section 3 sets out the opportunity presented by the site for delivery of highly sustainable residential development on the northern edge of Rayleigh.

2.0 Our Response to the Issues and Options

The Vision

2.1 The vision section of the emerging Plan details the aims of the Council in relation to the three pillars of sustainability; our economy, our environment and our society. We support the Council's acknowledgement that this vision identifies that growth must be promoted within the district. This is fundamental to the three pillars of sustainable development. It therefore follows that sufficient housing sites must be delivered through the emerging Plan to support the employment, economic
and demographic growth anticipated throughout the Plan period in order to achieve the vision.

2.2 London Southend Airport forms a major part of the planned economic growth of South Essex. Rochford District Council's London Southend Airport and Environs Joint Area Action Plan (JAAP) was adopted in December 2014 in conjunction with Southend Borough Council and the area surrounding the airport is identified as a high scale employment growth area in the JAAP for both Rochford and Southend authorities. Land to accommodate 109,000 additional square metres of employment floorspace is allocated in the JAAP, comprising the new Saxon Business Park and
other smaller business parks and industrial estates, along with the potential to redevelop an area of underutilised brownfield industrial land at Aviation Way. In total, the land is capable of providing an additional 6,200 jobs in the area excluding direct airport related employment, but in order to fully realise the potential offered by this increase in employment land there must be commensurate housing provision through which a local workforce can be located.

2.3 We therefore consider that the planned employment growth must be matched by housing delivery in the most sustainable locations within the district. Rayleigh is one such location. It is strategically well located near to the trunk road network, main line railway to London and to the airport business park, the key employment area in the district. It therefore has optimal characteristics to contribute
significantly to this required housing delivery within the district.

Strategic Priority 1: The homes and jobs needed in the area

2.4 The emerging Plan sets out several strategic priorities for the Plan area in order to achieve the vision. The most relevant to these representations is strategic priority 1, relating to the delivery of homes and jobs in the district.

2.5 In the first instance we support the Council's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District. We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18). The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery. We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the National Planning Policy Framework (the "Framework"), which clearly requires local planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

2.6 We also consider that the emerging Plan should allocate sufficient housing sites to ensure that housing delivery matches the employment growth anticipated in the JAAP and wider Thames Gateway South Essex, a national priority area for growth and regeneration. The JAAP anticipates that the airport employment park alone could generate 6,200 new jobs by 2031 and the wider Thames Gateway South Essex is anticipated to deliver at least 52,000 new jobs1 over the same
period. Delivery of full OAHN in Rochford is therefore a crucial part of the wider strategic growth of South Essex.

2.7 RDC should therefore look to allocate land in the context of full OAHN for residential growth in the most sustainable locations to help attract and support the anticipated economic growth in and around the district and as part of the wider economic strategy for South Essex.

Strategic Priority 1.1: We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

2.8 Our comments relate specifically to objectively assessed housing need:

2.9 The options as set out are:
● A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
● B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
● C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

2.10 We consider that option A is the most suitable approach in relation to this issue, because it is the approach that is best supported by national planning policy and many local planning authorities local to Rochford are already taking this approach as part of their new Local Plans.

2.11 If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy
constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. Nearby local authorities of Basildon and Brentwood are both equally constrained by Green Belt but are both proposing to meet full OAHN. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

2.12 As a useful starting point, it is apparent from the Council's evidence base that the full OAHN could easily be accommodated on sites within the district; the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 identifies that there are 209 suitable and achievable sites within the district capable of accommodating 24,590 dwellings. This identified potential land capacity is well beyond that of the OAHN upper limit of 7,871 homes including the
shortfall in delivery prior to the emerging Plan period.

2.13 The potential land capacity above includes sites within the Green Belt and Special Landscape Areas and the majority of sites fall within these designations. These constraints should not prevent the allocation of the most suitable sites as part of a Local Plan review and in order to demonstrate that the Plan has been positively prepared, as part of the National Planning Policy Framework's
test of soundness under paragraph 182, we recommend that the Council undertakes further work in the form of a Green Belt review assessing individual sites for their contribution to the five purposes of including land within the Green Belt and their potential for release and development.

2.14 We therefore support option A.

Strategic Priority 1.3: How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?

2.15 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011). Rayleigh sits within the top tier of settlements as the most populated settlement in the district. Having regard to its sustainable location with easy access to public transport opportunities including mainline rail, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core Strategy was adopted.

2.16 Our comments on the Options are therefore as follows:

2.17 The realistic options as set out are:
● A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
● B. Increase density on allocated residential sites.
● C. Several small extensions to the existing residential area.
● D. A number of fewer larger extensions to the existing residential area.
● E. A new settlement.

2.18 We consider that option D is the most suitable method of meeting RDC's housing needs because it is the most deliverable over the Plan period.

2.19 Delivering homes in a fewer number of larger urban extensions, directed to established and wellserviced settlements within the district, would ensure that new homes would be connected to existing employment opportunities, transport networks and essential facilities, without a scale of requisite infrastructure provision that would threaten delivery of other planning policy objectives, such as affordable housing. The scale of larger extensions provides greater certainty of their deliverability and would generate higher levels of S106 and/or CIL contributions for improvements to infrastructure and services. They also have the potential to deliver significant onsite community uses. For example, Land at Lubards Lodge Farm represents a unique opportunity to provide significant public open space, allotments and a much needed sports facility for Rayleigh Boys and Girls FC (please see the Vision Document at Appendix 2).

2.20 Our contention for discounting the alternative options are discussed below:
● Whilst the reference to the efficient use of brownfield land in option A is desirable in line with the national policy, densification and infilling has implications for amenity and design quality and the capacity of brownfield sites alone is insufficient to meet full OAHN. Furthermore, options A and B would drastically alter the character of existing settlements and residential land allocations to the extent that would be damaging to existing character. For these reasons, options A and B are considered unsuitable.

● Smaller scale extensions as referenced in option C would fail to deliver sufficient CIL or s106 receipts to enable the cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

For this reason, we consider option C unsuitable.

● The spatial characteristics of Rochford do not lend themselves well to a new settlement identified in option E. Rochford District is constrained by its relatively small geographical area exacerbated by the environmental constraints of the rural estuarine environments in the north and east. There are no obvious opportunities for a new settlement capable of delivering the required housing in a manner that would create sustainable communities. For this reason, option E is considered unsuitable.

2.21 This confirms our view that the only reasonable option is option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rayleigh, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements, CIL or delivery onsite to mitigate the impact of any scheme. We agree with and support this approach.

2.22 Our submission at Section 3 of this report demonstrates that, as a highly sustainable settlement at the top of the settlement hierarchy in the adopted Plan, with the largest population in the district (circa 40% of the District's population), we consider that Rayleigh is the most suitable settlement for accommodating significant housing growth to support the town and the wider district. Land at
Lubards Farm presents an excellent opportunity to deliver a larger scale extension to Rayleigh.

Strategic Priority 1.4: How do we plan for and deliver a good mix of homes in the future?

What types, sizes and tenures are needed?
2.23 The options as set out are:
● A Retain the current policy on types of house, which takes a flexible, market driven approach to types;
● B Include specific reference to the size and types of homes referred to in the South Essex SHMA;
● C Continue to require new homes to meet the National Technical Housing Standards - nationally described space standards;
● D Do not adopt specific policy on the mix of homes.

2.24 We consider that option B is the most suitable approach in relation to this issue, but a greater amount of flexibility should be built into policy wording. The policy should make reference to the housing mix requirement in the most up-to-date SHMA evidence without prescribing exact figures from the most up-to-date available at the time of the emerging Plan publication. Referring to the specific evidence base provides a degree of clarity for the developer whilst concurrently not being so specific as to be inflexible.

2.25 A further matter that does not appear to be considered in the options is that planning for a series of larger extensions to existing settlements means that strategic planning objectives such as housing mix and tenure may be planned for and delivered on a strategic scale. Need may be adequately met this way.

Strategic Priority 3.1: How can we prioritise and deliver improvements to the strategic and local highway network over the next 20 years?

2.26 We do not have any specific comments relating to options as set out under this strategic priority. However, in response to the issue of how to prioritise improvements to the highway network, these should be delivered proportionately and be spatially related to the delivery of homes and jobs. As we have contended, the most appropriate strategy of housing delivery would be larger urban extensions located in highly sustainable towns at the top of the settlement hierarchy, with Rayleigh representing the optimum location for significant growth. Highways improvements would similarly be best located in this area commensurate to housing growth.

Strategic Priority 5: Protecting and Enhancing Our Environment

Strategic Priority 5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

2.27 The options are:
● A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
● B. Amend the current Green Belt policy in the Core Strategy.
● C. Do not have a policy on the Green Belt.

2.28 We consider that option B is the most suitable approach

2.29 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be possible to balance these competing objectives by ensuring that a fully up-to-date evidence base
is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

2.30 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries (paragraph 84). Furthermore, it says that local planning authorities should consider the
consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).

2.31 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.

2.32 This is why we support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's OAHN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A
Green Belt Review would enable RDC to assess land parcels against the five Green Belt purposes.

2.33 Only once the Green Belt Review is complete, can RDC come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

2.34 Our submission demonstrates in the following section that Land at Lubards Lodge Farm, Rayleigh could be removed from the Green Belt as part of the Local Plan review in a manner that would enable a defensible re-drawn boundary in accordance with the five Green Belt purposes.

3.0 The Opportunity - Land at Lubards Lodge Farm, Rayleigh

3.1 Taking account of:
● Rochford District Council's full OAHN;
● The limited availability of brownfield land in the district;
● The spatial characteristics of the district lending themselves best to larger extensions to existing higher order settlements, including Rayleigh; and
● The need to locate new development in sustainable locations,
we consider that the Land at Lubards Lodge Farm, Rayleigh, presents an excellent opportunity for Rochford District Council to help meet its strategic housing needs as part of the new Local Plan. Our reasons for this are set out below.

Sustainable location

3.2 The town of Rayleigh is identified in both the adopted and emerging Plans at the top of the settlement hierarchy demonstrating the Council's view that is represents the most sustainable location for development. Paragraph 6.38 of the emerging Plan states that settlements at the top of the hierarchy are intrinsically sustainable by virtue of their more developed nature, extensive infrastructure connectivity and accessibility to services and the Council seeks to direct housing development to these locations.

3.3 Rayleigh benefits from excellent connectivity to the rest of South Essex and London through the strategic road network comprising the A127, A130 and the A13. It is linked to London Liverpool Street, Southend Victoria and London Southend Airport by train station located in the town centre.

A range of services and facilities are available within the town. The centre of Rayleigh comprises a range of retail units interspersed with food and drink establishments. Recreational buildings such as the Rayleigh Town Museum and The Mill Arts & Events Centre add to the offer in the town centre. To the south, the Brook Road Industrial Estate, as well as the units on the opposite side of
the Southend Arterial Road to the south, offer employment opportunities above and beyond those in the town centre. 18 schools and nurseries are present in Rayleigh as well as 6 GP surgeries and 6 supermarkets providing a comprehensive service offering within the settlement.

3.1 The following table provides a representation of the site's accessibility to key amenities and demonstrates its suitability for development.

AMENITY DISTANCE FROM SITE
Bus stops 3 adjacent to site
Post office 1 within 50 metres

AMENITY DISTANCE FROM SITE
Pharmacy 1 within 50 metres
Shopping Asda within 400 metres
Rayleigh High Street within 1,800 metres
Schools 2 primary schools within 600 metres
2 secondary schools within 1,800 metres
Train station 1 within 1,600 metres
Leisure facilities The Rayleigh Club is adjacent to site
Rayleigh Leisure Centre is within 500 metres
Employment centres Lubards Farm is adjacent to site
Rawreth Lane Industrial Estate is within 1,000 metres
Library 1 within 1,900 metres
Banking 1 within 1,800 metres
Medical 1 within 200 metres

3.2 These demonstrate that the site is sustainably located. Many of these amenities are accessible by bicycle or on foot.

Deliverability

3.1 As the site is within single ownership and is unencumbered, we consider the site as a suitable candidate for allocation as a strategic residential development site because development would be deliverable. This correlates with the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 approved for inclusion and publication within the new Local Plan evidence base by the Planning Policy Sub-Committee on 17 November 2017. The site is assessed
in this document under the reference number CFS164 and the summary confirmed that the site is within Flood Zone 1 and not proximate to any environmental designations with the exception of the Green Belt; a policy designation.

