New Local Plan: Spatial Options Document 2021

Rochford District Residents (RDR) is a Registered Political Party and has 6 District Councillors as well as a Councillor on Rayleigh Town Council.

RDR is a Stakeholder Organisation in this Public Consultation. I am Party Leader.

The Government announced changes to the National Planning Policy Framework (NPPF) on Tuesday 20 July. These changes have significant implications on the Rochford District NEW Local Plan.

Rochford District Council is now required to prepare a Local plan detailing 30-year vision. The current Spatial Options Public Consultation proposals (Vision?) are to guide development to only 2040 when it must now be 2055.

This Public Consultation is premature and flawed because the Council has acknowledged that it will not publish full Infrastructure Capacity Data until after this engagement even though each will be available in the short term.

Without correct and up to date information on provision of infrastructure and what that could look like no one can make an informed decision.

A South Essex Plan is being developed by ASELA (a quango comprising all Councils in South Essex) that will set out an overall strategy for development across the whole area. Building on this partnership working approach, a South Essex 2050 Memorandum of Understanding was drawn up in January 2018 which was signed by all partner authorities, including both ECC and Rochford District Council, that sets a joint approach across South Essex to collectively support economic growth and importantly in the context of The Rochford District NEW Local Plan, puts sustainable development across the sub-region at the centre of respective plans.

There is no Reference to GREATER ESSEX GROWTH AND INFRASTRUCTURE FRAMEWORK 2016-2036 (AECOM) and the multi million £ shortfall for Rochford District.

SO WHY HAS RDC PUT FORWARD A SPATIAL OPTIONS PUBLIC CONSULTATION ASKING RESIDENTS TO CHOOSE OR OBJECT TO SITES, VILLAGES AND TOWNS WITHOUT A PLAN FOR SOUTH ESSEX BEING AVAILABLE TO RESIDENTS?

RDC UNDERTOOK AN URBAN CAPACITY SURVEY (UCS) IN 2020 WHICH IDENTIFIES EXISTING SITES FOR AROUND 3000 HOMES BUT THIS IS NOT SPECIFICALLY DRAWN TO THE ATTENTION OF RESIDENTS SUCH THAT THE COUNCIL SHOULD ONLY BE LOOKING FOR NEW SITES AT AROUND 4200. THIS IS A MATERIAL INFORMATION DEFICIT IN THIS PUBLIC CONSULTATION..

Being a largely rural district in nature OUR growing population is exerting more and more pressures on the local highway’s network and this will continue as the population grows. The population is expected to grow to 89,494 by 2025, up from 84,815 back in 2015,an increase of 5.5%. However due to the extent of Green Belt, the District is significantly constrained in how much and where new housing can be located. Therefore, there is a relatively limited amount of policy compliant developable land available in the Rochford area.

SO INSTEAD OF PUTTING EVERY PIECE OF LAND THAT SOMEONE WANTS TO DEVELOP, WHY HASN'T RDC THINNED THIS DOWN TO WHAT IS SUSTAINABLE ON INFRASTRUCTURE AND IF THE TARGET IS NOT THEN CHALLENGE THE TARGET WITH THE GOVERNMENT LIKE SOUTHEND AND BASILDON HAVE DONE?

Residents already recognise that there are strong synergies between Rochford and the surrounding areas of Southend, Castle Point and Basildon, including in relation to transport infrastructure and economic factors. It is likely that planned growth will have an impact on the transport infrastructure in Rochford, as well as beyond on wider Essex infrastructure.

In response to this strong synergy, we understand that consultants have been commissioned by Essex County Council to look into this and to produce fresh evidence in order to understand more deeply the existing transport infrastructure and future development, in line with the Duty to Co-operate requirement guiding Local Plan development.

Contained in this work there will be an assessment of sustainable travel levels in Rochford District and this is composed of three constituent areas; non-motorised users (walking and cycling),buses and rail services.

