Issues and Options Document

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

Rochford Local Plan Regulation 18 Consultation

Thank you for the opportunity to comment on the Regulation 18 version of the Rochford Local Plan. These representations are submitted on behalf of Rydon Homes which has an interest in land south of Wellington Road, Rayleigh (site CFS053 in the 2017 SHELAA).

Attached to this representation is a schedule which sets out Rydon's views on the options presented in the document. Hopefully, this will assist your analysis. However, such a point by point response can also obscure the Respondent's overall views on the plan and its main issues. In view of this, this letter brings together the various themes of the Rydon response.

The main points are :
1. The Vision and Strategic Objectives should make it clearer that the plan should seek to meet local housing needs in full. Many other Local Authorities with high levels of Green Belt (eg St Albans) have concluded that their housing needs have to be met and have commissioned a Green Belt Review to identify which land parcels serve the least Green Belt purposes.

2. The Green Belt Review should be progressed in parallel with an assessment of which sites would best promote a more sustainable pattern of development and minimise the use of the car.

3. The plan recognises that Rayleigh is the largest settlement in Rochford District and has the greatest range of facilities and services, plus public transport. As a
consequence, new housing allocations within and on the edge of Rayleigh have the
greatest chance of minimising the need to use the car in favour of walking, cycling
and public transport. Whilst it is accepted that the centre of Rayleigh is currently an
Air Quality Management Area, your 2015 Environmental Capacity Study (para 8.2)
recognises that a package of mitigation measures is available.

4. Whilst it is a matter of concern that your Environmental Capacity Study only focusses on the environmental facet of sustainable development and largely ignores the social and economic aspects, it is noted that it concludes (para 8.27) that the greatest capacity for further development lies within and on the edge of the urban areas in the north and west of the District. When this conclusion is combined with the sustainable credentials of Rayleigh, it is clear that the evidence base provides the justification for smaller housing allocations on the periphery of Rayleigh.

5. The Rydon land south of Wellington Road, Rayleigh (CFS053 - see attached plan) is a strong candidate for allocation since
* It is within walking distance of Rayleigh Town Centre
* It has an existing access on to Wellington Road
* It is close to schools, open space and community facilities
* It is not constrained by environmental or heritage issues
* It is outside the boundary of the Upper Roach Valley (see Figure 07 of the
Environmental Capacity Study)
* The site could be released from the Green Belt with only limited impacts on
the purposes of the Green Belt
* An indicative master plan is attached (No. 2575-A-1004 A) which shows how
the site can be planned to provide up to 80 homes. This master plan forms
part of the 'Site Appraisal and Promotion Document' provided to you on the
18th May 2017. If you would like this resubmitted, please let me know.
Should you feel that a meeting would be useful to discuss this site, perhaps you could suggest some dates.

1. Vision (para. 5.9) : The Vision should include the objective of fully meeting housing needs within the Rochford District.

2. Vision (para 5.10) : The 'Our Society' Vision should contain the objective of fully
meeting housing needs with Rochford District.

3. Strategic Objective (para 5.11) : The objective should make it clear that 'sufficient homes' equates to Objectively Assessed Housing Needs, or such housing figure that emerges from the 'Right Homes' consultation by DCLG. It is unclear what 'prioritising the use of previously developed land first' means. Given the scale of housing needs, it is likely that both previously developed land and Green Belt releases will be needed throughout the plan period.

4. Strategic Priority 1 (para 5.11) : There should be an objective to locate new housing where it can best deliver the most sustainable pattern of development.

5. Strategic Priority 1 (p38) : The plan should pursue Option A to seek to provide as
much housing as possible within Rochford District.

6. Affordable Housing Threshold (para. 6.31) : Option A should be selected to
maximise the delivery of affordable homes from a wider range of sites.

7. Affordable Housing Percentage (para 6.31) : In order to ensure delivery and viability the percentage of affordable housing should be retained at 35%.

8. Settlement Hierarchy (p42, Table 5) : The settlement hierarchy is supported as logical and evidence based.

9. (para 6.45) : Since housing need is likely to require the release of Green Belt land, the Council should commission a Green Belt Review to assess which sites contribute least to Green Belt purposes.

10. (para. 6.46) : Greater weight should be given to locations for new housing which
offer the opportunity to use non car based modes of travel.