3.2 Crest Nicholson is a national and multi-award-winning housebuilder with a proven track record of delivery of high quality residential schemes. This adds further weight to our demonstration that development on the site would be deliverable within early phases of the emerging Local Plan.

Benefitting from planned highways improvements

3.3 The site's location adjacent to the northern urban area of Rayleigh represents a logical extension to the town, well contained by Hullbridge Road to the east and Rawreth Lane to the south. Locating new development in this part of Rayleigh would mean it would benefit from planned improvements to the existing highway. Furthermore, its location near to the strategic highway network means that the impact of additional highway movements around the town centre would be minimised.

Figure 1: Extract from Drawing F221-202 General Arrangement 3Arm Roundabout from planning permission 16/00162/FUL

3.4 The consented and fully funded roundabout upgrade at the junction of Rawreth Lane and Hullbridge Road reference number 16/00162/FUL could, once delivered, allow for improved accessibility to the site with enhanced access to the wider strategic road network. The upgraded roundabout also offers the potential opportunity for a direct vehicle access from the roundabout itself.

Green Infrastructure

3.5 There is an opportunity to incorporate managed green infrastructure to the north of the site to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised. As the site is currently private
land it does not benefit from the same potential that its redevelopment would bring in this regard.

Green Belt

3.6 Below is a summary of a Green Belt Assessment undertaken by Eleanor Trenfield Landscape Architects Ltd of the site's contribution to the Green Belt. For further detail, please refer to the brochure appended to this report.
● Check the unrestricted sprawl of large built-up areas
An analysis of neighbouring land uses shows sporadic residential plotland development to the west and north of the site as well as commercial estate to the east and residential properties to the south-east which already contribute to the sprawl of Rayleigh north towards Hullbridge. The site therefore is more closely associated with the urban edge of Rayleigh than countryside and makes limited contribution to this purpose.
● Prevent neighbouring towns from merging
Existing sporadic development to the west and the north contribute to the erosion of this function on the site. The absence of a clearly defined urban edge of Rayleigh at this location is created by the plotland development and the site therefore does not act as a barrier preventing the spread of Rayleigh. Indeed, the plotland development already surrounds the site in most directions including towards neighbouring towns and so development on Lubards Farm would not deteriorate the function further.
● Assist in safeguarding the countryside from encroachment
Land between Rayleigh and Hullbridge has experienced piecemeal development resulting in minimal characteristics that would qualify it as 'countryside' land. Plotland developments already protrude significantly into the open land at this location, surrounding the site to the west and the north. In this sense, the countryside has already been significantly encroached and development on the site would not erode this function further.
● Preserve the setting and special character of historic towns
The land between Hullbridge and Rayleigh has no inter-visibility with the Conservation Area of Rayleigh. As such, development on the site is not considered to damage this purpose of including land within the Green Belt.

We consider it the most suitable Green Belt site adjacent to Rayleigh

3.7 In the context of the above, we have considered it appropriate to review the suitability of alternative Green Belt sites on the edge of Rayleigh. Given the scale of additional growth needed in Rochford, as identified by the OAHN, we have considered the credentials of alternative sites for strategic scale development.

3.8 Several sites around Rayleigh were submitted to the Council through the call for sites process for consideration within the new Local Plan and were presented at the Planning Policy Sub-Committee on 17 November 2017. The committee resolved to publish this document in the new Local Plan evidence base. These alternative sites are discussed briefly below along with our commentary regarding their comparatively weaker suitability credentials than that of Lubards Lodge Farm.
● Committed residential development exists to the west of Rayleigh under the reference number 15/00362/OUT on Land North of London Road, South of Rawreth Lane and West of Rawreth Industrial Estate. In our view, further development to the west of this location would lead to a significant increased sense of coalescence with Wickford and a sprawl of Rayleigh in this direction. See figure 2 below for reference.

Figure 2: Extract from the Council's Site Allocations Plan North of London Road, Rayleigh

To the north-east of Rayleigh, in the proximity of SHELAA site CFS105 Land north of Hambro Hill, is constrained by the topography and access. The area of CFS053 Land south of 38 and 39 Wellington Road, CFS098, CFS029 and CFS027 to the east of Rayleigh, falls within the Upper Roach Valley which is protected from development under CS Policy URV1. They would also require access through existing residential areas. We do not consider these sites of a scale capable of delivering strategic scale development and commensurate infrastructure requirements in accordance with the Council's priorities. Furthermore, their delivery would require land assembly and their delivery could not be guaranteed. See figure 3 below for reference.

To the south-east of Rayleigh, in the proximity of SHELAA site CFS127 Eastwood Nurseries off Bartletts, CFS044 south of Eastwood Road and CFS068 off Daws Heath Lane, there are small fragmented land parcels, likely to fall within different land ownerships. Development of this area is likely to be piecemeal and would in our view not be capable of delivering the high quality, integrated development achievable on the Lubards Lodge Farm site. In addition, site access from the narrow Daws Heath Road and from constrained access points off Eastwood Road are likely to be significant constraint in this location. See figure 4 below for reference.

To the south-west of Rayleigh, in the proximity of SHELAA site CFS121 Land north of A127, development is constrained by the exposed and open nature of the countryside experienced from this location. A substantial number of electricity pylons traverse the site between the substation adjacent to the south of the railway station and the National Grid main substation to the west of the A1245. A suitable point of vehicular access is also likely to be an issue for development in this area. See Figure 5 below for reference.

Evidence supporting this submission

Landscape

3.9 A Landscape and Visual Assessment (LVA) of the site has been undertaken and incorporated into the Vision Document in Appendix 2. The assessment identified a number of constraints and opportunities which have informed the proposed masterplan for the site but confirmed that development is entirely achievable in landscape terms.

3.10 The LVA recognised the existing neighbouring development and the mix of land uses at this location and concluded that residential development would not be uncharacteristic for the area. It recommends that the existing vegetation and hedgerow structures be retained as far as possible within the site, particularly bordering the 3 Public Right of Ways (PRoWs) on site. A significant opportunity exists to the north of the site, to provide a new open space connecting to the PRoW
network, providing amenity and green spaces for the proposed dwellings and enhancing biodiversity.

Ecology

3.11 An assessment of the Ecological Constraints and Opportunities has been undertaken and informed the proposed masterplan shown in the promotional brochure at Appendix 2.

3.12 The Assessment concluded that the site is largely of low ecological value but identified two European Designated sites within an 8km radius of the site. Of the two designations, the Crouch & Roach Estuary Special Protection Area (SPA) and Ramsar has the potential to be impacted indirectly due to increased recreational disturbance and a Habitat Regulations Assessment (HRA) is recommended to explore this further. This would be undertaken as the proposals progress.

3.13 The Assessment concludes that with an appropriately designed masterplan, development can be achieved on this site whilst also providing enhancements for biodiversity. An area of Suitable Accessible Natural Green Space (SANGS) is considered appropriate on the north of the site, to provide an alternative open space for future residents of the proposed new dwellings to minimise numbers travelling to the designated sites for recreational purposes.

3.14 Further phase 2 survey work is identified as necessary and these would be undertaken during the appropriate survey window as the proposals progress. Once all survey data is collected, appropriate mitigation measures would be incorporated into the proposals in line with recommendations.

Highways and Access

3.15 An appraisal of access opportunities has been undertaken on the site and has informed the masterplan shown in the promotional brochure in Appendix 2.

3.16 The appraisal identifies the potential for access to be obtained from a 4th arm on the consented roundabout at the junction of Hullbridge Road and Rawreth Lane under the planning permission 16/00162/FUL. Additional opportunities exist along Rawreth Lane, with potential for a 4th arm off the existing signalised junction with Downhall Park Way or a priority 'T' junction on Rawreth Lane.

3.17 Further work, in the form of a Transport Assessment, would be undertaken as the proposals progress. However, in light of the appraisal, residential development of the site as outlined in the promotional brochure is considered achievable.

Floods and Drainage

3.18 An initial floods and drainage assessment has been undertaken and informed the production of the masterplan shown in the promotional brochure at Appendix 2.

3.19 The site generally falls from the south-west to the north-east and located predominantly within Flood Zone 1, with small areas immediately adjacent to the watercourse flowing south to north on the eastern boundary. Some areas of the site are within areas of high, medium and low risk of surface water flooding with a depth of less than 300mm.

3.20 The Lead Local Flood Authority (LLFA) map places the site in a Critical Drainage Area and have produced a Surface Water Management Plan (SWMP) for the area. Whilst the site itself is not at risk of flooding, it is important that development does not increase the risk of flooding offsite within the wider catchment.

3.21 Unsuitable ground conditions exist for infiltration drainage techniques so a system of swales across the site would collect surface water and attenuate it before it passes to a detention basin. A Train of Sustainable Urban Drainage Systems (SuDS) would be incorporated into the scheme as well as 2 outfall points into the watercourse to drain the site. The features described above also offer habitats to support biodiversity and would enhance the environment by adding a water element to the scheme. The water detention centre, when not in use for water storage, would be designed to allow its use for other purposes.

3.22 Foul water would be collected in a tradition pipe network connecting to the existing Anglian Water sewers in Hullbridge Road. The pipe network would be offered to Anglian Water for adoption.

3.23 The drainage system on site has been developed in line with LLFA guidance and SuDS manual and is considered to appropriately address floods and drainage issues. Further refinement of the systems would be undertaken as the proposals progress.

4.0 Conclusion

4.1 These representations have been prepared on behalf of Crest Nicholson Eastern in respect of Land at Lubards Lodge Farm, Rayleigh for consideration in the Rochford Issues and Options Local Plan consultation of March 2018.

4.2 In order to achieve the vision and strategic priority 1 as detailed in the emerging Local Plan, development on the site is required. Significant employment growth is identified in the JAAP and in the wider South Essex sub-region. Housing delivery must match this growth.

4.3 Other neighbouring and nearby Green Belt local authorities are planning for their full OAHN within their Plan areas and there is no sound reason why Rochford should do otherwise.

4.4 In spatial strategy terms, a smaller number of large urban extensions would be the most sustainable approach for addressing this need, particularly in Rayleigh taking account of its sustainability and subsequent position at the top of the settlement hierarchy.

4.5 The Land at Lubards Lodge Farm is located in the Green Belt on the northern border of Rayleigh in a highly sustainable location, with access to the services and facilities within the town centre and the strategic road network and public transport links to London, wider south Essex and Southend airport. Within single ownership, the land is unencumbered and represents an excellent location for strategic scale residential development.

4.6 We would support the Council to undertake a Green Belt review of the district. This would confirm the Green Belt function of potential development sites including the Land at Lubards Lodge Farm and thereby justify strategic planning choices as part of the emerging Local Plan. We consider that Lubards Lodge Farm is the most suitable site for strategic scale residential development at Rayleigh. It also provides a unique opportunity to deliver significant community uses for the town's
existing and future residents.

4.7 A significant amount of preliminary assessments and appraisals have been undertaken to date and all conclude that development is entirely achievable on site. The Vision Document accompanying these representations at Appendix 2 provides further detail and shows the proposed initial masterplan for the site. Crest Nicholson specialises in the design and construction of high quality, community-led residential schemes and will continue to work with RDC and the local community to develop this vision for the site.

*THIS REPRESENTATION IS ACCOMPANIED BY MULTIPLE ATTACHMENTS INCLUDING A SITE MAP AND VISION DOCUMENT*

These representations have been prepared on behalf of Crest Nicholson Eastern in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the "Site") for consideration in the Rochford District Council ("RDC") Issues and Options Local Plan ("the emerging Plan") consultation of March 2018.

Appendix 1 contains a Site Location Plan which shows the extent of the boundaries
of the site.

1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council's strategic housing need as part of the wider full Objectively Assessed Housing Need (OAHN) for the district. A proposed indicated layout is included within the Vision Document in Appendix 2 of these representations.

1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full OAHN. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council's settlement hierarchy.

1.4 Crest Nicholson is an award-winning national housebuilder with a proven track record of delivery, so if the site were allocated in the emerging Local Plan, the residential development of the site could be guaranteed.

1.5 The specific emerging Plan sections that these representations refer to are as follows:
● Vision
● Strategic Priority 1 - the homes and jobs needed in the area
 Strategic Priority 1.1
 Strategic Priority 1.3
 Strategic Priority 1.4
● Strategic Priority 3 - the provision of infrastructure
 Strategic Priority 3.1
● Strategic Priority 5 - protecting and enhancing our environment

 Strategic Priority 5.1

1.6 Full responses to the relevant issues and options within the emerging Plan are detailed in section 2 of this report and section 3 sets out the opportunity presented by the site for delivery of highly sustainable residential development on the northern edge of Rayleigh.