SO WHY HAS RDC CONSULTED WITHOUT THE ECC EVIDENCE? IF THAT EVIDENCE WAS AVAILABLE THEN THE COUNCIL WOULD HAVE TO CONCLUDE THAT THE 7200 TARGET IS IMPOSSIBLE TO DELIVER WITHOUT CAUSING SIGNIFICANT DAMAGE TO THE DISTRICT.

Each site for potential housing development put forward to Rochford District Council by landowners and developers has been scored by RDC to ascertain the level of accessibility and unsurprisingly those sites with higher scores are predominantly within or proximate to settlements.

The higher scoring sites are predominantly close by to a rail station or town centre where bus facilities are also nearby.

WHY HAS ROCHFORD DISTRICT COUNCIL NOT RECOGNISED THIS IN ITS PUBLIC CONSULTATION ON SPATIAL OPTIONS AND COME UP WITH SOMETHING ELSE BECAUSE SURELY THE EXISTING INFRASTRUCTURE CANNOT COPE WITH THIS HOUSE BUILDING STRATEGY WITHOUT WRECKING OUR LIVES AND OUR BUSINESSES?

SOUTHEND BOROUGH COUNCIL (SBC) IS UNDERSTOOD TO BE PLANNING FOR A NEW SETTLEMENT IN THE FOSSETTS FARM AREA OF 7000 HOUSES. THIS HAS NOT BEEN DRAWN TO THE ATTENTION OF RESIDENTS. A SIGNIFICANT PROPORTION OF THE RESIDUAL 4200 HOMES (after UCS 3000) COULD ADDITIONALLY BE PLACED IN THE SAME AREA BY RDC ON CALL FOR SITES AVAILABILITY WITH A NEW ROAD PROPOSED BY SBC.

Please see the published RDC form for nominating sites which establishes criteria for approval of Nominations to Call for Sites.

Residents have brought to each other's attention that in respect two large sites, CSF045 (Belchamps) and CS194 (Rectory Road, Hawkwell) it is alleged that landowners do not wish to sell. In respect of CFS045 a Councillor has an email from Trustees.

On that basis neither should be under consideration unless RDC has nominated the sites itself as candidates for Compulsory Purchase. There is no evidence of the latter.

One wonders if there are any more sites that should not have been approved by RDC in accordance with its published criteria and policy.

A Conservative Councillor, a Member of The Planning Policy Committee has written in public about this public consultation " IF THERE IS NO LOCAL PLAN IT WOULD BE A FREE-FOR-ALL FOR DEVELOPERS TO BUY UP LAND WITHOUT HAVING TO GET PLANNING APPROVAL FROM THE LOCAL AUTHORITY."

That claim was also made throughout the Core Strategy.

Did that happen in Castle Point? Unarguably - NO.

Residents have expressed through a Petition their disappointment that The Council has not publicly challenged the housing target imposed by The Government and gained a reduction given that most of the target will be on green belt. Southend and Basildon Councils are challenging The Government. Castle Point Council has failed to deliver any local plan over the last 10 years or so but RDC has delivered several thousand homes against the background of a failing deficient infrastructure of 10's of £ millions which was established by consultants engaged by ECC and referred to as GIF. The Council has that evidence but has never discussed it in Council and apparently not included that evidence in The Evidence Base or Archive to this NEW Local Plan. This is unacceptable.

Residents are finding it very difficult to engage with this Public Consultation because it is unclear what they are asked to address; Strategy or Individual sites? The Volume of questions and the complexity of the online presentation was evidently not reviewed and tested by The Council before The Public Consultation was approved.

There is a failure to provide the necessary infrastructure capacity data, higher level strategy for South Essex and Essex and evidence of cooperation with other local Councils.

I am a participant in the following detailed assessment of CFS064 which is already held by The Council (Daniel Goodman). It is necessary to submit this in this Public Consultation because the Council's Assessment is shown as Deliverable for Development. This report from residents does not agree with The Council.