11. (para. 6.48) : The most appropriate option is one which combines A, B and C.
Options D and E (larger new allocations or a new settlement) conflict with the
conclusion of the Environmental Capacity Study that the preferred options would
entail smaller allocations within and on the edge of the urban areas in the north and
west of the District.

12. Housing Mix (p46, Table 6) : The table should be disaggregated to provide separate mixes for market and affordable housing. Option A on page 48 is the most
appropriate option.

13. Local Highways (p83) : Given the acknowledged current problems of air quality in
Rayleigh Town Centre, priority should be given to Option C to investigate the
upgrading of Rawreth Lane or Watering Lane to take traffic away from the centre of
Rayleigh.

14. Planning Obligations (p99) : The existing Policy should be retained (Option A).

15. (para. 10.15) : The conclusions of the Environmental Capacity Study that the greatest potential for development lies within and on the edge of settlements to the north and west of the District are supported. Given the size of Rayleigh and its range of services, facilities and public transport, it should be the logical first choice for sustainable housing allocations. Since recent development in the town has been to the west, this Local Plan should seek to 'rebalance' the spatial form of Rayleigh by the allocation of land to the east, such as the land south of Wellington Road.

16. Green Belt (para. 10.16) : It is considered that a Green Belt Review (Option B) will have to form an essential part of the evidence base for the new Local Plan. This
should be commissioned as soon as possible.

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

Rochford Local Plan Regulation 18 Consultation

Thank you for the opportunity to comment on the Regulation 18 version of the Rochford Local Plan. These representations are submitted on behalf of Rydon Homes which has an interest in land south of Wellington Road, Rayleigh (site CFS053 in the 2017 SHELAA).

Attached to this representation is a schedule which sets out Rydon's views on the options presented in the document. Hopefully, this will assist your analysis. However, such a point by point response can also obscure the Respondent's overall views on the plan and its main issues. In view of this, this letter brings together the various themes of the Rydon response.

The main points are :
1. The Vision and Strategic Objectives should make it clearer that the plan should seek to meet local housing needs in full. Many other Local Authorities with high levels of Green Belt (eg St Albans) have concluded that their housing needs have to be met and have commissioned a Green Belt Review to identify which land parcels serve the least Green Belt purposes.

2. The Green Belt Review should be progressed in parallel with an assessment of which sites would best promote a more sustainable pattern of development and minimise the use of the car.

3. The plan recognises that Rayleigh is the largest settlement in Rochford District and has the greatest range of facilities and services, plus public transport. As a
consequence, new housing allocations within and on the edge of Rayleigh have the
greatest chance of minimising the need to use the car in favour of walking, cycling
and public transport. Whilst it is accepted that the centre of Rayleigh is currently an
Air Quality Management Area, your 2015 Environmental Capacity Study (para 8.2)
recognises that a package of mitigation measures is available.

4. Whilst it is a matter of concern that your Environmental Capacity Study only focusses on the environmental facet of sustainable development and largely ignores the social and economic aspects, it is noted that it concludes (para 8.27) that the greatest capacity for further development lies within and on the edge of the urban areas in the north and west of the District. When this conclusion is combined with the sustainable credentials of Rayleigh, it is clear that the evidence base provides the justification for smaller housing allocations on the periphery of Rayleigh.

5. The Rydon land south of Wellington Road, Rayleigh (CFS053 - see attached plan) is a strong candidate for allocation since
* It is within walking distance of Rayleigh Town Centre
* It has an existing access on to Wellington Road
* It is close to schools, open space and community facilities
* It is not constrained by environmental or heritage issues
* It is outside the boundary of the Upper Roach Valley (see Figure 07 of the
Environmental Capacity Study)
* The site could be released from the Green Belt with only limited impacts on
the purposes of the Green Belt
* An indicative master plan is attached (No. 2575-A-1004 A) which shows how
the site can be planned to provide up to 80 homes. This master plan forms
part of the 'Site Appraisal and Promotion Document' provided to you on the
18th May 2017. If you would like this resubmitted, please let me know.
Should you feel that a meeting would be useful to discuss this site, perhaps you could suggest some dates.

1. Vision (para. 5.9) : The Vision should include the objective of fully meeting housing needs within the Rochford District.