2.0 Our Response to the Issues and Options

The Vision

2.1 The vision section of the emerging Plan details the aims of the Council in relation to the three pillars of sustainability; our economy, our environment and our society. We support the Council's acknowledgement that this vision identifies that growth must be promoted within the district. This is fundamental to the three pillars of sustainable development. It therefore follows that sufficient housing sites must be delivered through the emerging Plan to support the employment, economic
and demographic growth anticipated throughout the Plan period in order to achieve the vision.

2.2 London Southend Airport forms a major part of the planned economic growth of South Essex. Rochford District Council's London Southend Airport and Environs Joint Area Action Plan (JAAP) was adopted in December 2014 in conjunction with Southend Borough Council and the area surrounding the airport is identified as a high scale employment growth area in the JAAP for both Rochford and Southend authorities. Land to accommodate 109,000 additional square metres of employment floorspace is allocated in the JAAP, comprising the new Saxon Business Park and
other smaller business parks and industrial estates, along with the potential to redevelop an area of underutilised brownfield industrial land at Aviation Way. In total, the land is capable of providing an additional 6,200 jobs in the area excluding direct airport related employment, but in order to fully realise the potential offered by this increase in employment land there must be commensurate housing provision through which a local workforce can be located.

2.3 We therefore consider that the planned employment growth must be matched by housing delivery in the most sustainable locations within the district. Rayleigh is one such location. It is strategically well located near to the trunk road network, main line railway to London and to the airport business park, the key employment area in the district. It therefore has optimal characteristics to contribute
significantly to this required housing delivery within the district.

Strategic Priority 1: The homes and jobs needed in the area

2.4 The emerging Plan sets out several strategic priorities for the Plan area in order to achieve the vision. The most relevant to these representations is strategic priority 1, relating to the delivery of homes and jobs in the district.

2.5 In the first instance we support the Council's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District. We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18). The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery. We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the National Planning Policy Framework (the "Framework"), which clearly requires local planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

2.6 We also consider that the emerging Plan should allocate sufficient housing sites to ensure that housing delivery matches the employment growth anticipated in the JAAP and wider Thames Gateway South Essex, a national priority area for growth and regeneration. The JAAP anticipates that the airport employment park alone could generate 6,200 new jobs by 2031 and the wider Thames Gateway South Essex is anticipated to deliver at least 52,000 new jobs1 over the same
period. Delivery of full OAHN in Rochford is therefore a crucial part of the wider strategic growth of South Essex.

2.7 RDC should therefore look to allocate land in the context of full OAHN for residential growth in the most sustainable locations to help attract and support the anticipated economic growth in and around the district and as part of the wider economic strategy for South Essex.

Strategic Priority 1.1: We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

2.8 Our comments relate specifically to objectively assessed housing need:

2.9 The options as set out are:
● A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
● B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
● C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

2.10 We consider that option A is the most suitable approach in relation to this issue, because it is the approach that is best supported by national planning policy and many local planning authorities local to Rochford are already taking this approach as part of their new Local Plans.

2.11 If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy
constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. Nearby local authorities of Basildon and Brentwood are both equally constrained by Green Belt but are both proposing to meet full OAHN. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

2.12 As a useful starting point, it is apparent from the Council's evidence base that the full OAHN could easily be accommodated on sites within the district; the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 identifies that there are 209 suitable and achievable sites within the district capable of accommodating 24,590 dwellings. This identified potential land capacity is well beyond that of the OAHN upper limit of 7,871 homes including the
shortfall in delivery prior to the emerging Plan period.

2.13 The potential land capacity above includes sites within the Green Belt and Special Landscape Areas and the majority of sites fall within these designations. These constraints should not prevent the allocation of the most suitable sites as part of a Local Plan review and in order to demonstrate that the Plan has been positively prepared, as part of the National Planning Policy Framework's
test of soundness under paragraph 182, we recommend that the Council undertakes further work in the form of a Green Belt review assessing individual sites for their contribution to the five purposes of including land within the Green Belt and their potential for release and development.

2.14 We therefore support option A.

Strategic Priority 1.3: How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?

2.15 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011). Rayleigh sits within the top tier of settlements as the most populated settlement in the district. Having regard to its sustainable location with easy access to public transport opportunities including mainline rail, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core Strategy was adopted.

2.16 Our comments on the Options are therefore as follows:

2.17 The realistic options as set out are:
● A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
● B. Increase density on allocated residential sites.
● C. Several small extensions to the existing residential area.
● D. A number of fewer larger extensions to the existing residential area.
● E. A new settlement.

2.18 We consider that option D is the most suitable method of meeting RDC's housing needs because it is the most deliverable over the Plan period.

2.19 Delivering homes in a fewer number of larger urban extensions, directed to established and wellserviced settlements within the district, would ensure that new homes would be connected to existing employment opportunities, transport networks and essential facilities, without a scale of requisite infrastructure provision that would threaten delivery of other planning policy objectives, such as affordable housing. The scale of larger extensions provides greater certainty of their deliverability and would generate higher levels of S106 and/or CIL contributions for improvements to infrastructure and services. They also have the potential to deliver significant onsite community uses. For example, Land at Lubards Lodge Farm represents a unique opportunity to provide significant public open space, allotments and a much needed sports facility for Rayleigh Boys and Girls FC (please see the Vision Document at Appendix 2).

2.20 Our contention for discounting the alternative options are discussed below:
● Whilst the reference to the efficient use of brownfield land in option A is desirable in line with the national policy, densification and infilling has implications for amenity and design quality and the capacity of brownfield sites alone is insufficient to meet full OAHN. Furthermore, options A and B would drastically alter the character of existing settlements and residential land allocations to the extent that would be damaging to existing character. For these reasons, options A and B are considered unsuitable.

● Smaller scale extensions as referenced in option C would fail to deliver sufficient CIL or s106 receipts to enable the cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

For this reason, we consider option C unsuitable.

● The spatial characteristics of Rochford do not lend themselves well to a new settlement identified in option E. Rochford District is constrained by its relatively small geographical area exacerbated by the environmental constraints of the rural estuarine environments in the north and east. There are no obvious opportunities for a new settlement capable of delivering the required housing in a manner that would create sustainable communities. For this reason, option E is considered unsuitable.

2.21 This confirms our view that the only reasonable option is option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rayleigh, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements, CIL or delivery onsite to mitigate the impact of any scheme. We agree with and support this approach.

2.22 Our submission at Section 3 of this report demonstrates that, as a highly sustainable settlement at the top of the settlement hierarchy in the adopted Plan, with the largest population in the district (circa 40% of the District's population), we consider that Rayleigh is the most suitable settlement for accommodating significant housing growth to support the town and the wider district. Land at
Lubards Farm presents an excellent opportunity to deliver a larger scale extension to Rayleigh.

Strategic Priority 1.4: How do we plan for and deliver a good mix of homes in the future?

What types, sizes and tenures are needed?
2.23 The options as set out are:
● A Retain the current policy on types of house, which takes a flexible, market driven approach to types;
● B Include specific reference to the size and types of homes referred to in the South Essex SHMA;
● C Continue to require new homes to meet the National Technical Housing Standards - nationally described space standards;
● D Do not adopt specific policy on the mix of homes.

2.24 We consider that option B is the most suitable approach in relation to this issue, but a greater amount of flexibility should be built into policy wording. The policy should make reference to the housing mix requirement in the most up-to-date SHMA evidence without prescribing exact figures from the most up-to-date available at the time of the emerging Plan publication. Referring to the specific evidence base provides a degree of clarity for the developer whilst concurrently not being so specific as to be inflexible.

2.25 A further matter that does not appear to be considered in the options is that planning for a series of larger extensions to existing settlements means that strategic planning objectives such as housing mix and tenure may be planned for and delivered on a strategic scale. Need may be adequately met this way.

Strategic Priority 3.1: How can we prioritise and deliver improvements to the strategic and local highway network over the next 20 years?

2.26 We do not have any specific comments relating to options as set out under this strategic priority. However, in response to the issue of how to prioritise improvements to the highway network, these should be delivered proportionately and be spatially related to the delivery of homes and jobs. As we have contended, the most appropriate strategy of housing delivery would be larger urban extensions located in highly sustainable towns at the top of the settlement hierarchy, with Rayleigh representing the optimum location for significant growth. Highways improvements would similarly be best located in this area commensurate to housing growth.

Strategic Priority 5: Protecting and Enhancing Our Environment

Strategic Priority 5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

2.27 The options are:
● A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
● B. Amend the current Green Belt policy in the Core Strategy.
● C. Do not have a policy on the Green Belt.

2.28 We consider that option B is the most suitable approach

2.29 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be possible to balance these competing objectives by ensuring that a fully up-to-date evidence base
is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

2.30 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries (paragraph 84). Furthermore, it says that local planning authorities should consider the
consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).

2.31 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.

2.32 This is why we support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's OAHN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A
Green Belt Review would enable RDC to assess land parcels against the five Green Belt purposes.

2.33 Only once the Green Belt Review is complete, can RDC come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

2.34 Our submission demonstrates in the following section that Land at Lubards Lodge Farm, Rayleigh could be removed from the Green Belt as part of the Local Plan review in a manner that would enable a defensible re-drawn boundary in accordance with the five Green Belt purposes.

3.0 The Opportunity - Land at Lubards Lodge Farm, Rayleigh

3.1 Taking account of:
● Rochford District Council's full OAHN;
● The limited availability of brownfield land in the district;
● The spatial characteristics of the district lending themselves best to larger extensions to existing higher order settlements, including Rayleigh; and
● The need to locate new development in sustainable locations,
we consider that the Land at Lubards Lodge Farm, Rayleigh, presents an excellent opportunity for Rochford District Council to help meet its strategic housing needs as part of the new Local Plan. Our reasons for this are set out below.

Sustainable location

3.2 The town of Rayleigh is identified in both the adopted and emerging Plans at the top of the settlement hierarchy demonstrating the Council's view that is represents the most sustainable location for development. Paragraph 6.38 of the emerging Plan states that settlements at the top of the hierarchy are intrinsically sustainable by virtue of their more developed nature, extensive infrastructure connectivity and accessibility to services and the Council seeks to direct housing development to these locations.

3.3 Rayleigh benefits from excellent connectivity to the rest of South Essex and London through the strategic road network comprising the A127, A130 and the A13. It is linked to London Liverpool Street, Southend Victoria and London Southend Airport by train station located in the town centre.

A range of services and facilities are available within the town. The centre of Rayleigh comprises a range of retail units interspersed with food and drink establishments. Recreational buildings such as the Rayleigh Town Museum and The Mill Arts & Events Centre add to the offer in the town centre. To the south, the Brook Road Industrial Estate, as well as the units on the opposite side of
the Southend Arterial Road to the south, offer employment opportunities above and beyond those in the town centre. 18 schools and nurseries are present in Rayleigh as well as 6 GP surgeries and 6 supermarkets providing a comprehensive service offering within the settlement.

3.1 The following table provides a representation of the site's accessibility to key amenities and demonstrates its suitability for development.

AMENITY DISTANCE FROM SITE
Bus stops 3 adjacent to site
Post office 1 within 50 metres

AMENITY DISTANCE FROM SITE
Pharmacy 1 within 50 metres
Shopping Asda within 400 metres
Rayleigh High Street within 1,800 metres
Schools 2 primary schools within 600 metres
2 secondary schools within 1,800 metres
Train station 1 within 1,600 metres
Leisure facilities The Rayleigh Club is adjacent to site
Rayleigh Leisure Centre is within 500 metres
Employment centres Lubards Farm is adjacent to site
Rawreth Lane Industrial Estate is within 1,000 metres
Library 1 within 1,900 metres
Banking 1 within 1,800 metres
Medical 1 within 200 metres

3.2 These demonstrate that the site is sustainably located. Many of these amenities are accessible by bicycle or on foot.

Deliverability

3.1 As the site is within single ownership and is unencumbered, we consider the site as a suitable candidate for allocation as a strategic residential development site because development would be deliverable. This correlates with the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 approved for inclusion and publication within the new Local Plan evidence base by the Planning Policy Sub-Committee on 17 November 2017. The site is assessed
in this document under the reference number CFS164 and the summary confirmed that the site is within Flood Zone 1 and not proximate to any environmental designations with the exception of the Green Belt; a policy designation.