We, Betts Farm Residents Group, are writing to launch an OBJECTION to the proposed use of land for development standing by RDC in the Local Plan. Land Registry: EX817389. The proposal of use appears in The New Local Plan 2017 to 2037 for residential development ref: CFS 064.

Betts Farm Residents Group is a group of people - 483 members - who live on the Betts Farm Estate and the directly surrounding area. The group was created three years ago to discuss local matters of concern and work together as members of the community to enhance the area in which we live.

RDC development plan was originally proposed over a decade ago. It outlines prospective areas of development within the Rochford District. The plan has been reviewed and with changes to Government strategies the planning is due to be reviewed again. One of the areas highlighted – Stephenson’s Field, Hockley - land lying between Thistledown and Hockley Primary School with Betts Woods, the London-Southend train access with residential areas surrounding. The field is currently owned by a local farmer and is used for agricultural purposes, as well as containing a widely used public footpath and protected woodlands. Access to the proposed site is via a footpath only.


It is not our belief that the proposed development would enhance the area. The site is agricultural land and has been for centuries. The farm seeds annual crops and works on a rotational basis. The land is also well used for leisure activities by local people and supports groups that are set up for rambling and running in the area as well as local families and individuals wishing to take exercise and to access the public footpaths that surround the field mainly known as Footpath 11 or the Jubilee Walk.

The development of this site will not benefit the varied socio demographic of Hockley. The current expected rate is a 65:35 split for affordable housing of which a further 80:20 between ownership and rental. The proposal put forward by yourselves means that there will be only 112 properties that would fall into this category. The current market predictions show a downturn and therefore the cost of affordable housing would have to be considered viable. The recommendation from SHELTER is that affordable housing should cost no more that 35% of someone's earnings. The average salary in the RDC district is £34k.

The proposed density of the development using RDC formulae would lead to the development of an additional minimum of 320 properties based on the minimum ratio of 30:1 hectare - although it is known that RDC will allow this ratio to vary. With this rate of development a small area would extend the population by approximately two thousand people. This proposal creates a density of housing that is not in keeping with the local area and placing an additional growth in population in the Hockley area without the inclusion of sustainable access to key services would be unacceptable.

Evidence shows from previous developments the development of this site would not meet the needs of the residents of the area. As per the Projected Population Profile there is a direct need for housing that is lifelong, easily adaptable and suitable for the disabled and elderly.

Within the local area there are four NHS doctors who are all working at capacity. Before the recent pandemic there was a shortage of appointments with GP’s in the area and also nationally. With the expansion and development of this proposed development space, the expectation of Jones Family Practice would be to expand by over one thousand patients, something that it would not be able to subsist.

Dental surgeries within a viable walking distance from the proposed site have no patient availability. Hockley does have a large central private practice, however with the ongoing threat of recession and unemployment this is not a measure that people can be expected to take.

The nearest school to the proposed site is Hockley Primary School which forms part of the AET academies of which all Hockley schools belong. Hockley School’s headteacher, Mrs. Heatherson, has placed an objection previously based on the lack of spaces available and the increase in traffic flow - we believe in 2010. Hockley School is a small purpose built school with no room for expansion. The grounds are surrounded by ancient woodland and the school playing field lies adjacent to the proposed site. We also believe that the school has recently had an expansion of the numbers of pupils refused. This application was made due to the lack of spaces available versus the required places. The school also has a unique acceptance process that puts children without siblings in catchment below those out of catchment as well as staff children. Essex County Council’s School Place Planning indicates that there will be a rise in demand over the coming decade which does not accommodate changes in population. With the opening of Jelly Beans Open Air in 2018 the pupils rates have also grown as have traffic issues in the area.

The Betts Farm estate has a problematic traffic flow and parking for residents. The estate has parking, often on both sides of the road, during the day. This has led to issues at the school which have an impact on health and safety. An example being children not being able to be returned to school after a school trip as the coach was unable to gain access due to parking. The number of vehicles has risen in recent years and continues to increase. RDC is aware of this situation due to complaints from residents. The estate is also used for parking by commuters using the London-Southend trains and SEETEC employees who are employed on Main Road. Any form of vehicle increase would cause the roads to have blind spots, lack of residential parking and poor levels of accessibility.