2. Vision (para 5.10) : The 'Our Society' Vision should contain the objective of fully
meeting housing needs with Rochford District.

3. Strategic Objective (para 5.11) : The objective should make it clear that 'sufficient homes' equates to Objectively Assessed Housing Needs, or such housing figure that emerges from the 'Right Homes' consultation by DCLG. It is unclear what 'prioritising the use of previously developed land first' means. Given the scale of housing needs, it is likely that both previously developed land and Green Belt releases will be needed throughout the plan period.

4. Strategic Priority 1 (para 5.11) : There should be an objective to locate new housing where it can best deliver the most sustainable pattern of development.

5. Strategic Priority 1 (p38) : The plan should pursue Option A to seek to provide as
much housing as possible within Rochford District.

6. Affordable Housing Threshold (para. 6.31) : Option A should be selected to
maximise the delivery of affordable homes from a wider range of sites.

7. Affordable Housing Percentage (para 6.31) : In order to ensure delivery and viability the percentage of affordable housing should be retained at 35%.

8. Settlement Hierarchy (p42, Table 5) : The settlement hierarchy is supported as logical and evidence based.

9. (para 6.45) : Since housing need is likely to require the release of Green Belt land, the Council should commission a Green Belt Review to assess which sites contribute least to Green Belt purposes.

10. (para. 6.46) : Greater weight should be given to locations for new housing which
offer the opportunity to use non car based modes of travel.

11. (para. 6.48) : The most appropriate option is one which combines A, B and C.
Options D and E (larger new allocations or a new settlement) conflict with the
conclusion of the Environmental Capacity Study that the preferred options would
entail smaller allocations within and on the edge of the urban areas in the north and
west of the District.

12. Housing Mix (p46, Table 6) : The table should be disaggregated to provide separate mixes for market and affordable housing. Option A on page 48 is the most
appropriate option.

13. Local Highways (p83) : Given the acknowledged current problems of air quality in
Rayleigh Town Centre, priority should be given to Option C to investigate the
upgrading of Rawreth Lane or Watering Lane to take traffic away from the centre of
Rayleigh.

14. Planning Obligations (p99) : The existing Policy should be retained (Option A).

15. (para. 10.15) : The conclusions of the Environmental Capacity Study that the greatest potential for development lies within and on the edge of settlements to the north and west of the District are supported. Given the size of Rayleigh and its range of services, facilities and public transport, it should be the logical first choice for sustainable housing allocations. Since recent development in the town has been to the west, this Local Plan should seek to 'rebalance' the spatial form of Rayleigh by the allocation of land to the east, such as the land south of Wellington Road.

16. Green Belt (para. 10.16) : It is considered that a Green Belt Review (Option B) will have to form an essential part of the evidence base for the new Local Plan. This
should be commissioned as soon as possible.

*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

Rochford Local Plan Regulation 18 Consultation

Thank you for the opportunity to comment on the Regulation 18 version of the Rochford Local Plan. These representations are submitted on behalf of Rydon Homes which has an interest in land south of Wellington Road, Rayleigh (site CFS053 in the 2017 SHELAA).

Attached to this representation is a schedule which sets out Rydon's views on the options presented in the document. Hopefully, this will assist your analysis. However, such a point by point response can also obscure the Respondent's overall views on the plan and its main issues. In view of this, this letter brings together the various themes of the Rydon response.

The main points are :
1. The Vision and Strategic Objectives should make it clearer that the plan should seek to meet local housing needs in full. Many other Local Authorities with high levels of Green Belt (eg St Albans) have concluded that their housing needs have to be met and have commissioned a Green Belt Review to identify which land parcels serve the least Green Belt purposes.

2. The Green Belt Review should be progressed in parallel with an assessment of which sites would best promote a more sustainable pattern of development and minimise the use of the car.

3. The plan recognises that Rayleigh is the largest settlement in Rochford District and has the greatest range of facilities and services, plus public transport. As a
consequence, new housing allocations within and on the edge of Rayleigh have the
greatest chance of minimising the need to use the car in favour of walking, cycling
and public transport. Whilst it is accepted that the centre of Rayleigh is currently an
Air Quality Management Area, your 2015 Environmental Capacity Study (para 8.2)
recognises that a package of mitigation measures is available.