3.2 Crest Nicholson is a national and multi-award-winning housebuilder with a proven track record of delivery of high quality residential schemes. This adds further weight to our demonstration that development on the site would be deliverable within early phases of the emerging Local Plan.

Benefitting from planned highways improvements

3.3 The site's location adjacent to the northern urban area of Rayleigh represents a logical extension to the town, well contained by Hullbridge Road to the east and Rawreth Lane to the south. Locating new development in this part of Rayleigh would mean it would benefit from planned improvements to the existing highway. Furthermore, its location near to the strategic highway network means that the impact of additional highway movements around the town centre would be minimised.

Figure 1: Extract from Drawing F221-202 General Arrangement 3Arm Roundabout from planning permission 16/00162/FUL

3.4 The consented and fully funded roundabout upgrade at the junction of Rawreth Lane and Hullbridge Road reference number 16/00162/FUL could, once delivered, allow for improved accessibility to the site with enhanced access to the wider strategic road network. The upgraded roundabout also offers the potential opportunity for a direct vehicle access from the roundabout itself.

Green Infrastructure

3.5 There is an opportunity to incorporate managed green infrastructure to the north of the site to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised. As the site is currently private
land it does not benefit from the same potential that its redevelopment would bring in this regard.

Green Belt

3.6 Below is a summary of a Green Belt Assessment undertaken by Eleanor Trenfield Landscape Architects Ltd of the site's contribution to the Green Belt. For further detail, please refer to the brochure appended to this report.
● Check the unrestricted sprawl of large built-up areas
An analysis of neighbouring land uses shows sporadic residential plotland development to the west and north of the site as well as commercial estate to the east and residential properties to the south-east which already contribute to the sprawl of Rayleigh north towards Hullbridge. The site therefore is more closely associated with the urban edge of Rayleigh than countryside and makes limited contribution to this purpose.
● Prevent neighbouring towns from merging
Existing sporadic development to the west and the north contribute to the erosion of this function on the site. The absence of a clearly defined urban edge of Rayleigh at this location is created by the plotland development and the site therefore does not act as a barrier preventing the spread of Rayleigh. Indeed, the plotland development already surrounds the site in most directions including towards neighbouring towns and so development on Lubards Farm would not deteriorate the function further.
● Assist in safeguarding the countryside from encroachment
Land between Rayleigh and Hullbridge has experienced piecemeal development resulting in minimal characteristics that would qualify it as 'countryside' land. Plotland developments already protrude significantly into the open land at this location, surrounding the site to the west and the north. In this sense, the countryside has already been significantly encroached and development on the site would not erode this function further.
● Preserve the setting and special character of historic towns
The land between Hullbridge and Rayleigh has no inter-visibility with the Conservation Area of Rayleigh. As such, development on the site is not considered to damage this purpose of including land within the Green Belt.

We consider it the most suitable Green Belt site adjacent to Rayleigh

3.7 In the context of the above, we have considered it appropriate to review the suitability of alternative Green Belt sites on the edge of Rayleigh. Given the scale of additional growth needed in Rochford, as identified by the OAHN, we have considered the credentials of alternative sites for strategic scale development.

3.8 Several sites around Rayleigh were submitted to the Council through the call for sites process for consideration within the new Local Plan and were presented at the Planning Policy Sub-Committee on 17 November 2017. The committee resolved to publish this document in the new Local Plan evidence base. These alternative sites are discussed briefly below along with our commentary regarding their comparatively weaker suitability credentials than that of Lubards Lodge Farm.
● Committed residential development exists to the west of Rayleigh under the reference number 15/00362/OUT on Land North of London Road, South of Rawreth Lane and West of Rawreth Industrial Estate. In our view, further development to the west of this location would lead to a significant increased sense of coalescence with Wickford and a sprawl of Rayleigh in this direction. See figure 2 below for reference.

Figure 2: Extract from the Council's Site Allocations Plan North of London Road, Rayleigh

To the north-east of Rayleigh, in the proximity of SHELAA site CFS105 Land north of Hambro Hill, is constrained by the topography and access. The area of CFS053 Land south of 38 and 39 Wellington Road, CFS098, CFS029 and CFS027 to the east of Rayleigh, falls within the Upper Roach Valley which is protected from development under CS Policy URV1. They would also require access through existing residential areas. We do not consider these sites of a scale capable of delivering strategic scale development and commensurate infrastructure requirements in accordance with the Council's priorities. Furthermore, their delivery would require land assembly and their delivery could not be guaranteed. See figure 3 below for reference.

To the south-east of Rayleigh, in the proximity of SHELAA site CFS127 Eastwood Nurseries off Bartletts, CFS044 south of Eastwood Road and CFS068 off Daws Heath Lane, there are small fragmented land parcels, likely to fall within different land ownerships. Development of this area is likely to be piecemeal and would in our view not be capable of delivering the high quality, integrated development achievable on the Lubards Lodge Farm site. In addition, site access from the narrow Daws Heath Road and from constrained access points off Eastwood Road are likely to be significant constraint in this location. See figure 4 below for reference.

To the south-west of Rayleigh, in the proximity of SHELAA site CFS121 Land north of A127, development is constrained by the exposed and open nature of the countryside experienced from this location. A substantial number of electricity pylons traverse the site between the substation adjacent to the south of the railway station and the National Grid main substation to the west of the A1245. A suitable point of vehicular access is also likely to be an issue for development in this area. See Figure 5 below for reference.

Evidence supporting this submission

Landscape

3.9 A Landscape and Visual Assessment (LVA) of the site has been undertaken and incorporated into the Vision Document in Appendix 2. The assessment identified a number of constraints and opportunities which have informed the proposed masterplan for the site but confirmed that development is entirely achievable in landscape terms.

3.10 The LVA recognised the existing neighbouring development and the mix of land uses at this location and concluded that residential development would not be uncharacteristic for the area. It recommends that the existing vegetation and hedgerow structures be retained as far as possible within the site, particularly bordering the 3 Public Right of Ways (PRoWs) on site. A significant opportunity exists to the north of the site, to provide a new open space connecting to the PRoW
network, providing amenity and green spaces for the proposed dwellings and enhancing biodiversity.

Ecology

3.11 An assessment of the Ecological Constraints and Opportunities has been undertaken and informed the proposed masterplan shown in the promotional brochure at Appendix 2.

3.12 The Assessment concluded that the site is largely of low ecological value but identified two European Designated sites within an 8km radius of the site. Of the two designations, the Crouch & Roach Estuary Special Protection Area (SPA) and Ramsar has the potential to be impacted indirectly due to increased recreational disturbance and a Habitat Regulations Assessment (HRA) is recommended to explore this further. This would be undertaken as the proposals progress.

3.13 The Assessment concludes that with an appropriately designed masterplan, development can be achieved on this site whilst also providing enhancements for biodiversity. An area of Suitable Accessible Natural Green Space (SANGS) is considered appropriate on the north of the site, to provide an alternative open space for future residents of the proposed new dwellings to minimise numbers travelling to the designated sites for recreational purposes.

3.14 Further phase 2 survey work is identified as necessary and these would be undertaken during the appropriate survey window as the proposals progress. Once all survey data is collected, appropriate mitigation measures would be incorporated into the proposals in line with recommendations.

Highways and Access

3.15 An appraisal of access opportunities has been undertaken on the site and has informed the masterplan shown in the promotional brochure in Appendix 2.

3.16 The appraisal identifies the potential for access to be obtained from a 4th arm on the consented roundabout at the junction of Hullbridge Road and Rawreth Lane under the planning permission 16/00162/FUL. Additional opportunities exist along Rawreth Lane, with potential for a 4th arm off the existing signalised junction with Downhall Park Way or a priority 'T' junction on Rawreth Lane.

3.17 Further work, in the form of a Transport Assessment, would be undertaken as the proposals progress. However, in light of the appraisal, residential development of the site as outlined in the promotional brochure is considered achievable.

Floods and Drainage

3.18 An initial floods and drainage assessment has been undertaken and informed the production of the masterplan shown in the promotional brochure at Appendix 2.

3.19 The site generally falls from the south-west to the north-east and located predominantly within Flood Zone 1, with small areas immediately adjacent to the watercourse flowing south to north on the eastern boundary. Some areas of the site are within areas of high, medium and low risk of surface water flooding with a depth of less than 300mm.

3.20 The Lead Local Flood Authority (LLFA) map places the site in a Critical Drainage Area and have produced a Surface Water Management Plan (SWMP) for the area. Whilst the site itself is not at risk of flooding, it is important that development does not increase the risk of flooding offsite within the wider catchment.

3.21 Unsuitable ground conditions exist for infiltration drainage techniques so a system of swales across the site would collect surface water and attenuate it before it passes to a detention basin. A Train of Sustainable Urban Drainage Systems (SuDS) would be incorporated into the scheme as well as 2 outfall points into the watercourse to drain the site. The features described above also offer habitats to support biodiversity and would enhance the environment by adding a water element to the scheme. The water detention centre, when not in use for water storage, would be designed to allow its use for other purposes.

3.22 Foul water would be collected in a tradition pipe network connecting to the existing Anglian Water sewers in Hullbridge Road. The pipe network would be offered to Anglian Water for adoption.

3.23 The drainage system on site has been developed in line with LLFA guidance and SuDS manual and is considered to appropriately address floods and drainage issues. Further refinement of the systems would be undertaken as the proposals progress.

4.0 Conclusion

4.1 These representations have been prepared on behalf of Crest Nicholson Eastern in respect of Land at Lubards Lodge Farm, Rayleigh for consideration in the Rochford Issues and Options Local Plan consultation of March 2018.

4.2 In order to achieve the vision and strategic priority 1 as detailed in the emerging Local Plan, development on the site is required. Significant employment growth is identified in the JAAP and in the wider South Essex sub-region. Housing delivery must match this growth.

4.3 Other neighbouring and nearby Green Belt local authorities are planning for their full OAHN within their Plan areas and there is no sound reason why Rochford should do otherwise.

4.4 In spatial strategy terms, a smaller number of large urban extensions would be the most sustainable approach for addressing this need, particularly in Rayleigh taking account of its sustainability and subsequent position at the top of the settlement hierarchy.

4.5 The Land at Lubards Lodge Farm is located in the Green Belt on the northern border of Rayleigh in a highly sustainable location, with access to the services and facilities within the town centre and the strategic road network and public transport links to London, wider south Essex and Southend airport. Within single ownership, the land is unencumbered and represents an excellent location for strategic scale residential development.

4.6 We would support the Council to undertake a Green Belt review of the district. This would confirm the Green Belt function of potential development sites including the Land at Lubards Lodge Farm and thereby justify strategic planning choices as part of the emerging Local Plan. We consider that Lubards Lodge Farm is the most suitable site for strategic scale residential development at Rayleigh. It also provides a unique opportunity to deliver significant community uses for the town's
existing and future residents.

4.7 A significant amount of preliminary assessments and appraisals have been undertaken to date and all conclude that development is entirely achievable on site. The Vision Document accompanying these representations at Appendix 2 provides further detail and shows the proposed initial masterplan for the site. Crest Nicholson specialises in the design and construction of high quality, community-led residential schemes and will continue to work with RDC and the local community to develop this vision for the site.

*THIS REPRESENTATION IS ACCOMPANIED BY MULTIPLE ATTACHMENTS INCLUDING A SITE MAP AND VISION DOCUMENT*

These representations have been prepared on behalf of Crest Nicholson Eastern in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the "Site") for consideration in the Rochford District Council ("RDC") Issues and Options Local Plan ("the emerging Plan") consultation of March 2018.

Appendix 1 contains a Site Location Plan which shows the extent of the boundaries
of the site.

1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council's strategic housing need as part of the wider full Objectively Assessed Housing Need (OAHN) for the district. A proposed indicated layout is included within the Vision Document in Appendix 2 of these representations.

1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full OAHN. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council's settlement hierarchy.

1.4 Crest Nicholson is an award-winning national housebuilder with a proven track record of delivery, so if the site were allocated in the emerging Local Plan, the residential development of the site could be guaranteed.