During the Covid 19 pandemic the use of Broadband has become a prevalent service for all. Pre-pandemic Hockley has had several issues with the service provided. The main providers have an interrupted service which is slow and not on a par with advertised rates. There were many reports of people unable to work from home due to the speed of their Broadband and it’s incapability to cope with high traffic levels. Essex County Council is introducing the Super Speed Highway for broadband, “Super Fast Essex”, however there are no plans to provide this area with high speed broadband or fibre connectivity through the council but using private providers. With home working becoming more prevalent post-pandemic it is essential that any additional development would be able to provide a good broadband service which currently the area cannot.



RDC proposed access point is not viable for the free and safe movement of vehicles as required by both EEC and the DTI, the proposed access being a small road way between two properties. According to the land registry the proposed land markings are incorrect on the proposals pitched by the council. There is a boundary discrepancy with the surrounding property, Thistledown. This would mean that the proposed field would be inaccessible to larger vehicles required for development and in the longer term for delivery access and utilities.

‘The positioning of any site entrances, exits and haul roads in relation to the surrounding area should be positioned to route vehicles, whether on or off the site, away from sensitive locations, such as residential areas, schools and hospitals.’ Controlling particles, vapour and noise pollution from construction sites - RBKC.gov.uk

Studies show that the pollutant levels caused by building sites have a detrimental effect on local residents. These are caused by:

Air Pollution: the air will be contaminated by debris caused by the site. Apart from the noise, poor air quality is the most immediate pollution effect that residents will experience from a construction site. Airborne contaminants including contaminated particulate matter and volatile compounds spread around, mostly carried by wind, in the surrounding neighbourhood. The main wind direction will influence the area most affected by air pollution around a construction site. Contaminants spreading around in air can travel large distances in a short time. The main construction contaminants that spread around by wind include PM10 (particulate matter with a diameter less than 10 microns generating polluted dust), PAHs bound to particulate matter, VOCs (volatile organic compounds), asbestos, gases such as carbon monoxide, carbon dioxide, and nitrogen oxides.

Water Pollution: the surface water runoff and the groundwater close to a construction site become polluted with various materials used in the construction work. As described for air pollution above, the following construction contaminants can pollute the water: VOCs, paints, glues, diesel, oils, other toxic chemicals, and cement. The immediate effect is creating turbidity in the runoff water and affected surface and groundwater, since some of the runoff water may infiltrate in the subsurface reaching the groundwater. Both groundwaters below the top layer and surface runoff close to homes may constitute a source of pollution emanating from the construction sites. This is a threat to local protected wildlife and the ancient woodland that surrounds the proposed site as well as domestic animals who use the field. This will be of great effect to the school field and therefore local children. There have been repetitive run off issues within the field which also contains Hockley Brook which flows throughout Hockley and therefore would spread any pollutants that enter it.

Soil Pollution: soil at and around a construction site can become contaminated due to air transport followed by deposition of construction contaminants as well as water runoff of construction contaminants. Soil may constitute a sink for pollutants and some of those may accumulate in soil and persist over longer periods of time (e.g., PAHs).

Noise Pollution: noise is usually associated with construction work which may adversely affect the health of local residents, including effects such as stress, sleep disturbance, high blood pressure and even hearing loss.

With current proposals it is estimated that the development would add an increase of 600 cars to the narrow roads of Folly Chase, Folly Lane, Church Road and the main roads of Hockley. This does not include the additional traffic in the form of visitors, deliveries and day to day residential operations. Previous car monitoring in the area shows that vehicular use of the roads was in its thousands daily which in such close proximity can lead to health complications from pollutants - diesel is responsible for emissions of carbon monoxide, hydrocarbons, nitrogen oxides and carbon dioxides causing long term damage to the respiratory system. This would remain prevalent after the development had been finished.