4. Whilst it is a matter of concern that your Environmental Capacity Study only focusses on the environmental facet of sustainable development and largely ignores the social and economic aspects, it is noted that it concludes (para 8.27) that the greatest capacity for further development lies within and on the edge of the urban areas in the north and west of the District. When this conclusion is combined with the sustainable credentials of Rayleigh, it is clear that the evidence base provides the justification for smaller housing allocations on the periphery of Rayleigh.

5. The Rydon land south of Wellington Road, Rayleigh (CFS053 - see attached plan) is a strong candidate for allocation since
* It is within walking distance of Rayleigh Town Centre
* It has an existing access on to Wellington Road
* It is close to schools, open space and community facilities
* It is not constrained by environmental or heritage issues
* It is outside the boundary of the Upper Roach Valley (see Figure 07 of the
Environmental Capacity Study)
* The site could be released from the Green Belt with only limited impacts on
the purposes of the Green Belt
* An indicative master plan is attached (No. 2575-A-1004 A) which shows how
the site can be planned to provide up to 80 homes. This master plan forms
part of the 'Site Appraisal and Promotion Document' provided to you on the
18th May 2017. If you would like this resubmitted, please let me know.
Should you feel that a meeting would be useful to discuss this site, perhaps you could suggest some dates.

1. Vision (para. 5.9) : The Vision should include the objective of fully meeting housing needs within the Rochford District.

2. Vision (para 5.10) : The 'Our Society' Vision should contain the objective of fully
meeting housing needs with Rochford District.

3. Strategic Objective (para 5.11) : The objective should make it clear that 'sufficient homes' equates to Objectively Assessed Housing Needs, or such housing figure that emerges from the 'Right Homes' consultation by DCLG. It is unclear what 'prioritising the use of previously developed land first' means. Given the scale of housing needs, it is likely that both previously developed land and Green Belt releases will be needed throughout the plan period.

4. Strategic Priority 1 (para 5.11) : There should be an objective to locate new housing where it can best deliver the most sustainable pattern of development.

5. Strategic Priority 1 (p38) : The plan should pursue Option A to seek to provide as
much housing as possible within Rochford District.

6. Affordable Housing Threshold (para. 6.31) : Option A should be selected to
maximise the delivery of affordable homes from a wider range of sites.

7. Affordable Housing Percentage (para 6.31) : In order to ensure delivery and viability the percentage of affordable housing should be retained at 35%.

8. Settlement Hierarchy (p42, Table 5) : The settlement hierarchy is supported as logical and evidence based.

9. (para 6.45) : Since housing need is likely to require the release of Green Belt land, the Council should commission a Green Belt Review to assess which sites contribute least to Green Belt purposes.

10. (para. 6.46) : Greater weight should be given to locations for new housing which
offer the opportunity to use non car based modes of travel.

11. (para. 6.48) : The most appropriate option is one which combines A, B and C.
Options D and E (larger new allocations or a new settlement) conflict with the
conclusion of the Environmental Capacity Study that the preferred options would
entail smaller allocations within and on the edge of the urban areas in the north and
west of the District.

12. Housing Mix (p46, Table 6) : The table should be disaggregated to provide separate mixes for market and affordable housing. Option A on page 48 is the most
appropriate option.

13. Local Highways (p83) : Given the acknowledged current problems of air quality in
Rayleigh Town Centre, priority should be given to Option C to investigate the
upgrading of Rawreth Lane or Watering Lane to take traffic away from the centre of
Rayleigh.

14. Planning Obligations (p99) : The existing Policy should be retained (Option A).

15. (para. 10.15) : The conclusions of the Environmental Capacity Study that the greatest potential for development lies within and on the edge of settlements to the north and west of the District are supported. Given the size of Rayleigh and its range of services, facilities and public transport, it should be the logical first choice for sustainable housing allocations. Since recent development in the town has been to the west, this Local Plan should seek to 'rebalance' the spatial form of Rayleigh by the allocation of land to the east, such as the land south of Wellington Road.

16. Green Belt (para. 10.16) : It is considered that a Green Belt Review (Option B) will have to form an essential part of the evidence base for the new Local Plan. This
should be commissioned as soon as possible.