1.5 The specific emerging Plan sections that these representations refer to are as follows:
● Vision
● Strategic Priority 1 - the homes and jobs needed in the area
 Strategic Priority 1.1
 Strategic Priority 1.3
 Strategic Priority 1.4
● Strategic Priority 3 - the provision of infrastructure
 Strategic Priority 3.1
● Strategic Priority 5 - protecting and enhancing our environment

 Strategic Priority 5.1

1.6 Full responses to the relevant issues and options within the emerging Plan are detailed in section 2 of this report and section 3 sets out the opportunity presented by the site for delivery of highly sustainable residential development on the northern edge of Rayleigh.

2.0 Our Response to the Issues and Options

The Vision

2.1 The vision section of the emerging Plan details the aims of the Council in relation to the three pillars of sustainability; our economy, our environment and our society. We support the Council's acknowledgement that this vision identifies that growth must be promoted within the district. This is fundamental to the three pillars of sustainable development. It therefore follows that sufficient housing sites must be delivered through the emerging Plan to support the employment, economic
and demographic growth anticipated throughout the Plan period in order to achieve the vision.

2.2 London Southend Airport forms a major part of the planned economic growth of South Essex. Rochford District Council's London Southend Airport and Environs Joint Area Action Plan (JAAP) was adopted in December 2014 in conjunction with Southend Borough Council and the area surrounding the airport is identified as a high scale employment growth area in the JAAP for both Rochford and Southend authorities. Land to accommodate 109,000 additional square metres of employment floorspace is allocated in the JAAP, comprising the new Saxon Business Park and
other smaller business parks and industrial estates, along with the potential to redevelop an area of underutilised brownfield industrial land at Aviation Way. In total, the land is capable of providing an additional 6,200 jobs in the area excluding direct airport related employment, but in order to fully realise the potential offered by this increase in employment land there must be commensurate housing provision through which a local workforce can be located.

2.3 We therefore consider that the planned employment growth must be matched by housing delivery in the most sustainable locations within the district. Rayleigh is one such location. It is strategically well located near to the trunk road network, main line railway to London and to the airport business park, the key employment area in the district. It therefore has optimal characteristics to contribute
significantly to this required housing delivery within the district.

Strategic Priority 1: The homes and jobs needed in the area

2.4 The emerging Plan sets out several strategic priorities for the Plan area in order to achieve the vision. The most relevant to these representations is strategic priority 1, relating to the delivery of homes and jobs in the district.

2.5 In the first instance we support the Council's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District. We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18). The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery. We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the National Planning Policy Framework (the "Framework"), which clearly requires local planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

2.6 We also consider that the emerging Plan should allocate sufficient housing sites to ensure that housing delivery matches the employment growth anticipated in the JAAP and wider Thames Gateway South Essex, a national priority area for growth and regeneration. The JAAP anticipates that the airport employment park alone could generate 6,200 new jobs by 2031 and the wider Thames Gateway South Essex is anticipated to deliver at least 52,000 new jobs1 over the same
period. Delivery of full OAHN in Rochford is therefore a crucial part of the wider strategic growth of South Essex.

2.7 RDC should therefore look to allocate land in the context of full OAHN for residential growth in the most sustainable locations to help attract and support the anticipated economic growth in and around the district and as part of the wider economic strategy for South Essex.

Strategic Priority 1.1: We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

2.8 Our comments relate specifically to objectively assessed housing need:

2.9 The options as set out are:
● A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
● B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
● C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

2.10 We consider that option A is the most suitable approach in relation to this issue, because it is the approach that is best supported by national planning policy and many local planning authorities local to Rochford are already taking this approach as part of their new Local Plans.

2.11 If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy
constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. Nearby local authorities of Basildon and Brentwood are both equally constrained by Green Belt but are both proposing to meet full OAHN. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

2.12 As a useful starting point, it is apparent from the Council's evidence base that the full OAHN could easily be accommodated on sites within the district; the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 identifies that there are 209 suitable and achievable sites within the district capable of accommodating 24,590 dwellings. This identified potential land capacity is well beyond that of the OAHN upper limit of 7,871 homes including the
shortfall in delivery prior to the emerging Plan period.

2.13 The potential land capacity above includes sites within the Green Belt and Special Landscape Areas and the majority of sites fall within these designations. These constraints should not prevent the allocation of the most suitable sites as part of a Local Plan review and in order to demonstrate that the Plan has been positively prepared, as part of the National Planning Policy Framework's
test of soundness under paragraph 182, we recommend that the Council undertakes further work in the form of a Green Belt review assessing individual sites for their contribution to the five purposes of including land within the Green Belt and their potential for release and development.

2.14 We therefore support option A.

Strategic Priority 1.3: How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?

2.15 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011). Rayleigh sits within the top tier of settlements as the most populated settlement in the district. Having regard to its sustainable location with easy access to public transport opportunities including mainline rail, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core Strategy was adopted.

2.16 Our comments on the Options are therefore as follows:

2.17 The realistic options as set out are:
● A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
● B. Increase density on allocated residential sites.
● C. Several small extensions to the existing residential area.
● D. A number of fewer larger extensions to the existing residential area.
● E. A new settlement.

2.18 We consider that option D is the most suitable method of meeting RDC's housing needs because it is the most deliverable over the Plan period.

2.19 Delivering homes in a fewer number of larger urban extensions, directed to established and wellserviced settlements within the district, would ensure that new homes would be connected to existing employment opportunities, transport networks and essential facilities, without a scale of requisite infrastructure provision that would threaten delivery of other planning policy objectives, such as affordable housing. The scale of larger extensions provides greater certainty of their deliverability and would generate higher levels of S106 and/or CIL contributions for improvements to infrastructure and services. They also have the potential to deliver significant onsite community uses. For example, Land at Lubards Lodge Farm represents a unique opportunity to provide significant public open space, allotments and a much needed sports facility for Rayleigh Boys and Girls FC (please see the Vision Document at Appendix 2).

2.20 Our contention for discounting the alternative options are discussed below:
● Whilst the reference to the efficient use of brownfield land in option A is desirable in line with the national policy, densification and infilling has implications for amenity and design quality and the capacity of brownfield sites alone is insufficient to meet full OAHN. Furthermore, options A and B would drastically alter the character of existing settlements and residential land allocations to the extent that would be damaging to existing character. For these reasons, options A and B are considered unsuitable.

● Smaller scale extensions as referenced in option C would fail to deliver sufficient CIL or s106 receipts to enable the cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

For this reason, we consider option C unsuitable.

● The spatial characteristics of Rochford do not lend themselves well to a new settlement identified in option E. Rochford District is constrained by its relatively small geographical area exacerbated by the environmental constraints of the rural estuarine environments in the north and east. There are no obvious opportunities for a new settlement capable of delivering the required housing in a manner that would create sustainable communities. For this reason, option E is considered unsuitable.

2.21 This confirms our view that the only reasonable option is option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rayleigh, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements, CIL or delivery onsite to mitigate the impact of any scheme. We agree with and support this approach.

2.22 Our submission at Section 3 of this report demonstrates that, as a highly sustainable settlement at the top of the settlement hierarchy in the adopted Plan, with the largest population in the district (circa 40% of the District's population), we consider that Rayleigh is the most suitable settlement for accommodating significant housing growth to support the town and the wider district. Land at
Lubards Farm presents an excellent opportunity to deliver a larger scale extension to Rayleigh.

Strategic Priority 1.4: How do we plan for and deliver a good mix of homes in the future?

What types, sizes and tenures are needed?
2.23 The options as set out are:
● A Retain the current policy on types of house, which takes a flexible, market driven approach to types;
● B Include specific reference to the size and types of homes referred to in the South Essex SHMA;
● C Continue to require new homes to meet the National Technical Housing Standards - nationally described space standards;
● D Do not adopt specific policy on the mix of homes.

2.24 We consider that option B is the most suitable approach in relation to this issue, but a greater amount of flexibility should be built into policy wording. The policy should make reference to the housing mix requirement in the most up-to-date SHMA evidence without prescribing exact figures from the most up-to-date available at the time of the emerging Plan publication. Referring to the specific evidence base provides a degree of clarity for the developer whilst concurrently not being so specific as to be inflexible.

2.25 A further matter that does not appear to be considered in the options is that planning for a series of larger extensions to existing settlements means that strategic planning objectives such as housing mix and tenure may be planned for and delivered on a strategic scale. Need may be adequately met this way.

Strategic Priority 3.1: How can we prioritise and deliver improvements to the strategic and local highway network over the next 20 years?

2.26 We do not have any specific comments relating to options as set out under this strategic priority. However, in response to the issue of how to prioritise improvements to the highway network, these should be delivered proportionately and be spatially related to the delivery of homes and jobs. As we have contended, the most appropriate strategy of housing delivery would be larger urban extensions located in highly sustainable towns at the top of the settlement hierarchy, with Rayleigh representing the optimum location for significant growth. Highways improvements would similarly be best located in this area commensurate to housing growth.

Strategic Priority 5: Protecting and Enhancing Our Environment

Strategic Priority 5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

2.27 The options are:
● A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
● B. Amend the current Green Belt policy in the Core Strategy.
● C. Do not have a policy on the Green Belt.

2.28 We consider that option B is the most suitable approach

2.29 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be possible to balance these competing objectives by ensuring that a fully up-to-date evidence base
is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

2.30 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries (paragraph 84). Furthermore, it says that local planning authorities should consider the
consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).

2.31 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.

2.32 This is why we support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's OAHN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A
Green Belt Review would enable RDC to assess land parcels against the five Green Belt purposes.

2.33 Only once the Green Belt Review is complete, can RDC come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

2.34 Our submission demonstrates in the following section that Land at Lubards Lodge Farm, Rayleigh could be removed from the Green Belt as part of the Local Plan review in a manner that would enable a defensible re-drawn boundary in accordance with the five Green Belt purposes.

3.0 The Opportunity - Land at Lubards Lodge Farm, Rayleigh

3.1 Taking account of:
● Rochford District Council's full OAHN;
● The limited availability of brownfield land in the district;
● The spatial characteristics of the district lending themselves best to larger extensions to existing higher order settlements, including Rayleigh; and
● The need to locate new development in sustainable locations,
we consider that the Land at Lubards Lodge Farm, Rayleigh, presents an excellent opportunity for Rochford District Council to help meet its strategic housing needs as part of the new Local Plan. Our reasons for this are set out below.

Sustainable location

3.2 The town of Rayleigh is identified in both the adopted and emerging Plans at the top of the settlement hierarchy demonstrating the Council's view that is represents the most sustainable location for development. Paragraph 6.38 of the emerging Plan states that settlements at the top of the hierarchy are intrinsically sustainable by virtue of their more developed nature, extensive infrastructure connectivity and accessibility to services and the Council seeks to direct housing development to these locations.

3.3 Rayleigh benefits from excellent connectivity to the rest of South Essex and London through the strategic road network comprising the A127, A130 and the A13. It is linked to London Liverpool Street, Southend Victoria and London Southend Airport by train station located in the town centre.

A range of services and facilities are available within the town. The centre of Rayleigh comprises a range of retail units interspersed with food and drink establishments. Recreational buildings such as the Rayleigh Town Museum and The Mill Arts & Events Centre add to the offer in the town centre. To the south, the Brook Road Industrial Estate, as well as the units on the opposite side of
the Southend Arterial Road to the south, offer employment opportunities above and beyond those in the town centre. 18 schools and nurseries are present in Rayleigh as well as 6 GP surgeries and 6 supermarkets providing a comprehensive service offering within the settlement.

3.1 The following table provides a representation of the site's accessibility to key amenities and demonstrates its suitability for development.

AMENITY DISTANCE FROM SITE
Bus stops 3 adjacent to site
Post office 1 within 50 metres

AMENITY DISTANCE FROM SITE
Pharmacy 1 within 50 metres
Shopping Asda within 400 metres
Rayleigh High Street within 1,800 metres
Schools 2 primary schools within 600 metres
2 secondary schools within 1,800 metres
Train station 1 within 1,600 metres
Leisure facilities The Rayleigh Club is adjacent to site
Rayleigh Leisure Centre is within 500 metres
Employment centres Lubards Farm is adjacent to site
Rawreth Lane Industrial Estate is within 1,000 metres
Library 1 within 1,900 metres
Banking 1 within 1,800 metres
Medical 1 within 200 metres

3.2 These demonstrate that the site is sustainably located. Many of these amenities are accessible by bicycle or on foot.

Deliverability

3.1 As the site is within single ownership and is unencumbered, we consider the site as a suitable candidate for allocation as a strategic residential development site because development would be deliverable. This correlates with the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 approved for inclusion and publication within the new Local Plan evidence base by the Planning Policy Sub-Committee on 17 November 2017. The site is assessed
in this document under the reference number CFS164 and the summary confirmed that the site is within Flood Zone 1 and not proximate to any environmental designations with the exception of the Green Belt; a policy designation.