AQMA’s will not be reduced due to the substantial amount of traffic using Main Road as an access route to other areas eg Southend Airport. During periods of the day there are two junctions that are affected by stagnant traffic by the additional flow of up to six hundred residential vehicles as their direct access route on to Main Road and the surrounding roads. There is no scope for the redevelopment of junctions in the area due to the narrow formation of the involved roads.

The proposed site would only allow a small amount of sustainable transport modes to reduce pollutants. This would be in the form of a bicycle, however Hockley does not have a developed cycle route and the roads in the local area are too narrow to do so. Neither does Hockley have access to hire services and bicycles are expensive to purchase and maintain.

The site does not reduce the need to travel to reach amenities. The original development plan and recent County Council proposals mean that people will need to travel to access library and council facilities. The proposed merger of services for Basildon, Southend and Broomfield Hospitals means that patients will need to travel further to reach previously easily accessed services.

Whilst there is a timetabled regular bus service with an average ten minute walking distance, the extent of traffic congestion means that these do not run on time in either direction. The closest bus stop would be approximately 0.4 miles from the proposed entrance or 1.0 miles for a different service via the road. Employment opportunities in the local area are limited and travel to work would be frequent to and from the Southend and London areas in particular.

This expansion in the volume of the traffic will lead to the increase of air pollutants. There will also be an increase in air pollutants caused by the development itself. During the time of the proposed build there would be an increase in airborne pollutants. Pollution emissions from construction sites can have a detrimental effect on health and the local environment. Particles and vaporous discharges can have an adverse impact on the health of local residents by affecting particularly the eyes, nose, mouth, lungs and skin. Fine particles can penetrate deep into the lungs, contributing to respiratory and cardiovascular problems. Large particles can cause nuisance through soiling of surfaces such as cars, property and washing. Excessive noise levels can be a hazard to local people and disturb local wildlife.

It is our understanding that a recent development on Folly Lane has led to a public drainage issue in the area. We understand from residents that until recently this new housing development was not able to be connected to sewage outlets resulting in the use of a cesspit which was being emptied daily. The pump house on the Folly Grove estate, that the waste system is now connected to, leads to the pump house on Caernarvon Close on the Betts Farm estate. This pump house already services the Betts Farm estate, Folly Chase and now the new development on Folly Lane. It is our belief that the pump house in Caernarvon Close is now at flow capacity and would not be able to cope with any more additional flow.

Light pollution is especially relevant in this area with many species relying on moon patterns for breeding seasons, for example the local glow worm community which actively breeds in the vicinity. Light pollution caused by a new development would have a detrimental effect on such breeding programmes. Currently the proposed site is sheltered from these forms of pollutants due to the canopies created by the trees that form the surround of the field. All of the current residential properties have a tree break between themselves and the proposed site.

The proposed area has a number of protected wildlife species that form part of the micro environment within the woodland and field areas. There is an established badger sett, closely monitored by the Essex Badger Protection Group, within Betts Wood. Also, local residents have mentioned the field providing a breeding ground for glow worms that can be seen in the field past dusk. A full ecological survey of the land would be required prior to any land being considered for development.

Betts wood is found on the perimeter of the field. The wood consists of ten acres of ancient semi natural woodland. Several species are found within the area including Hornbeam, Hawthorne, Holly and Silver Birch. There is a range of Oak trees that are also in the area. The wood is maintained by RDC and coppiced five years ago. Areas such as these provide biodiversity that should be protected in the current climate. Locally, Betts Wood, and also Hockley-Hall Wood South, are known as the “Bluebell Woods”, due to the magnificent display of bluebells in spring.

Hockley-Hall Wood South lies within the boundary of the potential field development, near the railway line. The wood contains a range of Oak-Hornbeam wood. This ancient wood is small yet contains Period II boundary woodbanks with pollard trees. The woodland is referenced by Oliver Rackham in his book, ‘The Ancient Woods of South-East Essex’. This wood also contains, as does Betts Wood, a range of veteran trees that provide a contribution to the biodiversity of the area. The Woodland Trust has stated that, “Ancient Woodland dates back hundreds of years and supports more threatened species than any other habitat in the UK. However, only around 550000ha remains. It is a functionally irreplaceable resource for biodiversity and is also an important part of our cultural heritage.”