3.2 Crest Nicholson is a national and multi-award-winning housebuilder with a proven track record of delivery of high quality residential schemes. This adds further weight to our demonstration that development on the site would be deliverable within early phases of the emerging Local Plan.

Benefitting from planned highways improvements

3.3 The site's location adjacent to the northern urban area of Rayleigh represents a logical extension to the town, well contained by Hullbridge Road to the east and Rawreth Lane to the south. Locating new development in this part of Rayleigh would mean it would benefit from planned improvements to the existing highway. Furthermore, its location near to the strategic highway network means that the impact of additional highway movements around the town centre would be minimised.

Figure 1: Extract from Drawing F221-202 General Arrangement 3Arm Roundabout from planning permission 16/00162/FUL

3.4 The consented and fully funded roundabout upgrade at the junction of Rawreth Lane and Hullbridge Road reference number 16/00162/FUL could, once delivered, allow for improved accessibility to the site with enhanced access to the wider strategic road network. The upgraded roundabout also offers the potential opportunity for a direct vehicle access from the roundabout itself.

Green Infrastructure

3.5 There is an opportunity to incorporate managed green infrastructure to the north of the site to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised. As the site is currently private
land it does not benefit from the same potential that its redevelopment would bring in this regard.

Green Belt

3.6 Below is a summary of a Green Belt Assessment undertaken by Eleanor Trenfield Landscape Architects Ltd of the site's contribution to the Green Belt. For further detail, please refer to the brochure appended to this report.
● Check the unrestricted sprawl of large built-up areas
An analysis of neighbouring land uses shows sporadic residential plotland development to the west and north of the site as well as commercial estate to the east and residential properties to the south-east which already contribute to the sprawl of Rayleigh north towards Hullbridge. The site therefore is more closely associated with the urban edge of Rayleigh than countryside and makes limited contribution to this purpose.
● Prevent neighbouring towns from merging
Existing sporadic development to the west and the north contribute to the erosion of this function on the site. The absence of a clearly defined urban edge of Rayleigh at this location is created by the plotland development and the site therefore does not act as a barrier preventing the spread of Rayleigh. Indeed, the plotland development already surrounds the site in most directions including towards neighbouring towns and so development on Lubards Farm would not deteriorate the function further.
● Assist in safeguarding the countryside from encroachment
Land between Rayleigh and Hullbridge has experienced piecemeal development resulting in minimal characteristics that would qualify it as 'countryside' land. Plotland developments already protrude significantly into the open land at this location, surrounding the site to the west and the north. In this sense, the countryside has already been significantly encroached and development on the site would not erode this function further.
● Preserve the setting and special character of historic towns
The land between Hullbridge and Rayleigh has no inter-visibility with the Conservation Area of Rayleigh. As such, development on the site is not considered to damage this purpose of including land within the Green Belt.

We consider it the most suitable Green Belt site adjacent to Rayleigh

3.7 In the context of the above, we have considered it appropriate to review the suitability of alternative Green Belt sites on the edge of Rayleigh. Given the scale of additional growth needed in Rochford, as identified by the OAHN, we have considered the credentials of alternative sites for strategic scale development.

3.8 Several sites around Rayleigh were submitted to the Council through the call for sites process for consideration within the new Local Plan and were presented at the Planning Policy Sub-Committee on 17 November 2017. The committee resolved to publish this document in the new Local Plan evidence base. These alternative sites are discussed briefly below along with our commentary regarding their comparatively weaker suitability credentials than that of Lubards Lodge Farm.
● Committed residential development exists to the west of Rayleigh under the reference number 15/00362/OUT on Land North of London Road, South of Rawreth Lane and West of Rawreth Industrial Estate. In our view, further development to the west of this location would lead to a significant increased sense of coalescence with Wickford and a sprawl of Rayleigh in this direction. See figure 2 below for reference.

Figure 2: Extract from the Council's Site Allocations Plan North of London Road, Rayleigh

To the north-east of Rayleigh, in the proximity of SHELAA site CFS105 Land north of Hambro Hill, is constrained by the topography and access. The area of CFS053 Land south of 38 and 39 Wellington Road, CFS098, CFS029 and CFS027 to the east of Rayleigh, falls within the Upper Roach Valley which is protected from development under CS Policy URV1. They would also require access through existing residential areas. We do not consider these sites of a scale capable of delivering strategic scale development and commensurate infrastructure requirements in accordance with the Council's priorities. Furthermore, their delivery would require land assembly and their delivery could not be guaranteed. See figure 3 below for reference.

To the south-east of Rayleigh, in the proximity of SHELAA site CFS127 Eastwood Nurseries off Bartletts, CFS044 south of Eastwood Road and CFS068 off Daws Heath Lane, there are small fragmented land parcels, likely to fall within different land ownerships. Development of this area is likely to be piecemeal and would in our view not be capable of delivering the high quality, integrated development achievable on the Lubards Lodge Farm site. In addition, site access from the narrow Daws Heath Road and from constrained access points off Eastwood Road are likely to be significant constraint in this location. See figure 4 below for reference.

To the south-west of Rayleigh, in the proximity of SHELAA site CFS121 Land north of A127, development is constrained by the exposed and open nature of the countryside experienced from this location. A substantial number of electricity pylons traverse the site between the substation adjacent to the south of the railway station and the National Grid main substation to the west of the A1245. A suitable point of vehicular access is also likely to be an issue for development in this area. See Figure 5 below for reference.

Evidence supporting this submission

Landscape

3.9 A Landscape and Visual Assessment (LVA) of the site has been undertaken and incorporated into the Vision Document in Appendix 2. The assessment identified a number of constraints and opportunities which have informed the proposed masterplan for the site but confirmed that development is entirely achievable in landscape terms.

3.10 The LVA recognised the existing neighbouring development and the mix of land uses at this location and concluded that residential development would not be uncharacteristic for the area. It recommends that the existing vegetation and hedgerow structures be retained as far as possible within the site, particularly bordering the 3 Public Right of Ways (PRoWs) on site. A significant opportunity exists to the north of the site, to provide a new open space connecting to the PRoW
network, providing amenity and green spaces for the proposed dwellings and enhancing biodiversity.

Ecology

3.11 An assessment of the Ecological Constraints and Opportunities has been undertaken and informed the proposed masterplan shown in the promotional brochure at Appendix 2.

3.12 The Assessment concluded that the site is largely of low ecological value but identified two European Designated sites within an 8km radius of the site. Of the two designations, the Crouch & Roach Estuary Special Protection Area (SPA) and Ramsar has the potential to be impacted indirectly due to increased recreational disturbance and a Habitat Regulations Assessment (HRA) is recommended to explore this further. This would be undertaken as the proposals progress.

3.13 The Assessment concludes that with an appropriately designed masterplan, development can be achieved on this site whilst also providing enhancements for biodiversity. An area of Suitable Accessible Natural Green Space (SANGS) is considered appropriate on the north of the site, to provide an alternative open space for future residents of the proposed new dwellings to minimise numbers travelling to the designated sites for recreational purposes.

3.14 Further phase 2 survey work is identified as necessary and these would be undertaken during the appropriate survey window as the proposals progress. Once all survey data is collected, appropriate mitigation measures would be incorporated into the proposals in line with recommendations.

Highways and Access

3.15 An appraisal of access opportunities has been undertaken on the site and has informed the masterplan shown in the promotional brochure in Appendix 2.

3.16 The appraisal identifies the potential for access to be obtained from a 4th arm on the consented roundabout at the junction of Hullbridge Road and Rawreth Lane under the planning permission 16/00162/FUL. Additional opportunities exist along Rawreth Lane, with potential for a 4th arm off the existing signalised junction with Downhall Park Way or a priority 'T' junction on Rawreth Lane.

3.17 Further work, in the form of a Transport Assessment, would be undertaken as the proposals progress. However, in light of the appraisal, residential development of the site as outlined in the promotional brochure is considered achievable.

Floods and Drainage

3.18 An initial floods and drainage assessment has been undertaken and informed the production of the masterplan shown in the promotional brochure at Appendix 2.

3.19 The site generally falls from the south-west to the north-east and located predominantly within Flood Zone 1, with small areas immediately adjacent to the watercourse flowing south to north on the eastern boundary. Some areas of the site are within areas of high, medium and low risk of surface water flooding with a depth of less than 300mm.

3.20 The Lead Local Flood Authority (LLFA) map places the site in a Critical Drainage Area and have produced a Surface Water Management Plan (SWMP) for the area. Whilst the site itself is not at risk of flooding, it is important that development does not increase the risk of flooding offsite within the wider catchment.

3.21 Unsuitable ground conditions exist for infiltration drainage techniques so a system of swales across the site would collect surface water and attenuate it before it passes to a detention basin. A Train of Sustainable Urban Drainage Systems (SuDS) would be incorporated into the scheme as well as 2 outfall points into the watercourse to drain the site. The features described above also offer habitats to support biodiversity and would enhance the environment by adding a water element to the scheme. The water detention centre, when not in use for water storage, would be designed to allow its use for other purposes.

3.22 Foul water would be collected in a tradition pipe network connecting to the existing Anglian Water sewers in Hullbridge Road. The pipe network would be offered to Anglian Water for adoption.

3.23 The drainage system on site has been developed in line with LLFA guidance and SuDS manual and is considered to appropriately address floods and drainage issues. Further refinement of the systems would be undertaken as the proposals progress.

4.0 Conclusion

4.1 These representations have been prepared on behalf of Crest Nicholson Eastern in respect of Land at Lubards Lodge Farm, Rayleigh for consideration in the Rochford Issues and Options Local Plan consultation of March 2018.

4.2 In order to achieve the vision and strategic priority 1 as detailed in the emerging Local Plan, development on the site is required. Significant employment growth is identified in the JAAP and in the wider South Essex sub-region. Housing delivery must match this growth.

4.3 Other neighbouring and nearby Green Belt local authorities are planning for their full OAHN within their Plan areas and there is no sound reason why Rochford should do otherwise.

4.4 In spatial strategy terms, a smaller number of large urban extensions would be the most sustainable approach for addressing this need, particularly in Rayleigh taking account of its sustainability and subsequent position at the top of the settlement hierarchy.

4.5 The Land at Lubards Lodge Farm is located in the Green Belt on the northern border of Rayleigh in a highly sustainable location, with access to the services and facilities within the town centre and the strategic road network and public transport links to London, wider south Essex and Southend airport. Within single ownership, the land is unencumbered and represents an excellent location for strategic scale residential development.

4.6 We would support the Council to undertake a Green Belt review of the district. This would confirm the Green Belt function of potential development sites including the Land at Lubards Lodge Farm and thereby justify strategic planning choices as part of the emerging Local Plan. We consider that Lubards Lodge Farm is the most suitable site for strategic scale residential development at Rayleigh. It also provides a unique opportunity to deliver significant community uses for the town's
existing and future residents.

4.7 A significant amount of preliminary assessments and appraisals have been undertaken to date and all conclude that development is entirely achievable on site. The Vision Document accompanying these representations at Appendix 2 provides further detail and shows the proposed initial masterplan for the site. Crest Nicholson specialises in the design and construction of high quality, community-led residential schemes and will continue to work with RDC and the local community to develop this vision for the site.

*THIS REPRESENTATION IS ACCOMPANIED BY MULTIPLE ATTACHMENTS INCLUDING A SITE MAP AND VISION DOCUMENT*

These representations have been prepared on behalf of Crest Nicholson Eastern in support of Land at Lubards Lodge Farm, Rayleigh (hereafter referred to as the "Site") for consideration in the Rochford District Council ("RDC") Issues and Options Local Plan ("the emerging Plan") consultation of March 2018.

Appendix 1 contains a Site Location Plan which shows the extent of the boundaries
of the site.

1.2 The site comprises approximately 42.4 hectares of greenfield land with the potential to deliver a proportion of Rochford District Council's strategic housing need as part of the wider full Objectively Assessed Housing Need (OAHN) for the district. A proposed indicated layout is included within the Vision Document in Appendix 2 of these representations.

1.3 Green Belt release is recognised as necessary within the emerging Plan, where it is acknowledged that there is an insufficient supply of brownfield sites within the District to meet the full OAHN. As an unencumbered greenfield, Green Belt site, Lubards Lodge Farm represents a sustainable and logical extension of Rayleigh and an excellent opportunity for residential development in the most sustainable settlement in the district according to the Council's settlement hierarchy.

1.4 Crest Nicholson is an award-winning national housebuilder with a proven track record of delivery, so if the site were allocated in the emerging Local Plan, the residential development of the site could be guaranteed.

1.5 The specific emerging Plan sections that these representations refer to are as follows:
● Vision
● Strategic Priority 1 - the homes and jobs needed in the area
 Strategic Priority 1.1
 Strategic Priority 1.3
 Strategic Priority 1.4
● Strategic Priority 3 - the provision of infrastructure
 Strategic Priority 3.1
● Strategic Priority 5 - protecting and enhancing our environment

 Strategic Priority 5.1

1.6 Full responses to the relevant issues and options within the emerging Plan are detailed in section 2 of this report and section 3 sets out the opportunity presented by the site for delivery of highly sustainable residential development on the northern edge of Rayleigh.

2.0 Our Response to the Issues and Options

The Vision

2.1 The vision section of the emerging Plan details the aims of the Council in relation to the three pillars of sustainability; our economy, our environment and our society. We support the Council's acknowledgement that this vision identifies that growth must be promoted within the district. This is fundamental to the three pillars of sustainable development. It therefore follows that sufficient housing sites must be delivered through the emerging Plan to support the employment, economic
and demographic growth anticipated throughout the Plan period in order to achieve the vision.

2.2 London Southend Airport forms a major part of the planned economic growth of South Essex. Rochford District Council's London Southend Airport and Environs Joint Area Action Plan (JAAP) was adopted in December 2014 in conjunction with Southend Borough Council and the area surrounding the airport is identified as a high scale employment growth area in the JAAP for both Rochford and Southend authorities. Land to accommodate 109,000 additional square metres of employment floorspace is allocated in the JAAP, comprising the new Saxon Business Park and
other smaller business parks and industrial estates, along with the potential to redevelop an area of underutilised brownfield industrial land at Aviation Way. In total, the land is capable of providing an additional 6,200 jobs in the area excluding direct airport related employment, but in order to fully realise the potential offered by this increase in employment land there must be commensurate housing provision through which a local workforce can be located.

2.3 We therefore consider that the planned employment growth must be matched by housing delivery in the most sustainable locations within the district. Rayleigh is one such location. It is strategically well located near to the trunk road network, main line railway to London and to the airport business park, the key employment area in the district. It therefore has optimal characteristics to contribute
significantly to this required housing delivery within the district.

Strategic Priority 1: The homes and jobs needed in the area

2.4 The emerging Plan sets out several strategic priorities for the Plan area in order to achieve the vision. The most relevant to these representations is strategic priority 1, relating to the delivery of homes and jobs in the district.

2.5 In the first instance we support the Council's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District. We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18). The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery. We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the National Planning Policy Framework (the "Framework"), which clearly requires local planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

2.6 We also consider that the emerging Plan should allocate sufficient housing sites to ensure that housing delivery matches the employment growth anticipated in the JAAP and wider Thames Gateway South Essex, a national priority area for growth and regeneration. The JAAP anticipates that the airport employment park alone could generate 6,200 new jobs by 2031 and the wider Thames Gateway South Essex is anticipated to deliver at least 52,000 new jobs1 over the same
period. Delivery of full OAHN in Rochford is therefore a crucial part of the wider strategic growth of South Essex.

2.7 RDC should therefore look to allocate land in the context of full OAHN for residential growth in the most sustainable locations to help attract and support the anticipated economic growth in and around the district and as part of the wider economic strategy for South Essex.

Strategic Priority 1.1: We have a real and identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?

2.8 Our comments relate specifically to objectively assessed housing need:

2.9 The options as set out are:
● A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
● B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
● C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

2.10 We consider that option A is the most suitable approach in relation to this issue, because it is the approach that is best supported by national planning policy and many local planning authorities local to Rochford are already taking this approach as part of their new Local Plans.

2.11 If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy
constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. Nearby local authorities of Basildon and Brentwood are both equally constrained by Green Belt but are both proposing to meet full OAHN. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

2.12 As a useful starting point, it is apparent from the Council's evidence base that the full OAHN could easily be accommodated on sites within the district; the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 identifies that there are 209 suitable and achievable sites within the district capable of accommodating 24,590 dwellings. This identified potential land capacity is well beyond that of the OAHN upper limit of 7,871 homes including the
shortfall in delivery prior to the emerging Plan period.

2.13 The potential land capacity above includes sites within the Green Belt and Special Landscape Areas and the majority of sites fall within these designations. These constraints should not prevent the allocation of the most suitable sites as part of a Local Plan review and in order to demonstrate that the Plan has been positively prepared, as part of the National Planning Policy Framework's
test of soundness under paragraph 182, we recommend that the Council undertakes further work in the form of a Green Belt review assessing individual sites for their contribution to the five purposes of including land within the Green Belt and their potential for release and development.

2.14 We therefore support option A.

Strategic Priority 1.3: How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?

2.15 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011). Rayleigh sits within the top tier of settlements as the most populated settlement in the district. Having regard to its sustainable location with easy access to public transport opportunities including mainline rail, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core Strategy was adopted.

2.16 Our comments on the Options are therefore as follows:

2.17 The realistic options as set out are:
● A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
● B. Increase density on allocated residential sites.
● C. Several small extensions to the existing residential area.
● D. A number of fewer larger extensions to the existing residential area.
● E. A new settlement.

2.18 We consider that option D is the most suitable method of meeting RDC's housing needs because it is the most deliverable over the Plan period.

2.19 Delivering homes in a fewer number of larger urban extensions, directed to established and wellserviced settlements within the district, would ensure that new homes would be connected to existing employment opportunities, transport networks and essential facilities, without a scale of requisite infrastructure provision that would threaten delivery of other planning policy objectives, such as affordable housing. The scale of larger extensions provides greater certainty of their deliverability and would generate higher levels of S106 and/or CIL contributions for improvements to infrastructure and services. They also have the potential to deliver significant onsite community uses. For example, Land at Lubards Lodge Farm represents a unique opportunity to provide significant public open space, allotments and a much needed sports facility for Rayleigh Boys and Girls FC (please see the Vision Document at Appendix 2).

2.20 Our contention for discounting the alternative options are discussed below:
● Whilst the reference to the efficient use of brownfield land in option A is desirable in line with the national policy, densification and infilling has implications for amenity and design quality and the capacity of brownfield sites alone is insufficient to meet full OAHN. Furthermore, options A and B would drastically alter the character of existing settlements and residential land allocations to the extent that would be damaging to existing character. For these reasons, options A and B are considered unsuitable.

● Smaller scale extensions as referenced in option C would fail to deliver sufficient CIL or s106 receipts to enable the cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

For this reason, we consider option C unsuitable.

● The spatial characteristics of Rochford do not lend themselves well to a new settlement identified in option E. Rochford District is constrained by its relatively small geographical area exacerbated by the environmental constraints of the rural estuarine environments in the north and east. There are no obvious opportunities for a new settlement capable of delivering the required housing in a manner that would create sustainable communities. For this reason, option E is considered unsuitable.

2.21 This confirms our view that the only reasonable option is option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rayleigh, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements, CIL or delivery onsite to mitigate the impact of any scheme. We agree with and support this approach.

2.22 Our submission at Section 3 of this report demonstrates that, as a highly sustainable settlement at the top of the settlement hierarchy in the adopted Plan, with the largest population in the district (circa 40% of the District's population), we consider that Rayleigh is the most suitable settlement for accommodating significant housing growth to support the town and the wider district. Land at
Lubards Farm presents an excellent opportunity to deliver a larger scale extension to Rayleigh.

Strategic Priority 1.4: How do we plan for and deliver a good mix of homes in the future?

What types, sizes and tenures are needed?
2.23 The options as set out are:
● A Retain the current policy on types of house, which takes a flexible, market driven approach to types;
● B Include specific reference to the size and types of homes referred to in the South Essex SHMA;
● C Continue to require new homes to meet the National Technical Housing Standards - nationally described space standards;
● D Do not adopt specific policy on the mix of homes.

2.24 We consider that option B is the most suitable approach in relation to this issue, but a greater amount of flexibility should be built into policy wording. The policy should make reference to the housing mix requirement in the most up-to-date SHMA evidence without prescribing exact figures from the most up-to-date available at the time of the emerging Plan publication. Referring to the specific evidence base provides a degree of clarity for the developer whilst concurrently not being so specific as to be inflexible.

2.25 A further matter that does not appear to be considered in the options is that planning for a series of larger extensions to existing settlements means that strategic planning objectives such as housing mix and tenure may be planned for and delivered on a strategic scale. Need may be adequately met this way.

Strategic Priority 3.1: How can we prioritise and deliver improvements to the strategic and local highway network over the next 20 years?

2.26 We do not have any specific comments relating to options as set out under this strategic priority. However, in response to the issue of how to prioritise improvements to the highway network, these should be delivered proportionately and be spatially related to the delivery of homes and jobs. As we have contended, the most appropriate strategy of housing delivery would be larger urban extensions located in highly sustainable towns at the top of the settlement hierarchy, with Rayleigh representing the optimum location for significant growth. Highways improvements would similarly be best located in this area commensurate to housing growth.

Strategic Priority 5: Protecting and Enhancing Our Environment

Strategic Priority 5.1: How do we balance protection of the district's Green Belt that meets the five Green Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

2.27 The options are:
● A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
● B. Amend the current Green Belt policy in the Core Strategy.
● C. Do not have a policy on the Green Belt.

2.28 We consider that option B is the most suitable approach

2.29 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be possible to balance these competing objectives by ensuring that a fully up-to-date evidence base
is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

2.30 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries (paragraph 84). Furthermore, it says that local planning authorities should consider the
consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).

2.31 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.

2.32 This is why we support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's OAHN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A
Green Belt Review would enable RDC to assess land parcels against the five Green Belt purposes.

2.33 Only once the Green Belt Review is complete, can RDC come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

2.34 Our submission demonstrates in the following section that Land at Lubards Lodge Farm, Rayleigh could be removed from the Green Belt as part of the Local Plan review in a manner that would enable a defensible re-drawn boundary in accordance with the five Green Belt purposes.

3.0 The Opportunity - Land at Lubards Lodge Farm, Rayleigh

3.1 Taking account of:
● Rochford District Council's full OAHN;
● The limited availability of brownfield land in the district;
● The spatial characteristics of the district lending themselves best to larger extensions to existing higher order settlements, including Rayleigh; and
● The need to locate new development in sustainable locations,
we consider that the Land at Lubards Lodge Farm, Rayleigh, presents an excellent opportunity for Rochford District Council to help meet its strategic housing needs as part of the new Local Plan. Our reasons for this are set out below.

Sustainable location

3.2 The town of Rayleigh is identified in both the adopted and emerging Plans at the top of the settlement hierarchy demonstrating the Council's view that is represents the most sustainable location for development. Paragraph 6.38 of the emerging Plan states that settlements at the top of the hierarchy are intrinsically sustainable by virtue of their more developed nature, extensive infrastructure connectivity and accessibility to services and the Council seeks to direct housing development to these locations.

3.3 Rayleigh benefits from excellent connectivity to the rest of South Essex and London through the strategic road network comprising the A127, A130 and the A13. It is linked to London Liverpool Street, Southend Victoria and London Southend Airport by train station located in the town centre.

A range of services and facilities are available within the town. The centre of Rayleigh comprises a range of retail units interspersed with food and drink establishments. Recreational buildings such as the Rayleigh Town Museum and The Mill Arts & Events Centre add to the offer in the town centre. To the south, the Brook Road Industrial Estate, as well as the units on the opposite side of
the Southend Arterial Road to the south, offer employment opportunities above and beyond those in the town centre. 18 schools and nurseries are present in Rayleigh as well as 6 GP surgeries and 6 supermarkets providing a comprehensive service offering within the settlement.

3.1 The following table provides a representation of the site's accessibility to key amenities and demonstrates its suitability for development.