On the field boundary, opposite Hockley-Hall Wood South, lying adjacent to Betts Wood, there is a further ancient wood - Folly Wood. There is great concern that any form of development would cause disturbance and damage to all three of these ancient woodland areas which partially surround the site on three sides. All three of these woods have grown and developed over hundreds of years. The effects of the development being built are listed above. There would be an increase of pollution after the development is completed due to the increase of an average 450 cars to the estate, and light pollution. Even the additional impact of domestic pets on the site would need to be taken into consideration, as well as trampling and the risk of fly-tipping. We are of the understanding that all three of these sites would have equal protection in the National Planning Policy Framework. RDC would need to make considerations for the woodland pasture identified as ancient in planning decisions in the same way as any other larger woodland area.

Previously mentioned is the use of land for recreational purposes by the local community. Whilst being used for agriculture, a main public footpath, Footpath 11, is situated around the field. This key footpath services the Jubilee Walk as well as Footpath 10 and is actually directed through Hockley-Hall Wood South. These footpaths give access to a variety of areas in Hockey and the surrounding areas.

A development in the site would do nothing to conserve the areas or enhance the diversity of species that are found within. The development would cause a range of potential issues for the immediate wildlife and the three ancient woodlands that surround the field. As these areas of woodland are relatively small they face a larger potential risk from the damage that is caused by the chemical effects of the development not only as building takes place but after once the buildings are in situ. The development would ‘increase the isolation of natural habitats by creating increasing barriers to movement ‘(Belisle&Clair 2002). It may be associated with the destruction of semi natural habitats and movement corridors between ancient woodland fragments and ancient woods and nearby semi natural habitats. (ref. Woodland Trust)

A development on this site would not maintain and enhance the general greenbelt location of this site. The ability to conserve the wildlife, trees and plants within the space would decline and there is the further opportunity for non-native plant species invasion. The development would lower the probability for species to disperse successfully between the woods. There would also be a change caused in local species breeding behaviour as previously mentioned.

Over the past six months we have seen the need for green spaces in this country. Not always the bigger places but small areas of recreation that have allowed the local community to walk, children to play and develop their experience of nature whilst developing a sense of respect and understanding of the area in which they live. The land is currently used effectively and development here would not deliver any form of enhancement to the use or management on the Urban Fringe. The area provides vital access to less mobile local people who are limited with their travel options to an outdoors haven for exercise and helping their physical and mental wellbeing. Losing this would directly negatively impact the quality of life for the residents who rely on this area remaining natural and free from development. MIND has stated that the ability to spend time in nature has been found to help with a range of mental health problems including anxiety and depression. Research into, ‘Ecotheraphy’ has shown that it can and does help with a variety of Mental Health problems.

In conclusion, the representatives of Betts Farm Residents Group OBJECT to the proposals made by Rochford District Council. It is felt that the proposed site would not enhance the local area nor would it bring advantages to those living on the Betts Farm estate, Folly Lane or the general Hockley area. We believe that it would result in a series of issues, from its commencement, to local residents and the surrounding natural area, that are clearly laid out in this objection.

I feel that both MP's should invite The Rt Hon Robert Jenrick, Secretary of State to Rochford District to help The Council decide on whether The Government wishes The Council to build on Green Belt to meet The Government Target of 7200.

There is evidence from another area that The Government does not expect Green Belt to be lost if such a visit cannot be arranged.

https://www.getsurrey.co.uk/news/surrey-news/dont-want-homes-built-surreys-21468986.amp?fbclid=IwAR1Zar9c24XF4pnSVgguGnpEtcxjQ53in69u2WveFUtTfiIZRekorbeCSyE