AMENITY DISTANCE FROM SITE
Bus stops 3 adjacent to site
Post office 1 within 50 metres

AMENITY DISTANCE FROM SITE
Pharmacy 1 within 50 metres
Shopping Asda within 400 metres
Rayleigh High Street within 1,800 metres
Schools 2 primary schools within 600 metres
2 secondary schools within 1,800 metres
Train station 1 within 1,600 metres
Leisure facilities The Rayleigh Club is adjacent to site
Rayleigh Leisure Centre is within 500 metres
Employment centres Lubards Farm is adjacent to site
Rawreth Lane Industrial Estate is within 1,000 metres
Library 1 within 1,900 metres
Banking 1 within 1,800 metres
Medical 1 within 200 metres

3.2 These demonstrate that the site is sustainably located. Many of these amenities are accessible by bicycle or on foot.

Deliverability

3.1 As the site is within single ownership and is unencumbered, we consider the site as a suitable candidate for allocation as a strategic residential development site because development would be deliverable. This correlates with the Council's Strategic Housing and Employment Land Availability Assessment (SHEELA) 2017 approved for inclusion and publication within the new Local Plan evidence base by the Planning Policy Sub-Committee on 17 November 2017. The site is assessed
in this document under the reference number CFS164 and the summary confirmed that the site is within Flood Zone 1 and not proximate to any environmental designations with the exception of the Green Belt; a policy designation.

3.2 Crest Nicholson is a national and multi-award-winning housebuilder with a proven track record of delivery of high quality residential schemes. This adds further weight to our demonstration that development on the site would be deliverable within early phases of the emerging Local Plan.

Benefitting from planned highways improvements

3.3 The site's location adjacent to the northern urban area of Rayleigh represents a logical extension to the town, well contained by Hullbridge Road to the east and Rawreth Lane to the south. Locating new development in this part of Rayleigh would mean it would benefit from planned improvements to the existing highway. Furthermore, its location near to the strategic highway network means that the impact of additional highway movements around the town centre would be minimised.

Figure 1: Extract from Drawing F221-202 General Arrangement 3Arm Roundabout from planning permission 16/00162/FUL

3.4 The consented and fully funded roundabout upgrade at the junction of Rawreth Lane and Hullbridge Road reference number 16/00162/FUL could, once delivered, allow for improved accessibility to the site with enhanced access to the wider strategic road network. The upgraded roundabout also offers the potential opportunity for a direct vehicle access from the roundabout itself.

Green Infrastructure

3.5 There is an opportunity to incorporate managed green infrastructure to the north of the site to enhance the already strong natural defensible Green Belt boundary and to ensure the maintenance of the gap between the settlements of Rayleigh and Hullbridge, to help prevent coalescence in accordance with Green Belt policy. It would also ensure that opportunities to enhance the beneficial use of the Green Belt, as redrawn, could be maximised. As the site is currently private
land it does not benefit from the same potential that its redevelopment would bring in this regard.

Green Belt

3.6 Below is a summary of a Green Belt Assessment undertaken by Eleanor Trenfield Landscape Architects Ltd of the site's contribution to the Green Belt. For further detail, please refer to the brochure appended to this report.
● Check the unrestricted sprawl of large built-up areas
An analysis of neighbouring land uses shows sporadic residential plotland development to the west and north of the site as well as commercial estate to the east and residential properties to the south-east which already contribute to the sprawl of Rayleigh north towards Hullbridge. The site therefore is more closely associated with the urban edge of Rayleigh than countryside and makes limited contribution to this purpose.
● Prevent neighbouring towns from merging
Existing sporadic development to the west and the north contribute to the erosion of this function on the site. The absence of a clearly defined urban edge of Rayleigh at this location is created by the plotland development and the site therefore does not act as a barrier preventing the spread of Rayleigh. Indeed, the plotland development already surrounds the site in most directions including towards neighbouring towns and so development on Lubards Farm would not deteriorate the function further.
● Assist in safeguarding the countryside from encroachment
Land between Rayleigh and Hullbridge has experienced piecemeal development resulting in minimal characteristics that would qualify it as 'countryside' land. Plotland developments already protrude significantly into the open land at this location, surrounding the site to the west and the north. In this sense, the countryside has already been significantly encroached and development on the site would not erode this function further.
● Preserve the setting and special character of historic towns
The land between Hullbridge and Rayleigh has no inter-visibility with the Conservation Area of Rayleigh. As such, development on the site is not considered to damage this purpose of including land within the Green Belt.

We consider it the most suitable Green Belt site adjacent to Rayleigh

3.7 In the context of the above, we have considered it appropriate to review the suitability of alternative Green Belt sites on the edge of Rayleigh. Given the scale of additional growth needed in Rochford, as identified by the OAHN, we have considered the credentials of alternative sites for strategic scale development.

3.8 Several sites around Rayleigh were submitted to the Council through the call for sites process for consideration within the new Local Plan and were presented at the Planning Policy Sub-Committee on 17 November 2017. The committee resolved to publish this document in the new Local Plan evidence base. These alternative sites are discussed briefly below along with our commentary regarding their comparatively weaker suitability credentials than that of Lubards Lodge Farm.
● Committed residential development exists to the west of Rayleigh under the reference number 15/00362/OUT on Land North of London Road, South of Rawreth Lane and West of Rawreth Industrial Estate. In our view, further development to the west of this location would lead to a significant increased sense of coalescence with Wickford and a sprawl of Rayleigh in this direction. See figure 2 below for reference.

Figure 2: Extract from the Council's Site Allocations Plan North of London Road, Rayleigh

To the north-east of Rayleigh, in the proximity of SHELAA site CFS105 Land north of Hambro Hill, is constrained by the topography and access. The area of CFS053 Land south of 38 and 39 Wellington Road, CFS098, CFS029 and CFS027 to the east of Rayleigh, falls within the Upper Roach Valley which is protected from development under CS Policy URV1. They would also require access through existing residential areas. We do not consider these sites of a scale capable of delivering strategic scale development and commensurate infrastructure requirements in accordance with the Council's priorities. Furthermore, their delivery would require land assembly and their delivery could not be guaranteed. See figure 3 below for reference.

To the south-east of Rayleigh, in the proximity of SHELAA site CFS127 Eastwood Nurseries off Bartletts, CFS044 south of Eastwood Road and CFS068 off Daws Heath Lane, there are small fragmented land parcels, likely to fall within different land ownerships. Development of this area is likely to be piecemeal and would in our view not be capable of delivering the high quality, integrated development achievable on the Lubards Lodge Farm site. In addition, site access from the narrow Daws Heath Road and from constrained access points off Eastwood Road are likely to be significant constraint in this location. See figure 4 below for reference.

To the south-west of Rayleigh, in the proximity of SHELAA site CFS121 Land north of A127, development is constrained by the exposed and open nature of the countryside experienced from this location. A substantial number of electricity pylons traverse the site between the substation adjacent to the south of the railway station and the National Grid main substation to the west of the A1245. A suitable point of vehicular access is also likely to be an issue for development in this area. See Figure 5 below for reference.

Evidence supporting this submission

Landscape

3.9 A Landscape and Visual Assessment (LVA) of the site has been undertaken and incorporated into the Vision Document in Appendix 2. The assessment identified a number of constraints and opportunities which have informed the proposed masterplan for the site but confirmed that development is entirely achievable in landscape terms.

3.10 The LVA recognised the existing neighbouring development and the mix of land uses at this location and concluded that residential development would not be uncharacteristic for the area. It recommends that the existing vegetation and hedgerow structures be retained as far as possible within the site, particularly bordering the 3 Public Right of Ways (PRoWs) on site. A significant opportunity exists to the north of the site, to provide a new open space connecting to the PRoW
network, providing amenity and green spaces for the proposed dwellings and enhancing biodiversity.

Ecology

3.11 An assessment of the Ecological Constraints and Opportunities has been undertaken and informed the proposed masterplan shown in the promotional brochure at Appendix 2.

3.12 The Assessment concluded that the site is largely of low ecological value but identified two European Designated sites within an 8km radius of the site. Of the two designations, the Crouch & Roach Estuary Special Protection Area (SPA) and Ramsar has the potential to be impacted indirectly due to increased recreational disturbance and a Habitat Regulations Assessment (HRA) is recommended to explore this further. This would be undertaken as the proposals progress.

3.13 The Assessment concludes that with an appropriately designed masterplan, development can be achieved on this site whilst also providing enhancements for biodiversity. An area of Suitable Accessible Natural Green Space (SANGS) is considered appropriate on the north of the site, to provide an alternative open space for future residents of the proposed new dwellings to minimise numbers travelling to the designated sites for recreational purposes.

3.14 Further phase 2 survey work is identified as necessary and these would be undertaken during the appropriate survey window as the proposals progress. Once all survey data is collected, appropriate mitigation measures would be incorporated into the proposals in line with recommendations.

Highways and Access

3.15 An appraisal of access opportunities has been undertaken on the site and has informed the masterplan shown in the promotional brochure in Appendix 2.

3.16 The appraisal identifies the potential for access to be obtained from a 4th arm on the consented roundabout at the junction of Hullbridge Road and Rawreth Lane under the planning permission 16/00162/FUL. Additional opportunities exist along Rawreth Lane, with potential for a 4th arm off the existing signalised junction with Downhall Park Way or a priority 'T' junction on Rawreth Lane.

3.17 Further work, in the form of a Transport Assessment, would be undertaken as the proposals progress. However, in light of the appraisal, residential development of the site as outlined in the promotional brochure is considered achievable.

Floods and Drainage

3.18 An initial floods and drainage assessment has been undertaken and informed the production of the masterplan shown in the promotional brochure at Appendix 2.

3.19 The site generally falls from the south-west to the north-east and located predominantly within Flood Zone 1, with small areas immediately adjacent to the watercourse flowing south to north on the eastern boundary. Some areas of the site are within areas of high, medium and low risk of surface water flooding with a depth of less than 300mm.

3.20 The Lead Local Flood Authority (LLFA) map places the site in a Critical Drainage Area and have produced a Surface Water Management Plan (SWMP) for the area. Whilst the site itself is not at risk of flooding, it is important that development does not increase the risk of flooding offsite within the wider catchment.

3.21 Unsuitable ground conditions exist for infiltration drainage techniques so a system of swales across the site would collect surface water and attenuate it before it passes to a detention basin. A Train of Sustainable Urban Drainage Systems (SuDS) would be incorporated into the scheme as well as 2 outfall points into the watercourse to drain the site. The features described above also offer habitats to support biodiversity and would enhance the environment by adding a water element to the scheme. The water detention centre, when not in use for water storage, would be designed to allow its use for other purposes.

3.22 Foul water would be collected in a tradition pipe network connecting to the existing Anglian Water sewers in Hullbridge Road. The pipe network would be offered to Anglian Water for adoption.

3.23 The drainage system on site has been developed in line with LLFA guidance and SuDS manual and is considered to appropriately address floods and drainage issues. Further refinement of the systems would be undertaken as the proposals progress.

4.0 Conclusion

4.1 These representations have been prepared on behalf of Crest Nicholson Eastern in respect of Land at Lubards Lodge Farm, Rayleigh for consideration in the Rochford Issues and Options Local Plan consultation of March 2018.

4.2 In order to achieve the vision and strategic priority 1 as detailed in the emerging Local Plan, development on the site is required. Significant employment growth is identified in the JAAP and in the wider South Essex sub-region. Housing delivery must match this growth.

4.3 Other neighbouring and nearby Green Belt local authorities are planning for their full OAHN within their Plan areas and there is no sound reason why Rochford should do otherwise.

4.4 In spatial strategy terms, a smaller number of large urban extensions would be the most sustainable approach for addressing this need, particularly in Rayleigh taking account of its sustainability and subsequent position at the top of the settlement hierarchy.

4.5 The Land at Lubards Lodge Farm is located in the Green Belt on the northern border of Rayleigh in a highly sustainable location, with access to the services and facilities within the town centre and the strategic road network and public transport links to London, wider south Essex and Southend airport. Within single ownership, the land is unencumbered and represents an excellent location for strategic scale residential development.

4.6 We would support the Council to undertake a Green Belt review of the district. This would confirm the Green Belt function of potential development sites including the Land at Lubards Lodge Farm and thereby justify strategic planning choices as part of the emerging Local Plan. We consider that Lubards Lodge Farm is the most suitable site for strategic scale residential development at Rayleigh. It also provides a unique opportunity to deliver significant community uses for the town's
existing and future residents.

4.7 A significant amount of preliminary assessments and appraisals have been undertaken to date and all conclude that development is entirely achievable on site. The Vision Document accompanying these representations at Appendix 2 provides further detail and shows the proposed initial masterplan for the site. Crest Nicholson specialises in the design and construction of high quality, community-led residential schemes and will continue to work with RDC and the local community to develop this vision for the site.